Linfo IP LLC v. Dixie Belle Paint Co LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Dixie Belle Paint Company LLC (Florida)
  • Plaintiff’s Counsel: Law Office of Victoria E. Brieant, P.A.
• Case Identification: 8:25-cv-02960, M.D. Fla., 11/01/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in Florida, has a regular and established place of business in the district, conducts substantial business in the forum, and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website and related systems infringe a patent related to methods for organizing and presenting unstructured data objects based on user-defined importance criteria.
• Technical Context: The technology addresses information overload by enabling systems to filter and display data, such as files or messages, based on relevance scores rather than simple chronological or alphabetical sorting.
• Key Procedural History: The complaint discloses that Plaintiff and its predecessors have entered into prior settlement licenses related to its patents. It argues that because these settlements did not involve admissions of infringement or agreements to produce a patented article, the patent marking requirements of 35 U.S.C. § 287(a) do not limit its claim for pre-suit damages.

Case Timeline

Date	Event
2013-03-25	’131 Patent Priority Date
2016-08-30	’131 Patent Issue Date
2025-11-01	Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,430,131 - "System, Methods, And User Interface for Organizing Unstructured Data Objects"

The Invention Explained

• Problem Addressed: The patent’s background section describes the problem of “information overload” faced by users of social networks, email, and search engines, where a high volume of information makes it difficult to discern value and locate relevant items efficiently (’131 Patent, col. 1:20-32). Conventional filtering methods are described as providing only limited functionality (’131 Patent, col. 1:43-47).
• The Patented Solution: The invention provides a system where electronic data objects (e.g., files, contacts, messages) are assigned an “importance measure” based on user-specified criteria or other attributes. This measure is then used to organize the objects and display them in different visual formats or separate areas, thereby distinguishing high-relevance content from low-relevance content to aid user focus (’131 Patent, Abstract; col. 3:30-43). Figure 1 illustrates a system where user interest (120) is used by a relevance calculation module (140) to process message objects (150) and generate a differentiated display (165, 170).
• Technical Importance: This approach provided a method for creating more dynamic and user-centric information displays, moving beyond static sorting criteria to a more granular, relevance-based organization of data (’131 Patent, col. 1:50-57).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-20 (Compl. ¶9). Independent claim 1 is representative.
• Essential elements of independent claim 1 include:
  • Obtaining a plurality of electronic objects, comprising existing files, folders, or contacts in a contact list.
  • Displaying the electronic objects in a user interface.
  • Receiving a user-entered “importance value” associated with at least one object.
  • Determining a display position for the objects directly from the importance value.
  • Placing the objects in the determined position.
• The complaint reserves the right to assert infringement of all claims 1-20, including dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Defendant’s system for electronic commerce, including its website ("https://dixiebellepaint.com/") and “related systems” (Compl. ¶¶2, 12).

Functionality and Market Context

• The complaint alleges that the accused system includes methods and a user interface for “discovering information in a text content and extracting and presenting the information” (Compl. ¶9). This functionality is allegedly used in connection with Defendant’s sales of products throughout Florida and the United States (Compl. ¶¶2-3). The complaint also makes a specific reference to "review platforms" in connection with instructing customers on infringing use (Compl. ¶12). Notably, the complaint contains a factual discrepancy, identifying Defendant as Dixie Belle Paint Company LLC (Compl. ¶2) while also alleging that it "sells foods products" (Compl. ¶3).

IV. Analysis of Infringement Allegations

The complaint references a "preliminary exemplary table attached as Exhibit B" to support its infringement allegations, but this exhibit was not included with the provided pleading (Compl. ¶10). In the absence of a claim chart, the infringement theory must be inferred from the complaint's narrative allegations. Plaintiff alleges that Defendant "maintains, operates, and administers a system" that infringes by "discovering information in a text content and extracting and presenting the information" (Compl. ¶9). The complaint does not specify which features of the Defendant's e-commerce website perform the claimed steps of receiving a user-entered importance value and positioning content based on that value.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: The infringement analysis may focus on whether the patent's claims, which expressly define "electronic objects" as comprising "files or file folders or directories in a computer file system, contacts in a contact list or address book" (’131 Patent, col. 18:32-35), can be construed to cover the product listings or customer reviews on a public e-commerce website.
• Technical Questions: A key question will be what evidence demonstrates that Defendant's website performs the central claimed function: receiving a specific, user-entered "importance value" (as distinct from a generic sort command) and using it to "determin[e] a position" for display, as required by claim 1 (’131 Patent, col. 18:41-48).

V. Key Claim Terms for Construction

The Term: "importance value"

Context and Importance

This term is the core of the claimed invention. Its construction will be critical in determining whether standard e-commerce sorting or filtering functions, such as sorting by price or popularity, meet this limitation. Practitioners may focus on this term because the complaint’s theory appears to equate general e-commerce display logic with the patent's specific mechanism for user-defined importance.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification suggests the value can be specified in multiple ways, including through a "text description, a binary or non-binary numerical value, or a selection of a user interface object corresponding to a predefined importance value" (’131 Patent, col. 8:17-20). This could support an argument that selecting a standard sort option qualifies.
• Evidence for a Narrower Interpretation: The patent’s figures and embodiments repeatedly illustrate the "importance value" as a granular, user-assigned numerical score on a scale (e.g., 0.95, 0.8) for specific criteria like "Contains the term" or "Related to the region of" (’131 Patent, FIG. 2A, col. 8:30-34). This may support a narrower construction requiring an explicit, quantitative user input rather than a categorical choice.

The Term: "electronic objects"

Context and Importance

The definition of what constitutes an "electronic object" under the patent will determine if the patent applies to the accused instrumentality at all. The dispute will likely center on whether product listings on an e-commerce site are the type of "objects" the patent was intended to cover.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The patent abstract refers generally to "unstructured collection of electronic objects," and the detailed description gives examples including "message objects in a feed or an email" (’131 Patent, Abstract; col. 3:41-42). This language could suggest a broader application beyond the specific items listed in claim 1.
• Evidence for a Narrower Interpretation: Independent claim 1 contains a "comprising" clause that appears to define the scope of the term for that claim: "wherein the electronic objects comprise currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book" (’131 Patent, col. 18:32-35). This language provides a strong basis to argue the claim is limited to personal information management data structures, not public website content.

VI. Other Allegations

Indirect Infringement

• The complaint alleges inducement, stating Defendant instructs customers on how to use its products and services, including through "review platforms" and "product instruction manuals," in a manner that allegedly causes infringement (Compl. ¶¶11-12).

Willful Infringement

• Willfulness allegations are based on knowledge of the patent "from at least the filing date of the lawsuit" (Compl. ¶11). The complaint also seeks a finding of willfulness should discovery reveal pre-suit knowledge of the patent (Compl. p. 9, ¶e).

VII. Analyst’s Conclusion: Key Questions for the Case

1. A core issue will be one of definitional scope: can the claim term “electronic objects,” which is explicitly defined in Claim 1 in the context of personal files, folders, and contacts, be construed to cover product listings or customer reviews displayed on a public e-commerce website?
2. A key evidentiary question will be one of functional proof: what specific feature of the accused website allows a user to enter a non-binary, granular “importance value” for a data object, and how does the system then use that specific value to “determine a position” for display, as required by the asserted claims?