Linfo IP LLC v. Shein Distribution Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Shein Distribution Corporation (Delaware)
  • Plaintiff’s Counsel: Law Office of Victoria E. Brieant, P.A.
• Case Identification: 1:25-cv-24534, S.D. Fla., 10/02/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website and associated systems infringe a patent related to methods for organizing and presenting unstructured data objects.
• Technical Context: The technology addresses the problem of information overload by providing user interfaces and methods to sort, rank, and display electronic data objects based on assigned relevance or importance scores.
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity and notes that it and its predecessors have entered into prior settlement licenses. The complaint asserts that these settlements did not involve admissions of infringement or licenses to produce a patented article, which may be an attempt to address potential defenses related to the patent marking statute.

Case Timeline

Date	Event
2013-03-25	’131 Patent Priority Date
2016-08-30	’131 Patent Issue Date
2025-10-02	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 systems like social networks, email, and search engines, where a high volume of information makes it difficult to discern valuable or relevant content (Compl. Ex. A, ’131 Patent, col. 1:19-35). Conventional filtering methods are described as having only "limited functionality" (’131 Patent, col. 1:43-44).
• The Patented Solution: The invention provides systems and methods for organizing collections of "unstructured data objects" (e.g., files, contacts, emails) by assigning them "importance measures" (’131 Patent, Abstract). A user can specify a granular degree of importance for an object, such as a numerical value, which the system then uses to determine the object's display position or format, thereby distinguishing more relevant items from less relevant ones (’131 Patent, col. 8:7-13; col. 17:41-49). For example, objects with higher importance scores can be displayed in a separate, larger area or with a larger font size (’131 Patent, col. 8:60-64; Fig. 4).
• Technical Importance: The described approach provides a method for users to apply fine-grained, subjective importance values to data objects, moving beyond simple binary sorting (e.g., alphabetical) or system-generated relevance rankings.

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 (Compl. ¶9). Independent claim 1 is representative of the asserted method claims.
• Essential Elements of Independent Claim 1:
  • Obtaining a plurality of electronic objects, comprising currently existing files, folders, or contacts in a contact list.
  • Displaying the electronic objects in a user interface.
  • Receiving an "importance value" associated with at least one object, where the value is a non-binary numerical value entered by a user.
  • Determining a position to place the object in the user interface "directly from the importance value."
  • Placing the object in the determined position.
• The complaint reserves the right to assert other claims, which may include dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's systems, methods, and user interfaces for "discovering information in a text content and extracting and presenting the information," as implemented on websites such as us.shein.com (Compl. ¶¶3, 9).

Functionality and Market Context

The complaint alleges that Defendant "maintains, operates, and administers a system" that allows for the discovery, extraction, and presentation of information (Compl. ¶9). The functionality is broadly characterized in the context of Defendant's operation of an e-commerce platform that sells products and services throughout Florida and elsewhere (Compl. ¶3). The complaint does not provide specific technical details about the operation of the accused system beyond this general description. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a preliminary claim chart in "Exhibit B," but this exhibit was not attached to the filed document (Compl. ¶10). The infringement theory must therefore be drawn from the narrative allegations in the body of the complaint.

The complaint alleges that Defendant’s system for "discovering information in a text content and extracting and presenting the information" infringes one or more claims of the ’131 Patent (Compl. ¶9). This allegation is framed at a high level of generality and does not map specific features of the accused Shein website to the limitations of the asserted claims. The complaint does not, for example, identify a specific feature where a user can enter a "non-binary numerical value" to directly control the position of a displayed object, as recited in claim 1.

Identified Points of Contention

• Scope Questions: A central question may be whether the claimed method, which focuses on a user explicitly entering a numerical "importance value" for an existing object like a file or contact, can be read to cover the functionalities of a typical e-commerce platform. The defense may argue that features like keyword searching, filtering by attributes (e.g., size, color), or sorting by system-generated criteria (e.g., "Best Sellers," "Price: Low to High") do not meet the claim limitation of receiving a user-entered, non-binary numerical importance value that directly determines an object's position.
• Technical Questions: The infringement analysis will depend on whether Plaintiff can identify a specific component of the Shein website that performs the claimed steps. A key question for discovery will be what evidence demonstrates that the accused system receives a "non-binary numerical value" from a user and uses it "directly" to determine the display position of an object, as opposed to using it as one of many inputs into a broader relevance-ranking algorithm. The complaint does not provide sufficient detail for analysis of this element.

V. Key Claim Terms for Construction

The Term

"importance value" (and its characterization as a "non-binary numerical value")

Context and Importance

The construction of this term appears central to the dispute. The infringement case may turn on whether this term is limited to an explicit numerical value entered by a user for the purpose of ranking (e.g., rating a contact "9" out of 10), or if it can be construed more broadly to encompass implicit user actions or selections within a standard e-commerce interface that influence a system's relevance score. Practitioners may focus on this term because its scope will likely define the boundary between the patented method and conventional search-and-sort functionality.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The patent specification refers to relevance criteria more generally, including items such as "terms, values, topics, classes, etc." (’131 Patent, col. 2:22-24). Plaintiff may argue that user selections in a filtering menu on an e-commerce site constitute the selection of such "values," which are then used to calculate an implicit importance score.
• Evidence for a Narrower Interpretation: The language of claim 1 explicitly requires the importance value to be a "non-binary numerical value... entered by a user" (’131 Patent, col. 17:42-44). The specification provides numerous examples consistent with this narrower reading, such as a user specifying a numerical importance of "0.8" for the search term "electric cars" or assigning values on a 1-5 scale to contacts in a list (’131 Patent, Fig. 6A; Fig. 9). This suggests the value is a specific, user-supplied number rather than an abstract score derived from other user interactions.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement by asserting that Defendant actively encourages or instructs its customers on how to use its products and services in an infringing manner (Compl. ¶11). Contributory infringement is alleged on the grounds that the accused service is not a staple commercial product and that the only reasonable use is an infringing one (Compl. ¶12).

Willful Infringement

Willfulness is alleged based on Defendant’s purported knowledge of the ’131 Patent from "at least the filing date of the lawsuit" (Compl. ¶¶11, 12). The prayer for relief seeks a finding of willfulness if pre-suit knowledge is revealed during discovery (Compl. ¶(e)).

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

1. A core issue will be one of definitional scope: can the claim term "importance value," described as a "non-binary numerical value entered by a user," be construed to cover the filtering, sorting, or relevance-ranking mechanisms of a conventional e-commerce website, or is it limited to interfaces where users explicitly assign a numerical rank to a data object?
2. A second issue will be one of evidentiary sufficiency: what specific functionality on the accused Shein platform meets the claim limitations, particularly the requirement of receiving a user-entered numerical value that "directly" determines the display position of an object? The complaint’s high-level allegations suggest this will be a central point of factual dispute.