Internet Media Interactive Corp v. Trans Union Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Internet Media Interactive Corp. (Delaware)
  • Defendant: Trans Union LLC (Delaware)
  • Plaintiff’s Counsel: Haller Law PLLC
• Case Identification: 9:19-cv-81282, S.D. Fla., 09/18/2019
• Venue Allegations: Venue is based on Defendant maintaining a regular and established place of business in Boca Raton, Florida, within the judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s use of a third-party link-shortening service to direct users from social media and other advertisements to specific web pages infringes a patent related to accessing internet locations via unique "jump codes."
• Technical Context: The technology concerns methods for simplifying user access to specific internet destinations by substituting short, memorable codes for long, complex Uniform Resource Locators (URLs), a technique now common in digital marketing.
• Key Procedural History: The complaint references a January 4, 2009, claim construction order from a prior proceeding in the District of Delaware involving the same patent. The existence of these prior constructions for key claim terms may significantly influence how those terms are interpreted in the current litigation.

Case Timeline

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

U.S. Patent No. 6,049,835 - "System For Providing Easy Access To The World Wide Web Utilizing A Published List Of Preselected Internet Locations Together With Their Unique Multi-Digit Jump Codes," issued April 11, 2000

The Invention Explained

• Problem Addressed: The patent describes the difficulty for early internet users of navigating the World Wide Web, citing the need to type "confusing string[s] of subdirectories, files or executable commands" (URLs) to reach a specific site. It also notes the challenge of finding useful, high-quality content among the rapidly growing number of websites. (’835 Patent, col. 4:51-65, col. 3:55-60).
• The Patented Solution: The invention proposes a system where users are provided with a "published compilation" (e.g., a printed guide or book) of preselected websites, each assigned a unique, simple "jump code." A user navigates to a single, specialized website (referred to as "JumpCity"), enters a jump code from the guide into an on-screen form, and is then automatically redirected to the corresponding destination website, bypassing the need to know or type the full URL. (’835 Patent, Abstract; col. 5:44-56).
• Technical Importance: In an era before sophisticated search engines became dominant, this method provided a user-friendly bridge between offline media (like print advertisements) and online content, functioning as a "speed dial" for the web. (’835 Patent, col. 4:1-22).

Key Claims at a Glance

• The complaint asserts infringement of at least independent method claim 11 (Compl. ¶14, ¶15).
• The essential steps of independent claim 11 include:
  • Publishing a compilation of preselected Internet locations with an associated unique multi-digit jump code for each.
  • Providing a predetermined Internet location (e.g., a central website) with means for capturing a jump code entered by a user.
  • A user accessing that predetermined location and entering the jump code.
  • Receiving the entered jump code.
  • Converting the jump code to its corresponding destination URL address.
  • Automatically accessing the destination location using that URL. (’835 Patent, col. 9:1-30).
• The complaint does not explicitly reserve the right to assert other claims.

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Defendant's method of using its website (transunion.com), its Twitter account (@TransUnion), and a third-party link-shortening service ("spr.ly," alleged to be managed by Sprinklr) to advertise and direct users to content (Compl. ¶4, ¶14.b-c).

Functionality and Market Context

• The complaint alleges that Trans Union posts content on media like Twitter that includes shortened URLs (e.g., spr.ly/6015BaZaW). When a user clicks this link, the spr.ly service receives the unique code from the URL, looks up the corresponding full destination URL, and redirects the user's browser to that final web page. The complaint frames this automated redirection process as the infringing method (Compl. ¶14.a-g). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’835 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A primary question is whether a modern, distributed link-shortening service, which operates largely in the background, constitutes the "predetermined Internet location" as described in the patent. The patent's specification appears to describe a distinct, user-facing portal that a user first accesses and then interacts with separately. (’835 Patent, col. 5:34-43).
  • Technical Questions: The infringement theory raises the question of whether a user clicking a single hyperlink is technically equivalent to "entering [a]... jump code into said predetermined Internet location" as required by the claim. The patent specification describes this step as inputting a code into an "on-screen HTML box or form," which suggests a different user action. (’835 Patent, col. 7:6-8).

V. Key Claim Terms for Construction

• The Term: "entering said desired multi-digit jump code into said predetermined Internet location"
• Context and Importance: The viability of the infringement claim may depend on the construction of this term. The central dispute is whether a single click on a hyperlink, which initiates an automated redirection, satisfies this limitation. Practitioners may focus on this term because the factual correspondence between the accused one-click process and the claim's language of "entering" a code appears to be a weak point in the allegation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that the claim language does not specify the mode of entry (e.g., typing vs. clicking) and that any user action that communicates the jump code to the system constitutes "entering" it.
  • Evidence for a Narrower Interpretation: The specification provides context that may support a narrower definition requiring manual input. It states that after accessing the specialized website, the user "enters the four-digit jump code," which "is entered in a standard on-screen HTML box or form." (’835 Patent, col. 5:65-66, col. 7:6-8). This suggests a two-step process: (1) navigating to a site, and (2) separately inputting a code.

VI. Other Allegations

• Indirect Infringement: While not pleaded as a separate count, the complaint's direct infringement theory for the method claim is based on divided infringement principles articulated in Akamai Techs., Inc. v. Limelight Networks, Inc. Plaintiff alleges that Defendant is liable for the actions of end-users and the third-party service provider (Sprinklr) because it "condition[s] participation" on the user's click and has an "agreement" with Sprinklr, thereby directing or controlling all steps of the claimed method (Compl. ¶14.d-e, ¶15).
• Willful Infringement: The complaint does not include allegations to support willful infringement, such as pre-suit knowledge of the patent.

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

1. A core issue will be one of claim scope and technical operation: Can the claim step requiring a user to "enter" a jump code into a "predetermined Internet location" be construed to cover a modern, one-click hyperlink redirection process, or does the patent’s disclosure limit the claim to a more interactive, two-stage system involving manual data entry?

2. A central legal question will be the sufficiency of the divided infringement allegations: Has the plaintiff pleaded sufficient facts to show that Trans Union directs or controls the actions of both end-users and the third-party link-shortening service to the degree required under Akamai to attribute all steps of the method to Trans Union as a single infringer?

3. The case will likely examine the relevance of prior claim constructions: How will the court apply the 2009 Delaware court’s construction of "a unique predetermined multi-digit jump code" to the alphanumeric strings (e.g., "6015BaZaW") used by the accused link-shortening service, and what precedential weight will that prior ruling carry?