DCT
3:25-cv-03262
Horace Mann Insurance Co v. Aloft Media LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Horace Mann Insurance Company (Illinois)
- Defendant: Aloft Media, LLC (Texas)
- Plaintiff’s Counsel: Freeman Mathis & Gary, LLP
- Case Identification: 3:25-cv-03262, C.D. Ill., 09/05/2025
- Venue Allegations: Plaintiff asserts venue is proper in the Central District of Illinois because its headquarters is located there, a substantial part of the events giving rise to the action occurred in the district, and Defendant purposefully directed patent enforcement communications into the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its corporate website does not infringe Defendant's patent related to displaying hyperlink information, and/or that the patent is invalid.
- Technical Context: The technology at issue concerns user interface methods for web navigation, specifically how drop-down menus display information about hyperlink destinations to a user.
- Key Procedural History: The complaint was filed in response to a notice letter from Defendant dated July 25, 2025, which accused Plaintiff of infringement and included a claim chart. The complaint notes that U.S. Patent No. 7,032,183, which allegedly discloses a similar menu system to the accused website, was cited as prior art by the examiner during the prosecution of the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2006-03-20 | ’793 Patent Priority Date |
| 2019-08-06 | ’793 Patent Issue Date |
| 2025-07-25 | Defendant sent notice letter to Plaintiff |
| 2025-09-05 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,372,793 - "Hyperlink with Graphical Cue"
- Patent Identification: U.S. Patent No. 10,372,793, "Hyperlink with Graphical Cue," issued August 6, 2019 (the "’793 Patent"). (Compl. ¶25).
The Invention Explained
- Problem Addressed: The patent specification describes a drawback of conventional textual hyperlinks on web pages: they often do not make the destination of the link clear to the user, requiring the user to navigate away from the current page to view the destination content, an operation described as "tedious and time-consuming." (’793 Patent, col. 1:49-65).
- The Patented Solution: The invention proposes a multi-step user interface method. First, a web page displays a set of menu items. When a user interacts with a menu item (e.g., by hovering over it), the system displays a second set of representations of hyperlinks (e.g., graphical logos or previews of the destination pages). The user can then select one of these representations to navigate. This allows a user to preview a link's destination without leaving the initial web page, as illustrated in the patent's Figure 5A, which depicts content from a selected hyperlink appearing in a separate frame on the same page as the initial menu. (’793 Patent, Abstract; Compl. ¶¶35-37).
- Technical Importance: The described technique aims to improve the efficiency of web navigation by providing users with a "look-ahead" capability, which helps manage limited "visual 'real estate'" on a web page. (’793 Patent, col. 2:7-15).
Key Claims at a Glance
- The complaint identifies independent claim 29 as the sole asserted claim. (Compl. ¶¶15, 27).
- The essential elements of method claim 29 are:
- Providing content for a web page that includes menu items and initially hidden hyperlinks.
- Causing the display of the menu items without images.
- Allowing receipt of a first user input selecting a menu item.
- In response, causing the display of the set of hyperlinks.
- Allowing receipt of a second user input selecting one of the displayed hyperlinks.
- In response, causing the display of "another web page" with "additional content simultaneously with the set of one or more representations of one or more menu items." (Compl. ¶27).
- The complaint does not indicate if the right to assert dependent claims has been reserved.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the Horace Mann corporate website. (Compl. ¶12).
Functionality and Market Context
- The website is used to market insurance products and engage with customers. (Compl. ¶12). It features a nested menu system for navigation. (Compl. ¶29). A user's selection of a top-level menu item (e.g., "Retirement") triggers a drop-down menu with hyperlinks. (Compl. ¶44). The complaint alleges that when a user clicks one of these hyperlinks, the browser is directed to an "entirely new page where a new instance of the main menu is rendered." (Compl. ¶30). The complaint includes a screenshot of the accused website showing a top-level menu button ("Retirement") and a resulting drop-down menu with hyperlink options. (Compl. ¶43, p. 11).
- The complaint asserts that the website's navigation menu and header are reloaded with each new page, rather than persisting from the prior page. (Compl. ¶¶30-31).
IV. Analysis of Infringement Allegations
Note: As this is a complaint for declaratory judgment of non-infringement, the following chart summarizes the Plaintiff's arguments for why its website does not infringe the asserted patent claim.
’793 Patent Infringement Allegations
| Claim Element (from Independent Claim 29) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| causing, using the web page code of the web page and in response to receipt of the second input indicating the selection of the one of the set of one or more representations of one or more hyperlinks, display of another web page...including at least a portion of additional content simultaneously with the set of one or more representations of one or more menu items... | The Horace Mann website navigates the user to an entirely new web page. The navigation menu on the new page is a re-rendered instance, not the original instance from the previous page. Thus, the new content is not displayed "simultaneously with" the original set of menu items. | ¶¶30, 32, 46 | col. 1:57-65 |
- Identified Points of Contention:
- Scope Questions: The central dispute appears to be the meaning of displaying new content "simultaneously with the set of...menu items." The complaint advances a theory that this requires the original instance of the menu to remain on-screen with the new content, as depicted in the patent's Figure 5A which shows a preview frame on the initial page. (Compl. ¶¶33, 36). The case will raise the question of whether navigating to a new page that re-renders a functionally identical menu satisfies this limitation.
- Technical Questions: A key factual question will be how the accused website is architected. The complaint alleges that the menu is reloaded with each new page's server-rendered HTML, distinguishing it from a persistent, client-side component that would remain static while other content updates around it. (Compl. ¶¶31, 46). Evidence regarding the website's source code and operation will be central to determining if its function aligns with the patent's description of displaying a preview "without navigating away from the first web page." (Compl. ¶33). The complaint contrasts the accused functionality with the patent's frame-based preview system and also likens the accused website to prior art cascading menus, as shown in Figure 7 of the '183 patent. (Compl. ¶¶38, 41-42).
V. Key Claim Terms for Construction
- The Term: "display of another web page... simultaneously with the set of one or more representations of one or more menu items"
- Context and Importance: This limitation is the crux of Plaintiff's non-infringement argument. The definition will determine whether the claim covers traditional website navigation (where a new page is loaded that includes a header/menu) or is limited to more specific implementations, such as displaying a preview of a destination page within a frame on the original page. Practitioners may focus on this term because its construction appears to be dispositive of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that the plain meaning of "simultaneously" is met as long as some version of the menu items and the new content appear on the screen at the same time, regardless of whether the menu is the original instance or a newly rendered one. The claim language refers to "the set of" menu items, which could be read to mean the collection of items rather than a specific software instance of those items.
- Evidence for a Narrower Interpretation: The complaint points to the patent's background, which identifies the problem as the "tedious and time-consuming" need to "leave the current web page" to identify a link's destination. (’793 Patent, col. 1:57-65; Compl. ¶33). The solution, as embodied in Figure 5A, shows the new content appearing in a second frame (502b) on the same initial page as the first frame (502a) containing the menu. (Compl. ¶36). This context suggests "simultaneously with" implies a single-page user experience where the original menu persists.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaration that it is not liable for any indirect infringement. (Compl. ¶49). The complaint does not, however, detail any specific allegations of knowledge or intent made by Defendant that would form the basis of such a claim.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: does the claim phrase "display... simultaneously with the set of... menu items" require the original software instance of the menu to persist on the same page alongside new content, as the patent's "preview" embodiment suggests, or can it be construed to cover navigating to a new web page that simply re-renders a functionally identical menu?
- A related evidentiary question will be one of technical distinction: what factual evidence supports the complaint's assertion that the accused website's page-reload architecture is fundamentally different from the patent's described method of displaying a preview without navigating away from the initial page, and is that difference sufficient to place it outside the scope of the asserted claim?
- An underlying issue is one of validity: the complaint raises an anticipatory validity challenge, arguing that if the claim is construed broadly enough to read on the accused website, it would also read on prior art menu systems that were before the patent office during prosecution. (Compl. ¶57). This presents a classic dilemma for the patent holder in defining its claim scope.