DCT

1:20-cv-05927

Caddo Systems Inc v. Siemens Aktiengesellschaft AG

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:20-cv-05927, N.D. Ill., 10/21/2020
  • Venue Allegations: Venue is alleged to be proper because Defendant Siemens AG is a foreign corporation subject to personal jurisdiction, and Defendant Siemens Industry, Inc. has a regular and established place of business within the Northern District of Illinois.
  • Core Dispute: Plaintiffs allege that Defendant’s Desigo CC building management platform and its corporate websites infringe six patents related to graphical user interfaces for navigating multi-level hierarchical menus via an "Active Path" breadcrumb system.
  • Technical Context: The patents address user interface designs for navigating complex, multi-layered menus, a fundamental challenge in software and web design aimed at improving user efficiency.
  • Key Procedural History: The complaint notes that this action was originally filed in the Eastern District of Texas on March 27, 2020, and was subsequently transferred to the Northern District of Illinois via a joint motion on October 5, 2020.

Case Timeline

Date Event
2002-06-06 Earliest Priority Date for all Asserted Patents
2007-03-13 U.S. Patent No. 7,191,411 Issues
2007-05-08 U.S. Patent No. 7,216,301 Issues
2009-12-29 U.S. Patent No. 7,640,517 Issues
2010-05-25 U.S. Patent No. 7,725,836 Issues
2013-01-08 U.S. Patent No. 8,352,880 Issues
2018-07-31 U.S. Patent No. 10,037,127 Issues
2020-03-27 Original Complaint Filed in E.D. Tex.
2020-10-21 Second Amended Complaint Filed in N.D. Ill.

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

U.S. Patent No. 7,191,411

  • Patent Identification: U.S. Patent No. 7,191,411, "Active Path Menu Navigation System," issued March 13, 2007.
  • The Invention Explained:
    • Problem Addressed: The patent’s background section identifies a key inefficiency in conventional “collapsing menu systems” (e.g., standard pull-down menus). Navigation must always begin from the top “root level,” preventing experienced users from leveraging their knowledge of the menu structure to access deeper levels directly (’411 Patent, col. 1:36-50).
    • The Patented Solution: The invention proposes a graphical navigation system that automatically constructs an “Active Path”—a series of selectable links resembling a breadcrumb trail—as a user navigates a hierarchical menu. This Active Path remains displayed after the standard menu collapses, providing an alternative navigation tool where each link gives direct access back to its corresponding level without requiring the user to restart from the top (’411 Patent, col. 2:37-52, Abstract).
    • Technical Importance: This approach aimed to combine the guided, step-by-step nature of traditional collapsing menus with the direct-access efficiency of text-based path commands, improving usability in complex software interfaces (’411 Patent, col. 1:11-20).
  • Key Claims at a Glance:
    • Independent Claim Asserted: Claim 1.
    • Essential Elements of Claim 1:
      • A method for navigating a multi-level hierarchical collapsing menu structure.
      • Providing a graphical user menu system for displaying and selecting items, where accessing a given level requires sequential access of preceding levels.
      • Automatically constructing an "Active Path" as a sequence of hierarchical active links as items are selected, with one link corresponding to each selected item.
      • Each active link is independently selectable, providing direct access to the hierarchical level from which the item was selected without using the graphical user menu system.
      • Displaying the Active Path as an alternative to the graphical user menu system after the user has finished selecting items and the menu has collapsed.
      • Pre-selecting a given active link triggers the display of "sibling menu items" on that level without disturbing the displayed Active Path.
    • The complaint asserts dependent claims 2-4 (Compl. ¶35).

U.S. Patent No. 7,216,301

  • Patent Identification: U.S. Patent No. 7,216,301, "Active Path Menu Navigation System," issued May 8, 2007.
  • The Invention Explained:
    • Problem Addressed: Like its parent patent, the ’301 Patent addresses the inefficiency of conventional menu systems that force users to navigate from the root level for every action (’301 Patent, col. 1:43-49).
    • The Patented Solution: The invention refines the "Active Path" concept, describing a method where browsing a hierarchical structure by "rolling over" a graphic element with a pointing device displays subordinate items. Selecting an item then dynamically constructs the Active Path, whose links provide direct access to a function or level without navigating from the root of the hierarchy (’301 Patent, Abstract; col. 2:50-67). This patent places more emphasis on the interactive browsing experience before a final selection is made.
    • Technical Importance: The technology sought to make deep, complex information structures more discoverable by allowing users to explore different branches of a hierarchy ("rolling over") before committing to a selection that alters the navigation path (’301 Patent, col. 4:48-56).
  • Key Claims at a Glance:
    • Independent Claims Asserted: Claims 1 and 9.
    • Essential Elements of Claim 1:
      • A method for navigating a multi-level hierarchical information structure.
      • Providing a graphical user menu system for item selection.
      • Dynamically constructing an Active Path as a sequence of active links as items are selected.
      • One active link corresponds to each selected item.
      • The active links provide direct access to a function, corresponding level, and menu item without needing to navigate via the graphical user menu system.
      • Each active link enables the user to directly browse all items on any given level, including all hierarchically subordinate items, without affecting the Active Path.
    • Essential Elements of Claim 9:
      • A method for navigating a multi-level hierarchical information structure.
      • Displaying a graphic element representing a root of the structure.
      • Browsing the structure by "rolling over" the graphic element, which displays sibling or subordinate items.
      • Selecting one of the displayed items.
      • Dynamically constructing an Active Path as a sequence of active links.
      • The active links provide direct access to a function or level without navigating from the root.
    • The complaint asserts dependent claims 2-5 (Compl. ¶57).

Multi-Patent Capsules

  • Patent Identification: U.S. Patent No. 7,640,517, "Active Path Menu Navigation System," issued December 29, 2009.

  • Technology Synopsis: This patent continues the "Active Path" concept, focusing on the ability to display the Active Path as an "alternative" to the main graphical menu after a user has finished making selections. It also claims the interaction of rolling over an active link with a pointing device to display sibling menu items without disturbing the main Active Path (’517 Patent, Abstract).

  • Asserted Claims: Independent claims 1 and 5; dependent claims 2-3 and 6 (Compl. ¶83).

  • Accused Features: The Desigo CC platform and Siemens website breadcrumb navigation systems are accused of constructing and displaying an "Active Path" as claimed (Compl. ¶¶84-86).

  • Patent Identification: U.S. Patent No. 7,725,836, "Active Path Navigation System," issued May 25, 2010.

  • Technology Synopsis: This patent describes a method for navigating a multi-level information structure, specifically identifying the structure as a website with hierarchically organized web pages. It claims the dynamic construction of an Active Path where each link corresponds to a hierarchical level and provides direct access to it, and the ability to browse items starting from any level via its active link without affecting the path (’836 Patent, Abstract; col. 10:2-12).

  • Asserted Claims: Independent claims 1, 7, and 8; dependent claims 2-5 (Compl. ¶105).

  • Accused Features: The Siemens website is explicitly accused of being the claimed "multi-level hierarchical website," with its breadcrumb trail functioning as the claimed "Active Path" (Compl. ¶¶113-114).

  • Patent Identification: U.S. Patent No. 8,352,880, "Active Path Navigation System," issued January 8, 2013.

  • Technology Synopsis: This patent claims an apparatus with a processor configured to provide the Active Path navigation system. It introduces the concept of a "provisional selection" of an active link (e.g., a mouse-over) displaying items on that level without affecting the active path. It also claims that selection of an active link causes the path to "truncate" to that point (’880 Patent, Abstract).

  • Asserted Claims: Independent claims 1 and 10; dependent claims 3-10, 12-20, and 22 (Compl. ¶130).

  • Accused Features: The Siemens Desigo CC and web platforms are accused of providing the claimed apparatus, where hovering over breadcrumb links provisionally displays items and clicking a link truncates the path (Compl. ¶¶132, 139).

  • Patent Identification: U.S. Patent No. 10,037,127, "Active Path Menu Navigation System," issued July 31, 2018.

  • Technology Synopsis: This patent claims an apparatus for navigating an information structure where a function is associated with at least one of the active links. It also claims a system where two functions (e.g., displaying sibling items and directing a user to content) are associated with an active link and are initiated by selecting different portions of that link (’127 Patent, col. 10:1-12; col. 9:48-52).

  • Asserted Claims: Independent claims 1, 14, and 26; dependent claims 3-11 and 13-24 (Compl. ¶167).

  • Accused Features: The Siemens platforms are accused of associating functions with the active breadcrumb links, such as allowing a user to access an item by selecting from items displayed by one of the active links (Compl. ¶170).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies two primary categories of accused instrumentalities:
    1. Product Platform Instrumentalities: The Siemens "Desigo CC Integrated Facilities Management Platform" and similar product platforms or tools (Compl. ¶35(i)).
    2. Web Instrumentalities: Web pages, menus, and menu structures accessible via Siemens' websites, such as https://new.siemens.com/global/en.html (Compl. ¶35(ii)).
  • Functionality and Market Context: The complaint alleges that both the Desigo CC platform and the Siemens websites feature multi-level hierarchical menu structures for user navigation. The Desigo CC platform is depicted as a tool for managing building automation systems, with a tree-like menu structure on the left side of the interface (Compl. p. 9). The Siemens websites are described as providing access to information about products and services through a similar hierarchical structure (Compl. p. 10). Both are alleged to implement an "Active Path" or breadcrumb-style navigation bar at the top of the user interface that displays the user's current location within the hierarchy (Compl. ¶¶36-37). The screenshot of the Desigo CC interface on page 9 shows a hierarchical tree menu on the left and a breadcrumb-style "Active Path" at the top reading "Site01-CCDemo > Site01-CCDemo > Gebäude 01-Virtuelles Gebäude..." (Compl. p. 9).

IV. Analysis of Infringement Allegations

'411 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a method for navigating within a multi-level hierarchical collapsing menu structure... The Accused Instrumentalities provide a method for navigating a multi-level hierarchical menu structure, such as the tree menu in the Desigo CC platform or the navigation menus on the Siemens website. ¶36 col. 2:41-43
automatically constructing an Active Path as a sequence of hierarchical active links as items are selected using the graphical user menu system... As a user selects items in the menu, the systems automatically construct an active path, such as the breadcrumb trail "Products & Services—Industrial Automation—Automation Systems..." ¶37 col. 2:53-57
each said active link being independently selectable thereby providing direct access to the hierarchical level from which the corresponding item was selected... Each link in the displayed breadcrumb trail (e.g., "Industrial Automation") is alleged to be independently selectable, providing direct access back to that level without navigating from the start. ¶38 col. 2:57-62
displaying the Active Path as an alternative to the graphical user menu system... after the user has finished selecting items... such that the Active Path is displayed after the multi-level hierarchical collapsing menu structure has collapsed... The complaint alleges the Active Path is displayed as an alternative navigation method after the user has made a selection and the primary collapsing menu structure is no longer displayed. ¶39 col. 2:62-67
wherein pre-selecting a given active link triggers the display of sibling menu items on the level associated with said given active link without disturbing the displayed Active Path Pre-selecting an active link (e.g., "IO Systems") allegedly triggers the display of sibling menu items (e.g., a list of SIMATIC products) without altering the breadcrumb trail itself. The screenshot on page 17 illustrates this functionality on the Siemens website (Compl. p. 17). ¶40 col. 3:1-5

'301 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for navigating within a multi-level hierarchical information structure... The Accused Instrumentalities provide a method for navigating a multi-level information structure, such as the Desigo CC platform menu. ¶58 col. 2:44-46
dynamically constructing an Active Path as a sequence of active links as items are selected using the graphical user menu system... The systems dynamically construct a breadcrumb trail as the user selects items from the main menu. ¶59 col. 2:54-57
said active links providing direct access to one of a function, corresponding level and menu item without the need to navigate using said graphical user menu system... Each link in the breadcrumb trail allegedly provides direct access to its corresponding level or function, bypassing the need to use the main graphical menu. ¶59 col. 2:58-62
each said active link enabling the user to directly browse all items on any given level of the hierarchical information structure including all hierarchically subordinate items without affecting the Active Path An active link, such as "IO Systems," allegedly allows the user to browse all items under it without changing the displayed "Products & Services—...—IO Systems" active path. ¶60 col. 4:57-67
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the term "collapsing menu structure" from the ’411 Patent, which the specification illustrates with traditional desktop pull-down menus, can be construed to read on the persistent tree-view menus shown in the accused Desigo CC platform (Compl. p. 9). The defense may argue that a persistent tree menu does not "collapse" in the manner contemplated by the patent.
    • Technical Questions: The infringement allegation for the ’411 Patent requires "pre-selecting" an active link to trigger a display of sibling items. It will be a factual question what specific user action in the accused products (e.g., a mouse-over, a click on a dropdown arrow) constitutes "pre-selecting" as distinct from "selecting," and whether that action performs the claimed function without "disturbing the displayed Active Path."
    • Functional Questions: A key issue will be whether the accused breadcrumb trails are merely locational indicators or if they function as an "alternative" navigation system as required by claim 1 of the ’411 Patent. The defense may contend that the primary navigation tool remains the main menu, and the breadcrumb is merely a supplementary feature.

V. Key Claim Terms for Construction

  • The Term: "Active Path"

  • Context and Importance: This is the central term of the asserted patents. Its construction will determine whether a modern, conventional breadcrumb navigation bar falls within the scope of the claims. Practitioners may focus on this term because the dispute will likely hinge on whether the accused breadcrumb functionality is coextensive with the specific interactive features described and claimed for the "Active Path."

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the Active Path as a "sequential listing of active links" that provides "direct access to a corresponding level" (’301 Patent, col. 4:33-37). This language could support an interpretation covering any breadcrumb trail that allows users to click on parent levels to navigate backward.
    • Evidence for a Narrower Interpretation: The specification details specific interactive behaviors, such as "rolling over" an active link to display sibling items without altering the path and selecting the final link to re-execute the last function (’411 Patent, col. 2:67-3:5; ’301 Patent, col. 3:55-59). The defense could argue these specific functions are definitional limitations of what constitutes an "Active Path."

  • The Term: "collapsing menu structure" (’411 Patent, Claim 1)

  • Context and Importance: This term in the preamble of Claim 1 of the ’411 Patent sets the technical environment for the invention. Its construction is critical because if the accused systems are found not to have a "collapsing menu structure," infringement may be avoided.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term could be construed broadly to mean any menu system where subordinate levels are hidden until a parent level is selected, which could encompass a modern tree-view menu where branches can be expanded and collapsed.
    • Evidence for a Narrower Interpretation: The patent’s background section explicitly describes the "so-called collapsing menu system" as one where "the menu collapses or disappears after a selection is made" and navigation "always commences from the initial or root level" (’411 Patent, col. 1:36-44). This could support a narrower definition limited to traditional top-bar pull-down menus, which may not describe the accused instrumentalities' persistent tree-view menus.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement under 35 U.S.C. § 271(b). The alleged acts of inducement include Siemens advertising, promoting, and providing instructions (e.g., promotional materials, websites, and support platforms) that encourage and teach customers to use the accused "Active Path" navigation features (Compl. ¶¶45-47, 71-73).
  • Willful Infringement: Willfulness is alleged based on Defendants' continued infringement after having actual knowledge of the patents and their infringement. The complaint alleges this knowledge exists "since at least the date Defendants received notice based on the filing of this First Amended Complaint" (Compl. ¶¶53, 79). This frames the willfulness contention as primarily post-suit conduct.

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

  • A core issue will be one of claim scope and evolving technology: can the term "Active Path," conceived in the context of early-2000s desktop software, be construed to cover the now-ubiquitous breadcrumb navigation bars found on modern web and application interfaces? The case may turn on whether the specific interactive functionalities described in the patents are essential limitations of the claims or merely preferred embodiments.
  • A key evidentiary question will be one of functional operation: does discovery show that the accused Siemens platforms perform the specific, multi-part methods required by the claims? For instance, does "rolling over" a breadcrumb link in the Siemens UI actually trigger the display of "sibling items" without "disturbing the displayed Active Path" as claimed in the ’411 Patent, or does it perform a different function?
  • A central claim construction dispute will likely be the meaning of a "collapsing menu structure." The resolution of whether this term is limited to the traditional pull-down menus described in the patent's background, or if it can encompass the persistent, expandable tree-view menus shown in the complaint's screenshots, may be dispositive for the infringement analysis of the ’411 Patent.