DCT
1:22-cv-06131
Union Tank Car Co v. Locket IP LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Union Tank Car Company (Delaware)
- Defendant: Locket IP LLC (Texas)
- Plaintiff’s Counsel: Arnold & Porter Kaye Scholer LLP
- Case Identification: 1:22-cv-06131, N.D. Ill., 11/04/2022
- Venue Allegations: Plaintiff alleges venue is proper because a substantial part of the events giving rise to the claim occurred in the Northern District of Illinois.
- Core Dispute: Plaintiff seeks a declaratory judgment that its corporate website does not infringe Defendant's patent related to personalized user interfaces and that the patent is invalid.
- Technical Context: The technology at issue involves methods for automatically rearranging graphical user interface elements, or "cards," to display portions deemed most relevant to a user based on their preferences.
- Key Procedural History: The action was filed in response to an October 26, 2022 notice letter from Defendant accusing Plaintiff of infringing the patent-in-suit. The complaint notes that Defendant has asserted the same patent against numerous other companies in 2022 and characterizes Defendant as a non-practicing entity associated with IP Edge LLC.
Case Timeline
| Date | Event |
|---|---|
| 2010-12-22 | '832 Patent Priority Date |
| 2019-12-24 | '832 Patent Issue Date |
| 2022-10-26 | Locket IP sends Notice Letter to UTLX |
| 2022-11-04 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,514,832 - "Method for locating regions of interest in a user interface," issued December 24, 2019
The Invention Explained
- Problem Addressed: The patent describes the task of finding specific topics of interest within multiple on-screen windows or "cards" as "cumbersome," particularly when the content within each card exceeds the visible display area and requires individual scrolling ('832 Patent, col. 1:26-37).
- The Patented Solution: The invention proposes a method where, upon a single user command, the system automatically analyzes multiple displayed cards, determines a "region of interest" within each, and then repositions the cards to bring those specific regions into view simultaneously ('832 Patent, col. 1:39-44). The process can involve determining user preferences from a profile or past activity and may also include removing cards that lack a region of interest and replacing them with new, more relevant cards ('832 Patent, Abstract; Fig. 17).
- Technical Importance: This approach aims to streamline user interaction with content-rich digital interfaces, such as media libraries or program guides, by personalizing the visual layout and minimizing manual navigation ('832 Patent, col. 1:19-24).
Key Claims at a Glance
- The complaint's non-infringement count focuses on independent claim 1 (Compl. ¶32).
- The essential elements of independent claim 1 are:
- determining, in response to a user command, regions of interest within each of a plurality of cards by searching information indicating previous user preferences;
- updating for display the plurality of cards to visibly show in a display area of a display device the at least one region of interest of multiple cards included in a first group of the plurality of cards;
- wherein said updating includes repositioning the plurality of cards to remove cards not included in the first group from the display area and to visibly display the at least one region of interest within all of the multiple cards included in the first group within the display area of the display device.
- The complaint seeks a declaratory judgment of non-infringement of any claim of the '832 Patent (Compl. ¶31).
III. The Accused Instrumentality
Product Identification
The website "www.utlx.com" (Compl. ¶15).
Functionality and Market Context
The complaint identifies Plaintiff UTLX as a "manufacturer, lessor, and maintainer of railroad tank cars" (Compl. ¶11). The complaint does not provide specific details about the functionality of the accused website, other than to state that Defendant accused it of infringement in a notice letter (Compl. ¶13). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement, asserting that its website does not practice the limitations of Claim 1 of the '832 Patent. The core of Plaintiff's non-infringement position is summarized below.
'832 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged (Non-)Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| determining, in response to a user command, regions of interest within each of a plurality of cards by searching information indicating previous user preferences; | Plaintiff asserts that its website does not perform this step of determining regions of interest based on user preferences. | ¶32 | col. 10:11-25 |
| updating for display the plurality of cards to visibly show in a display area of a display device the at least one region of interest of multiple cards included in a first group of the plurality of cards; | Plaintiff asserts that its website does not perform this step of updating the display to show regions of interest from a group of cards. | ¶32 | col. 10:41-50 |
| wherein said updating includes repositioning the plurality of cards to remove cards not included in the first group from the display area and to visibly display the at least one region of interest... | Plaintiff asserts that its website does not perform this step of repositioning and removing cards to display the identified regions of interest. | ¶32 | col. 9:57-63 |
Identified Points of Contention
- Scope Questions: The dispute raises a question of claim scope regarding whether the user interface elements on a corporate industrial website constitute "cards" as that term is used in the patent, which provides examples primarily from the media and television program guide context ('832 Patent, FIGS. 5-6). A further question concerns the scope of "previous user preferences" and what level of user activity tracking is required to meet this limitation.
- Technical Questions: A central factual question is whether the accused website's user interface performs the specific, multi-step process recited in Claim 1. The court will need to determine if the website, in response to a user command, actively (1) determines "regions of interest" by "searching" user data, (2) groups certain UI elements, (3) removes other elements, and (4) repositions the grouped elements to make the "regions of interest" visible as claimed.
V. Key Claim Terms for Construction
The Term: "cards"
- Context and Importance: The applicability of the patent to the accused website may depend on whether the website's UI elements (e.g., product listings, news items) fall within the definition of "cards." Practitioners may focus on this term due to the potential mismatch between the patent's media-centric examples and the accused industrial website.
- Evidence for a Broader Interpretation: The specification states that "cards can represent different applications such as electronic program guides, playlists, social media interfaces, games, video, audio, web pages, browsers, rendered media services, and the like" ('832 Patent, col. 8:57-62).
- Evidence for a Narrower Interpretation: The patent's detailed embodiments and figures almost exclusively depict "cards" in the context of television program guides and media libraries, which could support an argument that the term is implicitly limited to that technological environment ('832 Patent, FIGS. 5, 6, 11, 12).
The Term: "searching information indicating previous user preferences"
- Context and Importance: This term defines the active personalization mechanism of the invention. Its construction will be critical to determining if the accused website's functionality, if any, meets this limitation.
- Evidence for a Broader Interpretation: The patent suggests preferences can be inferred from user activity, stating that "video and audio media that are accessed more are assumed to be more relevant to a user than video and audio media that are accessed infrequently" ('832 Patent, col. 10:20-24).
- Evidence for a Narrower Interpretation: The claim's use of the verb "searching" may imply a more active process than passive tracking. The specification also describes a "user profile where a user explicitly lists keywords or indicates various subjects that the user has interest" ('832 Patent, col. 10:15-18), which could be argued as a requirement for the claimed "searching."
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment of no indirect infringement, alleging that because there is no direct infringement by the website, Plaintiff cannot be liable for inducing or contributing to infringement by its customers (Compl. ¶¶34, 35, 37).
- Willful Infringement: Willfulness is not alleged by Plaintiff, as this is a declaratory judgment action. However, the complaint establishes that Plaintiff was on notice of the patent as of October 26, 2022, via the letter from Defendant (Compl. ¶12). The complaint also asserts a "good faith belief that claim 1 is invalid and not infringed" (Compl. ¶36), which may be raised to counter any future allegation of willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "cards," which is described and illustrated in the patent within the context of television guides and media libraries, be construed to cover the user interface components of a corporate website for a railroad tank car company?
- A key evidentiary question will be one of technical operation: does the accused website perform the specific, sequential method of claim 1—actively determining "regions of interest" based on "previous user preferences" and then dynamically repositioning and removing UI elements—or does it employ a more generic or static content display architecture?
- The case also presents a significant validity challenge, raising questions of whether the claimed method is patent-eligible under 35 U.S.C. § 101 as more than an abstract idea of sorting information, whether it is indefinite under § 112 for lacking antecedent basis, and whether it is anticipated or rendered obvious by prior art (Compl. ¶¶41-44).