DCT
1:23-cv-10031
Mass Bay Brewing Co Inc v. Locket IP LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Mass Bay Brewing Company, Inc. (Massachusetts)
- Defendant: Locket IP LLC (Texas)
- Plaintiff’s Counsel: Downs Rachlin Martin, PLLC
- Case Identification: 1:23-cv-10031, D. Mass., 01/06/2023
- Venue Allegations: Venue is asserted in the District of Massachusetts because a substantial part of the events giving rise to the claims—specifically, Plaintiff's receipt of infringement notice letters at its Boston headquarters—occurred in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its commercial website does not infringe U.S. Patent No. 10,514,832 and that the patent's claims are invalid.
- Technical Context: The technology at issue involves graphical user interfaces that display content in a series of "cards" and automatically rearrange those cards to highlight regions of interest based on user preferences.
- Key Procedural History: This action was filed in response to a November 25, 2022 notice letter from Defendant's agent, IP Edge LLC, which accused Plaintiff of infringement and included a claim chart. The complaint notes that Defendant is a non-practicing entity that has asserted the patent-in-suit against numerous other companies in 2022.
Case Timeline
| Date | Event |
|---|---|
| 2010-12-22 | ’832 Patent Priority Date |
| 2019-12-24 | ’832 Patent Issue Date |
| 2022-11-25 | Defendant sent initial notice letter to Plaintiff |
| 2022-12-09 | Defendant sent first follow-up notice to Plaintiff |
| 2022-12-23 | Defendant sent second follow-up notice, referencing litigation |
| 2023-01-06 | Complaint for Declaratory Judgment filed |
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’s background section identifies as "cumbersome" the task of manually scrolling through multiple on-screen windows or "cards" to find specific topics of interest, particularly when the content on a card exceeds the visible display area (’832 Patent, col. 1:26-37).
- The Patented Solution: The invention is a method for a user interface that, in response to a single user command, automatically analyzes multiple content cards, determines "regions of interest" on those cards based on user preference data, and then rearranges the display to make those specific regions visible without requiring the user to manipulate each card individually (’832 Patent, Abstract; col. 1:40-46). The process can also involve removing cards that do not contain regions of interest from the display (’832 Patent, col. 10:47-50).
- Technical Importance: The described method aims to streamline content navigation on devices with graphical user interfaces, such as media servers or tablets, by reducing the manual input required to locate relevant information across multiple sources (’832 Patent, col. 1:26-37).
Key Claims at a Glance
- The complaint’s non-infringement and invalidity allegations focus on independent claim 1 (Compl. ¶¶34, 44-46).
- The essential elements of independent method 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 concerning all claims of the patent (’832 Patent, Prayer for Relief ¶A).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is the website of Plaintiff Mass Bay Brewing Company, "https://www.harpoonbrewery.com/" (Compl. ¶15).
Functionality and Market Context
The complaint identifies the accused instrumentality as the commercial website for the Plaintiff’s brewery business (Compl. ¶¶11, 15). The complaint does not provide specific details on the technical operation or features of the website, as its purpose is to deny, rather than explain, the infringement allegations made by the Defendant. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint is for a declaratory judgment of non-infringement and does not contain a claim chart from the Plaintiff. It does, however, identify specific claim limitations that it alleges the accused website fails to meet (Compl. ¶34). The following table summarizes the dispute by presenting the claim elements and noting the functionality the complaint denies performing.
’832 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged 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; | The complaint asserts that the accused website does not perform this function. | ¶34 | col. 10:11-28 |
| 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; | The complaint asserts that the accused website does not perform this function. | ¶34 | col. 9:41-51 |
| 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 asserts that the accused website does not perform this function. | ¶34 | col. 9:57-63 |
Identified Points of Contention
- Scope Questions: The patent’s specification is heavily oriented toward media navigation interfaces, such as television program guides and movie libraries (’832 Patent, FIG. 5, FIG. 6). A threshold question will be whether the patent’s claims can be construed to read on the product-listing features of a general-purpose commercial website.
- Technical Questions: Based on the complaint’s specific denials, the central factual dispute raises the question of whether the accused website performs the core functionality of the claim. What evidence exists that the website, in response to a user command, automatically identifies "regions of interest" based on "previous user preferences" and dynamically repositions and removes on-screen elements to feature them in the specific manner recited by the claim? (Compl. ¶34).
V. Key Claim Terms for Construction
The Term: "cards"
- Context and Importance: The applicability of the patent to a commercial website largely depends on whether a product listing or other website element constitutes a "card." Practitioners may focus on this term because its construction will determine if the accused instrumentality falls within the patent's fundamental architecture.
- Intrinsic Evidence for Interpretation:
- 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. 8:58-62).
- Evidence for a Narrower Interpretation: The patent’s figures consistently depict "cards" as discrete, window-like containers for specific media content, such as a TV show or a movie, which are manipulated as distinct objects within the interface (’832 Patent, FIGs. 5-6, 11).
The Term: "regions of interest"
- Context and Importance: This term is the object of the claimed method's search-and-display function. Its definition is critical for determining whether the accused website identifies and displays content in the claimed manner.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent suggests regions of interest can be based on a wide array of "topics, metadata, graphics, and the like" that match user preference information (’832 Patent, col. 10:11-14).
- Evidence for a Narrower Interpretation: The figures illustrate a "region of interest" as a specific portion of a larger card that is programmatically brought into view (e.g., region 1325 on card 1320 in FIGs. 13-14). This could support a narrower construction where the term requires identifying a sub-component of a card, not just an entire content item that matches a filter.
The Term: "repositioning the plurality of cards to remove cards not included in the first group from the display area"
- Context and Importance: This limitation defines a specific mechanism for updating the user interface and is one of the elements the complaint expressly denies practicing (Compl. ¶34).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue this language covers any filtering function that causes non-matching results to be hidden from the user's view.
- Evidence for a Narrower Interpretation: The specification describes this step as "cards that do not possess any regions of interest... can be optionally closed and removed from a display area," and Figure 16 shows intervening cards being "deleted/removed" to bring relevant cards together (’832 Patent, col. 9:57-63; col. 10:47-50). This may require more than a simple filter, suggesting an affirmative removal and consolidation of UI elements.
VI. Other Allegations
Indirect Infringement
The complaint states that Locket IP's notice letter accused Mass Bay of infringement by "instructing [Mass Bay] customers to use" the website (Compl. ¶14). Mass Bay denies inducing or contributing to any infringement by its customers and further argues that no indirect infringement can occur because there is no underlying direct infringement by those customers (Compl. ¶¶36, 37, 39).
Willful Infringement
The complaint does not use the term "willful infringement," but it establishes the factual basis for a potential future dispute over the issue. It acknowledges receipt of a notice letter and claim chart on November 25, 2022, establishing pre-suit knowledge (Compl. ¶12). It preemptively defends against a potential willfulness claim by asserting a "good faith belief that claim 1 is invalid and not infringed" (Compl. ¶38).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can key claim terms like "cards" and "regions of interest," which are described in the patent primarily in the context of interactive television guides and media libraries, be construed to cover the product-listing elements and filtering functionality of a standard e-commerce website?
- A key evidentiary question will be one of operational function: separate from claim construction, does the accused website actually perform the specific, multi-step method of Claim 1? The case may turn on whether the Plaintiff can show a fundamental mismatch between the website's operation and the claim's requirements for automatically determining interest based on user history, repositioning content, and simultaneously removing non-relevant content from the display in response to a single command.