IDB Ventures LLC v. Burlington Stores Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: IDB Ventures, LLC (Texas)
  • Defendant: Burlington Stores, Inc. (Delaware)
  • Plaintiff’s Counsel: Cunningham Swaim, LLP
• Case Identification: 2:17-cv-00589, E.D. Tex., 07/06/2017
• Venue Allegations: Plaintiff alleges venue is proper because Defendant transacts business and has a regular place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to a graphical user interface for filtering and sorting data objects.
• Technical Context: The technology concerns user interfaces for database management, specifically methods that allow users to rapidly and interactively define search parameters and sort criteria to reformat data displays.
• Key Procedural History: The complaint notes that predecessors in interest to the patent complied with marking requirements. No other significant procedural history is mentioned.

Case Timeline

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

U.S. Patent No. 6,216,139 - “Integrated Dialog Box for Rapidly Altering Presentation of Parameter Text Data Objects on a Computer Display,” Issued April 10, 2001

The Invention Explained

• Problem Addressed: The patent describes a problem with then-existing database and spreadsheet programs, which it contends were not well-suited for users needing to quickly analyze data by viewing it from different perspectives. The patent states that reformatting tables or changing sort parameters required "a series of precisely-specified steps that can frustrate a user interested in quickly pursuing many varying lines of thought" and often required specialized training. (’139 Patent, col. 1:40-45, col. 2:6-21).
• The Patented Solution: The invention proposes a single, integrated "Query dialog box" that combines the functions of data filtering and sort-order construction. A user can select values for multiple data parameters (e.g., "Issue," "Type") and simultaneously define a multi-level sort order using those same parameters, all within one interface. (’139 Patent, col. 3:11-28; Fig. 3). This integrated approach is intended to allow a user to "rapidly to switch from viewing a table of text data objects... sorted according to one or more parameters... to viewing a table of the same text data objects sorted according to a different set of parameters." (’139 Patent, col. 2:55-62).
• Technical Importance: The invention claims to enhance a user's analytical capabilities by enabling "contextual data modeling," which is the rapid perception of relationships between data objects by quickly reformatting displays without interrupting the user's "line of thought." (’139 Patent, col. 2:30-45).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 19, as well as dependent claim 2 (Compl. ¶9).
• Independent Claim 1 (Method):
  • imaging, on a display device controlled by the computer system, a query dialog box,
  • wherein the query dialog box displays each of a plurality of parameters associated with each of the text data objects, forms a plurality of spaces for listing values associated with each displayed parameter, and further forms a space for selecting a sort order;
  • designating, for each displayed parameter, a parameter value;
  • constructing a sort order from the displayed parameters in the space for selecting a sort order;
  • selecting, using the computer system, text data objects satisfying the designated values; and
  • sorting, using the computer system, the selected text data objects according to the constructed sort order.
• Independent Claim 19 (Computer Memory Storage Device): This claim recites a computer memory storage device encoded with a program containing "means for" performing the five core functions outlined in method claim 1 (imaging a query dialog box, designating a parameter value, constructing a sort order, selecting objects, and sorting objects).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Defendant's website, www.burlingtonstores.com (Compl. ¶9).

Functionality and Market Context

The complaint alleges the website provides an e-commerce platform where users can search for and purchase products. The relevant functionality includes a "search menu" that allows users to filter product listings based on a "plurality of parameters" such as "category brand, price, etc." (Compl. ¶12). The complaint further alleges that this interface provides a "space for selecting a sort order," giving examples such as "sort by: best match" or "featured newest, best selling, etc." (Compl. ¶12). After a user selects filter parameters and a sort order, the website allegedly displays a list of matching products sorted accordingly (Compl. ¶12-13). The complaint alleges this functionality is provided to customers in the United States (Compl. ¶10).

IV. Analysis of Infringement Allegations

'139 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be whether a modern, integrated e-commerce webpage with filter menus constitutes a "query dialog box" as that term is used in the patent. The patent's figures depict a self-contained, modal-style window (e.g., '139 Patent, Fig. 3), which may support an argument that the claims require a UI element distinct from the main content-display area. The interpretation of "text data objects" could also be a point of dispute, specifically whether the term is limited to purely textual database records or can read on modern product listings that include images and other rich media.
  • Technical Questions: The claim requires "constructing a sort order from the displayed parameters." The complaint alleges this is met by selecting from a list like "best selling" (Compl. ¶12). A technical question is whether selecting from a pre-defined list of sort options is equivalent to the patent's teaching of actively "constructing" a sort order by selecting and prioritizing multiple parameters (e.g., sort first by 'Type', then by 'Date Due') ('139 Patent, col. 6:40-60).

V. Key Claim Terms for Construction

• The Term: "query dialog box"
• Context and Importance: This term defines the core user interface element of the invention. Its construction will be critical to the infringement analysis, as the defendant's modern webpage interface differs visually from the 1995-era interface depicted in the patent's figures. Practitioners may focus on this term because its scope determines whether the patent can read on modern web design or is limited to the specific implementation shown.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's "Summary of Invention" describes the invention in functional terms as a system to "rapidly to switch from viewing a table... sorted according to one or more parameters to viewing a table... sorted according to a different set of parameters" (’139 Patent, col. 2:55-62). The specification also refers to the element's function of displaying parameters and providing spaces for value selection and sort order construction, without explicitly limiting its form to a pop-up window (’139 Patent, col. 3:14-24).
  • Evidence for a Narrower Interpretation: The patent’s figures, which "illustrate particular embodiments of the invention," consistently depict a distinct, titled, and bordered window labeled "I-TRAC Query" (e.g., ’139 Patent, Fig. 3). This visual embodiment, which is separate from the underlying data table, may be used to argue that a "dialog box" is structurally distinct from the main application window or webpage.

VI. Other Allegations

• Indirect Infringement: The prayer for relief seeks judgment for "inducing the infringement of, or contributing to the infringement of" the '139 Patent (Compl. p. 6). However, the body of the complaint does not contain specific factual allegations detailing acts of inducement or contributory infringement, such as knowledge of the patent and specific intent to cause infringement.
• Willful Infringement: The complaint does not include an explicit allegation of willful infringement or facts to support pre-suit or post-suit knowledge of infringement.

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

• A core issue will be one of definitional scope: can the term "query dialog box," which is described and depicted in the patent as a discrete, windowed user interface element common in 1990s software, be construed to cover an integrated filtering and sorting sidebar or menu within a modern, dynamic e-commerce webpage?
• A second key question will be one of functional operation: does the accused website's feature of selecting a sort option from a pre-defined dropdown list (e.g., "best selling") meet the claim limitation of "constructing a sort order from the displayed parameters," which the patent specification describes as an interactive process of selecting and prioritizing multiple data fields?