DCT

2:25-cv-02521

GeoSymm Ventures LLC v. Telus Intl US Corp

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-02521, D. Nev., 12/18/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Nevada because Defendant maintains an established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to the architecture of a virtual "assistive agent" that processes user requests by interfacing with external web services.
  • Technical Context: The technology at issue falls within the domain of digital personal assistants (e.g., Siri, Google Assistant), which interpret natural language queries and interact with various application programming interfaces (APIs) to provide intelligent responses.
  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2013-03-15 U.S. Patent No. 9,130,900 Priority Date (Application Filing)
2015-09-08 U.S. Patent No. 9,130,900 Issued
2025-12-18 Complaint Filed

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

U.S. Patent No. 9,130,900 - "Assistive agent"

  • Issued: September 8, 2015

The Invention Explained

  • Problem Addressed: The patent background describes how early personal information managers (PIMs) and productivity software failed to "take full advantage of the information available to them" to enhance user productivity, such as intelligently scheduling reminders based on context. (Compl. ¶8; ’900 Patent, col. 1:21-30).
  • The Patented Solution: The invention discloses a system and method for an intelligent "assistive agent" that can process a user's request by breaking it down into its core meaning ("semantics") and then interacting with multiple, distinct "semantic web services" through an Application Program Interface (API) to formulate a response. (’900 Patent, Abstract; Fig. 2). The process involves receiving a request (202), determining its semantics to identify a domain, task, and parameters (204, 206), accessing external web services via an API (208), determining a responsive answer (210), and responding to the user (212). (’900 Patent, col. 5:26-col. 6:21).
  • Technical Importance: The described architecture provides a framework for a centralized digital assistant to leverage the capabilities of disparate, specialized third-party services, enabling it to fulfill complex user requests that span multiple information domains. (’900 Patent, col. 3:4-9).

Key Claims at a Glance

  • The complaint alleges infringement of "Exemplary '900 Patent Claims" contained in a non-proffered exhibit. (Compl. ¶10). Claim 1 is the first independent method claim of the patent.
  • Claim 1 recites a method with the essential elements of:
    • receiving a user request for assistance from a mobile device;
    • determining semantics of the user request and identifying at least one domain, task, and parameter by parsing the request to identify representations of meaning, along with location and personal information from the device;
    • accessing one or more semantic web services through an API to retrieve matching data;
    • identifying, generating, or providing personalized recommendations;
    • presenting possible responses to the user by interacting with the semantic web services via the API, and confirming user responses by accessing a text messaging or phonebook API;
    • determining at least one responsive answer; and
    • responding to the user request.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products or services by name, referring only to "Exemplary Defendant Products." (Compl. ¶7, ¶10).

Functionality and Market Context

The complaint does not describe the specific features, functions, or market context of the accused instrumentalities. It alleges that infringement details are provided in "charts incorporated into this Count," but these charts (identified as Exhibit 2) were not filed with the complaint. (Compl. ¶10, ¶15-16).

IV. Analysis of Infringement Allegations

The complaint references claim charts in Exhibit 2 that compare the "Exemplary '900 Patent Claims to the Exemplary Defendant Products," but this exhibit was not provided. (Compl. ¶15-16). The infringement theory is therefore limited to the general allegation that Defendant makes, uses, sells, or imports products that "practice the technology claimed by the '900 Patent." (Compl. ¶10, ¶15).

No probative visual evidence provided in complaint.

Identified Points of Contention

Given the lack of specific infringement allegations, any litigation will first require discovery to establish the technical operation of the accused products. Based on the patent’s claims, subsequent disputes may center on several questions:

  • Scope Questions: Does the accused system perform the claimed step of "determining semantics...by parsing the user request to identify representations of meaning," or does it use a different method for query interpretation?
  • Technical Questions: What constitutes a "semantic web service" under the patent's claims, and do the external services accessed by the accused products meet that definition? Further, what evidence demonstrates that the accused products access a "text messaging API or a phonebook API" for the specific purpose of "confirming user responses" as required by Claim 1?

V. Key Claim Terms for Construction

"determining semantics of the user request"

  • Context and Importance: This term appears central to the invention, describing the "intelligence" of the assistive agent. Its construction will be critical to distinguishing the claimed invention from simple keyword matching or direct command execution. Practitioners may focus on whether this requires a specific multi-part analysis (identifying domain, task, and parameter) as suggested by the claim language.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes this step in general terms, such as interpreting user intent and disambiguating among interpretations. (’900 Patent, col. 5:12-16).
    • Evidence for a Narrower Interpretation: The claim itself links this step to the specific outcome of "identifying at least one domain, at least one task, and at least one parameter." (’900 Patent, col. 27:60-63). The specification also provides a specific code-like example of mapping a request to a "domain," "task," and "parameter." (’900 Patent, col. 6:12-19).

"semantic web services"

  • Context and Importance: The scope of this term defines the universe of external services with which the claimed assistant must interact. The dispute will likely question whether this term applies to any service accessible via an API or is limited to services employing specific semantic web technologies.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent frequently uses the term in a general sense to refer to third-party data sources like "Facebook, Amazon, Yahoo, eBay, and the like sources." (’900 Patent, col. 4:32-34).
    • Evidence for a Narrower Interpretation: The specification explicitly mentions technologies like Resource Description Framework (RDF) and "web ontology language" in connection with semantic web services, suggesting a more technical and limited meaning. (’900 Patent, col. 13:20-23).

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement, asserting that Defendant distributes "product literature and website materials" that direct end users to use the accused products in an infringing manner. (Compl. ¶13). The complaint states these materials are referenced in the non-proffered Exhibit 2. (Compl. ¶13, ¶26).

Willful Infringement

The complaint alleges that Defendant has had "actual knowledge" of its infringement since the service of the complaint and has continued its infringing activities despite this knowledge, which forms the basis for a claim of post-suit willful infringement. (Compl. ¶12-13).

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

The initial phase of this case will be defined by the complaint’s lack of factual specificity. The central questions that emerge are:

  1. An Evidentiary Question: What are the accused products and what is their precise technical architecture? Without this foundational information, which the complaint defers to an unfiled exhibit, no meaningful infringement analysis is possible.
  2. A Question of Claim Scope: Assuming an accused product is identified, the dispute will likely turn on the construction of core claim terms. A key issue will be one of definitional scope: does the term "semantic web service" encompass any modern third-party API, or is it limited to a narrower, more technical definition suggested by the patent’s references to specific ontology languages?
  3. A Question of Infringement: Can Plaintiff prove that the accused products perform the specific multi-step process of "determining semantics" by "parsing" a request to identify a "domain, task, and parameter" as recited in the claims, or is there a fundamental mismatch in the accused systems' operational logic?