Linfo IP LLC v. Raymours Furniture Co Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Raymour's Furniture Company, Inc. (New York)
  • Plaintiff’s Counsel: David J. Hoffman; Ramey LLP
• Case Identification: 1:24-cv-01163, S.D.N.Y., 02/16/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district, has committed acts of infringement in the district, and conducts substantial business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s system for presenting information infringes a patent related to discovering, analyzing, and presenting information within text content.
• Technical Context: The technology at issue involves computer-assisted methods for analyzing unstructured text (such as user reviews) to identify attributes like sentiment or topics, and providing user interfaces to filter or display information based on those attributes.
• Key Procedural History: The complaint states that the Plaintiff is a non-practicing entity with no products to mark. No other significant procedural events are mentioned.

Case Timeline

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

U.S. Patent No. 9,092,428 - "System, methods and user interface for discovering and presenting information in text content"

• Patent Identification: U.S. Patent No. 9,092,428, "System, methods and user interface for discovering and presenting information in text content," issued July 28, 2015.

The Invention Explained

• Problem Addressed: The patent addresses the problem of "information overload," where users face large amounts of unstructured text, such as hundreds of product or hotel reviews, making it difficult and time-consuming to find specific, relevant information (e.g., all negative comments about a hotel's room service) ('428 Patent, col. 1:12-38).
• The Patented Solution: The invention is a computer-assisted system that automatically analyzes text to identify grammatical, semantic, or topical attributes of words and phrases. It then provides a user with interface objects (e.g., buttons, menus) to perform actions like extracting, displaying, or highlighting text based on a selected attribute, thereby organizing and presenting the information in a more digestible format ('428 Patent, Abstract; col. 3:15-29). Figure 1 illustrates a system architecture including a linguistic analysis module (120) that processes text and a user interface (150) that allows a user to select attributes and actions.
• Technical Importance: This approach aims to save users "a considerable amount of time in gathering, organizing and digesting the information that would otherwise be difficult to handle" ('428 Patent, col. 3:12-15).

Key Claims at a Glance

• The complaint asserts claims 1-20 (Compl. ¶8). Independent claim 1 is central.
• Independent Claim 1 Elements:
  • Obtaining a text content comprising words or phrases.
  • Selecting a first and a second semantic attribute for users to select from.
  • Identifying words or phrases in the text associated with the first or second semantic attribute.
  • Displaying an "actionable user interface object" associated with a label representing the semantic attributes.
  • Allowing a user to select one of the semantic attributes via the user interface object.
  • Performing an action (extracting, displaying, hiding, highlighting, etc.) on the words or phrases associated with the user-selected attribute.
• The complaint does not explicitly reserve the right to assert dependent claims, but the general assertion of claims 1-20 implies they are at issue (Compl. ¶8).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify a specific accused product, service, or website feature by name. It refers generally to Defendant's "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶8).

Functionality and Market Context

• The complaint alleges that the Defendant "maintains, operates, and administers" a system that infringes the ’428 patent (Compl. ¶8). It provides no specific details about how the accused system operates or its features. The complaint alleges Defendant's actions caused the claimed inventions to be put into service, resulting in "monetary and commercial benefit" for the Defendant (Compl. ¶8).

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or detailed infringement allegations within its body. It states that "Support for the allegations of infringement may be found in the preliminary exemplary table attached as Exhibit B," but this exhibit was not filed with the complaint (Compl. ¶9). The narrative theory is that Defendant's system directly infringes by performing the claimed methods, and that Defendant puts the claimed inventions "into service" (Compl. ¶8). Without the specific allegations from Exhibit B, a detailed element-by-element analysis is not possible based on the complaint alone.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "semantic attribute" (Claim 1)

  • Context and Importance: This term is the core of the invention, defining the criteria upon which information is filtered and presented. Its construction will determine whether the patent covers only sophisticated linguistic analysis (like sentiment) or also applies to more common, structured data filtering (like category or price). Practitioners may focus on this term because its breadth is a central point of dispute in many software patents.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes "semantic attributes" as including "connotation" ('428 Patent, col. 8:24) and lists various types, including "opinion," "drug," and topic importance, suggesting the term encompasses any meaning-based property of a word or phrase ('428 Patent, col. 8:25-34).
    • Evidence for a Narrower Interpretation: The examples provided focus on concepts derived from unstructured text analysis, such as positive/negative opinions ('428 Patent, col. 9:1-5) or identifying "over-the-counter drug names" ('428 Patent, col. 3:51-53). A party might argue the term is limited to attributes that are linguistically derived from the text itself, not pre-existing database tags.

• The Term: "actionable user interface object" (Claim 1)

  • Context and Importance: This term defines the mechanism through which the user interacts with the system. The scope of this term is critical to determining whether common web interface elements, like standard filter checkboxes or dropdown menus, fall within the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad. The specification discloses various examples, which could be argued to be merely illustrative of a broader concept of any interactive UI element that allows a user to "select" an attribute and trigger an "action."
    • Evidence for a Narrower Interpretation: The specification shows specific examples, such as a dropdown menu for selecting opinion types (Fig. 7), clickable buttons for extracting terms (Fig. 3, element 320), and radio buttons for showing/hiding comments (Fig. 9A, element 910). An argument could be made that the term should be construed in light of these specific, disclosed embodiments.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. It asserts that Defendant "actively encouraged or instructed others (e.g., its customers...)" to use its services in an infringing manner (Compl. ¶¶10-11).
• Willful Infringement: The complaint alleges knowledge of the ’428 patent "from at least the filing date of the lawsuit" and reserves the right to amend if pre-suit knowledge is discovered (Compl. ¶¶10-11 & fn. 1-2). The prayer for relief seeks a declaration that infringement is willful and requests treble damages (Compl. ¶VI.e).

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

• A primary issue will be one of pleading sufficiency: Does the complaint, which lacks specific factual allegations mapping product features to claim elements and instead relies on an unprovided exhibit, satisfy the plausibility standard required by Federal Rule of Civil Procedure 8 and the "Twombly/Iqbal" precedents?
• The case will likely hinge on a question of definitional scope: How broadly will the court construe the term "semantic attribute"? The viability of the infringement claim may depend on whether this term can be interpreted to cover the conventional product filtering options common on e-commerce websites, or if it is limited to more complex linguistic analysis (e.g., sentiment) as emphasized in the patent's examples.
• A key evidentiary question will concern technical operation: Assuming the complaint survives a motion to dismiss, discovery will focus on whether the accused system performs the claimed function of dynamically identifying and associating attributes with words or phrases within text, or if it simply filters a product database using pre-assigned, structured metadata, which may represent a fundamental mismatch with the claimed invention.