DCT
1:24-cv-08821
Ctext IP LLC v. Apple Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ctext IP LLC (Texas)
- Defendant: Apple Inc. (California)
- Plaintiff’s Counsel: Stamoulis & Weinblatt
- Case Identification: 1:24-cv-08821, S.D.N.Y., 03/03/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Southern District of New York because Apple has committed acts of infringement in the district and maintains regular and established places of business there.
- Core Dispute: Plaintiff alleges that the "Tapback" and "Reply" features in Defendant's iOS and iPadOS devices infringe patents related to methods for visually correlating messages within a conversation.
- Technical Context: The technology addresses user interface challenges in digital messaging, specifically the difficulty of tracking multiple conversational threads that occur in parallel within a single chat window.
- Key Procedural History: The complaint notes that both asserted patents overcame Section 101 eligibility rejections during prosecution after amendments were made to the claims. Plaintiff argues these amendments, which added limitations about changing a visual element of the message entry location, distinguish the claims from abstract ideas and conventional user interfaces.
Case Timeline
| Date | Event |
|---|---|
| 2013-12-23 | Earliest Priority Date for ’857 and ’304 Patents |
| 2015-05-29 | Non-Final Rejection for '857 Patent Application |
| 2015-08-19 | Applicant Interview for '857 Patent Application |
| 2015-09-04 | Notice of Allowability for '857 Patent Application |
| 2016-01-26 | U.S. Patent No. 9,246,857 Issues |
| 2016 | Alleged Launch of Accused "Tapback" Feature |
| 2017-07-06 | Non-Final Rejection for '304 Patent Application |
| 2017-12-27 | Applicant Response for '304 Patent Application |
| 2018-02-26 | Notice of Allowance for '304 Patent Application |
| 2018-06-26 | U.S. Patent No. 10,009,304 Issues |
| 2020 | Alleged Launch of Accused "Reply" Feature |
| 2023-01-05 | Plaintiff Notifies Defendant of Alleged Infringement |
| 2025-03-03 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,246,857 - Method and System for Correlating Conversations in a Messaging Environment, issued January 26, 2016
The Invention Explained
- Problem Addressed: In digital "chat" interfaces, multiple conversations often occur in parallel, with messages presented in a simple chronological order. This can lead to confusion, as it is often unclear which prior message a new message is responding to, especially when participants switch topics rapidly (Compl. ¶¶12-13; ’857 Patent, col. 1:46-50).
- The Patented Solution: The invention provides a method for a user to select a specific prior message, thereby defining an "active conversation." The system then alters a visual aspect of the message entry location to match a "visual cue" (e.g., a color or pattern) associated with that active conversation. When the user sends a new message, it is displayed with the same visual cue, explicitly linking it to the prior message and clarifying the conversational thread (’857 Patent, Abstract; col. 2:5-15).
- Technical Importance: The method provides a specific graphical user interface (GUI) solution to improve the clarity and usability of messaging applications that handle complex, multi-threaded dialogues (’857 Patent, col. 1:58-62).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 15, and dependent claims 2, 5-7, and 14-16 (Compl. ¶49).
- Independent Claim 1: A method comprising the essential elements of:
- Providing a discussion interface with a first and second message.
- Providing a message entry location.
- Receiving an indication that the first message is part of an "active conversation."
- Changing a visual element of the message entry location upon receipt of the indication to match a first visual cue shared by messages in the active conversation.
- Receiving a new message at the message entry location.
- Displaying the new message, which incorporates the first visual cue.
U.S. Patent No. 10,009,304 - Method and System for Correlating Conversations in a Messaging Environment, issued June 26, 2018
The Invention Explained
- Problem Addressed: The patent, which is a continuation of the '857 Patent, addresses the same problem of conversational ambiguity in chronologically ordered chat interfaces (Compl. ¶20; ’304 Patent, col. 1:29-32).
- The Patented Solution: Like its parent, the ’304 Patent describes a GUI method for linking messages. It specifies receiving an indication that a new message is responsive to a specific prior message. In response, a visual element of the message entry location is changed to match a visual cue from the prior message. The new message is then displayed with that same cue, visually connecting the reply to its antecedent (’304 Patent, Abstract; col. 2:5-23). The patent further refines the "visual cue" to include forms such as associated text and proximity (’304 Patent, col. 2:50-54).
- Technical Importance: This invention refines the GUI-based solution for managing conversational threads, offering specific implementations of visual cues like text and proximity to enhance user comprehension (’304 Patent, col. 1:58-62).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 14, and dependent claims 2, 6, 7, 11, 12, and 15 (Compl. ¶60).
- Independent Claim 1: A method comprising the essential elements of:
- Providing a discussion interface displaying a first and second message.
- Providing a message entry location.
- Receiving an indication that a new message is responsive to the first message.
- Changing a visual element of the message entry location to match a first visual cue shared with the first message.
- Receiving the new message at the message entry location.
- Displaying the new message with the first visual cue applied, where the cue is shared by the first message and the new message.
III. The Accused Instrumentality
Product Identification
- Apple iPhone and iPad devices running iOS version 10 or later, which include the iMessage application (collectively, the "Accused Products") (Compl. ¶49).
Functionality and Market Context
- The complaint focuses on two specific iMessage features: "Tapback" and "Reply" (Compl. ¶32).
- The Tapback feature allows a user to long-press on a message and apply a small icon (e.g., a heart, thumbs-up) that appears attached to the original message bubble (Compl. ¶¶18, 33). The complaint presents a screenshot from an Apple support document showing the menu of Tapback options, including a heart, thumbs up, and question mark, appearing after a user interacts with a specific message (Compl. p. 18).
- The Reply feature allows a user to select a specific message and open a new, dedicated conversational thread. Subsequent replies are visually linked to the original message, often with a line, and can be viewed either inline with the main conversation or in a separate, focused view (Compl. ¶¶18, 32, 35). A screenshot from an Apple support page for the "Reply inline" feature shows a user swiping on a message bubble to open a dedicated reply interface (Compl. p. 25).
- The complaint alleges these features are "innovative" and central to the "exclusivity" and user retention ("lock-in") of Apple's iMessage ecosystem (Compl. ¶¶33-34).
IV. Analysis of Infringement Allegations
'857 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing a discussion interface ... wherein the discussion interface displays a first message and a second message | Apple's iMessage application displays a conversation transcript containing multiple message bubbles. | ¶49; p. 18 | col. 5:12-14 |
| providing a message entry location for inputting new messages | The iMessage interface includes a text input field for composing new messages. | ¶49; p. 18 | col. 5:14-17 |
| receiving, at the first interface device, a first indication that the first message is part of an active conversation | A user provides an indication by touching and holding a specific message bubble to initiate a Tapback or Reply. | ¶¶16, 18, 32 | col. 5:36-44 |
| changing a visual element of the message entry location upon receipt of the first indication to match a first visual cue shared by messages associated with the active conversation | When a user initiates a Reply, a new reply interface appears that is visually distinct from the main message entry location, allegedly constituting the required change. | ¶¶16, 18 | col. 2:45-49 |
| receiving a first new message at the message entry location; and displaying the first new message within the discussion interface ... wherein the displaying of the first new message incorporates the first visual cue | A user types and sends a Tapback (e.g., a heart icon) or a textual Reply. The resulting icon or message is displayed visually associated with the selected prior message (e.g., attached to the bubble or linked by a thread line). | ¶¶16, 18, 32 | col. 5:58-63 |
- Identified Points of Contention:
- Scope Question: Does initiating a "Reply," which opens a new, temporary input interface, constitute "changing a visual element of the message entry location" as required by the claim? A court may need to determine if "the" message entry location refers only to the primary, persistent text box at the bottom of the screen, or if it can encompass other input fields that appear.
- Technical Question: Does applying a "Tapback" icon satisfy all steps of the claim? The complaint's theory appears to conflate the indication step with the new message itself, which may raise questions about whether the sequence of claimed steps is met by the accused functionality.
'304 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing a discussion interface at a first interface device, wherein the discussion interface displays a first message and a second message | The iMessage application displays a conversation with multiple messages from different parties. | ¶60; p. 25 | col. 4:39-42 |
| providing a message entry location for inputting new messages | The iMessage interface provides a text field for message composition. | ¶60; p. 30 | col. 4:40-42 |
| receiving, at the first interface device, a first indication that a first new message is responsive to the first message | A user indicates responsiveness by swiping or long-pressing a specific message to invoke the "Reply" feature. The complaint includes an instructional graphic from Apple showing a user swiping on a message bubble to reply (Compl. p. 30). | ¶¶60, 63 | col. 5:36-41 |
| changing a visual element of the message entry location upon receipt of the first indication to match a first visual cue shared with the first message | When the Reply feature is invoked, the input focus shifts to a dedicated reply thread interface, which the complaint alleges is a change to the visual element of the message entry location. | ¶¶23, 60 | col. 11:29-34 |
| receiving the first new message at the message entry location; and displaying the first new message with the first visual cue applied | A user enters a reply in the new interface, and the sent message appears visually connected to the original message by a threading line, which acts as the "visual cue." | ¶¶60, 63 | col. 6:11-15 |
- Identified Points of Contention:
- Scope Question: The infringement analysis for the ’304 patent raises a similar claim scope question as the '857 patent regarding the "message entry location" limitation.
- Technical Question: Claim 11, which is asserted, requires the visual cue to be in the form of "text associated with the first message and proximity." Does the visual threading line in Apple's Reply feature meet the "text associated with the first message" requirement? The analysis may depend on whether the visual context of the threaded reply implicitly provides the required textual association.
V. Key Claim Terms for Construction
The Term: "changing a visual element of the message entry location"
- Context and Importance: This term appears in the independent claims of both patents and was added during prosecution to overcome §101 rejections (Compl. ¶¶21, 23). Its construction is therefore critical to both validity and infringement. The dispute will likely center on whether the appearance of a separate, temporary reply interface (as in the accused "Reply" feature) constitutes a "change" to "the" message entry location, or if the claim requires a modification of the primary, persistent text box itself.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discusses modifying the message entry location so that "text entered appears in the same format and with the same visual cues as will appear when the text is transmitted," which could be read to include a new, specially-formatted input area (’857 Patent, col. 11:29-34).
- Evidence for a Narrower Interpretation: The patent figures (e.g., ’857 Patent, Figs. 3A-3G) consistently depict a single, persistent "message entry location" (440) at the bottom of the screen. A defendant may argue that "changing a visual element" of this specific location means altering its properties (e.g., its background color), not creating a separate interface.
The Term: "visual cue"
- Context and Importance: The nature of the "visual cue" is core to the invention. While the term itself is broad, the claims require that the cue is "shared" and "incorporated." The infringement analysis will depend on whether the accused features (a small Tapback icon or a threading line) function as the claimed "visual cue."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of potential cues, including "color coding," "text size, symbols or icons appended to the message, indentation levels, font formatting," and "proximity" (’857 Patent, col. 5:63-col. 6:3; col. 2:50-54). This broad definition appears to support the plaintiff's theory that icons and threading lines fall within the scope.
- Evidence for a Narrower Interpretation: A defendant may argue that the context of the claims requires a cue that is more integral to the message content or background itself, rather than a simple appended icon (Tapback) or a connecting line (Reply). The emphasis on changing the "message entry location" to match the cue could suggest a more robust visual link, such as a shared background color, is required.
VI. Other Allegations
- Indirect Infringement: The complaint alleges Apple induces infringement by providing customers with advertisements and "instructive materials" that "specifically teach and encourage" users to use the accused Tapback and Reply features in an infringing manner (Compl. ¶¶52, 63). The complaint includes screenshots from Apple's official support website with step-by-step instructions on how to "Reply inline to a specific message" and "React with Tapbacks" (Compl. pp. 25-26, 30-31).
- Willful Infringement: Willfulness is alleged based on Apple's purported knowledge of the patents since at least January 5, 2023, via a notice letter from CText (Compl. ¶¶42, 54, 65). The complaint argues that Apple's continued infringement despite this notice is deliberate and justifies enhanced damages (Compl. ¶¶54, 65).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction and infringement: Can the claim limitation "changing a visual element of the message entry location" be construed to read on the accused iMessage "Reply" feature, which generates a separate, temporary input interface rather than altering the primary, persistent text box? The outcome of this question may determine infringement for a key part of the accused functionality.
- The case will likely involve a significant dispute over validity under 35 U.S.C. § 101: The complaint dedicates extensive argument to the patents' prosecution histories and their survival of §101 rejections. The key question for the court will be whether the claims, as amended, are directed to a specific improvement in computer GUI technology, as Plaintiff contends, or merely an abstract idea of organizing conversations implemented on a generic computer, as Defendant will likely argue.
- A third key question will be one of evidentiary proof for inducement: While Plaintiff provides Apple's user guides as evidence of intent, the ultimate question will be whether these materials, in view of the specific claim limitations, actively encourage acts that constitute direct infringement. This will tie back to the court's construction of the key claim terms.