Linfo IP LLC v. Knot Worldwide Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: The Knot Worldwide, Inc. (Delaware)
  • Plaintiff’s Counsel: David J. Hoffman
• Case Identification: 1:25-cv-01633, S.D.N.Y., 02/26/2025
• Venue Allegations: Venue is alleged to be proper in the Southern District of New York because Defendant maintains a regular and established place of business in the district and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s online marketplace websites and related services, which organize and present vendor information, infringe a patent related to methods for organizing and displaying unstructured data objects based on importance.
• Technical Context: The technology addresses information overload by providing systems and user interfaces to organize large collections of electronic data, such as files or contacts, based on user-defined or system-inferred relevance.
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity and discloses that it and its predecessors-in-interest have entered into prior settlement licenses. The complaint argues these licenses do not trigger patent marking requirements under 35 U.S.C. § 287 because they did not authorize the production of a patented article, a point that may be contested in litigation over the scope of recoverable damages.

Case Timeline

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

U.S. Patent No. 9,430,131 - "System, Methods, And User Interface For Organizing Unstructured Data Objects"

• Issued: August 30, 2016

The Invention Explained

• Problem Addressed: The patent’s background section identifies the problem of "information overload" in the "Big Data" era, where users are inundated with information from sources like social network feeds, emails, and voluminous search results, making it difficult to discern valuable information from irrelevant data (ʼ131 Patent, col. 1:19-36).
• The Patented Solution: The invention proposes a system to organize unstructured electronic objects (e.g., files, contacts, messages) by assigning them "importance measures." These measures, which can be specified by a user, are used to display more relevant objects more prominently—for instance, in a separate, larger display area or with a different visual effect—while keeping less relevant objects accessible but visually de-emphasized (’131 Patent, Abstract; col. 2:7-16). Figure 1 illustrates a system where user interest (120) is used to calculate relevance (140), leading to a separated display (165, 170) of high and low relevance objects.
• Technical Importance: The described methods sought to provide a more effective way to manage and navigate large datasets by moving beyond conventional chronological or alphabetical sorting to a more granular, relevance-based presentation tunable by the user (’131 Patent, col. 1:46-51).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 (Compl. ¶9). The lead independent claim appears to be Claim 1.
• Independent Claim 1 recites a computer-implemented method with the following essential elements:
  • obtaining a plurality of electronic objects, where the objects comprise "currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book";
  • displaying the electronic objects (or their names/icons) in a user interface;
  • receiving a user-entered "importance value" associated with at least one of the objects;
  • determining a position for the electronic objects in the user interface "directly from the importance value"; and
  • placing the electronic objects in that determined position.
• The complaint notes that infringement is alleged for one or more of claims 1-20, preserving the right to assert dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendant’s "Products," which include its websites (e.g., theknot.com), related systems, and services for advertising and distributing "wedding products and wedding venues" (Compl. ¶3).

Functionality and Market Context

• The complaint alleges the accused products constitute a "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶9). The functionality appears to relate to the way Defendant’s marketplace organizes and displays vendor listings to end-users, for example on its "review platforms" (Compl. ¶12). The complaint does not provide specific technical details about how the accused systems operate beyond these general characterizations. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a "preliminary exemplary table attached as Exhibit B" to support its infringement allegations, but this exhibit was not included with the filed document (Compl. ¶10). In its absence, the infringement theory is based on the narrative allegations. The complaint posits that Defendant "maintains, operates, and administers a system" that practices the patented methods (Compl. ¶9). The core theory appears to be that the processes by which The Knot's marketplace platform organizes and displays wedding vendor listings to users—potentially based on user searches, filters, or internal ranking logic—infringe the claimed methods for organizing electronic objects based on an "importance value" (Compl. ¶9).

• Identified Points of Contention:
  • Scope Questions: A central question may be whether a "vendor listing" on a commercial website, which is typically an entry in a database, qualifies as an "electronic object" that comprises "files or file folders or directories... [or] contacts in a contact list or address book," as required by Claim 1. The patent's examples focus heavily on personal data management and enterprise search rather than public-facing e-commerce marketplaces (’131 Patent, Figs. 7, 9, 10A).
  • Technical Questions: The infringement analysis will likely require evidence of how the accused system "receiv[es] an importance value... entered by a user." It raises the question of whether a user's input of a search term (e.g., "photographer") or the selection of a filter (e.g., "sort by rating") on Defendant's website meets this claim limitation, or if the claim requires a more explicit assignment of a granular, non-binary value as depicted in the patent's embodiments (’131 Patent, Fig. 2A, 6A).

V. Key Claim Terms for Construction

• The Term: "importance value"

• Context and Importance: This term is the core mechanism of the invention. Its construction will be critical to determining whether the functionality of the accused marketplace (e.g., sorting by user review, location, or other criteria) infringes. Practitioners may focus on this term because the outcome of the infringement analysis depends on whether standard web search and filter inputs can be considered a user-entered "importance value."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that an importance measure can be specified in the form of a "text description, a binary or non-binary numerical value, or a selection of a user interface object" (’131 Patent, col. 8:17-20). This language could support an interpretation that encompasses a wide range of user inputs.
  • Evidence for a Narrower Interpretation: The patent's figures and specific embodiments consistently depict the "importance value" as an explicit, granular numerical score (e.g., "0.95," "0.8") or a selection from a multi-level scale (e.g., "High normal low," a 1-5 scale) that a user assigns to a specific criterion or object (’131 Patent, Figs. 2A-2C, 6A, 9). This may support a narrower construction that excludes more general search or filter commands.

• The Term: "electronic objects, wherein the electronic objects comprise currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book"

• Context and Importance: This phrase in Claim 1 defines the subject matter being organized. The viability of the infringement claim hinges on whether Defendant's vendor profiles fall within this definition.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent's title and abstract refer more broadly to organizing "unstructured data objects" (’131 Patent, Title, Abstract). Plaintiff may argue that the listed items ("files," "folders," "contacts") are merely exemplary and that a vendor profile on a website is analogous to a "contact" in an "address book."
  • Evidence for a Narrower Interpretation: The explicit recitation of "files," "folders," "directories," and "contacts" could be interpreted as limiting the claim scope to these specific types of personal or enterprise data structures, as distinguished from database records rendered on a commercial website. The patent repeatedly frames its examples in this context (’131 Patent, col. 2:55-57, col. 21:40-51).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting Defendant encourages and instructs customers on how to use its website in an infringing manner (Compl. ¶11). It also alleges contributory infringement, claiming Defendant's service is not a staple product and that Defendant has reason to know its customers' use is infringing, referencing "product instruction manuals" (Compl. ¶12).
• Willful Infringement: The complaint alleges willfulness based on Defendant’s knowledge of the ’131 patent from "at least the filing date of the lawsuit," reserving the right to prove pre-suit knowledge through discovery (Compl. ¶11, fn. 1).

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

1. A core issue will be one of definitional scope: can the term "electronic objects" comprising "files... folders... or contacts," rooted in the patent's context of personal and enterprise data management, be construed to cover the commercial vendor profiles displayed in Defendant’s online marketplace?
2. A key evidentiary question will be one of functional mapping: does a user's act of entering a search query or applying a filter on the accused website constitute "receiving an importance value... entered by a user" as required by Claim 1, or does the claim require a more explicit, granular assignment of a numerical or multi-level importance score as depicted in the patent's specific embodiments?
3. A significant legal and factual battle may concern damages limitation: given Plaintiff's status as a non-practicing entity with a history of licensing, the court will likely need to resolve whether Plaintiff's prior settlement agreements triggered the marking requirements of 35 U.S.C. § 287, which could substantially impact the period for which damages are recoverable.