GeoSymm Ventures LLC v. Pixelplex Labs LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GeoSymm Ventures LLC (Texas)
  • Defendant: Pixelplex Labs LLC (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-04772, S.D.N.Y., 06/05/2025
• Venue Allegations: Venue is alleged to be proper in the Southern District of New York because the Defendant maintains an established place of business in the district and has allegedly committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified "Exemplary Defendant Products" infringe a patent related to a server-based "assistive agent" that processes user requests by determining their semantic meaning and orchestrating responses from multiple web services via an API.
• Technical Context: The technology at issue falls within the domain of digital personal assistants, such as those found on smartphones and smart speakers, which integrate data from various sources to answer user queries and perform tasks.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

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

The Invention Explained

• Problem Addressed: The patent describes conventional Personal Information Managers (PIMs) as having failed to "take full advantage of the information available to them" ('900 Patent, col. 1:22-30). For instance, they require users to manually set reminders without context and are ineffective if the user is away from their device when a reminder is triggered (col. 1:24-30).
• The Patented Solution: The invention proposes a system where a user request on a mobile device is sent to a server that acts as an intelligent intermediary ('900 Patent, Fig. 1). The server parses the request to determine its "semantics"—identifying the domain, task, and parameters—and then accesses one or more "semantic web services" through an Application Program Interface (API) to generate a relevant response or perform an action (col. 5:53-62). This architecture is designed to integrate disparate data sources and services in a consistent manner to provide more useful assistance (col. 3:1-9).
• Technical Importance: The patented architecture provides a method for creating sophisticated digital assistants that can understand user intent and orchestrate complex actions across multiple independent services, moving beyond simple, siloed applications ('900 Patent, col. 3:1-9).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" of the ’900 Patent, referencing "exemplary claims" in a separate exhibit (Compl. ¶11; Prayer ¶B). Independent claim 1 is representative.
• Independent Claim 1 requires:
  • Receiving a user request for assistance from a mobile device;
  • Determining the semantics of the request by parsing it to identify meaning, along with location and personal information (e.g., telephone/texting activity);
  • Accessing one or more "semantic web services" via an API to retrieve matching data;
  • Identifying, generating, or providing personalized recommendations;
  • Presenting possible responses by interacting with the web services and confirming user responses by accessing a text messaging or phonebook API;
  • Determining a responsive answer; and
  • Responding to the user request.
• The complaint's reference to "one or more claims" suggests the right to assert dependent claims is reserved.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any of the accused instrumentalities by name. It refers generally to "Exemplary Defendant Products" that are purportedly identified in an exhibit not filed with the complaint (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It makes only the conclusory allegation that the products "practice the technology claimed by the '900 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

Infringement Theory

The complaint does not contain a narrative description of the infringement theory. Instead, it states that infringement allegations are detailed in claim charts attached as Exhibit 2, which was not filed publicly with the complaint (Compl. ¶¶16, 17). These charts purportedly compare the asserted claims to the "Exemplary Defendant Products" (Compl. ¶16). The complaint further alleges inducement of infringement through the distribution of "product literature and website materials" that instruct users on the products' infringing use (Compl. ¶14). No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the claim language and the general nature of the technology, the infringement analysis raises several questions:

• Scope Questions: Claim 1 requires accessing "semantic web services." A central dispute may be whether the services accessed by the accused products qualify as "semantic web services" as described in the patent, which contemplates specific technologies like RDF and ontologies, or if they are merely standard web APIs.
• Technical Questions: The claim requires "determining semantics of the user request" by "parsing the user request to identify representations of meaning or interpretation." A key technical question will be whether the accused products perform this level of semantic analysis, as opposed to simpler keyword matching or rule-based routing, and what evidence Plaintiff can produce to demonstrate this internal functionality.

V. Key Claim Terms for Construction

• The Term: "semantic web services" (Claim 1)

• Context and Importance: The scope of this term is fundamental to the infringement analysis, as it defines the universe of back-end technologies covered by the claim. Practitioners may focus on this term because its definition could either confine the patent to a niche set of technologies or allow it to read on the vast majority of modern digital assistants.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests the term could cover a wide range of services, listing common examples like "Facebook, Amazon, Yahoo, eBay, and the like sources" as potential third-party service providers ('900 Patent, col. 4:33-35).
  • Evidence for a Narrower Interpretation: The specification also explicitly references formal "Semantic Web" technologies, stating that the web services may include "Resource Description Framework (RDF)" and "web ontology language" ('900 Patent, col. 13:20-24). This could support a narrower construction limited to services employing such formalisms.

• The Term: "determining semantics of the user request ... by parsing the user request to identify representations of meaning or interpretation" (Claim 1)

• Context and Importance: This term defines the level of "intelligence" the accused system must possess. Its construction will determine whether simple query processing is sufficient to infringe or if a more sophisticated, model-based understanding is required.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent provides relatively simple examples, such as mapping the string "send a message" to the action of creating a new text message, which may suggest a broader, functional definition ('900 Patent, col. 9:26-29).
  • Evidence for a Narrower Interpretation: The detailed description emphasizes a more complex, structured approach using an "ontology" to model domains, tasks, and relationships (see Fig. 7). This could support an argument that "determining semantics" requires the use of such a structured, ontology-like framework ('900 Patent, col. 16:1-col. 17:61).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that direct and encourage end users to use the accused products in a manner that infringes the ’900 Patent (Compl. ¶14, ¶15). The allegation is predicated on knowledge gained, at the latest, from the service of the complaint itself (Compl. ¶15).
• Willful Infringement: The complaint alleges that service of the complaint provides "Actual Knowledge of Infringement" and that Defendant's continued infringing activities despite this knowledge are ongoing (Compl. ¶13, ¶14). The prayer for relief requests enhanced damages under 35 U.S.C. § 284 (Prayer ¶D).

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

• A core issue will be one of definitional scope: can the term "semantic web services," which has a specific meaning in computer science, be construed broadly to cover the conventional, non-ontological web APIs used by most modern applications, or will it be limited to the formal "Semantic Web" technologies explicitly mentioned in the patent?
• A key evidentiary question will be one of technical proof: given the complaint's lack of specific factual allegations, the case will depend on whether Plaintiff can, through discovery, produce evidence demonstrating that the accused products' internal software architecture performs the specific semantic parsing, task identification, and API orchestration functions as required by the claims.
• Finally, a central question for damages and willfulness will be one of timing and knowledge: the complaint appears to predicate its claims for indirect and willful infringement primarily on knowledge obtained from the complaint itself. The viability of these claims will depend on evidence of Defendant's pre-suit knowledge or post-suit conduct.