DCT
2:15-cv-00585
eDekka LLC v. E Revolution Ventures Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: eDekka LLC (Texas)
- Defendant: E Revolution Ventures, Inc. (Delaware)
- Plaintiff’s Counsel: Austin Hansley P.L.L.C.
- Case Identification: 2:15-cv-00585, E.D. Tex., 05/01/2015
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has transacted business and committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s e-commerce website functionality, specifically its shopping cart feature, infringes a patent related to storing and retrieving information using user-defined labels.
- Technical Context: The technology concerns a method for users to create, organize, and randomly access stored information (originally contemplated as audio) using custom labels within a hierarchical data structure.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history. It asserts that willfulness, if found, should commence from the filing date of the complaint.
Case Timeline
| Date | Event |
|---|---|
| 1992-03-16 | U.S. Patent No. 6,266,674 Priority Date |
| 2001-07-24 | U.S. Patent No. 6,266,674 Issue Date |
| 2015-05-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,266,674 - Random Access Information Retrieval Utilizing User-Defined Labels
- Patent Identification: U.S. Patent No. 6,266,674, issued July 24, 2001.
The Invention Explained
- Problem Addressed: The patent identifies the drawbacks of contemporary information storage methods, such as written lists that are cumbersome to sort and restructure, and cassette tape recorders that are limited to slow, sequential access. (’674 Patent, col. 1:21-38).
- The Patented Solution: The invention proposes a method and apparatus where a user can store information (such as a spoken memo), designate a portion of that information to act as a "label," and then organize these labels into a user-defined data structure, such as a hierarchy with "parent," "child," and "peer" relationships. (’674 Patent, Abstract; col. 2:48-58). This structure allows the user to navigate and randomly access the stored information using the labels, for instance via a keypad with directional controls. (’674 Patent, col. 5:38-44).
- Technical Importance: The technology provided a system for creating a customizable, navigable index for non-textual data like audio, enabling random access in a manner distinct from the purely sequential methods common at the time. (’674 Patent, col. 1:40-44).
Key Claims at a Glance
- The complaint alleges infringement of "one or more claims" and specifically quotes language corresponding to independent method Claim 1 and independent apparatus Claim 17 (Compl. ¶11-13).
- Independent Claim 1 (Method): The essential elements include:
- in response to user input, receiving and storing information;
- in response to user input, designating the information as data while the information is being received;
- in response to user input, designating at least a portion of the information as a label while the information is being received;
- in response to user input, traversing a data structure and providing an indication of a location in the data structure;
- in response to user input, storing the label at the location in the data structure; and
- associating the label with the data.
- Independent Claim 17 (Apparatus): This claim recites a series of "means" for performing the functions outlined in Claim 1. The essential elements are:
- info input means...for receiving and storing information;
- data means...for designating the information as data while the information is being received;
- label means...for designating at least a portion of the information as a label while the information is being received;
- search means...for traversing a data structure and for providing an indication of a location;
- means...for storing the label at the location in the data structure; and
- associating means...for associating the label with the data.
- The complaint does not explicitly limit its allegations to these claims, preserving the right to assert others. (Compl. ¶13).
III. The Accused Instrumentality
Product Identification
The "Checkout, Shopping Cart, and/or Shopping Bag functionality" on the website www.thinkfastbaby.com. (Compl. ¶13).
Functionality and Market Context
The complaint alleges that the accused instrumentality is an e-commerce shopping cart system. (Compl. ¶13). Functionally, such systems allow a user to select products for purchase, which are then held in a temporary list or "cart." The user can typically view the contents of the cart before proceeding to checkout. The complaint does not provide specific details about the operation of the accused website's cart, its user interface, or its underlying software architecture. No probative visual evidence provided in complaint. Further, the complaint does not contain allegations regarding the product's commercial importance or market position.
IV. Analysis of Infringement Allegations
The complaint does not provide a claim chart exhibit. The following table summarizes the plaintiff's apparent infringement theory for Claim 1 by mapping the claim elements to the general functionality of an e-commerce shopping cart, as the complaint itself lacks specific factual mappings.
’674 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| in response to user input, receiving and storing information | A user clicks an "add to cart" button, causing the server to receive and store the selection. | ¶11 | col. 18:5-7 |
| in response to user input, designating the information as data while the information is being received | The system processes the user's selection as a product to be purchased. | ¶11 | col. 18:8-10 |
| in response to user input, designating at least a portion of the information as a label while the information is being received | The product's name and image are designated as an identifier for the selected item. | ¶11 | col. 18:11-14 |
| in response to user input, traversing a data structure and providing an indication of a location in the data structure | A user navigates to the shopping cart page to view the list of selected items. | ¶11 | col. 18:15-18 |
| in response to user input, storing the label at the location in the data structure | The product identifier (name/image) is stored in the data structure representing the cart's contents. | ¶11 | col. 18:19-21 |
| associating the label with the data | The system links the product identifier in the cart to the underlying product data (e.g., SKU, price, quantity). | ¶11 | col. 18:22-23 |
- Identified Points of Contention:
- Scope Questions: The patent specification heavily focuses on a handheld audio recording device. (’674 Patent, Fig. 7). A central dispute may be whether claim terms rooted in that context read on the functionality of a web-based e-commerce platform. For instance, does a user clicking "add to cart" meet the limitation of "designating...a label while the information is being received"?
- Technical Questions: What specific functionality in the accused system constitutes "traversing a data structure"? The patent describes active navigation of a hierarchy using directional inputs. (’674 Patent, col. 7:1-14). It raises the question of whether simply viewing a linear list of items in a shopping cart satisfies this limitation, or if more active navigation is required.
- Means-Plus-Function Analysis: Claim 17 is a means-plus-function claim, limiting its scope to the structures disclosed in the specification and their equivalents. The specification discloses a CPU, DSP, and keypad as the relevant structure. (’674 Patent, col. 3:1-12). The infringement analysis for this claim will depend on whether the accused website's distributed architecture (e.g., web servers, databases, client-side JavaScript) is structurally equivalent to the patent's disclosed handheld device.
V. Key Claim Terms for Construction
The Term: "label"
Context and Importance: The definition of "label" is fundamental, as the invention is a system for organizing information with labels. The plaintiff's case may depend on this term being construed broadly to mean any identifier, while the defendant may argue for a narrower definition tied to the patent's embodiments.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent defines a label as "an identifier which refers to speech information," suggesting it can be any reference. (’674 Patent, col. 4:65-66). It also contemplates that information can be text or other forms, not just speech, which may support a broader view of what constitutes a label. (’674 Patent, col. 2:30-34).
- Evidence for a Narrower Interpretation: The specification repeatedly describes a preferred embodiment where the user "defines a portion of the speech to serve as a label." (’674 Patent, col. 2:62-64). This language, tying the label to the underlying data it represents, could support a narrower construction that a product's name (pre-existing data) does not meet.
The Term: "traversing a data structure"
Context and Importance: This term is critical to the "random access" aspect of the invention. Whether viewing a shopping cart constitutes "traversing" will be a key point of dispute.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification notes that the simplest hierarchy is a "linear list," which could be argued to describe a standard shopping cart view. (’674 Patent, col. 6:52-54).
- Evidence for a Narrower Interpretation: The detailed description extensively discusses traversing as an active process of moving a "cursor" up, down, left, and right between "parent," "child," and "peer" nodes in a hierarchy using specific keypad inputs. (’674 Patent, col. 5:38-44; col. 7:1-24). This may support a narrower construction requiring active, multi-directional navigation rather than passive viewing.
VI. Other Allegations
- Willful Infringement: The complaint requests a finding of willful infringement, but only for conduct occurring after the defendant was put on notice by the filing of the complaint. (Compl., Prayer for Relief D). There are no allegations of pre-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can claim terms such as "label" and "traversing a data structure", which are described in the patent in the context of a 1990s-era handheld audio organizer, be construed broadly enough to encompass the functions of a modern, web-based e-commerce shopping cart?
- A key infringement question will be one of structural equivalence: for the asserted apparatus claims, are the software-driven, distributed components of the accused website (e.g., servers, databases, browser clients) structurally equivalent to the specific, self-contained hardware (CPU, keypad) disclosed in the patent's specification for performing the claimed functions?
- A central evidentiary question will be one of operational mapping: can the plaintiff produce sufficient evidence to demonstrate that the accused shopping cart's operation performs each step of the claimed method, particularly showing that a "label" is designated "while the information is being received" in a manner consistent with the patent's teachings.