DCT
2:18-cv-00215
Relativity Display LLC v. Home Depot Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Relativity Display LLC (Texas)
- Defendant: The Home Depot, Inc. (Delaware)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: Relativity Display LLC v. The Home Depot, Inc., 2:18-cv-00215, E.D. Tex., 05/21/2018
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of patent infringement in the district and maintains a regular and established place of business, specifically a retail store, within the district.
- Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes patents related to methods for retrieving, integrating, and displaying data in a hierarchical, object-oriented manner.
- Technical Context: The patents address challenges in e-commerce and web search technology, specifically how to retrieve data from disparate sources and present it to users in a structured, navigable format to reduce information overload.
- Key Procedural History: The complaint notes that U.S. Patent No. 6,301,584 is a continuation-in-part of an earlier application and claims priority to a 1998 European application, which may be relevant for determining the scope of prior art and for claim construction. U.S. Patent No. 6,868,525 claims the benefit of a provisional application filed in 2000.
Case Timeline
| Date | Event |
|---|---|
| 1997-08-21 | '584 Patent Priority Date |
| 2000-02-01 | '525 Patent Priority Date |
| 2001-10-09 | '584 Patent Issue Date |
| 2005-03-15 | '525 Patent Issue Date |
| 2018-05-21 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,301,584 - System and Method for Retrieving Entities and Integrating Data (Issued Oct. 9, 2001)
The Invention Explained
- Problem Addressed: The patent identifies a need for a mechanism to collect relevant information located at multiple sites and stored in incompatible formats, a common problem for conventional search engines not well-suited to indexing structured or disparate databases (’584 Patent, col. 1:56-64, col. 2:16-19; Compl. ¶10).
- The Patented Solution: The invention is a data integration system that gathers information from diverse sources, structures it into a configurable, object-oriented model, and then outputs it to the user. A key aspect is the use of a class hierarchy, where a "dependent class" can inherit properties from a base class and also have its own additional properties, allowing the system to retrieve a richer set of data than would be available by querying the base class alone (’584 Patent, Abstract, col. 2:20-39). The patent’s Figure 3 illustrates a detailed data metamodel defining the relationships between classes, attributes, and other data structures.
- Technical Importance: This technology provided a structured framework for integrating data from varied sources, a crucial capability as e-commerce platforms began needing to consolidate product information from different suppliers and internal databases into a single user-facing catalog (’584 Patent, col. 1:20-27).
Key Claims at a Glance
- The complaint asserts independent claim 17 (Compl. ¶18).
- The essential elements of method claim 17 include:
- Storing a plurality of classes, where each class defines a structure for entities with property definitions.
- Including at least one "dependent class" that is hierarchically linked to another class and comprises "additional property definitions."
- Receiving a query that identifies a particular class and property values.
- Selecting the identified class.
- Accessing data sources and retrieving property values for an entity.
- Establishing if the retrieved entity pertains to a dependent class.
- If so, retrieving the "additional properties" of that dependent class.
- Outputting the retrieved entities with their properties.
U.S. Patent No. 6,868,525 - Computer Graphic Display Visualization System and Method (Issued Mar. 15, 2005)
The Invention Explained
- Problem Addressed: The patent’s background section recognizes that internet searches often return an "incredibly numerous" amount of hits, including many "garbage" results, making it impractical for users to find relevant information (’525 Patent, col. 3:7-15; Compl. ¶¶14-15).
- The Patented Solution: The invention describes an improved user interface that organizes and displays information in a "graphic representation of a hierarchy populated with naturally classified objects" (’525 Patent, Abstract). This hierarchical visualization is intended to make large sets of search results more navigable and comprehensible. The system may also employ a collaborative filter to define an "associated object," such as a sponsored product, to generate revenue (’525 Patent, Abstract; col. 3:45-51).
- Technical Importance: The technology aimed to move beyond simple, flat lists of search results by providing a taxonomic or hierarchical structure, a method intended to improve the user's ability to navigate and understand large, complex data sets online (’525 Patent, col. 4:45-51).
Key Claims at a Glance
- The complaint asserts independent claim 44 (Compl. ¶33).
- The essential elements of method claim 44 include:
- Providing an "object browser."
- Receiving user-defined selection criteria and returning resource locators for selected objects.
- Displaying the resource locators within the object browser in a "hierarchy."
- Placing objects in the hierarchy in a "content-dependent manner" and an "association-dependent manner," with the hierarchy having at least one level with at least two objects.
III. The Accused Instrumentality
- Product Identification: The Home Depot website (homedepot.com) and its associated backend systems (Compl. ¶18, ¶34).
- Functionality and Market Context: The complaint describes the accused instrumentality as an e-commerce website that allows users to search for products ("entities") by entering search terms or browsing through a system of categories and subcategories (Compl. ¶¶18-19, ¶35). For example, a user can navigate from "Appliances" to "Microwaves" and then to more specific sub-types like "Over-the-Range Microwaves" (Compl. ¶21). The complaint includes a screenshot from the website's "Microwaves" page showing 240 search results, which are identified as "entities" (Compl. Fig. 2, p. 5). The complaint does not contain specific allegations about the website's market positioning beyond its operation by The Home Depot.
IV. Analysis of Infringement Allegations
’584 Patent Infringement Allegations
| Claim Element (from Independent Claim 17) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| storing a plurality of class | The website stores product categories and sub-categories, such as "Departments" and "Appliances," which the complaint alleges are "classes." (Compl. Fig. 4, p. 7). | ¶19 | col. 6:58-62 |
| said classes include at least one dependent class hierarchically linked to at least one other class, said dependent class comprising additional property definitions | "Over-the-Range Microwaves" is alleged to be a dependent class of "Microwaves," which is itself a dependent class of "Appliances." The dependent classes allegedly have additional property definitions, such as filters for brand or features. (Compl. Fig. 7, p. 10). | ¶21 | col. 2:31-36 |
| receiving a query, said query including an identifier for identifying a particular class and at least one of said property values | A user's selection of the "Microwaves" category is alleged to be a query for that particular class. (Compl. Fig. 9, p. 12). | ¶22 | col. 2:37-40 |
| retrieving property values pertaining to at least one particular entity that comprise said at least one of said property values | The website retrieves and displays information for specific products, such as "Over the Range" microwaves, which are alleged to be "entities." | ¶25 | col. 2:42-44 |
| retrieving... said additional properties of said dependent class | When a user navigates to a dependent class like "Over-the-Range Microwaves," the website allegedly retrieves additional properties like specific brands, colors, and features for those products. A screenshot shows filters for these properties. (Compl. Fig. 14, p. 17). | ¶27 | col. 2:45-49 |
| outputting the retrieved entities | The website displays the search results, showing the identified products (entities) along with their properties, such as price. (Compl. Fig. 15, p. 18). | ¶28 | col. 2:44-45 |
- Identified Points of Contention:
- Scope Questions: A primary question is whether the website's navigation structure (e.g., Department > Category > Sub-Category) meets the patent's specific, object-oriented definition of "class" and "dependent class." The analysis will likely focus on whether a sub-category with additional filters constitutes a "dependent class comprising additional property definitions" as taught in the patent's detailed data metamodel (’584 Patent, Fig. 3), or if this is a mischaracterization of standard faceted search functionality.
’525 Patent Infringement Allegations
| Claim Element (from Independent Claim 44) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing an object browser | The complaint alleges that the Home Depot e-commerce portal, which provides a web page for users to search for products, constitutes an "object browser." A screenshot of the homepage is labeled as such. (Compl. Fig. 16, p. 20). | ¶34 | col. 19:26-27 |
| receiving a user-defined content-based selection criteria and returning respective resource locators of selected objects | A user entering a search term is alleged to be providing "selection criteria." The website returns product listings, which contain links ("resource locators") to product detail pages. (Compl. Fig. 17, p. 21). | ¶35 | col. 19:28-33 |
| displaying the respective resource locators... within a hierarchy, wherein objects selected based on content are placed in the hierarchy in content-dependent manner | The complaint alleges that search results are displayed in a hierarchy, pointing to the ability to sort results by criteria like "Price Low to High." A screenshot shows this sorting menu, which is alleged to be a "hierarchy in content dependent manner." (Compl. Fig. 19, p. 23). | ¶36 | col. 19:34-43 |
- Identified Points of Contention:
- Scope Questions: The infringement theory raises the question of whether a standard e-commerce website can be considered an "object browser" within the meaning of the claim. Further, it raises the question of whether a simple, sortable list of search results (e.g., sorted by price) meets the claim's requirement for a "hierarchy" where objects are placed in both a "content-dependent" and "association-dependent" manner.
V. Key Claim Terms for Construction
For the ’584 Patent
- The Term: "dependent class"
- Context and Importance: This term is the technological core of asserted claim 17. The plaintiff’s infringement theory depends on construing the website’s product sub-categories as "dependent classes." The defendant will likely argue for a narrower construction that requires a more specific object-oriented data structure than is present in a typical e-commerce site.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language requires that the dependent class be "hierarchically linked" and comprise "additional property definitions" (’584 Patent, col. 26:3-9). This could be interpreted to cover any sub-category that adds new filters or attributes not available at the parent level.
- Evidence for a Narrower Interpretation: The specification describes a detailed "information metamodel" with specific fields and relationships, such as the "Is A" data type (229) that formally defines subclass relationships (’584 Patent, Fig. 3, col. 7:21-41). A court may determine that the term requires the implementation of such a formal, object-oriented inheritance structure.
For the ’525 Patent
- The Term: "object browser"
- Context and Importance: This term appears in the first step of asserted claim 44. Its construction is critical because if a standard website is not an "object browser," the claim may not apply at all. Practitioners may focus on this term because it is not explicitly defined in the specification, making it a central point of dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent’s background discusses standard "web browsers" and the problems of navigating the web, suggesting the invention is meant to operate in that environment (’525 Patent, col. 1:17-20). This may support an interpretation where "object browser" broadly covers any interface for browsing objects online.
- Evidence for a Narrower Interpretation: The patent aims to provide an "improved" interface, distinct from conventional systems (’525 Patent, Abstract). This could support a narrower reading where an "object browser" is a specialized tool with the specific hierarchical visualization capabilities taught in the patent, rather than a generic web page.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Home Depot induces infringement by its customers. The alleged inducement is based on providing access to and instructions for its website, thereby enabling and encouraging customers to perform the steps of the patented methods (Compl. ¶29, ¶38).
- Willful Infringement: The prayer for relief requests trebled damages for willful infringement (Compl. p. 25, ¶D). However, the complaint does not allege a factual basis for willfulness, such as pre-suit notice of the patents or egregious conduct.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of definitional scope: can the hierarchical categories of a standard e-commerce website (e.g., 'Over-the-Range Microwaves' as a subset of 'Microwaves') be construed as the specific "dependent class" structure, with inherited and "additional properties," as contemplated by the ’584 patent’s detailed data metamodel?
- A key evidentiary and legal question will be one of technical and definitional equivalency: does a standard e-commerce webpage qualify as an "object browser," and does its simple sorting functionality (e.g., "Price Low to High") constitute the specific, dual-basis "hierarchy" required by Claim 44 of the ’525 patent?
- The resolution of these cases will likely depend on whether the court construes the claim terms broadly to cover conventional e-commerce features or narrowly to require the specific, more complex software architectures described in the patent specifications.