DCT
2:22-cv-00375
Ridgeview IP LLC v. Anthology Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ridgeview IP LLC (Texas)
- Defendant: Anthology Inc. (Florida)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:22-cv-00375, E.D. Tex., 09/27/2022
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a "regular and established business presence" in the District, including a physical office in Dallas, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s "Connector" software component, which integrates data between educational software platforms, infringes a patent related to methods for dynamically displaying database search results to guide users and prevent invalid queries.
- Technical Context: The technology addresses user interfaces for database searching, aiming to prevent "null result" errors by interactively updating available search criteria and operators based on a user's prior selections.
- Key Procedural History: The complaint notes that the asserted patent family has been cited in 29 subsequent patents issued to various technology companies. No prior litigation, licensing, or post-grant proceedings are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2001-01-24 | Priority Date for U.S. Patent 6,983,270 |
| 2006-01-03 | Issue Date for U.S. Patent 6,983,270 |
| 2022-09-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,983,270 - "Method and Apparatus for Displaying Database Search Results"
- Patent Identification: U.S. Patent 6983270, "Method and Apparatus for Displaying Database Search Results," issued January 3, 2006.
The Invention Explained
- Problem Addressed: The patent identifies a common issue in database searching where users construct queries that yield no results (a "null result"), often because they are unaware of which combinations of search terms are valid within the database (’270 Patent, col. 2:6-11). This requires users to guess or rely on a pre-existing "query history" to formulate a successful search (’270 Patent, col. 2:12-16).
- The Patented Solution: The invention proposes a method and user interface that actively guide the user during query construction. After a user selects an initial search term or "entry," the system automatically updates the list of available logical operators (e.g., AND, OR) and subsequent entries to show only those choices that are guaranteed to produce at least one valid result (’270 Patent, Abstract; col. 3:2-10). This step-by-step pruning of impossible options prevents the user from ever constructing a query that would result in a null response (’270 Patent, Fig. 6).
- Technical Importance: This method simplifies the search process by making it interactive and error-proof, eliminating the need for complex correlation software or user expertise to avoid failed queries (’270 Patent, col. 2:4-16, 25-36).
Key Claims at a Glance
- The complaint asserts independent claim 1 as exemplary (Compl. ¶22).
- The essential elements of independent claim 1 include:
- displaying a set of entries and a set of operators from a database;
- selecting an initial entry;
- displaying valid results based on the selection;
- updating the displayed set of operators based on the selected entry to include only operators that will produce at least one valid result when combined with other entries;
- selecting an operator from the updated set;
- updating the displayed set of entries in response to the selected operator to include only entries that will produce at least one valid result when combined with the previous selections;
- selecting an entry from the updated set; and
- repeating the process until a desired result is achieved.
- The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations covering the patent.
III. The Accused Instrumentality
Product Identification
- The "Accused Instrumentalities" are identified as Defendant's "Connector" component and related platforms (Compl. ¶17).
Functionality and Market Context
- The complaint alleges that the accused "Connector" is a software component that "connects the Constituent Relationship Management (CRM) system with the Student Information System (SIS)" (Compl. ¶17, Fig. 2). Figure 2, a screenshot from Defendant's website, describes the product's function as integrating data between these two systems to achieve "closed loop tracking and performance measurement" (Compl. ¶17, Fig. 2). The infringement allegations assert that the accused products provide a method for performing a "CampusNexus Student database search" using filters and operators like "AND" and "OR" to refine results (Compl. ¶22(i)-(ii)).
IV. Analysis of Infringement Allegations
’270 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. displaying a set of entries from a database and a set of operators... | The accused system displays different filters (entries) and Boolean operators (e.g., AND, OR) for a database search, such as in the CampusNexus Student database (Compl. ¶22(ii)). | ¶22(ii) | col. 11:47-52 |
| b. selecting an initial entry of said displayed set of entries; | A user selects an initial filter, such as a property, from the displayed set of filters (Compl. ¶22(iii)). | ¶22(iii) | col. 11:53-53 |
| d. updating said set of displayed operators based on said selected entry, wherein said updated set of displayed operators includes only operators from the set of operators, wherein the operators...produce at least one valid result; | The system updates the displayed row operators based on the selected entry to include only those operators (e.g., AND, OR) that, when combined with the entry and another entry, will produce a valid result (Compl. ¶22(v)). | ¶22(v) | col. 11:56-62 |
| f. updating said displayed set of entries in response to the selected operator, wherein said updated displayed set of entries includes only entries from the database, wherein the entries combined...produce at least one valid result; | In response to selecting an operator (e.g., 'AND'), the system updates the available filters to include only entries that will produce a valid result when combined with the previously selected entry and operator. | ¶22(vii) | col. 12:1-5 |
| i. while said updated displayed set of valid results is not the desired result, repeating steps d. through h. ... to select an additional operator and an additional entry for the database search query, and to update said displayed set of valid results. | The system repeats the filtering steps with additional fields, entries (e.g., selecting an additional filter), and operators (e.g., 'OR') to further refine the database search query and update the results (Compl. ¶22(x)). | ¶22(x) | col. 12:9-17 |
- Identified Points of Contention:
- Technical Questions: The complaint alleges that the accused system updates available operators and entries to guarantee a valid result, but it provides no direct evidence (such as a user interface screenshot) demonstrating this specific dynamic functionality. A key question for the court will be whether the accused "Connector" product actually performs the claimed "updating" steps (1d and 1f), or if it simply provides a standard query-builder interface where users can construct a complex search that may or may not yield a result. The provided product description in Figure 2 does not detail the mechanics of its search interface (Compl. Fig. 2).
- Scope Questions: The core of the dispute may center on whether the accused product's filtering mechanism falls within the scope of the claim term "updating." The patent describes a system that actively "eliminates the irrelevant and impossible responses" to prevent null results (’270 Patent, col. 3:8-10). The question will be whether the accused product’s general filtering capability meets this specific requirement of proactively pruning options to ensure a non-null outcome with each selection.
V. Key Claim Terms for Construction
- The Term: "updating said set of displayed operators... [to] include[] only operators... [that] produce at least one valid result" (from claim 1(d)).
- Context and Importance: This limitation is central to the patent’s novelty of creating a "guided" search that avoids null results. The infringement analysis depends entirely on whether the accused system is found to perform this specific function. Practitioners may focus on this term because it defines the core logic of the invention, distinguishing it from conventional search interfaces that allow users to submit queries that might fail.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states a general goal of providing "a method for avoiding null results" and eliminating "irrelevant and impossible responses" (’270 Patent, col. 2:7-8, 65). Plaintiff may argue this supports a functional interpretation where any mechanism that prunes the operator list to guide the user toward a valid result meets the limitation.
- Evidence for a Narrower Interpretation: The detailed description and figures illustrate a very specific, sequential process. The flowchart in Figure 6 shows that after an item is selected, the system must update the operation-list before an operator can be selected. Defendant may argue this requires a mandatory, exhaustive re-evaluation and re-display of the operator list after every single entry selection, a rigid process their system may not follow.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by "advertising an infringing use" and providing the accused products for use by others (Compl. ¶27, ¶30). The factual support for these allegations is not detailed beyond general statements about Defendant’s business activities.
- Willful Infringement: The willfulness allegation appears to be based on post-suit knowledge, stating that infringement "will now be willful through the filing and service of this Complaint" (Compl. ¶26). The complaint also makes a conclusory allegation of willful blindness, asserting Defendant has a practice of not reviewing the patent rights of others before launching products (Compl. ¶31).
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of evidentiary proof and technical operation: Does the accused "Connector" software actually function as alleged? The case may depend on evidence demonstrating that the product’s user interface dynamically and sequentially updates the available operators and data entries to proactively guarantee a non-null search result with each user selection, as the patent claims require.
- The case will also turn on a question of claim construction and scope: How narrowly will the court define the "updating... [to] include only" limitations? The resolution will depend on whether this language requires a strict, exhaustive pruning of all impossible subsequent choices after each click, or if it can be read more broadly to cover any interface that guides a user toward a valid search result by limiting options.