DCT
2:23-cv-00200
Interface IP Holdings LLC v. Latam Airlines Group SA
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Interface IP Holdings LLC (Oregon)
- Defendant: LATAM Airlines Group S.A. (Chile)
- Plaintiff’s Counsel: FINDLAY CRAFT, P.C.; BRADFORD BLACK P.C.
- Case Identification: 2:23-cv-00200, E.D. Tex., 05/08/2023
- Venue Allegations: Venue is asserted on the basis that the defendant is a foreign company not resident in the United States.
- Core Dispute: Plaintiff alleges that Defendant’s website infringes three patents related to graphical user interface technologies, specifically data input methods for browser-based drop-down menus.
- Technical Context: The technology concerns user interface design for web-based forms, aiming to improve usability by dynamically adjusting the size of selection lists and enhancing search functionality within those lists.
- Key Procedural History: The complaint alleges a history of licensing and enforcement of the patents-in-suit. It notes prior lawsuits against Delta Air Lines (2012) and Qatar Airways (2017) that resulted in settlement and license agreements. The complaint also alleges that Defendant was made aware of the patents through a license offer via the Oneworld airline alliance in 2017 and a direct notice of infringement in 2022.
Case Timeline
| Date | Event |
|---|---|
| 2002-02-22 | Earliest Priority Date for ’325, ’663, and ’201 Patents |
| 2006-07-18 | U.S. Patent No. 7,080,325 Issues |
| 2008-07-29 | U.S. Patent No. 7,406,663 Issues |
| 2009-03-03 | U.S. Patent No. 7,500,201 Issues |
| 2012-11-20 | Plaintiff sues Delta Air Lines for infringing ’663 and ’201 Patents |
| 2013-01-09 | Plaintiff and Delta settle litigation |
| 2017-06-19 | Plaintiff sues Qatar Airways for infringing ’663 and ’201 Patents |
| 2017-11-21 | Plaintiff and Qatar Airways settle litigation |
| 2018 (mid) | Defendant allegedly becomes aware of patents via Oneworld License Agreement |
| 2021 (at least) | Defendant allegedly begins using the accused technology |
| 2022-11-18 | Plaintiff provides specific notice of infringement to Defendant's counsel |
| 2023-05-08 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,080,325 - "Graphical Device For Comprehensive Viewing And Input Of Variable Data Via A Browser-Based Display," issued July 18, 2006
The Invention Explained
- Problem Addressed: The patent describes a limitation in conventional browser-based pull-down menus where the width of the input field is dictated by the widest possible entry in the selection list ('325 Patent, col. 3:36-44). This can lead to inefficient use of screen space and poor user interface layout, especially when lists contain a few very long entries or when the list of choices is customized for different users ('325 Patent, col. 4:45-56).
- The Patented Solution: The invention provides a data input method where the displayed list of choices can be wider than the data entry field itself ('325 Patent, Abstract). It uses a script that runs on the user's computer to dynamically calculate the minimum width needed to display the current set of user-dependent choices, and then generates the selection list at that calculated width, which may be expandable relative to the initial field ('325 Patent, col. 8:15-28; Fig. 2B).
- Technical Importance: This approach allows for more flexible and aesthetically aligned web page layouts without truncating long entries in a selection list, improving user experience ('325 Patent, col. 12:5-9).
Key Claims at a Glance
- The complaint asserts independent claim 1 ('325 Patent, col. 14:1-51; Compl. ¶41).
- Essential elements of claim 1 include:
- Generating a graphical input device with a data entry field of a first display width.
- Associating a set of user-selectable choices with the device.
- Upon user selection, displaying a list of the choices having a second display width.
- Executing a script locally to automatically and dynamically determine a minimum display width necessary to make the widest choice visible.
- Setting the second display width to be at least that minimum width, such that the list's width is a function of the choices and is expandable relative to the first display width.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,406,663 - "Graphical Input Device With Dynamic Field Width Adjustment For Input Of Variable Data Via A Browser-Based Display," issued July 29, 2008
The Invention Explained
- Problem Addressed: The patent addresses the same problem as its parent '325 patent: the inflexible, fixed-width nature of standard HTML pull-down menus ('663 Patent, col. 2:40-49).
- The Patented Solution: The invention provides a method using a client-side script to generate what appears to be a drop-down menu but is technically a "non-menu, text-input graphic device" ('663 Patent, col. 8:46-50). This script-generated device allows the selection list to be dynamically sized based on the actual content of the choices for that specific user, overcoming the limitations of standard HTML elements ('663 Patent, col. 7:4-14).
- Technical Importance: By replacing a standard browser element with a custom-scripted one, the invention provides web developers greater control over the appearance and functionality of user input forms ('663 Patent, col. 11:35-42).
Key Claims at a Glance
- The complaint asserts independent claim 1 ('663 Patent, col. 13:40-14:7; Compl. ¶50).
- Essential elements of claim 1 include:
- Executing a client-side script.
- Generating a graphical input device as a "non-menu, text-input graphic device" that has the "general appearance of the drop-down menu."
- Sensing user entry of a character sequence.
- Automatically and dynamically determining a width of a second display as a function of the user-selectable choices' full display width.
- Displaying the second display near the initial data entry field.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,500,201 - "Data Input Method And System With Multi-Sub-Field Matching Of User Entries Into A Graphical Input Device," issued March 3, 2009
Technology Synopsis
This patent addresses the problem of inefficient keyboard navigation in long, hierarchically structured drop-down lists ('201 Patent, col. 6:46-53). The invention allows a user's typed input to be matched against different "information fields" within a single choice, especially fields that appear after a delimiter (e.g., a comma or colon), rather than just matching the beginning of the entire text string ('201 Patent, col. 13:8-13).
Asserted Claims
Independent claim 1 is asserted ('201 Patent, col. 13:40-14:12; Compl. ¶59).
Accused Features
The complaint alleges that the LATAM website's search function, which allows users to search for destinations by city, airport code, or country within the same input field, infringes this patent (Compl. ¶¶34, 37).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is the data input method and graphical input device on Defendant's website, www.latamairlines.com (Compl. ¶31).
Functionality and Market Context
- The functionality at issue is the flight search widget on the website's homepage (Compl. ¶31). The complaint alleges this widget is a graphical input device used in a markup language-based browser (Compl. ¶31). When a user begins typing in the "Enter origin" or "Enter destination" field, a list of selectable choices appears (Compl. ¶33). The complaint includes a screenshot showing a list of choices for "Dallas" that includes airport names and codes. (Compl. p. 6). This list is allegedly wider than the initial text entry field (Compl. ¶35). The complaint further alleges the system allows users to search multiple information fields, such as city names and airport codes (Compl. ¶37).
- The complaint alleges this technology has been in use on the website since at least 2021 (Compl. ¶38).
IV. Analysis of Infringement Allegations
’325 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| in a mark-up language-based browser in a user's computer, generating and displaying on a display screen a graphical input device... having a displayed data entry field of a first display width; | Latam's website uses a data input method in a browser to generate a graphical input device for flight searches. A screenshot depicts the initial input fields for origin and destination. | ¶31 | col. 8:1-6 |
| associating a current set of user-selectable choices with the graphical input device... | The website associates a set of user-selectable choices, such as airport locations, with the graphical input device. A screenshot shows a dropdown list of airport options after a user types "Dall". | ¶33 | col. 8:10-14 |
| upon sensing user selection of the graphical input device, displaying on the screen a list of the user-selectable choices, the list having a second display width; | The website is designed to sense user selection and display a list of choices. A screenshot shows the list displayed below the input field. | ¶35 | col. 8:15-18 |
| by executing a script locally... automatically and dynamically determining a minimum display width necessary to make visible a widest one of the user-selectable choices and automatically setting the second display width... whereby the second display width... is expandable relative to the first display width; | By executing a script, the website allegedly determines a minimum display width to make the widest choice visible and sets the list's width accordingly. A screenshot shows a selection list that appears wider than the input box. | ¶36 | col. 8:19-28 |
’663 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| executing a client-side script... generating and displaying on a web page a graphical input device... as a non-menu, text-input graphic device in place of a defined drop-down menu but having the general appearance of the drop-down menu; | Latam's website allegedly uses a script to generate the graphical input device, which appears as a drop-down menu. A screenshot shows the initial flight search widget. | ¶¶31, 36 | col. 8:46-50 |
| sensing user selection of said graphical input device; sensing user entry... of a character sequence... | The website senses user selection of the input field and subsequent character entry. A screenshot shows the user has typed "San". | ¶37 | col. 13:51-53 |
| automatically and dynamically determining a width of a second display as a function of the user-selectable choices' full display width... said user selectable choices not being truncated in said second display; | The website is alleged to execute a script to determine the display width needed to make the widest choice visible without truncation and sets the display width of the list. | ¶36 | col. 13:59-14:4 |
| displaying the second display near the initial data entry field; | The website displays the list of selectable choices near the origin/destination input field. A screenshot shows the list appearing directly below the input field after a user types "San". | ¶35 | col. 14:5-6 |
Identified Points of Contention
- Scope Questions: A central question for the '663 patent will be whether the accused flight search widget is a standard HTML
<select>element or a "non-menu, text-input graphic device" as the claim requires. The patent's specification distinguishes the invention from conventional HTML, suggesting this distinction is material to the claim's scope. - Technical Questions: A key factual question for the '325 and '663 patents will be whether the width of the displayed choice list is truly "dynamically" determined based on the current set of choices for a given user session, as required by the claims. The defense may argue the width is fixed or pre-set, not calculated on-the-fly as the patent describes.
V. Key Claim Terms for Construction
The Term: "graphical input device" (from '325 Claim 1 and '663 Claim 1)
- Context and Importance: The scope of this term is fundamental. Practitioners may focus on whether this term can read on a standard, browser-native HTML element (like a
<select>menu) or if it is limited to a custom-scripted object that merely mimics one. The construction will be particularly critical for the '663 patent, which further qualifies the term as a "non-menu, text-input graphic device." - Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is general. The specification describes the invention as "resembl[ing] a drop-down menu" ('325 Patent, col. 8:15-16), which could suggest it encompasses things that look and act like standard menus.
- Evidence for a Narrower Interpretation: The '325 patent specification repeatedly contrasts the invention with the limitations of "conventional graphical, text-input devices generated by browsers" and standard "HTML tags" ('325 Patent, col. 2:36-43). The '663 patent is explicit, claiming a "non-menu, text-input graphic device" that is generated "in place of the defined drop-down menu" ('663 Patent, col. 13:46-49), strongly suggesting it cannot be a standard menu itself.
- Context and Importance: The scope of this term is fundamental. Practitioners may focus on whether this term can read on a standard, browser-native HTML element (like a
The Term: "automatically and dynamically determining a minimum display width" (from '325 Claim 1)
- Context and Importance: This functional language is the core of the asserted invention in the '325 patent. The dispute will likely center on the meaning of "dynamically."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue "dynamically" simply means the width is not hard-coded and can change, without specifying when or how that change is calculated.
- Evidence for a Narrower Interpretation: The specification states the width is "sized automatically according to the selections available to the current user" ('325 Patent, col. 8:20-22) and is "customized for, the choices to be included in the list 520 downloaded for the current user" ('325 Patent, col. 10:36-38). This suggests the determination is not static but is performed in real-time based on the specific data set presented to a particular user in a particular session.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement by Defendant’s customers who use the website. The basis for this claim is that Defendant operates the website and provides promotional and marketing materials that encourage and facilitate its use (Compl. ¶¶44, 53, 62).
- Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge. The complaint asserts Defendant was aware of the patents since mid-2018 through a license agreement transmitted via the Oneworld alliance and had specific notice from Plaintiff's counsel on November 18, 2022 (Compl. ¶¶43, 52, 61). It is also alleged that Defendant engaged in reckless conduct by not investigating whether its services infringe (Compl. ¶¶46, 55, 64).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical implementation: Is the accused flight-search widget a standard HTML element, or is it a "non-menu, text-input graphic device" generated by a client-side script as required by the '663 patent? The answer will dictate whether a primary claim limitation is met.
- A key evidentiary question will be one of functional operation: Does the accused website’s code "dynamically determine" the width of the selection list based on the specific choices presented to a user in a given session, as claimed in the '325 patent? Or is the width a pre-determined, static value, which would suggest a mismatch with the claimed functionality?
- A third question will relate to the scope of search functionality: For the '201 patent, does the accused website's ability to find a location by searching for either a city name or an airport code constitute the claimed "multi-sub-field matching" of "information fields separated by a delimiter," or is it a more conventional full-text search that falls outside the claim's scope?