GeoSymm Ventures LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GeoSymm Ventures LLC (Texas)
  • Defendant: Samsung Electronics Co., Ltd. (South Korea)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:23-cv-324, E.D. Tex., 07/13/2023
• Venue Allegations: Venue is alleged to be proper because the defendant is a foreign corporation and has committed acts of patent infringement in the district, causing harm.
• Core Dispute: Plaintiff alleges that certain of Defendant’s products with digital assistant functionality infringe a patent related to methods for processing user requests and interacting with web services.
• Technical Context: The technology at issue falls within the domain of digital personal assistants, which interpret natural language queries to perform tasks or retrieve information by orchestrating various applications and remote services.
• 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. Plaintiff is identified as the assignee of the patent.

Case Timeline

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

• Patent Identification: U.S. Patent No. 9,130,900 (“Assistive agent”), issued September 8, 2015 (the “’900 Patent”).

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

The Invention Explained

• Problem Addressed: The patent’s background section describes a shortcoming in existing Personal Information Managers (PIMs), which hold extensive user data but "have failed to take full advantage of the information" to enhance productivity proactively (e.g., automatically determining reminder times for appointments) (’900 Patent, col. 1:21-30).
• The Patented Solution: The invention proposes a system where a user's request is received by a server that determines the "semantics" of the request by identifying a domain, task, and parameters (’900 Patent, Abstract). This server then uses an Application Program Interface (API) to access one or more "semantic web services" to gather information or perform an action, ultimately formulating and delivering a response to the user (’900 Patent, col. 3:1-19; Fig. 2). The system is designed to act as an intelligent intermediary, unifying disparate services to fulfill a user's intent.
• Technical Importance: The described technology aims to provide a more integrated and intelligent virtual assistant capable of understanding user intent and orchestrating multiple independent web services to fulfill complex requests (’900 Patent, col. 4:1-19).

Key Claims at a Glance

• The complaint does not identify specific claims but incorporates by reference an unfiled exhibit that allegedly contains this information (Compl. ¶11, 16). The analysis below focuses on independent claim 1 as a representative claim.
• Independent Claim 1 (Method):
  • receiving a user request for assistance from a mobile device;
  • determining semantics of the user request and identifying at least one domain, task, and parameter by parsing the request to identify its meaning along with location and user personal information (including telephone, texting, and user activity) captured by the device;
  • accessing one or more "semantic web services" via an API to retrieve matching data;
  • identifying, generating, or providing personalized recommendations;
  • presenting responses by interacting with the web services and "confirming user responses by accessing a text messaging API or a phonebook API";
  • determining a responsive answer; and
  • responding to the user request.
• The complaint’s general allegation of infringement of "one or more claims" suggests it reserves the right to assert additional independent and dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products. It refers generally to "Exemplary Defendant Products" that are purportedly identified in an unfiled exhibit (Compl. ¶11, 16).

Functionality and Market Context

• The complaint provides no specific details regarding the technical functionality or operation of the accused products. It makes the conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '900 Patent" and that they "satisfy all elements of the Exemplary '900 Patent Claims" (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint’s substantive infringement allegations are incorporated by reference from "Exhibit 2," which was not filed with the public complaint (Compl. ¶16, 17). The complaint alleges that Defendant directly infringes by making, using, and selling the accused products and by having its employees test and use them (Compl. ¶11-12). Without the specific comparisons from Exhibit 2, the infringement theory must be inferred from the patent claims and the general nature of Defendant's business, which includes mobile devices and digital assistant software. The core of the infringement theory appears to be that Defendant's digital assistant technology performs the method steps recited in the '900 Patent's claims.

• Identified Points of Contention:
  • Scope Questions: A central dispute may concern the proper construction of the claim term "semantic web services." The question for the court will be whether this term is limited to formal Semantic Web technologies like RDF, which are mentioned in the specification, or if it can be read more broadly to cover any modern, API-accessible web service that returns structured data (’900 Patent, col. 13:18-22).
  • Technical Questions: The complaint's allegations raise the evidentiary question of whether Plaintiff can prove that the accused products perform every limitation of the asserted claims. For example, Claim 1 requires "confirming user responses by accessing a text messaging API or a phonebook API" (’900 Patent, col. 28:7-10). A technical dispute may arise over whether the accused products perform this specific, arguably unconventional, confirmation step.

V. Key Claim Terms for Construction

• The Term: "semantic web services"

• Context and Importance: This term appears in the core "accessing" step of independent claim 1. Its construction will be critical to the scope of the patent. A narrow construction could significantly limit the range of accused technologies, while a broad one could cover a wide array of modern web architectures.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides examples of third-party sources like "Facebook, Amazon, Yahoo, eBay, and the like" as services the invention can interact with, suggesting a broad interpretation that is not limited to a specific protocol (’900 Patent, col. 4:31-35).
  • Evidence for a Narrower Interpretation: The specification also explicitly mentions technologies like "Resource Description Framework (RDF)" and "web ontology language," which a party could argue cabins the term to its more formal, technical meaning within computer science (’900 Patent, col. 13:18-22).

• The Term: "parsing the user request to identify... location and user personal information captured by the mobile device including telephone, texting, and user activity"

• Context and Importance: This limitation in claim 1 describes how the system determines the "semantics" of a request. The interpretation of this phrase is key to determining infringement, as it defines a specific method of using user context that may or may not be practiced by the accused products.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent’s stated goal is to "take full advantage of the information" available on a device to "enhance productivity" (’900 Patent, col. 1:25-30). This purpose may support a broader reading where any use of contextual information (e.g., current location, calendar entries) to interpret a query meets this limitation.
  • Evidence for a Narrower Interpretation: The explicit recitation of "telephone, texting, and user activity" could be interpreted to require an active analysis of the content or logs of these specific activities during the parsing step, as opposed to a more general use of device state or sensor data (’900 Patent, col. 27:63-65).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant encourages infringement by distributing "product literature and website materials" that instruct end users on how to use the accused products in their "customary and intended manner" (Compl. ¶14-15).
• Willful Infringement: The complaint does not allege pre-suit knowledge of the ’900 Patent. Instead, it asserts that "service of this Complaint... constitutes actual knowledge" (Compl. ¶13). This suggests any claim for willful infringement is based on Defendant's alleged continuation of infringing activities after the lawsuit was filed.

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

• A core issue will be one of pleading sufficiency: An initial question for the court may be whether the complaint, which identifies no specific products and contains its infringement contentions in an unfiled exhibit, provides plausible grounds for relief as required by federal pleading standards.
• The case will also turn on a question of definitional scope: The viability of the infringement claim will likely depend on whether the term "semantic web services" is construed broadly to encompass the general-purpose APIs common in modern digital assistants, or narrowly to require the specific Semantic Web technologies disclosed in the patent.
• Finally, a key evidentiary question will be one of functional specificity: Assuming the case proceeds, Plaintiff will face the challenge of proving that the accused products perform the specific, and at times idiosyncratic, method steps of the asserted claims, such as the requirement to parse "telephone, texting, and user activity" and confirm responses via a "phonebook API."