Linfo IP LLC v. Sakscom LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Sakscom, LLC (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 2:24-cv-00048, E.D. Tex., 01/26/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and conducts substantial business and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s system for discovering and presenting information within text content infringes a patent related to methods for analyzing and displaying such information.
• Technical Context: The technology at issue addresses information overload in large bodies of text, such as user reviews, by automatically identifying and allowing users to filter or highlight content based on semantic attributes like positive or negative sentiment.
• Key Procedural History: The complaint notes that Plaintiff is a non-practicing entity. No other significant procedural events, such as prior litigation or administrative proceedings involving the patent-in-suit, are mentioned.

Case Timeline

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

• Patent Identification: U.S. Patent No. 9,092,428, "System, methods and user interface for discovering and presenting information in text content," issued July 28, 2015.

The Invention Explained

• Problem Addressed: The patent identifies the problem of "data overload," where finding specific information within large amounts of unstructured text—such as thousands of hotel reviews—is difficult and time-consuming using conventional search methods (ʼ428 Patent, col. 1:12-24). Users may wish to find all negative comments about a specific topic (e.g., "room service"), a task that is inefficient with standard keyword searches (ʼ428 Patent, col. 1:24-38).
• The Patented Solution: The invention proposes a computer-assisted method that tokenizes text content and associates grammatical, semantic, and contextual attributes with the text. It then provides user interface objects that allow a user to specify an attribute (e.g., "positive opinion") and an action (e.g., "highlight" or "extract"), thereby filtering or reformatting the text to display only the desired information (ʼ428 Patent, Abstract; col. 3:16-29). Figure 1 depicts a system that processes text content (105) through a linguistic analysis module (120) and allows a user to make selections via an attribute selector (160) and an action selector (170) on a user interface (150).
• Technical Importance: The technology aimed to provide tools to make large volumes of user-generated content and other text-heavy documents more useful by enabling analysis based on semantic meaning and context, rather than relying solely on keyword matching (ʼ428 Patent, col. 1:55-64).

Key Claims at a Glance

• The complaint asserts claims 1-20 (Compl. ¶8). Independent claim 1 is central.
• The essential elements of independent claim 1 include:
  • Obtaining text content.
  • Selecting a first and second semantic attribute for users to choose from.
  • Identifying words or phrases in the text content associated with one of the semantic attributes.
  • Displaying an "actionable user interface object" with a label representing the semantic attributes.
  • Allowing a user to select a desired attribute via the user interface.
  • Performing an action (e.g., extracting, displaying, hiding, or highlighting) on the words or phrases associated with the user-selected attribute.
• The complaint states that direct and indirect infringement of claims 1-20 is alleged (Compl. ¶8, 10-11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify a specific accused product, service, or feature by name. It broadly refers to "a system with methods and user interface for discovering information in a text content and extracting and presenting the information" that Defendant "maintains, operates, and administers" (Compl. ¶8).

Functionality and Market Context

The complaint alleges that Defendant’s system performs infringing methods by discovering, extracting, and presenting information from text content (Compl. ¶7-8). It further alleges that Defendant puts these inventions into service for its commercial benefit (Compl. ¶8). The complaint does not provide specific details on how the accused system operates or its market position.

IV. Analysis of Infringement Allegations

The complaint alleges infringement through a preliminary exemplary table attached as Exhibit B (Compl. ¶9). As Exhibit B was not included with the provided complaint document, a detailed claim chart analysis cannot be performed. The complaint broadly alleges that Defendant's system performs the steps of the asserted claims. No probative visual evidence provided in complaint.

Identified Points of Contention

• Technical Questions: A primary question will be what evidence Plaintiff can provide to show that the accused system performs the claimed step of "identifying a words or phrases... associated with... [a] semantic attribute." This suggests a linguistic or contextual analysis is required by the claim, and it remains to be seen how the accused system's functionality is alleged to meet this limitation beyond simple keyword or metadata filtering.
• Scope Questions: The complaint's lack of specificity regarding the accused instrumentality raises the question of which features of Defendant's platform are at issue. A key point of contention may be whether common e-commerce features, such as filtering by star rating or sorting reviews, fall within the scope of the claims.

V. Key Claim Terms for Construction

The Term: "semantic attribute"

• Context and Importance: This term is the core of the claimed invention, defining the basis upon which information is filtered and presented. Its construction will be critical to determining the scope of infringement. Practitioners may focus on this term because its definition could distinguish between sophisticated linguistic analysis (e.g., identifying opinion-laden phrases) and more common data filtering (e.g., sorting by a numerical rating).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states that attributes can be "grammatical, semantic, and contextual" (ʼ428 Patent, col. 3:19-21) and that "semantic attributes" can be referred to as "connotation" (ʼ428 Patent, col. 8:22-26). This could support a broad interpretation covering various types of data classification.
  • Evidence for a Narrower Interpretation: Claim 3 specifies a contrast between attributes, such as "a positive opinion versus a negative option" (ʼ428 Patent, col. 16:26-32). The specification provides detailed examples of analyzing phrases like "is good" or "not so great," which suggests the term requires an understanding of opinion and context, not just objective data points (ʼ428 Patent, Fig. 8; col. 13:20-32).

The Term: "actionable user interface object"

• Context and Importance: This term defines the mechanism through which a user interacts with the system. The dispute may center on what constitutes such an "object" and whether it must have specific characteristics.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes this element broadly, noting it "can also be a set of radio buttons, a slider, or any sort of object that allows a user to selectively indicate an option" (ʼ428 Patent, col. 9:1-3).
  • Evidence for a Narrower Interpretation: Claim 1 requires the object to be "associated with a label representing the first name or description" of the semantic attribute (ʼ428 Patent, col. 16:10-13). This could be interpreted to require an explicit textual label, as shown in the patent's figures (e.g., "Extract positive opinions" in Fig. 7), potentially excluding more abstract interface elements like selectable icons without text.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement based on Defendant "actively encourag[ing] or instruct[ing] others (e.g., its customers...)" to use its services in a manner that infringes the patent (Compl. ¶10). A similar general allegation is made for contributory infringement (Compl. ¶11).

Willful Infringement

Willfulness is alleged based on Defendant’s knowledge of the '428 patent "from at least the filing date of the lawsuit" (Compl. ¶10, fn. 1; Compl. ¶11, fn. 2). Plaintiff reserves the right to amend if pre-suit knowledge is found during discovery.

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

• A central issue will be one of factual specificity: a primary task for the court will be to determine which specific features of the Defendant's online platform are accused of infringement, as the complaint currently makes only general allegations against an unnamed "system."
• The case will likely turn on a question of definitional scope: can the claim term "semantic attribute" be construed to cover conventional e-commerce filtering functions (such as sorting by star ratings), or does it require the more sophisticated, context-aware linguistic analysis of user-generated text that is described in the patent's detailed embodiments?
• A key evidentiary question will be what proof Plaintiff can produce to show that the accused functionality performs the claimed "identifying" of words with specific semantic attributes, as opposed to operating on simpler keyword or metadata filtering, and whether any such operation meets the limitations as construed by the court.