Linfo IP LLC v. Rockler Companies Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Rockler Companies, Inc. (Minnesota)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 2:24-cv-00055, E.D. Tex., 01/26/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement and maintains a regular and established place of business in the district, conducts substantial business there, and derives revenue from goods and services provided in Texas.
• Core Dispute: Plaintiff alleges that Defendant’s system for discovering and presenting information within text content infringes a patent related to user interfaces that identify, categorize, and act upon information based on its semantic attributes.
• Technical Context: The technology relates to automated text analysis and information retrieval, a field critical for managing data overload in contexts like online user reviews, technical documents, and customer feedback.
• 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 states it is a non-practicing entity.

Case Timeline

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

U.S. Patent No. 9,092,428 - "System, methods and user interface for discovering and presenting information in text content"

• 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: In an environment of information overload, users struggle to find specific, relevant information within large volumes of unstructured text, such as thousands of hotel reviews or long medical documents. Conventional search methods are often time-consuming and inefficient for parsing nuanced information, like positive versus negative opinions on a specific topic ('428 Patent, col. 1:12-39).
• The Patented Solution: The invention provides a computer-assisted method and system that analyzes text to identify various attributes of words and phrases (e.g., grammatical, semantic, contextual). It then presents the user with an interface to select a specific attribute (e.g., "positive opinion") and an action (e.g., "extract" or "highlight"), and automatically performs that action on all text segments matching the selected attribute ('428 Patent, Abstract; col. 3:16-44). The system architecture, as shown in Figure 1, involves modules for tokenization, linguistic analysis using a dictionary, and a user interface with attribute and action selectors ('428 Patent, Fig. 1).
• Technical Importance: This approach offers a more structured and efficient way for users to digest large text-based datasets by allowing them to filter and view information based on its meaning and context, rather than just simple keyword matching ('428 Patent, col. 1:55-64).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-20 (Compl. ¶8). Independent claim 1 is central.
• Independent Claim 1 Elements:
  • Obtaining a text content comprising words or phrases.
  • Selecting a first and second semantic attribute for users to select from, where each attribute has a name or description.
  • Identifying words or phrases in the text associated with the selected semantic attribute.
  • Displaying an actionable user interface object associated with a label representing the attribute's name.
  • Allowing a user to select an attribute via the interface.
  • Performing an action (e.g., extracting, displaying, hiding, highlighting) on the identified words or phrases associated with the user-selected attribute.
• The complaint reserves the right to assert dependent claims (Compl. ¶8).

III. The Accused Instrumentality

Product Identification

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

Functionality and Market Context

The complaint alleges the accused instrumentality provides functionality for "discovering information in a text content and extracting and presenting the information" (Compl. ¶8). It further alleges that Defendant's acts cause "claimed-invention embodiments as a whole to perform" (Compl. ¶8). The complaint does not provide sufficient detail for analysis of the specific technical operation or market context of the accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint references an "exemplary table attached as Exhibit B" to support its infringement allegations but does not include the exhibit (Compl. ¶9). The narrative infringement theory alleges that Defendant operates a system that performs the methods claimed in the '428 Patent, including discovering, extracting, and presenting information from text content (Compl. ¶¶7-8). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Question: A primary issue will be identifying the specific "system" accused of infringement and establishing evidence that it performs each step of the asserted claims. The complaint's lack of specificity on the accused instrumentality suggests this will be a focus of discovery.
  • Technical Question: It will be necessary to determine if the accused system's functionality meets the specific claim limitations. For example, does the system provide a user interface for selecting from "semantic attributes" (like "positive opinion"), or does it offer more conventional functionality like keyword searching, which may not map directly onto the claim language?
  • Scope Question: Does the accused system's user interface constitute an "actionable user interface object" as required by the claims, and does it "perform[] an action" such as extracting or highlighting based on a selected "semantic attribute"? The correspondence between the accused system's operation and these claimed functions will be a central point of dispute.

V. Key Claim Terms for Construction

• The Term: "semantic attribute" (Claim 1)

• Context and Importance: This term is the core of the invention, defining the criteria upon which the system acts. Its construction will determine whether the patent covers only systems that analyze nuanced meaning (like sentiment) or also those performing simpler categorical filtering. Practitioners may focus on this term because its breadth is critical to the infringement analysis against potentially any system that filters content.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself is broad ("an attribute type or attribute value") ('428 Patent, col. 16:3-4). The specification describes a wide range of attributes, including grammatical roles, "parts of speech," and topical importance, suggesting the term is not limited to a single type of meaning ('428 Patent, col. 8:1-13; col. 7:8-13).
  • Evidence for a Narrower Interpretation: The patent's examples and figures heavily emphasize "opinion" (positive/negative) as the primary embodiment of a semantic attribute ('428 Patent, Fig. 6; col. 9:1-8). The Abstract also highlights "grammatical, semantic, contextual, and topical attributes," which could be argued to define the outer bounds of the term ('428 Patent, Abstract).

• The Term: "actionable user interface object" (Claim 1)

• Context and Importance: This term defines the mechanism through which the user interacts with the system. The dispute may turn on whether any clickable button qualifies, or if the term requires a more specific UI element directly tied to the semantic attributes and consequent actions.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests various common UI elements, including "a dropdown menu, clickable buttons, radio buttons, or any sort of interface objects that allow a user to specify an option," which could support a broad reading ('428 Patent, col. 11:46-49).
  • Evidence for a Narrower Interpretation: The claims require the object to be "associated with a label representing the first name or description" of the attribute ('428 Patent, col. 16:11-13). This could support a narrower interpretation where the UI object must explicitly present the selectable semantic attribute to the user, as depicted in the patent's figures (e.g., a button labeled "extract positive opinion") ('428 Patent, Fig. 7).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating Defendant "has actively encouraged or instructed others (e.g., its customers...)" on how to use its products and services in an infringing manner (Compl. ¶10). It also alleges contributory infringement on a similar basis (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. ¶¶10-11). This allegation appears to be limited to potential post-filing conduct, as the complaint does not allege pre-suit knowledge.

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

1. A central evidentiary question will be one of identification and proof: what specific Rockler system is accused of infringement, and what evidence will Plaintiff present to demonstrate that this system practices each element of the asserted claims, particularly given the lack of detail in the complaint?
2. The case will likely hinge on a question of definitional scope: will the term "semantic attribute" be construed broadly to cover any content categorization or keyword filtering, or will it be limited to the more complex contextual and opinion-based analysis heavily featured in the patent's specification? The answer will substantially define the boundary between the patented invention and conventional search technologies.
3. A key technical question will be one of functional correspondence: does the user interface of the accused system actually allow a user to select from pre-defined semantic categories and then perform a specific action (e.g., "highlight all positive comments"), or is there a fundamental mismatch between the claimed process and the accused system's operation?