Linfo IP LLC v. 511 Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: 5.11, Inc. (California)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 2:24-cv-00241, E.D. Tex., 04/12/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district and maintains a regular and established place of business in Beaumont, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s system for discovering, extracting, and presenting information within text content infringes a patent related to user interfaces for text analysis.
• Technical Context: The technology addresses the problem of information overload by providing computer-assisted methods for users to analyze large volumes of text (e.g., product reviews) by identifying and acting upon specific attributes within the text, such as sentiment or topic.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

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," issued July 28, 2015

The Invention Explained

• Problem Addressed: The patent identifies the problem of "data overload," where users face difficulty finding specific, needed information when it is contained within a large amount of scattered text, such as numerous online user reviews for a hotel or a long medical document (’428 Patent, col. 1:12-24). Conventional search methods are described as potentially time-consuming and inefficient for locating nuanced information, such as all negative comments about a specific topic (’428 Patent, col. 1:31-38).
• The Patented Solution: The invention provides a computer-assisted system that analyzes text to associate "grammatical, semantic, and contextual attributes" with words or phrases (tokens) (’428 Patent, col. 3:20-23). It then presents a user with interface objects (e.g., buttons, menus) that allow the user to select a specific attribute (like "positive opinion" or "drug names") and perform an action (like "extract," "highlight," or "hide") on all text segments possessing that attribute (’428 Patent, Abstract; col. 3:23-29). This is designed to save the user time in "gathering, organizing and digesting" information (’428 Patent, col. 3:13-16).
• Technical Importance: The technology aims to move beyond simple keyword searching to a more sophisticated, attribute-based analysis, allowing users to interact with text based on its meaning and context, which is particularly relevant for tasks like sentiment analysis and topic extraction (’428 Patent, col. 1:55-63).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 (Compl. ¶10). Independent claim 1 is a representative method claim.
• Independent Claim 1:
  • Obtaining, by a computer system, a text content comprising one or more words or phrases.
  • Selecting a first semantic attribute and a second semantic attribute for users to select from, where these attributes are associated with a name or description.
  • Identifying words or phrases in the text content associated with the first or second semantic attribute.
  • Displaying an actionable user interface object associated with a label representing the name/description of the attributes.
  • Allowing the user to select one of the attribute names/descriptions as a user-specified attribute.
  • Performing an action (e.g., extracting, displaying, hiding, highlighting) on the word or phrase associated with the user-specified semantic attribute.
• Plaintiff reserves the right to assert other claims, including dependent claims (Compl. ¶10).

III. The Accused Instrumentality

Product Identification

The complaint does not identify a specific product or service by name. It alleges that Defendant "maintains, operates, and administers a system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶10).

Functionality and Market Context

The functionality of the accused instrumentality is described in general terms that track the language of the patent. The complaint alleges the system discovers, extracts, and presents information from text content, thereby infringing the ’428 patent (Compl. ¶9-10). The complaint does not provide detail regarding the specific operation or market context of the accused system.

IV. Analysis of Infringement Allegations

The complaint references a preliminary claim chart in an "Exhibit B" but does not include this exhibit in the filing (Compl. ¶11). Therefore, a detailed element-by-element analysis is not possible based on the provided documents.

The complaint’s narrative theory of infringement alleges that Defendant directly infringes by operating a system that practices the patented methods (Compl. ¶10). It states that "Defendant puts the inventions claimed by the ’428 Patent into service (i.e., used them)" and that these acts caused the claimed invention "as a whole to perform" (Compl. ¶10). The allegations cover claims 1-20, literally or under the doctrine of equivalents (Compl. ¶10).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Evidentiary Question: A primary question will be identifying the specific accused instrumentality. The complaint’s general description will require Plaintiff to produce evidence of a specific 5.11, Inc. system (e.g., a website feature, internal software) that performs the claimed steps.
• Technical Question: It will be necessary to determine whether the accused system actually performs the claimed steps of identifying "semantic attributes" and providing an "actionable user interface object" to manipulate text based on those attributes, as opposed to performing conventional keyword search or filtering.
• Scope Questions: The dispute may turn on whether the functionality of Defendant’s system falls within the scope of the patent’s claims. For example, does the Defendant's system allow a user to select from pre-defined "semantic attributes" as required by claim 1, or does it operate on a different principle?

V. Key Claim Terms for Construction

"semantic attribute" (Claim 1)

• Context and Importance: This term is the core of the invention, defining the type of information the system identifies and acts upon. Its construction will determine whether the accused system's text analysis capabilities (e.g., topic tagging, sentiment scoring) meet this limitation. Practitioners may focus on this term because its breadth is central to the scope of infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states such attributes "can be grammatical, semantic, contextual, or topical, etc." (’428 Patent, col. 6:7-8). It also provides a wide range of examples, including an "opinion," a "connotation," the "name of a drug," being a "pain-reliever," or being an "over-the-count drug" (’428 Patent, col. 8:23-29), suggesting the term is not limited to a single type of meaning.
  • Evidence for a Narrower Interpretation: Embodiments and figures focus heavily on specific types of semantic attributes, such as positive/negative "opinion" in the context of user reviews (e.g., Fig. 8, Fig. 11) or term importance (’428 Patent, col. 7:7-13). A defendant could argue these specific examples cabin the term's broader definition.

"actionable user interface object" (Claim 1)

• Context and Importance: This is the mechanism through which the user interacts with the system to perform the claimed method. The dispute will center on what kind of UI element (e.g., a button, a hyperlink, a dropdown menu) satisfies this limitation and whether the accused system incorporates such an element for the claimed purpose.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests this can be any object that "accepts the user selection as input to the system," including buttons, dropdown menus, or radio buttons (’428 Patent, col. 6:8-14; col. 9:1-3). Figure 7, for example, shows a dropdown menu for selecting an action.
  • Evidence for a Narrower Interpretation: The claims require the object to be associated with a label "representing the first name or description or the second name or description" of the semantic attributes. An argument could be made that a generic "filter" or "search" button without specific attribute labels would not meet this limitation. The examples consistently show explicit labels, such as "extract positive opinions" or "highlight negative comments" (’428 Patent, Fig. 7, Fig. 11).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant "actively encouraged or instructed others (e.g., its customers...)" on how to use its products and services in an infringing manner (Compl. ¶12). It also pleads contributory infringement on a similar basis (Compl. ¶13).

Willful Infringement

Willfulness is alleged based on Defendant’s knowledge of the ’428 patent "from at least the filing date of the lawsuit" (Compl. ¶12, ¶13). The prayer for relief requests a declaration that the infringement is willful and seeks treble damages (Compl. ¶16e).

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

1. A central evidentiary question will be one of identification and proof: given the complaint's lack of specificity, what particular product, service, or system of the Defendant will be accused, and what evidence will Plaintiff offer to demonstrate that this system performs each step of the asserted claims, especially the identification and user-selection of "semantic attributes"?
2. A core issue will be one of definitional scope: can the term "semantic attribute", which the patent illustrates with examples like positive/negative opinions and medical topics, be construed to read on the specific text analysis and filtering functionalities, if any, present in the yet-unidentified accused system?
3. The case will likely involve a key functional question: does the accused system’s user interface provide an "actionable user interface object" that allows users to select from pre-defined semantic categories to manipulate text, as claimed, or does it merely provide a conventional keyword search or a generic filtering tool that operates on a different technical principle?