DCT
2:24-cv-00647
Global Connect Technology Inc v. Christies Intl PLC
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Global Connect Technology, Inc. (Massachusetts)
- Defendant: Best Buy Co., Inc. (Minnesota) and BestBuy.com, LLC (Virginia)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:24-cv-00647, E.D. Tex., 12/05/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Best Buy maintains regular and established places of business within the district, including a specific retail location in Longview, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s e-commerce website and mobile application infringe a patent related to computer database systems that permit data to be stored, retrieved, and manipulated according to multiple user-defined hierarchical "points of view."
- Technical Context: The technology concerns flexible database architectures that allow users to apply different contextual frameworks to the same underlying data, a concept relevant to personalizing search and filtering in large-scale e-commerce platforms.
- Key Procedural History: The complaint asserts that the patent-in-suit is "pioneering" and has been cited as relevant prior art in 280 subsequent U.S. patent applications from various technology companies. No prior litigation or post-grant proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2002-06-12 | U.S. Patent No. 7,246,128 Priority Date |
| 2007-07-17 | U.S. Patent No. 7,246,128 Issues |
| 2025-12-05 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,246,128 - DATA STORAGE, RETRIEVAL, MANIPULATION AND DISPLAY TOOLS ENABLING MULTIPLE HIERARCHICAL POINTS OF VIEW
- Patent Identification: U.S. Patent No. 7,246,128, "DATA STORAGE, RETRIEVAL, MANIPULATION AND DISPLAY TOOLS ENABLING MULTIPLE HIERARCHICAL POINTS OF VIEW," issued July 17, 2007 (’128 Patent).
The Invention Explained
- Problem Addressed: The patent’s background section describes the limitations of conventional database systems where data is structured and presented from a single, fixed point of view (’128 Patent, col. 1:55-67). This is inefficient when the same data has different meanings in different contexts, forcing users to build distinct databases for various uses even when the data content substantially overlaps (’128 Patent, col. 2:8-14).
- The Patented Solution: The invention provides a system that allows a user to establish multiple "points of view," such as via a hierarchy, to retrieve, manipulate, and display data according to that specific context (’128 Patent, col. 2:16-21). This enables data to be organized and presented based on the user's focus without changing the underlying data structure itself, using concepts like relatedness maps and similarity functions to manage these different views (’128 Patent, col. 3:58-67).
- Technical Importance: This approach enabled a more flexible, user-centric method for interacting with large datasets, moving beyond the rigid schemas of conventional databases toward context-aware data organization and retrieval (Compl. ¶¶19-20).
Key Claims at a Glance
- The complaint asserts independent claim 21 (’128 Patent, col. 38:21-50; Compl. ¶28).
- Claim 21 is a system claim comprising the following essential elements:
- A host processor.
- A user interface for inputting points of view.
- A "connections generator" to receive the points of view and generate connections between their elements and metadata of data sources.
- A "connections database" operated on by the generator, which includes a data structure for "degrees of matching" between data elements and metadata.
- "Matching applications" that use the foregoing to determine and display sets of data elements having pre-selected degrees of matching.
- The complaint reserves the right to assert additional claims (Compl. ¶28).
III. The Accused Instrumentality
Product Identification
- The Accused Instrumentalities are Best Buy's online shopping system, which includes its website, its mobile application, and the associated backend servers, software, and network infrastructure (Compl. ¶27).
Functionality and Market Context
- The complaint focuses on the product search and filtering functionality of the Best Buy e-commerce platform (Compl. ¶¶28, 40). This system allows a user to enter a search query and then apply a variety of filters—such as by RAM, brand, storage capacity, or sale status—to refine the product listings (Compl. ¶¶41-42). These selectable filters are alleged to constitute the infringing "hierarchical points of view" that allow users to manipulate how the underlying product data is presented (Compl. ¶40). A screenshot in the complaint shows a search for "computer" with selectable filters for "RAM" and "Total Storage Capacity" presented in a sidebar. (Compl. p. 9).
IV. Analysis of Infringement Allegations
’128 Patent Infringement Allegations
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system for enabling multiple hierarchical points of view, comprising: a host processor; | The backend servers, software, and network infrastructure that power the Best Buy website and mobile app. | ¶27 | col. 38:21-23 |
| a user interface controlled by the host processor for inputting points of view to the system; | The Best Buy website and mobile app, through which users select product categories and apply search filters. The complaint provides a screenshot showing selectable filters for product attributes like "RAM" and "Total Storage Capacity." | ¶¶27, 40; p. 9 | col. 38:24-26 |
| a connections generator controlled by the host processor...to receive the points of view and generate connections between elements in the points of view and metadata of data sources; | The backend system that allegedly processes user filter selections (the "points of view") and connects them to the corresponding metadata in Best Buy's product database. | ¶¶27, 34 | col. 38:27-32 |
| a connections database operated on by the connections generator...having a data structure including degrees of matching between data elements...and the metadata; | The backend database that stores product information and relationships, which the system uses to identify products that match the selected filter criteria. | ¶¶27, 34 | col. 38:33-38 |
| matching applications controlled by the host processor...to determine sets of data elements...having at least pre-selected degrees of matching...the user interface displaying the data elements...according to the points of view. | The software that executes the filtered search and presents the resulting set of products to the user. A screenshot shows product results after filters for brand ("Apple") and deal status ("On Sale") are applied. | ¶¶27, 42; p. 13 | col. 38:39-50 |
- Identified Points of Contention:
- Scope Questions: A primary question will be whether selecting standard e-commerce filters (e.g., "Brand," "RAM") constitutes "inputting points of view" as that term is defined and described in the ’128 Patent. The analysis may explore whether the patent’s disclosure, which describes creating and modifying complex data hierarchies, requires more than applying predefined search filters.
- Technical Questions: The complaint alleges the existence of a "connections generator" and a "connections database" with "degrees of matching" by pointing to the overall functionality of the accused system. A technical question for the court will be what evidence supports the existence of these specific, structurally distinct components as claimed, versus the functionality being the result of a conventional database query system.
V. Key Claim Terms for Construction
The Term: "point of view"
Context and Importance: This term is the central concept of the asserted claim. The outcome of the case may depend on whether the application of standard e-commerce filters falls within the patent’s definition of a "point of view." Practitioners may focus on this term because its construction will determine whether the accused system’s core functionality is within the scope of the claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that a system is needed that "permits a user to establish a point of view, such as via a hierarchy, and that allows the user to retrieve, manipulate, and display data according to that point of view" (’128 Patent, col. 2:17-21). This language could be interpreted to encompass any user-directed filtering that organizes data for display.
- Evidence for a Narrower Interpretation: The patent repeatedly refers to an "individual point of view (iPOV)" which "expresses itself via groups of hierarchically linked categories" (’128 Patent, col. 7:43-46). The detailed descriptions and figures often depict the creation and modification of complex, multi-level data structures (e.g., ’128 Patent, Fig. 2A, Fig. 10), which could support a narrower construction requiring a more user-definable and structured framework than pre-set filters.
The Term: "connections generator"
Context and Importance: This term defines a specific architectural component of the claimed system. The infringement analysis will require determining whether the accused Best Buy system contains a structure that performs the functions of this claimed element.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language describes the generator’s function as receiving points of view and generating "connections between elements in the points of view and metadata of data sources" (’128 Patent, col. 38:29-32). This could be argued to cover any backend logic that translates a user’s filter selection into a database query.
- Evidence for a Narrower Interpretation: The specification suggests a more dynamic capability, noting the system should be able to "generate new iPOV's by permutating the existing and relevant iPOV's" (’128 Patent, col. 2:50-53). This may imply a function beyond simply mapping a fixed set of filters to corresponding database fields, suggesting an ability to create novel relationships.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Best Buy provides instructions to its customers on how to use the Accused Instrumentalities, "including specifically how to perform the selection and unselecting of point of views, or search filters" (Compl. ¶40). The basis for this allegation is the functionality of the website and app that guides users to apply filters to refine searches.
- Willful Infringement: Willfulness is alleged based on "willful blindness," with the complaint asserting that Best Buy has a "policy or practice against investigating third party patent rights" (Compl. ¶35). The complaint does not allege pre-suit knowledge of the ’128 Patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "point of view," which is described in the patent in the context of creating and modifying complex, user-defined data hierarchies, be construed to cover the application of pre-defined filters on a conventional e-commerce website?
- A key evidentiary question will be one of architectural mapping: does the plaintiff’s evidence demonstrate that Best Buy’s backend system contains distinct components that map onto the claimed "connections generator" and "connections database," or does the accused functionality arise from a standard search architecture that is technically distinct from the specific system claimed in the patent?