DCT
2:24-cv-00649
Global Connect Technology Inc v. Costco Wholesale Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Global Connect Technology, Inc. (Massachusetts)
- Defendant: Costco Wholesale Corporation (Washington)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:24-cv-00649, E.D. Tex., 08/08/2024
- Venue Allegations: Venue is based on Defendant’s alleged regular and established places of business within the Eastern District of Texas, with specific retail locations cited in Frisco, Plano, and McKinney.
- Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to computer database systems that permit data storage, retrieval, and manipulation from multiple, user-defined hierarchical points of view.
- Technical Context: The technology addresses methods for organizing and searching large datasets by allowing users to apply context-specific hierarchical filters, a foundational concept for modern e-commerce and complex data presentation systems.
- Key Procedural History: The complaint asserts the patent-in-suit is "pioneering" and has been cited as relevant prior art in 280 subsequent U.S. Patent Applications. It also notes that damages are being sought for past infringement, a legal theory applicable to patents that may have expired.
Case Timeline
| Date | Event |
|---|---|
| 2002-06-12 | U.S. Patent No. 7,246,128B2 Priority Date |
| 2007-07-17 | U.S. Patent No. 7,246,128B2 Issue Date |
| 2024-08-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,246,128B2 - DATA STORAGE, RETRIEVAL, MANIPULATION AND DISPLAY TOOLS ENABLING MULTIPLE HIERARCHICAL POINTS OF VIEW, issued July 17, 2007
The Invention Explained
- Problem Addressed: The patent's background section notes that the proliferation of data on platforms like the Internet can obscure understanding by "burying the most relevant data among a large amount of irrelevant data" (Compl. ¶14; ’128 Patent, col. 1:21-30). It posits that conventional database systems, which provide rigid "views" of data, are ineffective when the same data must be interpreted in different contexts, often forcing the creation of redundant databases (’128 Patent, col. 2:1-14).
- The Patented Solution: The invention describes a system that allows a user to establish a "point of view" (iPOV), such as a hierarchy, to retrieve, manipulate, and display data according to that specific context (’128 Patent, col. 2:15-21). This framework enables the same underlying data to be organized and presented in multiple ways depending on a user's goal, using "hierarchical maps" as a "metaphor of choice for codifying and displaying the relationships" between data elements (Compl. ¶18; ’128 Patent, col. 3:6-9). The system architecture uses concepts like "similarity functions" and "relatedness maps" to manage these context-dependent relationships (’128 Patent, col. 3:54-67).
- Technical Importance: The described invention sought to provide a more flexible and context-aware method for querying complex datasets, shifting from fixed data structures toward customizable, user-centric data interaction (Compl. ¶18).
Key Claims at a Glance
- The complaint asserts independent claim 21 (Compl. ¶26, ¶29).
- Essential elements of claim 21 include:
- A system comprising a "host processor" and a "user interface" for inputting "points of view."
- A "connections generator" that receives the points of view and generates connections between their elements and "metadata of data sources."
- A "connections database" operated on by the generator, which has a data structure including "degrees of matching" between its data elements and the metadata.
- "Matching applications" that operate on the data sources to find data elements with "pre-selected degrees of matching" and display the results via the user interface.
- The complaint reserves the right to assert additional claims (Compl. ¶26).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the Costco website, identified by the URL https://www.costco.com/, and all associated systems (Compl. ¶25).
Functionality and Market Context
- The complaint alleges that the Costco website provides a "system for enabling multiple hierarchical points of view" (Compl. ¶25). The provided screenshot of a product search results page for laptops illustrates this functionality, showing a user interface with hierarchically organized filtering options such as "Category," "Brand," "Price," and "Customer Reviews" (Compl. p. 9). This interface allows a user to define their search criteria (a "point of view") and manipulate the set of products displayed in response. The complaint makes no specific allegations regarding the website's market position.
IV. Analysis of Infringement Allegations
The complaint references an "Exhibit A" containing further infringement detail, but this exhibit was not included with the filed complaint (Compl. ¶26). The following summary is based on the complaint's narrative allegations and the provided visual evidence.
’128 Patent Infringement Allegations
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a host processor; | The backend servers and computing infrastructure that operate the Costco website (Compl. ¶25, ¶30). | ¶30 | col. 38:22 |
| a user interface controlled by the host processor for inputting points of view to the system; | The product filtering and sorting interface on the Costco website, which allows users to select criteria like "Brand" and "Price" to define their search. The screenshot on page 9 of the complaint depicts this interface with its hierarchical filter options. | ¶25, p. 9 | col. 38:23-25 |
| a connections generator controlled by the host processor and in communication with the user interface to receive the points of view and generate connections between elements in the points of view and metadata of data sources; | Costco's backend software systems, which allegedly receive user-selected filters (the "points of view") and dynamically generate connections between those selections and product information in Costco's database (the "data sources") (Compl. ¶25, ¶30). | ¶30 | col. 38:26-30 |
| a connections database operated on by the connections generator in generating the connection and having a data structure including degrees of matching between data elements in the connections database and the metadata; and | A database structure allegedly used by Costco that stores relationships and "degrees of matching" (e.g., relevance scores) used by the backend system to connect user filters to products. The complaint does not provide specific evidence of this component's existence or structure (Compl. ¶26). | ¶26 | col. 38:31-35 |
| matching applications controlled by the host processor and operating on the data sources to determine sets of data elements...having at least pre-selected degrees of matching..., the user interface displaying the data elements... | Costco's backend applications that are alleged to query the product database to find matching items based on user filters. The website's user interface then displays the resulting list of products, as shown in the provided screenshot (Compl. p. 9). | ¶26, p. 9 | col. 38:36-44 |
Identified Points of Contention
- Scope Questions: A primary question will be whether a standard e-commerce filtering system, as depicted in the complaint, meets the specific architectural requirements of a "connections generator" and a "connections database." The defense may argue these claim terms recite a specific, novel architecture not present in conventional systems that use standard database queries.
- Technical Questions: What evidence supports the allegation that the accused system uses a "connections database" that stores "degrees of matching"? The complaint's allegations are made on "information and belief" and lack specific technical evidence. The accused functionality could potentially be implemented with a different architecture that does not meet these limitations.
V. Key Claim Terms for Construction
The Term: "connections generator"
Context and Importance
This term appears to name a central component of the claimed system. Its construction will be critical in determining whether the invention covers generic database query engines or is limited to a more specific implementation. Practitioners may focus on this term because the infringement case may depend on whether Costco's backend software performs the specific functions of this "generator."
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claim language describes the generator's function broadly as receiving "points of view and generat[ing] connections between elements in the points of view and metadata of data sources" (’128 Patent, col. 38:26-30), language which could arguably read on any software that translates user filter selections into a database query.
- Evidence for a Narrower Interpretation: The specification links the system's operation to a "Relativity DBMS," analogizing its function to "gravitational forces" that "bend the computational fabric of data and processes" (’128 Patent, col. 9:36-54). This more elaborate description may support a narrower construction tied to a specific, dynamic architecture.
The Term: "degrees of matching"
Context and Importance
This limitation is important because it requires the system to do more than find exact, binary matches; it implies a capability for scoring or ranking. Its interpretation will determine what level of "relevance" or "similarity" analysis the accused system must be shown to perform.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent states that matching can be determined by a "fitness function" or "similarity procedures" (’128 Patent, col. 37:21-26, col. 5:53-54), which could be argued to encompass standard relevance-ranking algorithms common in search technology.
- Evidence for a Narrower Interpretation: The specification also discusses "degrees of matching" in the context of "relatedness statistics" derived from "linguistic connections" within a "Language Database" (’128 Patent, col. 9:1-20). This may support a narrower definition requiring a specific type of semantic or statistical analysis beyond simple filtering.
VI. Other Allegations
- Indirect Infringement: The complaint includes a high-level allegation of indirect infringement, stating Defendant is an infringer "by virtue of its branding and marketing activities" (Compl. ¶30). The complaint does not plead specific facts to support the knowledge and intent elements required for induced or contributory infringement.
- Willful Infringement: The complaint alleges that Defendant "willfully" uses the infringing systems but provides no specific factual basis for this allegation, such as pre-suit knowledge of the patent (Compl. ¶6).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural equivalence: does Costco's e-commerce filtering system, which likely relies on conventional database technology, embody the specific "connections generator" and "connections database" architecture required by Claim 21? The case will likely turn on whether the claim language can be interpreted to cover standard web technologies or is limited to the more complex "Relativity DBMS" system described in the patent's specification.
- A key evidentiary question will be one of functional proof: can Plaintiff, through discovery, uncover evidence that Costco's system calculates and uses "degrees of matching" as required by the claim? The infringement allegations for this and other backend components are made on information and belief and will require substantial technical evidence to substantiate.
- The case will also raise a fundamental question of claim scope versus validity: if the claims are construed broadly enough to read on the accused Costco website, the court will then have to consider whether that broad scope renders the claims invalid over the state of the art in web search and database filtering technologies that existed prior to the patent's 2002 priority date.