Dynamic Data Innovations LLC v. Old Navy LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dynamic Data Innovations LLC (Texas)
  • Defendant: Old Navy, LLC (Delaware)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:24-cv-00712, E.D. Tex., 08/29/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant operates retail stores and an e-commerce distribution center within the district, has committed alleged acts of infringement in the district, and conducts substantial business there.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to methods for navigating and filtering large sets of data objects within a graphical user interface.
• Technical Context: The technology concerns user interface design for e-commerce and other large databases, aiming to simplify product discovery by allowing users to refine search results through exclusion rather than repeated keyword entry.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the asserted patent.

Case Timeline

Date	Event
2015-10-14	U.S. Patent No. 9,632,676 Priority Date
2017-04-25	U.S. Patent No. 9,632,676 Issued
2024-08-29	Complaint Filed

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

U.S. Patent No. 9,632,676 - “Systems And Methods For Navigating A Set Of Data Objects”

Issued April 25, 2017

The Invention Explained

• Problem Addressed: The patent describes the difficulty users face when navigating large datasets, such as e-commerce product listings, which can contain thousands or millions of items. Conventional methods requiring users to scroll through vast lists or manually refine search queries are described as "burdensome and unmanageable," particularly on devices with limited screen space (Compl. ¶28; ’676 Patent, col. 8:26-31).
• The Patented Solution: The invention provides a method where a user can perform a "single selection maneuver," such as a click or touch on a displayed data object (e.g., a product image). The system then automatically identifies a "differentiating parameter" of the selected object by evaluating its attributes against other objects in the set. Based on this parameter, the system excludes a subset of similar objects and dynamically updates the interface to show a smaller, more refined set of results (’676 Patent, Abstract; col. 2:40-65). This allows a user to narrow results by indicating what they don't want to see, based on the attributes of a single selected example.
• Technical Importance: This approach is presented as an improvement to the functionality of graphical user interfaces (GUIs) that enhances user navigation and improves the performance of the underlying computing systems by reducing processor utilization and network data traffic (Compl. ¶29; ’676 Patent, col. 8:46-50).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶31).
• The essential elements of independent claim 1 include:
  • A computer-implemented method for dynamically updating a set of data objects.
  • Managing an object dataset with objects having various attribute values.
  • Receiving a query and selecting a "first set of objects" to display in a GUI.
  • Detecting a user's "single click or touch" selection of one object from that first set.
  • Automatically identifying a "differentiating parameter" of the selected object by "evaluating differences" between its attributes and the attributes of other objects in the set.
  • Identifying a "second set of objects" from the first set based on this differentiating parameter.
  • Excluding the second set to create a "third set of objects" that has fewer members than the first set.
  • Dynamically rendering the third set of objects in the GUI.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused instrumentality is the website https://oldnavy.gap.com/, along with its "associated hardware, software, and functionality" (the "Accused Products") (Compl. ¶18).

Functionality and Market Context

• The complaint alleges the Accused Products provide a "graphical user interface presented on a display of a client terminal (computer, smartphone, etc.)" for navigating and purchasing products (Compl. ¶18). The complaint includes a screenshot of the Old Navy website homepage, showing various product categories and a sales banner, as an example of the accused interface (Compl. ¶18, Fig. 1).
• The core accused functionality involves a "computer-implemented method for dynamically updating a set of data objects" where users interact with the GUI to filter product listings (Compl. ¶32). The complaint alleges this functionality is used by Defendant's employees and customers via devices like phones, tablets, and computers (Compl. ¶¶19, 32).

IV. Analysis of Infringement Allegations

The complaint does not include the referenced "Exhibit A" claim chart. The following summary is based on the narrative allegations in the body of the complaint.

’676 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
managing an object dataset defining a plurality of attribute values of a plurality of attribute parameters of each of a plurality of objects;	The Accused Products manage an object dataset of products, each with a plurality of attribute values and parameters.	¶32	col. 10:18-22
receiving a query including at least one search term;	The Accused Products receive a query, such as a user-entered search term.	¶32	col. 10:40-42
applying the query to the object dataset to select... a first set of objects complying with the at least one search term;	The Accused Products apply the query to the dataset to select and display a first set of objects.	¶32	col. 10:43-47
in response to said query instructing rendering of the first set of objects within a graphical user interface (GUI)...;	The Accused Products render this first set of objects within the website's GUI for the user.	¶32	col. 10:60-64
detecting a selection of an object of the first set of objects, the selection performed by said user using a physical user interface...;	The Accused Products detect a user's selection of an object using a physical interface like a mouse or touchscreen.	¶32	col. 11:18-24
automatically identifying which of said plurality of attribute parameters of said object is a differentiating parameter by evaluating differences between... attribute values of said... object and respective... attribute values of... members of said first set of objects;	The Accused Products allegedly automatically identify a "differentiating parameter" by evaluating differences between the selected object's attributes and those of other objects in the displayed set.	¶32	col. 12:20-25
identifying a second set of objects from the first set of objects based on said differentiating parameter;	The Accused Products allegedly identify a second set of objects from the first set based on the identified differentiating parameter.	¶32	col. 19:55-57
excluding said second set of objects from the first set of objects to identify a third set of objects;	The Accused Products exclude the second set of objects to create a third, smaller set.	¶32	col. 14:37-40
instructing dynamic rendering to update the GUI to present the third set of objects... wherein the third set of objects includes fewer members than the first set of objects;	The Accused Products dynamically update the GUI to present this smaller third set of objects.	¶32	col. 14:66-67
wherein the said selection is a single click or touch on an indication of the object.	The user's selection is allegedly a single click or touch on the object's representation in the GUI.	¶32	col. 2:1-3

Identified Points of Contention

• Scope Questions: The complaint alleges the Accused Products perform the claimed method, but a central question will be how the term "differentiating parameter" is construed. The claim requires this parameter to be identified by "evaluating differences" between the selected object and others. The case may turn on whether the accused website's filtering logic performs this specific comparative evaluation or merely applies a standard, pre-defined filter category (e.g., brand, color) that happens to be an attribute of the selected item.
• Technical Questions: A key evidentiary question is what "automatically identifying" entails. The court will need to determine whether the accused system performs an analysis to identify the differentiating parameter without further user input after the initial selection, as claimed, or if it presents the user with a menu of filtering options derived from the selected object, which would require an intermediate user action not contemplated by the claim. The complaint does not provide screenshots or technical details of the accused filtering workflow itself, only of the website's homepage.

V. Key Claim Terms for Construction

• The Term: "differentiating parameter"
• Context and Importance: This term is the technological core of the claim. The entire exclusion process hinges on identifying this specific type of parameter. The infringement analysis will depend on whether the parameter used by the accused website to filter results meets the specific definition in the patent, which requires it to be identified "by evaluating differences" between objects. Practitioners may focus on this term because standard e-commerce filters often operate on user-selected categories (e.g., "filter by brand: X"), and the patent appears to claim a more intelligent, system-driven identification of what parameter is most useful for exclusion.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The body of claim 1 defines the term functionally as that which is identified "by evaluating differences between said plurality of attribute values of said plurality of attribute parameters of said object and respective said plurality of attribute values of... members of said first set of objects" (’676 Patent, col. 19:48-54). This functional definition could be argued to cover any parameter that distinguishes the selected object from others.
  • Evidence for a Narrower Interpretation: Dependent claim 3 adds the limitation that the differentiating parameter "includes at least one differentiating feature that most differentiates the selected object from other objects" (’676 Patent, col. 20:2-5, emphasis added). The doctrine of claim differentiation may suggest that the independent claim's "differentiating parameter" does not need to be the "most" differentiating one. However, the specification repeatedly discusses ranking attributes to find those that are "most different" or "most similar," which could support a narrower construction requiring a specific comparative analysis (’676 Patent, col. 12:20-35).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides the Accused Products and "distributing instructions that guide users" to use the infringing features (Compl. ¶33). It also alleges contributory infringement, asserting the Accused Products contain "special features" that are "specially designed to be used in an infringing way" and lack substantial non-infringing uses (Compl. ¶34).
• Willful Infringement: Willfulness is alleged based on knowledge of the ’676 Patent acquired "at least as early as the date Defendant received notice of the filing of this action" (Compl. ¶35). The complaint also alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others" (Compl. ¶36).

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

• A central issue will be one of claim scope and construction: How will the court define a "differentiating parameter"? Must it be the result of a specific, dynamic "evaluation of differences" between objects as performed by the system, or can it be construed to cover a standard filter attribute that is simply extracted from a user's selection?
• A key evidentiary question will be one of technical operation: Does the accused Old Navy website actually perform the claimed method? Specifically, does its filtering logic "automatically identify" a parameter for exclusion based on a comparative analysis, or does it follow a more conventional workflow where a user's click on an object simply populates a standard filtering menu from which the user must make a further selection?
• The resolution of the infringement claim will likely depend on the factual evidence presented regarding how the accused website's back-end filtering system functions, as the complaint's allegations closely track the patent's claim language without providing detailed, independent evidence of the underlying software logic.