Dynamic Data Innovations LLC v. Travismathew LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dynamic Data Innovations LLC (Texas)
  • Defendant: TravisMathew, LLC (California)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:24-cv-00748, E.D. Tex., 09/12/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district, including retail stores and a distribution center, and has committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to methods for navigating and dynamically filtering large sets of data objects.
• Technical Context: The technology concerns graphical user interface (GUI) methods that allow users to more efficiently refine search results in large databases, such as online product catalogs, by automatically excluding items based on attributes of a user-selected item.
• Key Procedural History: No significant procedural history, such as prior litigation or post-grant proceedings involving the asserted patent, is mentioned in the complaint.

Case Timeline

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 addresses the difficulty users face when navigating large sets of data objects, such as products in an online store. Conventional methods requiring users to manually scroll through numerous objects or repeatedly refine search queries are described as "burdensome and unmanageable." (’676 Patent, col. 8:29-31).
• The Patented Solution: The invention provides a method where a user can refine a set of search results through a single action, like a click or touch on a displayed object (’676 Patent, Claim 1). In response, the system automatically identifies a "differentiating parameter" of the selected object by evaluating its attributes against other objects in the set. It then excludes other objects based on this parameter, dynamically updating the GUI to present a smaller, more relevant set of results to the user (’676 Patent, Abstract; Fig. 1).
• Technical Importance: This approach is presented as an improvement over conventional systems by reducing the steps needed to filter large datasets, which can improve computing performance by reducing processor utilization and network traffic (’676 Patent, col. 9:46-50).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶31).
• The essential elements of independent claim 1 include:
  • A method involving managing an object dataset and receiving a query to select a "first set of objects."
  • Rendering the first set of objects in a GUI.
  • Detecting a "single click or touch" selection of an object from the first set.
  • "Automatically identifying" a "differentiating parameter" of the selected object by "evaluating differences" between its attributes and those of other objects in the first set.
  • Identifying a "second set of objects" from the first set based on this differentiating parameter.
  • "Excluding" the second set of objects to create a "third set of objects" with fewer members.
  • Instructing a dynamic rendering to update the GUI to present this smaller third set.
• The complaint does not explicitly reserve the right to assert dependent claims, but infringement is alleged for "one or more claims" (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is the website "https://www.travismathew.com/" and its associated hardware, software, and functionality used for e-commerce (the "Accused Products") (Compl. ¶18).

Functionality and Market Context

The complaint alleges the website provides a GUI that allows users to search for products and dynamically updates the set of displayed data objects (products) based on user input (Compl. ¶18). For example, a user can search for a product category like "tops," which returns an initial set of results. The complaint shows a screenshot of search results for "tops" filtered by "Tee" (Compl. Fig. 3). The complaint alleges that after a user selects a specific item, the system performs a method to refine the results (Compl. ¶32). A screenshot of a product detail page for an "OLYMPUS" t-shirt is provided as an example of a user's selection (Compl. Fig. 4).

IV. Analysis of Infringement Allegations

The complaint references an "Exhibit A" containing detailed infringement evidence, but this exhibit was not filed with the complaint (Compl. ¶31, 14). The following chart is based on the narrative infringement theory provided in the complaint body.

'676 Patent Infringement Allegations

Identified Points of Contention

• Technical Question: The central technical question will be whether the accused website actually performs the "automatically identifying... a differentiating parameter" and subsequent "excluding" steps as claimed. The complaint's visual evidence shows a standard e-commerce flow (search results page, product detail page), but does not itself demonstrate the automatic, difference-based analysis and exclusion required by the claim. For instance, the screenshot in Figure 5 depicts a "Similar Styles" section, which raises the question of whether the website is performing the claimed exclusion or merely suggesting related products.
• Scope Question: A key dispute may center on the meaning of "excluding said second set of objects." Does this require altering the primary list of results presented to the user, or could it be satisfied by a feature that simply suggests alternatives or filters in a separate part of the GUI? The evidence provided does not show the primary results list being updated to a smaller set.

V. Key Claim Terms for Construction

The Term: "differentiating parameter"

• Context and Importance: This term is the core of the claimed invention, defining the basis for exclusion. The infringement analysis depends entirely on whether the accused system identifies a parameter based on "evaluating differences" between a selected object and other results, as opposed to using a pre-defined or static rule. Practitioners may focus on this term because its construction will determine whether a simple filter (e.g., "show more like this brand") meets the claim limitation or if a more complex, dynamic comparison is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language requires "evaluating differences" but does not specify the method or complexity of that evaluation, which could support an argument that any automated comparison of attributes qualifies (col. 19:52-58).
  • Evidence for a Narrower Interpretation: The specification suggests this parameter is one that "most differentiates the selected at least one object from other objects of the first set" (’676 Patent, col. 2:6-9). This language could support a narrower construction requiring a ranking or maximization function, not just any difference.

The Term: "excluding said second set of objects from the first set of objects to identify a third set of objects"

• Context and Importance: This limitation defines the outcome of the claimed process. The case may turn on whether the accused website actually "excludes" items to create a new, smaller primary result set, or if it performs a different function, such as recommending other products while leaving the original result set intact.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "excluding" is not explicitly defined, leaving room to argue that removing items from consideration for a subsequent user action, even without visually altering the main list, could meet the limitation.
  • Evidence for a Narrower Interpretation: The claim structure moves from a "first set" to a "third set" that "includes fewer members" and is presented via an "update [to] the GUI" (col. 19:59 - 20:2). This strongly suggests that the user should be presented with a visually smaller and updated list of results, not just an auxiliary list of suggestions. The patent's goal of making large sets "more manageable" supports this interpretation (’676 Patent, col. 15:5-9).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant advertises, promotes, and provides instructions (e.g., through its website) that guide users to operate the accused system in an infringing manner (Compl. ¶33). It also alleges contributory infringement, asserting the Accused Products contain special features designed for infringing use that have no substantial non-infringing uses (Compl. ¶34).
• Willful Infringement: Willfulness is alleged based on knowledge of the patent as of the filing of the lawsuit (Compl. ¶35). The complaint further alleges, on information and belief, that Defendant has a policy of not reviewing patents of others, constituting willful blindness (Compl. ¶36).

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

• A central evidentiary question will be one of technical operation: what factual evidence, beyond the narrative allegations, demonstrates that the TravisMathew website performs the specific method of "automatically identifying which... attribute... is a differentiating parameter by evaluating differences" between products, as required by claim 1?
• A second critical issue will be one of functional performance: does the accused website actually "exclude" objects to create a smaller, updated primary set of results for the user, or does it merely present suggestions or related items in a separate section, potentially creating a mismatch with the claim's requirement to present a "third set of objects" with "fewer members"?
• The case will also likely involve a definitional dispute over the scope of "differentiating parameter", specifically whether it requires a dynamic, "most-differentiating" analysis as suggested by the specification, or if it can be read more broadly to cover simpler, attribute-matching filters.