HyperQuery LLC v. Access Technology Group Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HyperQuery LLC (Delaware)
  • Defendant: The Access Technology Group Limited (United Kingdom)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00155, E.D. Tex., 02/06/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has an established place of business in the District and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for determining a user's search intent to recommend and facilitate the download of mobile applications.
• Technical Context: The technology addresses the field of mobile application discovery, aiming to improve the relevance of search results in application repositories beyond simple keyword matching.
• Key Procedural History: The complaint notes that Plaintiff is the assignee of the patent-in-suit. No other procedural events, such as prior litigation or administrative proceedings, are mentioned.

Case Timeline

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

U.S. Patent No. 9,529,918 - "System and methods thereof for downloading applications via a communication network," issued December 27, 2016. (Compl. ¶9).

The Invention Explained

• Problem Addressed: The patent identifies that searching for applications in conventional repositories is often "very time consuming" and inefficient. Users must navigate through numerous applications that may be promoted by the repository owner rather than being relevant to the user's specific need or intent. ('918 Patent, col. 2:4-12).
• The Patented Solution: The invention proposes a system that receives a search query from a user, determines the user's underlying "search intent," and uses that intent to select one or more relevant applications from a central repository. An icon for the selected application is then displayed to the user, and upon user input, the system establishes a "direct communication link" to the application's source to initiate a download, bypassing the cumbersome navigation of the repository itself. ('918 Patent, Abstract; col. 2:20-33).
• Technical Importance: The technology purports to "overcome[] the limitations of current search solutions" by providing a more direct and relevance-driven method for application discovery. ('918 Patent, col. 2:12-16).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," including unspecified "Exemplary '918 Patent Claims." (Compl. ¶11). Independent claim 1 is representative.
• Independent Claim 1 (Method):
  • Receiving an input search query from a user device.
  • Determining the search intent based on the query.
  • Selecting at least one application from a repository based on the intent.
  • Causing an icon for the selected application to be displayed.
  • Receiving an input from the user indicating selection of the application.
  • Causing establishment of a direct communication link to the application's hosting location.
  • Causing initiation of the application download over the direct link. ('918 Patent, col. 9:56 - col. 10:11).
• The complaint implicitly reserves the right to assert other claims, including dependent claims. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name specific accused products in its main body. It refers to "Exemplary Defendant Products" that are purportedly identified in charts within "Exhibit 2." (Compl. ¶¶11, 16). However, Exhibit 2 was not filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality. It makes only conclusory allegations that the products "practice the technology claimed by the '918 Patent." (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference "claim charts of Exhibit 2," which was not provided with the public filing. (Compl. ¶17). The infringement theory must therefore be summarized from the complaint's narrative allegations.

The complaint alleges that Defendant's products infringe because they "practice the technology claimed by the '918 Patent" and "satisfy all elements of the Exemplary '918 Patent Claims." (Compl. ¶16). This general allegation suggests Plaintiff's infringement theory is that the accused products perform a method of receiving a user query, determining intent to find a relevant application, presenting that application, and facilitating its download in a manner that maps to the elements of the asserted claims.

Identified Points of Contention

Scope Questions

A principal dispute may arise over the meaning of "determining the search intent." The patent describes a sophisticated process involving tokenization, multiple "engines," and "certainty scores" to ascertain intent. ('918 Patent, col. 7:1-col. 8:43). A central question will be whether the accused products' search functionality performs a process that meets this detailed description or if it uses a more conventional search method that falls outside the claim's scope.

Technical Questions

The complaint's lack of technical detail raises the question of what evidence exists to show the accused products perform the claimed step of establishing a "direct communication link" to download the application. ('918 Patent, col. 10:5-11). The analysis will question whether the accused system provides a link that bypasses the host repository's standard interface, as contemplated by the patent, or if it merely redirects the user to a standard app store page, which may not meet the "direct" limitation.

V. Key Claim Terms for Construction

"determining the search intent" ('918 Patent, col. 9:62)

Context and Importance

This term is the technological core of the asserted claims. The case's outcome may depend on whether the accused functionality for analyzing user queries is covered by the court's construction of this term.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The plain language of claim 1, "determining the search intent based on the input search query," does not itself impose specific algorithmic limitations. (col. 9:62-63).
• Evidence for a Narrower Interpretation: Dependent claim 5 and the detailed description disclose a specific multi-step method for determining intent, which includes "tokenizing the input search query," processing it via a "plurality of engines," and analyzing "computed certainty scores." (col. 10:20-49). A defendant may argue that these detailed disclosures limit the scope of "determining the search intent" to this specific implementation.

"direct communication link" ('918 Patent, col. 10:5)

Context and Importance

This term is critical for distinguishing the invention from prior art methods that require navigating through an app store. Infringement will depend on whether the link provided by the accused product is sufficiently "direct."

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The term could be construed to mean any link that takes the user from the presented icon to a page where a download can be initiated, without requiring the user to manually re-enter the search in the repository.
• Evidence for a Narrower Interpretation: The background section criticizes prior art that requires navigating through categories and lists within a repository. ('918 Patent, col. 1:52-col. 2:8). This context suggests "direct" may be interpreted more narrowly to mean a link that bypasses the repository's user-facing search and discovery interface entirely, connecting the user device programmatically to the download source.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct customers on how to use the accused products in a way that infringes the '918 Patent. (Compl. ¶14).

Willful Infringement

The complaint alleges that by filing and serving the complaint and its (unattached) claim charts, it has provided Defendant with "actual knowledge of infringement." (Compl. ¶13). It further alleges that Defendant's continued infringing activities despite this knowledge support a claim for enhanced damages, establishing a basis for post-filing willfulness. (Compl. ¶14).

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

1. A core issue will be one of definitional scope: How will the court construe the term "determining the search intent"? Will its meaning be limited to the complex, multi-engine embodiment detailed in the specification, or will it be given a broader interpretation that could cover a wider range of semantic search technologies?

2. A key evidentiary question will be one of technical operation: As the complaint lacks specific details about the accused products, the case will turn on what evidence Plaintiff can marshall to prove that the accused products actually perform the specific functions required by the claims, particularly the establishment of a "direct communication link" that bypasses conventional app store navigation.