HyperQuery LLC v. Chaos Software GmbH

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HyperQuery LLC (Delaware)
  • Defendant: Chaos Software EOOD (Bulgaria)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00407, E.D. Tex., 10/15/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems for searching and downloading mobile applications that analyze user queries to determine search intent before selecting relevant applications.
• Technical Context: The technology addresses the challenge of application discovery in large repositories, aiming to move beyond simple keyword matching to a more nuanced, intent-based search paradigm.
• Key Procedural History: The complaint does not detail any prior litigation, licensing history, or administrative patent challenges related to the patent-in-suit.

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"

• Patent Identification: 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 describes prior art application search systems as inefficient and frustrating. Users had to either navigate through broad categories or use simplistic keyword searches (e.g., for "ticket") that returned numerous irrelevant results (e.g., for concerts, sports, and movies worldwide), requiring users to "review a list of irrelevant applications to find an application related to his particular desired topic." (Compl. ¶10-12; ’918 Patent, col. 1:58-2:9).
• The Patented Solution: The invention proposes a two-step process that first determines the user's "search intent"—the underlying "topic of interest"—from an input query, and only then selects applications based on that determined intent. (Compl. ¶13; ’918 Patent, Abstract). The detailed description discloses a system architecture involving an "intent detection unit" (IDU) that may use a plurality of specialized "engines" to tokenize a query, process the tokens, and compute "certainty scores" to derive the user's intent with greater accuracy than simple keyword matching. (’918 Patent, col. 6:10-67; Fig. 3).
• Technical Importance: This intent-based approach was designed to improve the efficiency and accuracy of application discovery, thereby reducing computational resources wasted on serving irrelevant results and decreasing network bandwidth consumption from repeated, unsuccessful user searches. (Compl. ¶16-17).

Key Claims at a Glance

• The complaint focuses its infringement theory primarily on independent Claim 1, while also referencing the concepts in dependent Claims 3 and 7. (Compl. ¶14, 17-18).
• The essential elements of asserted independent Claim 1 include:
  • receiving an input search query from a user device;
  • determining the search intent based on the input search query;
  • selecting, based on the search intent, at least one application from at least one applications central repository;
  • causing an icon for the selected application to be displayed;
  • receiving an input from the user indicating a particular application;
  • causing establishment of a direct communication link to a location hosting the application; and
  • causing initiation of a download of the application.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are detailed in claim charts allegedly incorporated into the complaint, but these charts were not provided with the filed document. (Compl. ¶22, 27).

Functionality and Market Context

• The complaint alleges that the accused products embody an "unconventional search intent determination protocol" for application discovery. (Compl. ¶18). The core accused functionality is a search mechanism that allegedly determines a user's intent and selects an application based on that intent, rather than relying on simple keyword matching. (Compl. ¶15, 17). The complaint does not provide specific details on the technical operation or market positioning of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an "Exhibit 2" that were not included in the provided filing. (Compl. ¶27-28). Therefore, the infringement allegations are summarized below in prose based on the complaint's narrative.

The complaint alleges that Defendant’s products directly infringe at least Claim 1 of the ’918 Patent. (Compl. ¶22). The infringement theory centers on the "determining" and "selecting" steps of the claim. (Compl. ¶17). Plaintiff alleges that the accused products perform the inventive two-step process of first "determining the search intent respective of the input search query" and then "selecting, based on the search intent, at least one application." (Compl. ¶18). This process is alleged to be a "fundamental technological improvement over prior art keyword-matching systems" and represents an inventive departure that improves computer functionality. (Compl. ¶17). The complaint asserts that this functionality in the "Exemplary Defendant Products" satisfies all elements of the asserted claims. (Compl. ¶27).

Identified Points of Contention

• Scope Questions: A central dispute may arise over the required technical implementation of the "determining the search intent" step. The question for the court will be whether this limitation can be met by any form of semantic search, or if it requires the more specific multi-engine, tokenizing, and certainty-scoring architecture described in the patent’s specification. (’918 Patent, col. 7:1-8:43).
• Technical Questions: The complaint provides a high-level functional description of the alleged infringement but does not specify how the accused products technically operate. A key question will be what evidence the Plaintiff can produce to show that the Defendant's products actually perform the claimed steps, particularly the internal process of analyzing a query to determine "intent" before selecting an application.

V. Key Claim Terms for Construction

• Term: "determining the search intent"

  • Context and Importance: This term is the central inventive concept of Claim 1. The outcome of the infringement analysis will likely depend on how this term is construed. Practitioners may focus on this term because its scope dictates whether modern semantic search technologies fall within the claim, or if infringement requires the specific architecture disclosed in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's abstract describes the invention as "determining the search intent respective of the input search query, wherein the search intent indicates a topic of interest of a user." (’918 Patent, Abstract). This language could support a construction that covers any process for identifying the user's subject matter of interest.
    • Evidence for a Narrower Interpretation: The detailed description explains that determining intent is accomplished via a specific process involving an "intent detection unit" (IDU) that utilizes "a plurality of engines," "tokenizer," and "analyzer" to compute "certainty scores." (’918 Patent, col. 6:10-8:16; Figs. 3-4). This detailed embodiment may be used to argue that "determining the search intent" should be limited to such a multi-engine, score-based system. The complaint itself highlights this multi-engine architecture as a key inventive aspect. (Compl. ¶19).

• Term: "applications central repository"

  • Context and Importance: This term defines the universe of applications from which the claimed method selects. Its construction will determine what types of application sources are covered by the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself does not contain explicit limitations and could be argued to encompass any centralized collection of applications accessible over a network.
    • Evidence for a Narrower Interpretation: The specification provides specific examples, stating that "applications repositories 150 are the AppStore®, Google Play® and the like." (’918 Patent, col. 4:45-47). This may support a narrower construction limited to curated, platform-specific marketplaces, as opposed to the general web.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant provides "product literature and website materials" that instruct and encourage end users to use the accused products in a manner that infringes the ’918 Patent. (Compl. ¶25-26).
• Willful Infringement: The willfulness claim is based on alleged post-suit knowledge. The complaint alleges that by serving the complaint and its associated (but unattached) claim charts, Plaintiff provided Defendant with actual knowledge of infringement, and that Defendant's continued infringement thereafter is willful. (Compl. ¶24-25).

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 central claim term "determining the search intent"? Will it be interpreted broadly to cover any modern semantic search that identifies a "topic of interest," or will it be limited more narrowly to the specific multi-engine, certainty-scoring architecture detailed in the patent’s specification?
2. A key evidentiary question will be one of technical proof: The complaint makes high-level functional allegations without detailing the accused products' internal workings. The case will likely turn on whether discovery reveals evidence that the accused systems technically perform the claimed method, particularly whether they analyze user queries to derive an "intent" that is then used as the basis for a separate application "selecting" step, as required by the claim.