HyperQuery LLC v. HTC Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HyperQuery LLC (Delaware)
  • Defendant: HTC Corporation (Taiwan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00409, E.D. Tex., 04/17/2025
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign corporation and has allegedly committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s unnamed products infringe a patent related to systems and methods for downloading mobile applications based on user search intent.
• Technical Context: The technology concerns search algorithms that analyze user queries to determine underlying intent, aiming to provide more relevant application suggestions than traditional keyword-based searches in app stores.
• Key Procedural History: The complaint is the initiating document in this litigation. No prior litigation, administrative proceedings, or licensing history between the parties is 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

The Invention Explained

• Problem Addressed: The patent describes the process of finding relevant mobile applications in existing repositories as "very time consuming," noting that search results are often promoted by the repository owner and may not align with the user's actual needs or intent (’918 Patent, col. 2:4-12).
• The Patented Solution: The invention proposes a system that goes beyond simple keyword matching by first "determining the search intent" behind a user's query (’918 Patent, Abstract). As depicted in the system architecture of Figure 1, an Intent Detection Unit (IDU 140) analyzes the query to understand the user's goal (’918 Patent, col. 4:1-5). Based on this determined intent, the system selects relevant applications from repositories (150) and presents them to the user for direct download, streamlining the discovery process (’918 Patent, col. 2:21-34).
• Technical Importance: The technology represents a shift toward more context-aware search, aiming to reduce user friction in mobile application discovery by providing more intelligent and personalized recommendations (’918 Patent, col. 2:9-12).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" and "Exemplary '918 Patent Claims" but does not identify any specific claims (Compl. ¶11). The independent claims of the patent are method claim 1 and system claim 11.
• The essential elements of 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 an applications central repository;
  • causing an icon for the selected application to be displayed;
  • receiving an input from the user indicating a particular selected application;
  • causing establishment of a direct communication link to the location hosting the application; and
  • causing initiation of the application's download.

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" but does not name any specific accused products, methods, or services (Compl. ¶11).

Functionality and Market Context

The complaint asserts that the accused products "practice the technology claimed by the '918 Patent" but provides no details regarding their specific functionality, operation, or market position (Compl. ¶16). The complaint does not provide sufficient detail for analysis of the accused instrumentality's features.

IV. Analysis of Infringement Allegations

The complaint states that infringement allegations are detailed in claim charts provided as Exhibit 2 (Compl. ¶16-17). However, this exhibit was not included with the filed complaint. As a result, the specific theory of how the accused products allegedly meet the claim limitations is not available for analysis from the provided documents. No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent and the nature of the technology, the infringement analysis may raise several technical and legal questions for the court.
  • Scope Questions: A central dispute may concern the scope of "determining the search intent." The question for the court could be whether the accused products' search algorithms perform the specific multi-engine, probabilistic analysis detailed in the patent’s specification (’918 Patent, col. 7:1-col. 8:44), or if they perform a different function that Plaintiff alleges is equivalent.
  • Technical Questions: A key evidentiary question may be what constitutes a "direct communication link" as required by claim 1. The court may need to determine if the accused products establish a specific type of link that bypasses a standard repository interface, or if they use conventional redirects that Defendant may argue fall outside the claim's scope.

V. Key Claim Terms for Construction

• Term: "determining the search intent"

  • Context and Importance: This phrase appears in independent claim 1 and captures the core inventive concept of moving beyond keyword matching. Practitioners may focus on this term because its construction will likely be dispositive; a narrow construction could place the accused functionality outside the claim scope, while a broader one may support infringement but raise validity questions.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad, reciting "determining the search intent based on the input search query" without further limitation (’918 Patent, col. 9:61-62). This could support an interpretation covering any method that infers a user's goal.
    • Evidence for a Narrower Interpretation: The specification describes a detailed embodiment for determining intent, including an "intent detection unit" (IDU), a "tokenizer," a "plurality of engines," and the use of "certainty scores" (’918 Patent, FIG. 3; col. 6:9-col. 8:16). This detailed description could be used to argue for a narrower construction limited to this specific implementation.

• Term: "direct communication link"

  • Context and Importance: This term is critical for defining the interaction between the user device and the application source. Its definition distinguishes the claimed process from, for example, a web page that simply provides a standard hyperlink to an app store.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states the link is established "between a source of the at least one selected application and the user device to initiate the application download," which could be argued to cover any connection that results in a download without significant intermediate user navigation (’918 Patent, col. 5:47-51).
    • Evidence for a Narrower Interpretation: Language in the patent describes establishing the link "responsive to the selection" and to "initiate the download," which could support a narrower reading that excludes standard, multi-step app store protocols or browser redirects (’918 Patent, col. 5:47-51).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement, asserting that Defendant provides "product literature and website materials" that instruct end users on how to use the accused products in a manner that allegedly infringes the ’918 Patent (Compl. ¶14).
• Willful Infringement: The basis for the willfulness allegation is post-suit knowledge. The complaint alleges that "at least since being served by this Complaint," Defendant has had "actual knowledge of infringement" and continued to infringe (Compl. ¶13, ¶15).

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

• A core issue will be one of definitional scope: can the claim term "determining the search intent," which the patent describes via a complex, multi-engine probabilistic system, be construed to cover the search and recommendation algorithms used in Defendant's commercial products?
• A key challenge for the Plaintiff will be one of evidentiary specificity: can the Plaintiff, who has not identified the accused products or provided its infringement charts, produce sufficient evidence to demonstrate that Defendant's technology performs each specific step of the claimed method, particularly given the complaint's current lack of detail?