HyperQuery LLC v. Huya Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HyperQuery LLC (Delaware)
  • Defendant: Huya Inc. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00410, E.D. Tex., 04/17/2025
• Venue Allegations: Venue is asserted on the basis that the defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods for searching for and downloading mobile applications based on a user's determined search intent.
• Technical Context: The technology concerns application discovery on mobile devices, a commercially significant field given the proliferation of mobile application marketplaces.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings involving 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

• Issued: December 27, 2016

The Invention Explained

• Problem Addressed: The patent identifies a problem in conventional application repositories where searching for a desired application can be "very time consuming" and yield irrelevant results, partly because the results are often "promoted by the repository's owner" rather than being based on the user's specific needs or intent (’918 Patent, col. 2:4-12).
• The Patented Solution: The invention describes a method and system that receives a search query from a user, determines the user's "search intent" for a particular topic, selects one or more applications from a central repository based on that intent, and then presents an icon for the selected application to facilitate its download (’918 Patent, Abstract). The system is designed to go beyond simple keyword matching by discerning the user's underlying intent, which can be determined "implicitly" based on environmental or personal variables, or "explicitly" based on the query itself (’918 Patent, col. 4:7-16, 36-39).
• Technical Importance: The described technology aims to improve the relevancy and efficiency of application discovery within crowded mobile ecosystems by replacing or augmenting simple keyword searches with a more sophisticated intent-based selection process (’918 Patent, col. 2:9-12).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" of the ’918 Patent without specifying them, referring to them as the "Exemplary '918 Patent Claims" (Compl. ¶11). Independent Claim 1 is representative and includes the following key elements:
  • receiving, via the communication network, 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 corresponding to the at least one selected application to be displayed on a display of the user device;
  • receiving via the communication network an input from the user device indicating a particular one of the at least one selected application;
  • causing establishment of a direct communication link between the user device and a location hosting the particular one of the at least one selected application; and
  • causing initiation of a download of the particular one of the at least one selected application to the user device.
• The complaint does not explicitly reserve the right to assert dependent claims, but its general reference to "one or more claims" suggests this possibility (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not specifically name any accused products or services. It refers generally to "at least the Defendant products identified in the charts incorporated into this Count below (among the “Exemplary Defendant Products”)" (Compl. ¶11).

Functionality and Market Context

The complaint does not describe the functionality of the accused products. It alleges that infringement details are provided in "Exhibit 2," which contains claim charts comparing the patent claims to the "Exemplary Defendant Products" (Compl. ¶16). This exhibit was not filed with the complaint. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '918 Patent" and that they "satisfy all elements of the Exemplary '918 Patent Claims" (Compl. ¶16). However, the complaint relies entirely on its "Exhibit 2" to provide the element-by-element mapping of the claims to the accused products (Compl. ¶17). As this exhibit is not available for analysis, a detailed claim chart summary cannot be constructed.

• Identified Points of Contention:
  • Technical Questions: A primary question will be what factual evidence supports the allegation that Defendant's unnamed products perform the specific steps of the asserted claims. For example, what evidence demonstrates that Defendant's systems "determin[e] the search intent" in a manner consistent with the patent's teachings, as opposed to performing a conventional keyword search with standard relevance ranking?
  • Scope Questions: The dispute may turn on the scope of key claim phrases. For instance, does the "direct communication link" required by the claim read on standard methods of initiating a download from a third-party app store, or does it require a more specific technical connection established by the infringing system itself?

V. Key Claim Terms for Construction

• The Term: "determining the search intent" (from Claim 1)
• Context and Importance: This term appears to be the central novel element of the claimed invention, distinguishing it from prior art search methods. The outcome of the infringement analysis will likely depend heavily on whether the Defendant’s accused functionality falls within the court’s construction of this term. Practitioners may focus on this term because it is not a standard term of art and the patent dedicates significant specification space to describing its complex, multi-faceted process.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states that search intent "represents the type of content...and/or actions that currently may be of an interest to the user" and can be determined "implicitly" based on environmental variables like location and time, or "explicitly" from the query (’918 Patent, col. 4:4-16, 36-39). This language could support a construction that covers any system that uses contextual data to refine search results beyond simple keyword matching.
  • Evidence for a Narrower Interpretation: The detailed description provides a specific and complex implementation for determining intent via an "intent detection unit (IDU) 140" that uses a "tokenizer," a "plurality of engines," and a process of computing "certainty score[s]" to map queries to "entities" (’918 Patent, Fig. 3; col. 6:10-col. 8:17). This detailed disclosure of a specific embodiment could be cited to argue that "determining the search intent" requires these more complex structural and functional features, potentially narrowing the claim scope.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the ’918 Patent (Compl. ¶14).
• Willful Infringement: The complaint alleges willful infringement based on knowledge obtained from the service of the complaint itself, asserting that Defendant "actively, knowingly, and intentionally continued to induce infringement" at least since that time (Compl. ¶15).

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

1. A core issue will be one of definitional scope: Will the term "determining the search intent" be construed broadly to encompass a wide range of modern contextual search algorithms, or will it be limited to the specific multi-engine, tokenizing, and probability-scoring architecture detailed in the patent's specification? The answer will substantially define the patent's reach.
2. A key evidentiary question will be one of technical mapping: Because the complaint is factually sparse and relies on an unprovided exhibit, a central issue will be whether Plaintiff can produce sufficient evidence to demonstrate that Defendant's unnamed products actually perform each specific step recited in the asserted claims, particularly the "search intent" determination and the establishment of a "direct communication link."