HyperQuery LLC v. Chaos Software GmbH

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HyperQuery LLC (Delaware)
  • Defendant: Chaos Software GmbH (Germany)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00415, 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’s unspecified software products infringe a patent related to methods for determining a user's search intent to recommend and facilitate the download of mobile applications.
• Technical Context: The technology addresses the "app discovery" problem, aiming to improve the relevance of search results within application marketplaces by moving beyond simple keyword matching to a more nuanced understanding of user intent.
• Key Procedural History: The complaint does not allege any prior litigation, licensing history, or administrative proceedings concerning the patent-in-suit. Plaintiff asserts it is the assignee of the patent.

Case Timeline

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

• Patent Identification: 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's background section describes the process of searching for mobile applications in conventional repositories as "very time consuming," noting that results are often not based on relevance to the user's true interest but are instead "promoted by the repository's owner" (’918 Patent, col. 2:4-9).
  • The Patented Solution: The invention proposes a system that receives a user's search query and determines the user’s "search intent," which may be based on the query itself and/or contextual data like location and time (’918 Patent, col. 4:3-16). Based on this inferred intent, the system selects a relevant application, displays an icon for it, and upon user selection, establishes a "direct communication link" to download the application, bypassing further navigation through a repository (’918 Patent, Abstract; col. 4:54-68). The system architecture is depicted in Figure 1, showing a search server (130) and an intent detection unit (140) mediating between a user device (110) and application repositories (150).
  • Technical Importance: This technology purports to overcome the limitations of keyword-based search in app stores by providing a more personalized and efficient application discovery mechanism based on user intent (’918 Patent, col. 2:9-13).
• Key Claims at a Glance:
  • The complaint asserts infringement of one or more unspecified claims, referring to them as the "Exemplary '918 Patent Claims" (Compl. ¶11). The patent’s foundational independent claims are method claim 1 and system claim 11.
  • Independent Claim 1 (Method): The essential steps include:
    • Receiving an input search query from a user device.
    • Determining the "search intent" based on the query.
    • Selecting at least one application from a central repository based on the determined intent.
    • Causing an icon for the selected application to be displayed.
    • Receiving a user input indicating selection of the application.
    • Causing the establishment of a "direct communication link" to the application's hosting location.
    • Causing the initiation of the application download over that link.
  • Independent Claim 11 (System): This claim recites a system with a processor and memory configured to perform the core functions described in method claim 1.
  • The complaint does not explicitly reserve the right to assert dependent claims, but the general allegation of infringing "one or more claims" leaves this possibility open (Compl. ¶11).

III. The Accused Instrumentality

• Product Identification: The complaint does not name any specific accused products or services, referring to them generally as the "Exemplary Defendant Products" (Compl. ¶11).
• Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context. It states that these details are provided in claim charts in an "Exhibit 2" (Compl. ¶16), which was not included with the filed complaint.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint states that infringement is detailed in claim charts attached as Exhibit 2 (Compl. ¶16). As this exhibit was not provided, a detailed claim chart summary cannot be constructed. The complaint’s narrative theory is that the "Exemplary Defendant Products" practice the technology claimed by the ’918 Patent and "satisfy all elements of the Exemplary '918 Patent Claims" (Compl. ¶16).

• Identified Points of Contention: Based on the patent and the general nature of the allegations, the infringement analysis raises several questions.
  • Scope Questions: A central dispute may concern the meaning of "determining the search intent" (’918 Patent, cl. 1). The question for the court will be whether this term covers any modern search algorithm that analyzes query meaning, or if it is limited to the patent's specific disclosure of using a plurality of "engines" to map tokens to entities and calculate "certainty scores" (’918 Patent, col. 6:18-34, col. 7:1-8:16).
  • Technical Questions: A key evidentiary question will be whether the accused products actually perform all the claimed steps sequentially. For example, what evidence does the complaint provide that the accused product "caus[es] establishment of a direct communication link" to a hosting location, as required by claim 1, rather than simply redirecting the user to a standard page within a third-party application store? (’918 Patent, col. 10:4-8).

V. Key Claim Terms for Construction

• The Term: "search intent"

• Context and Importance: This term is the conceptual core of the invention. Its construction will likely determine whether a wide range of modern, semantic search functionalities fall within the scope of the claims or if the claims are limited to a more specific implementation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The plain language of claim 1 requires only "determining the search intent based on the input search query," which could be argued to encompass any process that infers a user's goal beyond literal keyword matching (’918 Patent, col. 9:62).
  • Evidence for a Narrower Interpretation: The specification describes a detailed process for determining intent, involving an "intent detection unit" (IDU 140) that tokenizes queries, processes them through multiple engines (146), maps them to entities, and performs statistical and semantic analysis (’918 Patent, FIG. 3; col. 6:10-53). A party could argue that "search intent" should be construed to require these disclosed features.

• The Term: "direct communication link"

• Context and Importance: This term is critical for distinguishing the claimed invention from conventional methods of linking to an app store. The definition will be important for determining whether the final step of the accused process infringes.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term could be argued to mean any system-initiated connection that results in a download, without requiring the user to perform additional searches or navigation within a repository.
  • Evidence for a Narrower Interpretation: Claim 1 recites establishing a link "between the user device and a location hosting the particular one of the at least one selected application" (’918 Patent, col. 10:5-8). This might be construed to require a connection that bypasses an intermediary app store interface and directly accesses the download source, consistent with the patent’s goal of overcoming the navigational burdens of such stores (’918 Patent, col. 2:4-9).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that the Defendant distributes "product literature and website materials" that instruct and "direct end users to commit patent infringement" in the customary use of its products (Compl. ¶14).
• Willful Infringement: The allegation of willfulness appears to be based on post-suit knowledge. The complaint asserts that its service "constitutes actual knowledge of infringement" and that any subsequent infringing activities by the Defendant are therefore willful (Compl. ¶13-14).

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

• A core issue will be one of definitional scope: can the term "search intent," as used in the claims, be construed broadly to cover any form of semantic query analysis, or will it be tethered to the specific multi-engine, entity-mapping architecture detailed in the ’918 Patent’s specification? The outcome of this construction will be pivotal to the infringement analysis.
• A key evidentiary question will be one of technical implementation: assuming the complaint proceeds, discovery will be necessary to determine whether the accused products actually perform each claimed step. Specifically, does the accused functionality establish a "direct communication link" to a hosting location for download, or does it merely function as a sophisticated search front-end that ultimately redirects users to a conventional, third-party application store? This functional distinction may prove dispositive.