HyperQuery LLC v. Ugreen Group Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HyperQuery LLC (Delaware)
  • Defendant: Ugreen Group Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00417, E.D. Tex., 04/17/2025
• Venue Allegations: Venue is asserted on the basis that the Defendant is a foreign corporation and has allegedly committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for searching for and downloading mobile applications based on a user's inferred "search intent" rather than simple keywords.
• Technical Context: The technology addresses the field of mobile application discovery, aiming to improve the relevance and efficiency of search results within app stores or similar platforms.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

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.

U.S. Patent No. 9,529,918 - System and methods thereof for downloading applications via a communication network

The Invention Explained

• Problem Addressed: The patent asserts that conventional methods for finding mobile applications in repositories are inefficient and "time consuming" (’918 Patent, col. 2:4-6). Users must either navigate through broad categories or use keyword searches that return lists of applications that may be irrelevant or "promoted by the repository's owner" rather than being tailored to the user's specific needs (’918 Patent, col. 2:7-9).
• The Patented Solution: The invention proposes a system that goes beyond keywords to ascertain a user's "search intent" (’918 Patent, col. 4:3-6). After receiving a query, the system determines this intent, selects a corresponding application from a repository, and then generates a "display segment" (e.g., an overlay) on the user's device showing an icon for the selected app (’918 Patent, Abstract). When the user interacts with the icon, the system establishes a "direct communication link" to download the application, bypassing the cumbersome search process (’918 Patent, col. 4:58-64).
• Technical Importance: This approach seeks to provide a more streamlined and intelligent application discovery process by focusing on user intent, which can be inferred from context, rather than relying solely on explicit user search terms (’918 Patent, col. 2:9-12).

Key Claims at a Glance

• The complaint asserts infringement of "Exemplary '918 Patent Claims" without specifying claim numbers (Compl. ¶11). The patent contains two independent claims, 1 (method) and 11 (system).
• The essential elements of independent method claim 1 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 repository based on this intent.
  • Causing an icon for the selected application to be displayed.
  • Receiving an input from the user indicating a particular selected application.
  • Causing the establishment of a "direct communication link" to a location hosting the application.
  • Causing the initiation of a download over that link.
• The complaint reserves the right to assert other claims, which may include dependent claims that add further limitations (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name in its main body (Compl. ¶11). It refers generally to "Exemplary Defendant Products" and states that they are identified in charts incorporated by reference as Exhibit 2 (Compl. ¶11, ¶16). This exhibit was not publicly filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context. It alleges in general terms 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 alleges that the "Exemplary Defendant Products" infringe the '918 Patent but provides the specific element-by-element comparison in an external "Exhibit 2," which was not included with the filed complaint (Compl. ¶16, ¶17). The narrative alleges that the accused products "satisfy all elements of the Exemplary '918 Patent Claims" (Compl. ¶16). Without access to the referenced exhibit, a detailed claim chart analysis is not possible based on the provided documents.

• Identified Points of Contention: Based on the language of the '918 Patent and the general nature of the allegations, the infringement analysis may raise several key questions:
  • Scope Questions: A central dispute may concern the scope of "determining the search intent" (Claim 1). The question for the court could be whether the accused products' search function performs a simple keyword or semantic analysis, or if it conducts the more complex, context-based "intent" determination described in the patent's specification, which contemplates using "environmental variables" like location and time (’918 Patent, col. 4:9-16).
  • Technical Questions: The complaint's theory appears to require evidence that the accused products create a "display segment" with a selectable icon and establish a "direct communication link" for downloading an application, as required by Claim 1. A technical question will be whether the accused functionality, once identified, follows this specific workflow or operates through a standard, indirect app store interface, which may not meet the "direct" limitation.

V. Key Claim Terms for Construction

"determining the search intent"

• Context and Importance: This term appears in both independent claims and captures the core of the purported invention. Its construction will be critical, as it distinguishes the claimed method from conventional keyword searching. Practitioners may focus on this term because the outcome of the case could depend on whether the accused system's algorithm is found to determine "intent" as the patent defines it.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify how the intent must be determined, only that it is "based on the input search query" (’918 Patent, col. 9:61-10:1). This could support a construction covering any algorithm that infers user goals beyond literal term matching.
  • Evidence for a Narrower Interpretation: The specification provides specific examples of determining "implicit intent" by "receiving personal variables and/or environmental variables," analyzing their context, and correlating them to derive a "category of interest" (’918 Patent, col. 4:9-28; col. 10:18-30). This could support a narrower construction limited to systems that analyze such contextual data.

"direct communication link"

• Context and Importance: This term defines the mechanism for downloading the application and is a required step in the claimed method. Infringement will depend on the network architecture of the accused system.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term could be interpreted to mean any connection that allows the user to initiate a download from the presented icon without having to manually search again in a separate app store interface.
  • Evidence for a Narrower Interpretation: The patent contrasts its solution with navigating "central repositories" (’918 Patent, col. 2:40-45). This suggests "direct" could be construed to mean a link that bypasses the primary interface or servers of a platform like the Apple App Store or Google Play, connecting the user device more directly to the location "hosting" the application file (’918 Patent, col. 10:4-7).

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 allegedly infringes the '918 Patent (Compl. ¶14).

Willful Infringement

The complaint pleads a basis for post-filing willfulness by asserting that the service of the complaint itself provides Defendant with "actual knowledge of infringement" (Compl. ¶13). It alleges that despite this knowledge, Defendant continues its infringing activities (Compl. ¶14).

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

• A core issue will be one of definitional scope: can the term "determining the search intent," as used in the patent, be construed to cover the search and recommendation algorithms used in the accused products? The resolution will depend on whether the term is limited to the context-aware methods detailed in the specification or if it can encompass broader semantic search technologies.
• The case will also present a key evidentiary challenge for the Plaintiff: proving that the unspecified "Exemplary Defendant Products" practice each claimed step. This includes demonstrating the creation of a special "display segment" and, crucially, a "direct communication link" for downloads, as distinguished from a conventional, indirect app store download process. The lack of specific product identification in the complaint's body elevates the importance of discovery in revealing the accused functionality.