DCT

2:25-cv-00588

Dynamic Data Innovations LLC v. H E B LP

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00588, E.D. Tex., 08/22/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has committed acts of infringement and maintains regular and established places of business within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to methods for dynamically filtering and navigating large sets of data objects within a graphical user interface.
  • Technical Context: The technology at issue addresses user interface challenges in navigating large databases, such as online product catalogs, by providing a method to refine search results by excluding items based on the attributes of a user-selected example.
  • Key Procedural History: The complaint is a First Amended Complaint for Patent Infringement. No other significant procedural events, such as prior litigation or administrative proceedings involving the patent-in-suit, are mentioned in the complaint.

Case Timeline

Date Event
2015-10-14 ’676 Patent Priority Date
2017-04-25 ’676 Patent Issue Date
2025-08-22 Complaint Filing Date

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

U.S. Patent No. 9,632,676 - "Systems And Methods For Navigating A Set Of Data Objects"

  • Patent Identification: U.S. Patent No. 9,632,676, "Systems And Methods For Navigating A Set Of Data Objects," issued April 25, 2017 (the "’676 Patent").

The Invention Explained

  • Problem Addressed: The patent's background section describes the problem of users being presented with an unmanageable number of results when searching large datasets, such as online stores. It notes that "scrolling through a large number of objects is burdensome and unmanageable" when a set contains hundreds of thousands or even millions of members (’676 Patent, col. 8:26-31; Compl. ¶33).
  • The Patented Solution: The invention provides a method for improving a graphical user interface (GUI) by allowing a user to refine search results through exclusion. After an initial search, a user can select a single data object (e.g., an undesirable product) with a single click or touch. The system then automatically identifies key attributes of that selected object and uses them as "exclusion terms" to remove other similar objects from the result set, dynamically presenting a smaller, more refined list to the user (’676 Patent, col. 5:14-24; Compl. ¶34).
  • Technical Importance: This approach aims to improve the performance and usability of computer systems by reducing the number of manual steps a user must take to narrow down search results, thereby reducing data traffic and processor utilization compared to repeatedly entering new search queries (’676 Patent, col. 8:46-9:8; Compl. ¶36).

Key Claims at a Glance

  • The complaint asserts at least Claim 1 of the ’676 Patent (Compl. ¶59).
  • The essential elements of independent claim 1 include:
    • managing an object dataset defining attributes for a plurality of objects;
    • receiving a query and applying it to select a first set of objects;
    • rendering the first set of objects in a GUI;
    • detecting a user’s selection of an object from the first set;
    • automatically identifying a "differentiating parameter" of the selected object by evaluating differences between its attributes and the attributes of other members in the first set;
    • identifying a second set of objects from the first set based on that differentiating parameter;
    • excluding the second set to create a third, smaller set of objects; and
    • dynamically rendering the third set of objects in the GUI in response to the selection.
    • The selection must be a "single click or touch on an indication of the object."
  • The complaint notes that its arguments may apply to other claims in the patent beyond Claim 1 (Compl. ¶41).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is the website https://www.heb.com/ and its associated hardware, software, and functionality (the "Accused Products") (Compl. ¶¶ 20-21).

Functionality and Market Context

  • The complaint alleges the Accused Products provide an e-commerce platform where users can search for products, view results, and refine those results (Compl. ¶¶ 21, 60). Figure 2 of the complaint depicts the website presenting over 5,000 search results for the term "snacks," illustrating the presentation of a large set of data objects (Compl. Figure 2). Figure 3 shows a user interface with "Popular Filters," such as "Brand" and "Has Coupon," which the complaint appears to position as the mechanism for navigating the data objects (Compl. Figure 3). Defendant H-E-B is alleged to have annual sales of "more than $46 billion" (Compl. ¶9).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "Exhibit A" that was not provided with the filed document (Compl. ¶59). The infringement theory must therefore be summarized from the complaint’s narrative allegations.

’676 Patent Infringement Allegations

The complaint alleges that the Accused Products perform the computer-implemented method of Claim 1 (Compl. ¶60). The narrative theory suggests that when a user interacts with the H-E-B website, they are engaging in the claimed steps. A user first receives a "first set of objects" after performing a search, as shown in a screenshot of results for "snacks" (Compl. Figure 2). The complaint then alleges the website provides a mechanism for selecting an object or its attributes, which leads to the exclusion of other objects and the presentation of a dynamically updated, smaller set of results (Compl. ¶60). For instance, the complaint provides a screenshot of a specific product page for "Chomps 10g Protein Original Beef Jerky Meat Sticks," which may represent the "selection of an object" that triggers the filtering process (Compl. Figure 4).

  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the Accused Products' use of conventional filter menus (Compl. Figure 3) meets the claim limitation of "automatically identifying which of said plurality of attribute parameters... is a differentiating parameter by evaluating differences." The patent suggests an automated analysis to determine the most differentiating feature, whereas the complaint's visual evidence shows a static list of filter categories (e.g., "Brand," "Ways to Shop").
    • Technical Questions: The final limitation of Claim 1 requires the filtering action to be triggered by a "single click or touch on an indication of the object." It raises the question of whether the complaint provides evidence that selecting a checkbox in a separate filter pane constitutes a click "on an indication of the object" itself, as opposed to interacting with a distinct UI element separate from the product listings.

V. Key Claim Terms for Construction

  • The Term: "differentiating parameter"

    • Context and Importance: This term is central to the invention's automated nature. Its construction will determine whether a user's selection of a pre-defined filter category (like "Brand") can be considered equivalent to the patent's more complex-sounding process of "evaluating differences" to find a parameter that "most differentiates the selected object" (’676 Patent, col. 20:2-4).
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification lists common product characteristics like "price, brand, model, and component size" as examples of attribute parameters, which could support an argument that any user-selected category falls within the term's scope (’676 Patent, col. 20:65-21:2).
      • Evidence for a Narrower Interpretation: The claim requires the parameter to be identified by "evaluating differences" between the selected object and others. The specification further describes this as identifying a feature that "most differentiates the selected at least one object from other objects" (’676 Patent, col. 2:7-9). This language may support a narrower construction requiring a specific algorithm that analyzes and ranks parameters, rather than simply accepting a user's choice from a static menu.

  • The Term: "selection... is a single click or touch on an indication of the object"

    • Context and Importance: This term defines the specific user action that initiates the claimed filtering process. The dispute may turn on whether clicking a filter checkbox is legally equivalent to clicking on the product listing itself.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: One could argue that a filter label like "H-E-B" under the "Brand" category is an "indication" of all H-E-B brand objects, and clicking it is therefore a valid selection.
      • Evidence for a Narrower Interpretation: The specification describes the user action as clicking or touching "an icon representing one of the objects" (’676 Patent, col. 5:18-19). This, combined with the claim's focus on the "selection of an object," may support a construction requiring the user to interact directly with a specific product representation (e.g., an image or title in the results list), not a separate filter control.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement, stating that Defendant encourages and provides instructions for customers and employees to use the Accused Products in an infringing manner (Compl. ¶61). It also alleges contributory infringement, claiming the Accused Products have special features designed for infringement that are not staple articles of commerce (Compl. ¶62).
  • Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the ’676 Patent "at least as early as the date Defendant received notice of the filing of this action" (Compl. ¶63). The complaint also alleges willful blindness based on a supposed "policy or practice of not reviewing the patents of others" (Compl. ¶64).

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

  • A core issue will be one of operational equivalence: does the accused website's filtering functionality, which appears to rely on conventional user-selected filter menus (Compl. Figure 3), perform the specific method required by Claim 1—namely, automatically identifying a "differentiating parameter" by "evaluating differences" based on the selection of a single exemplar object?
  • A second key question will concern definitional scope: can the phrase "a single click or touch on an indication of the object" be construed to cover a user's interaction with a checkbox in a separate filtering pane, or does the claim language, informed by the specification, require a direct interaction with the representation of a specific data object in a results list?