Cedar Lane Tech Inc v. Momondo AS

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Momondo A/S (Denmark)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00641, E.D. Tex., 06/17/2025
• Venue Allegations: Venue is alleged to be proper because the defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods and systems for displaying and analyzing complex graphic information.
• Technical Context: The technology concerns graphical user interfaces that allow users to interact with and selectively display layered sets of data, aiming to improve the analysis of complex information.
• Key Procedural History: The complaint alleges that Defendant has been on notice of infringement since at least March 8, 2021, the date Plaintiff filed a lawsuit against Defendant's parent company, Booking Holdings, Inc. This prior litigation may be relevant to potential claims of willful infringement.

Case Timeline

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

U.S. Patent No. 8,397,177 - "Graphic-information flow method and system for visually analyzing patterns and relationships"

The Invention Explained

• Problem Addressed: The patent describes prior art computer graphic systems, such as Geographic Information Systems (GIS), as being cumbersome and unwieldy for non-technical users seeking to analyze complex data sets (col. 1:45-2:7). These systems allegedly make it difficult to seamlessly access and manipulate discrete subsets of information from large databases, breaking the flow of the analytical thought process (col. 2:32-39).
• The Patented Solution: The invention provides an interactive display system that organizes complex information into a "map" format with selectable layers and slots (col. 5:10-16). As described in the specification, users can manipulate "map" components, layers, and annotations through a graphical user interface to dynamically customize the view, enabling them to compare variations, study patterns, and discover relationships within the data more intuitively (’177 Patent, Abstract; col. 5:30-38). Figures 2B and 3 illustrate the concept of organizing data into distinct layers (302) and slots (3b) that a user can selectively view.
• Technical Importance: The technology purports to offer a more fluid and cognitively enhanced way for users to browse and analyze large, multi-faceted data sets compared to the static, page-to-page interfaces common at the time (col. 3:41-4:15).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying them, incorporating by reference an unprovided claim chart exhibit (Compl. ¶11, ¶13). Independent claim 1, a system claim, includes the following essential elements:
  • memory configured to store a database of elements and attributes;
  • a display module to generate a visual representation with a plurality of layers of selected elements for comparison;
  • wherein each selected element is represented by a symbol, text, or image given a "slot in the particular said layer";
  • and a control module to show or hide subsets of the selected elements responsive to input via a display control panel.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of the patent.

III. The Accused Instrumentality

Product Identification

The complaint does not name a specific accused product. It refers generally to "Exemplary Defendant Products" that are identified in charts included as Exhibit 2, which was not provided with the complaint (Compl. ¶11, ¶13).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused product's functionality or market context.

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 '177 Patent" and "satisfy all elements of the Exemplary '177 Patent Claims" (Compl. ¶13). However, it relies on claim charts in an unprovided Exhibit 2 to substantiate these allegations (Compl. ¶14). Without these charts, the complaint offers only conclusory statements of infringement.

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over whether the user interface of a commercial travel search engine, which is Momondo's business, falls within the patent's definition of a "map." The patent broadly defines a "map" as potentially any "diagrammatic representation of a complex object" (col. 7:5-7), but its examples are heavily focused on geographic or scientific data visualization. The court may need to determine if Defendant's presentation of flight and hotel search results constitutes such a "map."
  • Technical Questions: The complaint provides no factual basis to determine how the accused products meet specific technical limitations. A key question will be what evidence Plaintiff provides to show that the accused instrumentality organizes data into distinct "layers" and assigns elements to a "slot" within those layers, as required by claim 1.

V. Key Claim Terms for Construction

• The Term: "map"

• Context and Importance: The applicability of the patent hinges on this term's scope. If construed narrowly to mean only traditional geographic or cartographic representations, the infringement case against a travel search website may be weakened. If construed broadly, it could cover a wide range of data-driven user interfaces. Practitioners may focus on this term because its definition is likely outcome-determinative.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification explicitly defines a "map" as not only a "visual portrayal of a geographic area" but also "a diagrammatic representation of a complex object (the human body, a vehicle, a building)" or a graphical portrayal of a topic where pictures are understood in a series of subsets (col. 7:1-14).
  • Evidence for a Narrower Interpretation: The vast majority of the patent’s figures and detailed embodiments depict geographic maps (e.g., Figs. 6c, 6d, 7a-7e) or scientific diagrams (e.g., Fig. 11), which a defendant might argue cabins the term's meaning to those contexts.

• The Term: "a slot in the particular said layer"

• Context and Importance: This term appears central to the claimed structure for organizing data. Infringement will depend on whether Plaintiff can identify a corresponding structure in the accused products that functions as a "slot." A defendant would likely argue its user interface does not use a "slot" structure as described in the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not provide an explicit textual definition for "slot," which may support an argument that the term should be given its plain and ordinary meaning, potentially covering any designated position or container for a data element in a GUI.
  • Evidence for a Narrower Interpretation: The patent's figures consistently depict "slots" as discrete, grid-like containers (e.g., Fig. 3b, "Slotted Map Set -- Grid"; Fig. 10F, "Slotted Map with gridded matrix"). A defendant could argue these embodiments limit the term to a visually distinct, matrix-based organizational structure.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendant had notice of the '177 Patent "since at least March 8, 2021," based on a lawsuit filed against its parent company, Booking Holdings, Inc. (Compl. ¶15). Plaintiff further alleges a "unity of interest and ownership" between Defendant and its parent, which could form the basis for a claim of post-notice willful infringement (Compl. ¶15).

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

• A core issue will be one of definitional scope: can the term "map", which is defined broadly in the specification but primarily exemplified through geographic and scientific diagrams, be construed to cover the dynamic search-result interfaces of a commercial travel website?
• A key evidentiary question will be one of structural correspondence: given the complaint's conclusory allegations, what proof can Plaintiff offer to demonstrate that the accused products' software architecture contains the specific "layer" and "slot" structures required by the asserted claims, as opposed to simply displaying filtered data in a conventional manner?
• A third question concerns notice: will the court find that the 2021 lawsuit against Defendant's parent company, Booking Holdings, Inc., is sufficient to establish pre-suit knowledge of infringement by the Danish subsidiary Momondo A/S, a crucial element for establishing willfulness?