GeoSymm Ventures LLC v. Pixelplex Labs LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GeoSymm Ventures LLC (Texas)
  • Defendant: Pixelplex Labs LLC (United Kingdom)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00739, E.D. Tex., 07/23/2025
• Venue Allegations: Venue is alleged to be proper on the basis that the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to a digital "assistive agent" that processes user requests by determining their semantic meaning and interacting with various web services via an API.
• Technical Context: The technology at issue falls within the domain of virtual personal assistants, systems designed to understand natural language queries and orchestrate backend services to perform tasks for a user.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 9,130,900 - “Assistive agent”

Issued: September 8, 2015

The Invention Explained

• Problem Addressed: The patent describes a deficiency in then-existing personal information managers (PIMs), which it states failed to take full advantage of the user information they stored, requiring significant manual user input to perform combined functions (e.g., setting a calendar appointment and an appropriate travel-time reminder). (’900 Patent, col. 1:21-33).
• The Patented Solution: The invention describes a system and method for a more advanced "assistive agent." This agent receives a user's request, determines its underlying meaning ("semantics") by identifying a domain, task, and parameters, and then accesses one or more external "semantic web services" through an Application Programming Interface (API) to formulate and deliver a response. (’900 Patent, Abstract; Fig. 2). This architecture is designed to integrate various data sources and services to fulfill a user's intent with less manual intervention. (’900 Patent, col. 3:3-9).
• Technical Importance: The described technology represents an architectural approach for creating more capable digital assistants that can interpret user intent and orchestrate multiple backend services, a step beyond basic information management. (’900 Patent, col. 1:46-52).

Key Claims at a Glance

• The complaint refers to "Exemplary '900 Patent Claims" contained in an exhibit not attached to the publicly filed document (Compl. ¶16), but the patent contains two independent claims, 1 and 19.
• Independent Claim 1 (method) includes the following essential elements:
  • Receiving a user request from a mobile device.
  • Determining the request's semantics, including identifying a domain, task, and parameter, by parsing the request and using location and personal information from the device.
  • Accessing one or more "semantic web services" via an API to retrieve matching data.
  • Providing personalized recommendations.
  • Presenting responses by interacting with the web services and confirming user responses via a text messaging or phonebook API.
  • Determining a responsive answer and responding to the user.
• Independent Claim 19 (system) includes the following essential elements:
  • A computing device that captures user profile and interests.
  • A server that accesses semantic web services via an API to perform functions (e.g., adding a contact, setting an alarm) initiated from the computing device's user interface.
  • An "ontology" associated with the web services that integrates various models and data, including specific models for dining, event planning, and dialog flows.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to infringement of "one or more claims." (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, referring to them generally as the "Exemplary Defendant Products" and "numerous other devices." (Compl. ¶11).

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the '900 Patent" and that Defendant's "product literature and website materials" instruct end users on their infringing use. (Compl. ¶14, ¶16). The complaint does not provide specific details regarding the technical operation or market position of any accused product.

IV. Analysis of Infringement Allegations

The complaint states that infringement allegations are detailed in claim charts provided as Exhibit 2, which was not included with the filed complaint. (Compl. ¶16-17). The complaint's narrative theory asserts that the "Exemplary Defendant Products" directly infringe by practicing the claimed technology and satisfying all elements of the asserted claims. (Compl. ¶16). However, the complaint does not provide sufficient detail for a tabular analysis of the infringement allegations.

V. Key Claim Terms for Construction

"semantic web services" (Claim 1)

• Context and Importance: This term is foundational to the claimed invention, as it defines the universe of external data sources and applications the assistive agent interacts with. Its construction will be critical to determining the scope of infringement, particularly whether it is limited to specific "semantic web" technologies or applies more broadly to modern API-based services.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides examples of "third-party service providers" that include "Facebook, Amazon, Yahoo, eBay, and the like sources," as well as on-device applications like a "calendar application," suggesting a broad scope. (’900 Patent, col. 4:30-34, col. 6:58-62).
  • Evidence for a Narrower Interpretation: Practitioners may argue that dependent claims 2 and 3, which recite services comprising "web ontology language" and "RDF" respectively, imply the independent term should not be so broad as to make these dependent claims superfluous. (’900 Patent, col. 28:13-17). The specification also discusses these specific technologies in the context of the services. (’900 Patent, col. 13:20-24).

"determining semantics of the user request" (Claim 1)

• Context and Importance: This term defines the level of "understanding" the accused system must demonstrate. The dispute will likely center on whether simple keyword parsing is sufficient or if a more complex, structured analysis is required by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes a process to "match the word, phrase, or syntax such as to identify at least one task, at least one domain, and at least one parameter," which could support a simpler interpretation. (’900 Patent, col. 5:58-62).
  • Evidence for a Narrower Interpretation: The patent also describes a more sophisticated system involving a "grammatical analyzer" that "creates logical relationships" and an "ontology" that models domains, tasks, and dialog flows, which may support an argument for a narrower construction requiring more than basic parsing. (’900 Patent, col. 9:11-28; Fig. 7).

"ontology" (Claim 19)

• Context and Importance: This term is a central structural element of the system claimed in Claim 19. Its definition is critical, as a narrow construction could make infringement difficult to prove against systems that do not use a formally identical structure.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification offers a general, academic definition of ontology as providing "structures for data and knowledge representation such as classes or types, relations, attributes or properties and their instantiation." (’900 Patent, col. 16:4-8).
  • Evidence for a Narrower Interpretation: Claim 19 itself recites a detailed list of what the ontology must include, such as "a dining domain model," "event planning task flow models," and "dialog flow models." (’900 Patent, col. 29:4-29). The patent also provides a detailed depiction in Figure 7, which a party could argue defines the required structure and limits the term to a complex, multi-part framework rather than any generic data model.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, asserting that Defendant distributes "product literature and website materials" that direct and instruct end users to use the accused products in an infringing manner. (Compl. ¶14-15).

Willful Infringement

The complaint alleges knowledge of the ’900 Patent as of the date the complaint was served. (Compl. ¶13). It further alleges that Defendant's continued infringement despite this knowledge is willful, forming a basis for post-suit willfulness allegations. (Compl. ¶14).

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

• A primary issue will be one of pleading sufficiency: given that the complaint's substantive infringement allegations are contained entirely within an unattached exhibit, a threshold question is whether the pleading provides sufficient factual detail to state a plausible claim for relief under the Iqbal/Twombly standard.
• The case may also turn on a question of definitional scope: can the term "semantic web service", which has a specific meaning in computer science, be construed broadly to cover any modern web API, or will it be limited by the patent's references to formal "semantic web" technologies like RDF and web ontology language?
• A key evidentiary question will be one of technical implementation: assuming the case proceeds, the analysis will focus on whether the accused products' method for interpreting user commands meets the claim requirement of "determining semantics" by identifying a "domain, task, and parameter," or if there is a fundamental mismatch with the structured, ontology-driven approach described in the patent.

No probative visual evidence provided in complaint.