Geosymm Ventures LLC v. Streebo Solutions Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GeoSymm Ventures LLC (Texas)
  • Defendant: Streebo Solutions Limited (India)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00915, E.D. Tex., 08/29/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation, and that Defendant committed acts of patent infringement and caused harm in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified software products infringe a patent related to methods for processing user requests via an assistive agent.
• Technical Context: The technology at issue falls within the domain of virtual personal assistants (VPAs) or digital assistants, which interpret natural language user requests to interact with various data services and applications.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or inter partes review proceedings involving the patent-in-suit.

Case Timeline

Date	Event
2013-03-15	’900 Patent Priority Date
2015-09-08	’900 Patent Issue Date
2025-08-29	Complaint Filing Date

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

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

The Invention Explained

• Problem Addressed: The patent describes a limitation in prior "personal information managers" (PIMs) which, despite having access to a user's calendar, contacts, and other data, "have failed to take full advantage of the information" to enhance productivity. For example, a user creating a new appointment must still manually determine and set an appropriate reminder time, rather than the system intelligently assisting with that task. (’900 Patent, col. 1:21-31).
• The Patented Solution: The invention proposes a system where a user's request is received and its "semantics" are determined by identifying a relevant "domain," "task," and "parameter." (’900 Patent, Abstract; col. 5:56-62). The system then accesses one or more "semantic web services" through an Application Program Interface (API) to obtain a responsive answer, allowing for the integration of disparate services and data sources to fulfill the user's request. (’900 Patent, Fig. 2; col. 4:13-18).
• Technical Importance: This architecture describes a move from siloed applications to an integrated digital assistant capable of interpreting user intent and orchestrating actions across multiple services, a foundational concept for modern VPAs. (’900 Patent, col. 3:3-9).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring generally to the "Exemplary '900 Patent Claims" detailed in an exhibit not provided with the complaint (Compl. ¶11). Independent claim 1 is representative of the patented method.
• Claim 1 (Independent): A method for providing assistance to a user, comprising the steps of:
  • receiving a user request for assistance from a mobile device;
  • determining semantics of the user request and identifying at least one domain, at least one task, and at least one parameter for the user request by parsing the user request to identify representations of meaning or interpretation of the user request along with location and user personal information captured by the mobile device;
  • accessing one or more semantic web services, each service accessed through an application program interface (API) to retrieve data matching the at least one domain, task, and parameter;
  • identifying, generating, or providing personalized recommendations for activities, products, services;
  • presenting possible responses to the user by interact[ing] with the semantic web services;
  • determining at least one responsive answer; and
  • responding to the user request.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to infringement of "one or more claims of the '900 Patent" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products by name. It refers to "Exemplary Defendant Products" that are purportedly identified in an external claim chart exhibit (Exhibit 2), which was not provided with the filed complaint. (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the '900 Patent." (Compl. ¶16). Without specific product identification, the functionality is described only at the level of the patent claims themselves. The complaint does not provide detail regarding the market context or commercial importance of the accused products.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to an external document, "Exhibit 2," which contains claim charts that were not provided. (Compl. ¶16-17). The complaint's narrative theory asserts that the "Exemplary Defendant Products" satisfy all elements of the asserted claims. (Compl. ¶16). Without the claim charts or identification of the accused products, a detailed infringement analysis is not possible based on the provided documents.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the high-level allegations and the patent's claims, the central infringement questions will likely involve both technical operation and claim scope.
  • Scope Questions: A likely point of contention will be whether the accused products' architecture and data sources fall within the scope of "semantic web services" as that term is used in the patent. For instance, does the term require interaction with third-party, web-based APIs, or can it read on interactions with internal device applications and data?
  • Technical Questions: A key factual question will be whether the accused products perform the specific step of "determining semantics" by identifying a "domain," "task," and "parameter" from a user request. The analysis will depend on evidence showing how the accused software parses and processes user input, and whether this process maps to the specific parsing and identification steps required by the claims.

V. Key Claim Terms for Construction

The Term: "semantic web services"

• Context and Importance: This term is central to defining the scope of the invention. Its construction will determine what types of data sources and applications an accused product must interact with to infringe. Practitioners may focus on this term because its definition could either limit the claims to external, third-party services or broaden them to cover internal applications on the device itself.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the term can include functionalities "installed on the hardware device itself" and gives examples of interacting with on-device applications like an "alarm application ('app'), contacts, [or] calendar." (’900 Patent, col. 4:26-28, 4:41-44).
  • Evidence for a Narrower Interpretation: The specification also provides numerous examples of "third-party service providers" such as "Facebook, Amazon, Yahoo, eBay, and the like sources," suggesting the term may be understood in the context of external, internet-based services. (’900 Patent, col. 4:30-34).

The Term: "determining semantics of the user request and identifying at least one domain, at least one task, and at least one parameter"

• Context and Importance: This limitation defines the core "intelligence" of the claimed method. The infringement analysis will turn on whether the accused products perform this specific three-part identification (domain, task, parameter) when parsing a user request.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent claims this step in functional terms, without limiting it to a particular algorithm, which may support finding infringement in systems that achieve a similar outcome through different technical means. (’900 Patent, col. 27:58-65).
  • Evidence for a Narrower Interpretation: The specification provides a specific example of this process, stating the server is "configured to match the word, phrase, or syntax such as to identify at least one task, at least one domain, and at least one parameter." (’900 Patent, col. 5:58-62). An exemplary code snippet further illustrates this structure, which could be used to argue for a more constrained interpretation tied to this specific implementation. (’900 Patent, col. 6:1-22).

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 an infringing manner. (Compl. ¶14).
• Willful Infringement: The complaint bases its willfulness allegation on post-suit knowledge. It asserts that "service of this Complaint...constitutes actual knowledge of infringement" and that Defendant continued to infringe "[d]espite such actual knowledge." (Compl. ¶13-14).

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

• A primary issue will be procedural sufficiency: given the complaint's failure to identify any specific accused products or asserted claims, a key initial question is whether the allegations are sufficient to survive a motion to dismiss for failure to state a plausible claim for relief under the pleading standards established by Twombly and Iqbal.
• A central question will be one of claim scope: the viability of the infringement case will likely depend on the construction of "semantic web services." Can this term be interpreted broadly to cover interactions with internal device functions and applications, or is it limited to external, third-party web APIs as exemplified in parts of the specification?
• A key evidentiary question will be one of technical operation: does the accused software, once identified, actually perform the claimed step of parsing a user request to identify the distinct triplet of a "domain," a "task," and a "parameter"? This will require a deep dive into the accused system's natural language processing and intent-recognition architecture.