DCT

2:25-cv-01200

GeoSymm Ventures LLC v. Osp Labs Pvt Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01200, E.D. Tex., 12/09/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because the defendant is a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to digital assistive agent technology.
  • Technical Context: The technology concerns systems, like virtual assistants, that interpret a user's natural language request and interface with various web services to provide an automated response.
  • Key Procedural History: The complaint does not reference any prior litigation, administrative proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2013-03-15 U.S. Patent No. 9,130,900 Priority Date
2015-09-08 U.S. Patent No. 9,130,900 Issues
2025-12-09 Complaint Filed

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

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

  • Patent Identification: U.S. Patent No. 9,130,900 (“Assistive agent”), issued September 8, 2015 (the “'900 Patent”).

The Invention Explained

  • Problem Addressed: The patent describes conventional personal information managers (PIMs) as failing to "take full advantage of the information available to them to further enhance productivity" (’900 Patent, col. 1:21-30). For example, a user creating a calendar appointment must manually determine the appropriate lead time for a reminder, a task the system could potentially automate (’900 Patent, col. 1:23-28).
  • The Patented Solution: The invention is a system for providing automated assistance that receives a user request, determines its "semantics" by identifying a domain, task, and parameters, and then accesses one or more "semantic web services" through an Application Program Interface (API) to formulate a response (’900 Patent, Abstract). The system acts as an intelligent intermediary that translates a user's intent into actions performed by various backend services, as illustrated in the process flow of Figure 2 (’900 Patent, Fig. 2).
  • Technical Importance: The technology aims to advance the capabilities of virtual personal assistants beyond basic information management by enabling more sophisticated interpretation of user intent and seamless integration of disparate web services (’900 Patent, col. 1:47-54).

Key Claims at a Glance

The complaint does not identify any specific asserted claims in its main body, instead referring to "Exemplary '900 Patent Claims" detailed in an "Exhibit 2" that was not filed with the complaint (Compl. ¶11, 16). For illustrative purposes, the elements of independent claim 1 include:

  • Receiving a user request for assistance from a mobile device.
  • Determining semantics of the user request by identifying at least one domain, task, and parameter, which involves parsing the request to identify meaning along with user information captured by the mobile device (e.g., location, telephone, texting, and user activity).
  • Accessing one or more semantic web services through an API to retrieve matching data.
  • Identifying, generating, or providing personalized recommendations.
  • Presenting possible responses to the user by interacting with the semantic web services.
  • Determining a responsive answer and responding to the user.

III. The Accused Instrumentality

Product Identification

  • The complaint does not name any specific accused products (Compl. ¶11). It refers to them generally as the "Exemplary Defendant Products" throughout the pleading (Compl. ¶11, 12, 14, 16).

Functionality and Market Context

  • The complaint does not describe the specific functionality of the accused products. It alleges that the products "practice the technology claimed by the '900 Patent" and incorporates by reference the infringement allegations and comparisons from the unattached Exhibit 2 (Compl. ¶16-17). No allegations regarding the products' market positioning or commercial importance are provided.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are made by incorporating by reference "charts comparing the Exemplary '900 Patent Claims to the Exemplary Defendant Products" contained in Exhibit 2 (Compl. ¶16). As Exhibit 2 was not filed with the complaint, a claim chart summary cannot be constructed. The complaint’s narrative theory of infringement asserts that the "Exemplary Defendant Products" practice the claimed technology and "satisfy all elements of the Exemplary '900 Patent Claims" (Compl. ¶16).

No probative visual evidence provided in complaint.

  • Identified Points of Contention: Based on the patent language and the general nature of the allegations, the infringement analysis raises several potential questions.
    • Scope Questions: A central question may be whether the accused products' method for interpreting user commands constitutes "determining semantics" as claimed, which the patent specification links to a specific process of identifying a "domain," "task," and "parameter" (’900 Patent, col. 5:54-62). Another question is whether the third-party services accessed by the accused products qualify as "semantic web services" under the patent's definition.
    • Technical Questions: The complaint does not provide evidence regarding the internal architecture of the accused products. A key technical question will be what evidence demonstrates that the accused products use an "application program interface (API)" to "retrieve data" from external services in the manner required by the claims, as opposed to other methods of data exchange.

V. Key Claim Terms for Construction

The complaint does not identify specific claims or terms for construction. However, based on an analysis of representative independent claim 1 of the ’900 Patent, the following terms may be central to the dispute.

  • The Term: "determining semantics of the user request"

  • Context and Importance: This term is at the core of the invention, defining how the system understands a user's intent. Its construction will likely determine whether a wide range of digital assistants fall within the claim scope or if the scope is limited to assistants using a particular interpretive model.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The plain language of the term could be argued to cover any process that derives meaning from a user's input.
    • Evidence for a Narrower Interpretation: The specification repeatedly links this process to a specific three-part structure: "identify at least one domain, at least one task, and at least one parameter for the user request" (’900 Patent, Abstract; col. 5:58-62). The detailed description of the process in Figure 2 reinforces this structured approach (’900 Patent, Fig. 2, element 206).

  • The Term: "semantic web services"

  • Context and Importance: The definition of this term dictates what kind of backend services are covered by the claims. A narrow definition could exclude products that interact with generic web APIs, while a broad one could cover a vast range of modern internet-connected services.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification provides general examples of third-party services like "Facebook, Amazon, Yahoo, eBay, and the like sources" (’900 Patent, col. 4:31-34), which could support an interpretation covering any service that provides structured data via an API.
    • Evidence for a Narrower Interpretation: The specification explicitly mentions technologies like Resource Description Framework (RDF) and "web ontology language" in the context of semantic web services, suggesting the term may be limited to services that employ these specific semantic web standards (’900 Patent, col. 13:19-24).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, asserting that since being served with the complaint, the Defendant knowingly and intentionally induces infringement by selling the accused products and distributing "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶14-15).
  • Willful Infringement: The complaint does not contain an explicit count for willful infringement. However, it alleges that the "service of this Complaint... constitutes actual knowledge of infringement" and that Defendant continues to infringe despite this knowledge (Compl. ¶13-14). This allegation may form the basis for a claim of post-filing willfulness and enhanced damages.

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

  • A threshold procedural issue will be one of pleading sufficiency: does the complaint, which identifies neither the accused products nor the asserted claims and bases its infringement theory entirely on an unattached exhibit, provide sufficient factual detail to state a plausible claim for relief under the Iqbal/Twombly standard?
  • A central substantive issue will be one of definitional scope: how will the court construe the key terms "determining semantics" and "semantic web services"? The outcome of this construction will likely define the boundary between the specific technical solution described in the ’900 Patent and the broader field of general-purpose digital assistants.
  • A key evidentiary question will be one of architectural proof: assuming the complaint survives, what evidence can be produced from the accused product's internal architecture and source code to demonstrate that it performs the specific multi-step process of parsing user intent and interacting with external services through APIs as recited in the asserted claims?