DCT
2:25-cv-01207
Global Connect Technology Inc v. Anker Innovations Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Global Connect Technology, Inc. (Massachusetts)
- Defendant: Anker Innovations Ltd. (Hong Kong, S.A.R.)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:25-cv-01207, E.D. Tex., 12/11/2025
- Venue Allegations: Plaintiff asserts venue is proper in the Eastern District of Texas under the "alien venue rule," alleging that Defendant is a foreign entity that maintains a regular and established business presence in the United States.
- Core Dispute: Plaintiff alleges that Defendant’s online shopping system infringes a patent related to computer database systems that permit the storage, retrieval, and manipulation of data from multiple hierarchical "points of view."
- Technical Context: The technology addresses methods for organizing and analyzing large datasets by allowing users to define flexible, context-dependent hierarchical views, a concept relevant to e-commerce, data mining, and information retrieval systems.
- Key Procedural History: The complaint characterizes the patent-in-suit as "pioneering," noting it has been cited as relevant prior art in 280 subsequent U.S. patent applications. It also notes the patent’s expiration date is no earlier than September 22, 2027, and asserts its enforceability for past damages post-expiration.
Case Timeline
| Date | Event |
|---|---|
| 2002-06-12 | U.S. Patent No. 7,246,128 Priority Date |
| 2007-07-17 | U.S. Patent No. 7,246,128 Issue Date |
| 2025-12-11 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,246,128 - "DATA STORAGE, RETRIEVAL, MANIPULATION AND DISPLAY TOOLS ENABLING MULTIPLE HIERARCHICAL POINTS OF VIEW"
The Invention Explained
- Problem Addressed: The patent’s background section describes the problem that while computer networks provide unprecedented access to data, the sheer proliferation of that data can obscure connections and make it difficult to use effectively. Conventional database "views" are often rigid and do not adequately handle scenarios where the same data has different meanings in different contexts, forcing users to build separate, redundant databases for different analytical tasks (Compl. ¶¶13-14; ’128 Patent, col. 1:21-30, col. 2:1-14).
- The Patented Solution: The invention proposes a system that allows a user to establish a "point of view" (iPOV), often represented as a hierarchy, to store, retrieve, and display data according to that specific viewpoint. The system is designed to allow users to create, modify, and use multiple hierarchies interchangeably, regardless of the underlying data structure, thereby enabling more flexible and context-sensitive data manipulation (Compl. ¶¶11, 15; ’128 Patent, col. 2:15-28). The patent describes hierarchical maps as a primary "metaphor" for organizing and displaying these relationships (Compl. ¶17; ’128 Patent, col. 3:9-14).
- Technical Importance: This approach aimed to provide a unified system for context-dependent data analysis, allowing for greater flexibility than conventional database views without requiring the creation of distinct, overlapping databases (Compl. ¶16; ’128 Patent, col. 2:11-14).
Key Claims at a Glance
- The complaint asserts independent claim 21 (Compl. ¶25, ¶28).
- The essential elements of independent claim 21 are:
- A host processor;
- A user interface controlled by the host processor for inputting points of view to the system;
- A connections generator controlled by the host processor to receive the points of view and generate connections between elements in the points of view and metadata of data sources;
- A connections database operated on by the connections generator and having a data structure including degrees of matching between data elements in the connections database and the metadata; and
- Matching applications controlled by the host processor to determine and display sets of data elements from the data sources that have at least pre-selected degrees of matching with the elements in the points of view.
- The complaint reserves the right to assert additional claims (Compl. ¶25).
III. The Accused Instrumentality
Product Identification
The "Accused Instrumentalities" are identified as "Anker's online shopping system," which includes its website (https://www.anker.com/), its mobile application, and the associated backend servers, software, and network infrastructure (Compl. ¶24).
Functionality and Market Context
The complaint alleges that the accused system provides a "system for enabling multiple hierarchical points of view" (Compl. ¶24). The functionality at issue appears to be the product filtering interface available on Anker's e-commerce platforms. A screenshot provided in the complaint shows a product collection page with a filtering sidebar that allows users to select criteria such as "Price," "Offers," "Device Compatibility," and "Capacity" to refine the displayed product listings (Compl. p. 8). The complaint does not provide specific details on the commercial importance or market positioning of the accused system beyond general allegations of substantial business and revenues derived from its use in Texas and the U.S. (Compl. ¶¶5-6).
IV. Analysis of Infringement Allegations
’128 Patent Infringement Allegations
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A host processor; | Anker's backend servers and network infrastructure that host and operate its website and mobile application. | ¶24 | col. 38:2-3 |
| a user interface controlled by the host processor for inputting points of view to the system; | The product filtering sidebar on the Anker website and mobile app, which allows users to select categories to define how they view the product data. The complaint provides a screenshot of this interface. | ¶24, p. 8 | col. 38:4-5 |
| a connections generator...to receive the points of view and generate connections between elements in the points of view and metadata of data sources; | Backend software that receives a user's filter selections (the "points of view") and generates connections to corresponding metadata in Anker's product database. | ¶24 | col. 38:6-9 |
| a connections database...having a data structure including degrees of matching...; | Anker's backend product database that is operated on by the backend software and contains product metadata used for matching against user filter selections. | ¶24 | col. 38:10-14 |
| matching applications...to determine sets of data elements...having at least pre-selected degrees of matching...the user interface displaying the data elements...; | Backend software that executes the filtering logic based on user selections to determine the set of matching products, which are then displayed to the user on the website or app. | ¶24, p. 8 | col. 38:15-21 |
Identified Points of Contention
- Scope Questions: A central question may be whether selecting from a predefined list of filters on a standard e-commerce website constitutes "inputting points of view" as that term is used in the patent. The defense may argue that the patent contemplates a more dynamic system where users can create, define, and modify the hierarchies themselves, rather than merely selecting from a fixed set of options.
- Technical Questions: The complaint's allegations regarding the backend architecture (e.g., a "connections generator," "connections database," "matching applications") are described at a high level. A point of contention may be whether the accused Anker system actually contains these specific, discrete components as claimed, or whether it employs a more monolithic architecture where these functions are not separately identifiable. The complaint does not provide evidence to distinguish Anker's backend from a standard web application server connected to a product database.
V. Key Claim Terms for Construction
Term: "points of view"
- Context and Importance: This term is the central concept of the asserted claim. The outcome of the case may depend on whether the act of selecting from a predefined filtering menu on a website falls within the scope of "inputting points of view." Practitioners may focus on this term because its construction will determine whether the patent reads on a wide range of common e-commerce functionalities.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that a "point of view" can be represented by a "hierarchy," and provides a simple "drill down" hierarchy as an example, which could support an argument that any hierarchical filtering mechanism qualifies (Compl. ¶14; ’128 Patent, col. 1:36-40).
- Evidence for a Narrower Interpretation: The specification repeatedly describes a system where users can "establish," "construct," and "modify" hierarchies, and introduces the concept of an "individual point of view (iPOV)" as a complex, user-definable, and shareable data structure. This language may support a narrower construction requiring more user control and creativity than selecting from fixed filters (Compl. ¶15; ’128 Patent, col. 2:20-28, col. 7:42-45).
Term: "connections generator"
- Context and Importance: This term recites a specific structural component of the claimed system. Its construction is important because the defendant may argue that its system architecture does not include a distinct component that meets this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not define the precise software or hardware boundaries of the "connections generator." This may support an argument that any software module that translates user interface input into a query for a backend database performs the function of "generating connections."
- Evidence for a Narrower Interpretation: The patent's system diagrams depict a modular architecture with distinct functional blocks, such as a "Dynamic Query Generator" and "Matching Applications." This could suggest that the claimed "connections generator" is intended to be a specific, discrete software component, not merely an abstract function inherent in any database-driven application (’128 Patent, FIG. 9).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement by Anker's customers who use the accused online shopping system. Knowledge is alleged based on "willful blindness" (Compl. ¶¶33-34).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported "policy or practice against investigating third party patent rights," which the complaint asserts qualifies as "willful blindness" (Compl. ¶32).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the patent's central term "points of view," which the specification describes in the context of user-creatable and modifiable hierarchies (iPOVs), be construed broadly enough to read on a user's selection of predefined filtering options on a conventional e-commerce website?
- A key evidentiary question will be one of architectural mapping: Does the accused system possess the specific, multi-component architecture required by Claim 21—including a distinct "connections generator," a "connections database" with "degrees of matching," and "matching applications"—and what technical evidence will be needed to prove that structure exists beyond the high-level allegations in the complaint?