DCT

2:25-cv-01209

Global Connect Technology Inc v. Canon Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
    • Plaintiff: Global Connect Technology, Inc. (Massachusetts)
    • Defendant: Canon Inc. (Japan)
    • Plaintiff’s Counsel: Garteiser Honea, PLLC
  • Case Identification: 2:25-cv-01209, E.D. Tex., 12/11/2025
  • Venue Allegations: Plaintiff asserts that venue is proper in the Eastern District of Texas because the defendant is a foreign entity with a regular and established business presence in the United States, invoking the “alien venue rule.”
  • Core Dispute: Plaintiff alleges that Defendant’s online e-commerce system infringes a patent related to database systems that permit data to be stored, retrieved, and manipulated according to multiple, distinct hierarchical points of view.
  • Technical Context: The technology at issue concerns methods for providing flexible, context-aware data filtering and organization, a foundational component of modern e-commerce and information retrieval platforms.
  • Key Procedural History: The complaint characterizes the asserted patent as “pioneering” and alleges it has been cited as relevant prior art in 280 subsequent U.S. patent applications from various technology companies.

Case Timeline

Date Event
2002-06-12 ’128 Patent Priority Date
2007-07-17 ’128 Patent 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 inefficiency of conventional database systems in handling data that has different meanings or relevance depending on the user's context. It notes that traditional database "views" act merely as "censors" that blot out irrelevant information, rather than providing different contexts for acting on the data, forcing users to build distinct databases for different uses of the same data ( ’128 Patent, col. 1:21-2:14).
  • The Patented Solution: The invention provides a system that allows a user to establish multiple "points of view," such as via a hierarchy, and then use those user-defined structures to retrieve, manipulate, and display a given set of data accordingly (’128 Patent, col. 2:15-28). This allows the same underlying data to be organized and presented in different ways, interchangeably, depending on the user's specific informational needs at a given time (’128 Patent, Abstract).
  • Technical Importance: This approach allows for more flexible and dynamic data interaction than conventional, rigid database structures, enabling data presentation that is sensitive to user context and intent (Compl. ¶15).

Key Claims at a Glance

  • The complaint asserts independent claim 21 (’128 Patent, col. 38:21-50; Compl. ¶25).
  • The essential elements of independent claim 21 are:
    • A host processor;
    • A user interface for inputting points of view to the system;
    • A connections generator to generate connections between elements in the points of view and metadata of data sources;
    • A connections database with a data structure including degrees of matching between data elements and metadata; and
    • Matching applications to determine and display data elements that have a pre-selected degree of matching with 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 Canon's online shopping system, including its website (https://www.usa.canon.com), its mobile application, and its backend servers, software, and network infrastructure (Compl. ¶24-25).

Functionality and Market Context

  • The complaint focuses on the functionality of Canon's e-commerce platform that allows users to browse and filter products (Compl. ¶24). The system provides users with multiple filtering categories, such as "Experience Level" and "Configuration," which a user can select to refine the set of displayed products (Compl. p. 8). A screenshot provided in the complaint shows a webpage for "Digital Cameras" where these filtering options are presented in a sidebar next to product listings (Compl. p. 8).
  • The complaint alleges that Canon uses this system to sell "millions of products" (Compl. ¶6).

IV. Analysis of Infringement Allegations

The complaint references an "Exhibit A" that purportedly contains a detailed, element-by-element infringement analysis for claim 21 of the ’128 Patent; however, this exhibit was not attached to the filed complaint (Compl. ¶25). In the absence of a claim chart, the infringement theory must be summarized from the complaint's narrative allegations.

The complaint alleges that Canon's online shopping system practices the system claimed in claim 21 of the ’128 Patent (Compl. ¶28). The narrative theory suggests that Canon's servers function as the claimed "host processor" (Compl. ¶24-25). The website and mobile application's user-selectable filtering options, such as those depicted for "Digital Cameras," are alleged to be the "user interface for inputting points of view" (Compl. p. 8). The complaint further alleges that Canon's backend infrastructure contains the software and databases that perform the functions of the claimed "connections generator," "connections database," and "matching applications," which operate to process a user's filter selections and display a corresponding set of products (Compl. ¶24).

  • Identified Points of Contention:
    • Scope Questions: A central question may be whether a user selecting a filter from a predefined list on an e-commerce website constitutes "inputting points of view" as that term is used in the patent, which describes creating and modifying custom hierarchies.
    • Technical Questions: The infringement allegation relies on assumptions about Canon's backend architecture. A key technical question will be what evidence exists that Canon’s system includes the specifically claimed "connections generator" and a "connections database" with a data structure for "degrees of matching," as opposed to a conventional web server and database query system.

V. Key Claim Terms for Construction

The Term: "point of view"

  • Context and Importance: This term is central to the patent's inventive concept. Its construction will be critical in determining whether the patent's scope covers predefined filtering options on an e-commerce website. Practitioners may focus on this term because the dispute may hinge on whether a "point of view" must be actively constructed by a user, as shown in certain patent figures, or if it can simply be selected from a pre-existing menu.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that a system is needed that "permits a user to establish a point of view, such as via a hierarchy," which may suggest a hierarchy is an example, not a requirement (’128 Patent, col. 2:17-19).
    • Evidence for a Narrower Interpretation: The patent distinguishes the invention from conventional database "views" that merely "act as censors" (’128 Patent, col. 1:64-67). The detailed description and figures like 2B and 2C illustrate user interfaces for actively adding and defining elements within a hierarchy, which may support a narrower construction requiring user creation or modification rather than just selection (’128 Patent, col. 17:1-18:21).

The Term: "connections generator"

  • Context and Importance: This term defines a specific functional component of the claimed system. The infringement analysis will depend on whether Canon's backend architecture includes a component that performs the function of this specific term, or if its system uses a more generic database query engine that falls outside the term's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself defines the term by its function: "to receive the points of view and generate connections between elements in the points of view and metadata of data sources" (’128 Patent, col. 38:31-34). This could be argued to broadly cover any software module that links a user’s filter selection to corresponding product metadata.
    • Evidence for a Narrower Interpretation: The specification describes a complex "Relativity Database Management System" and associated knowledge structures like "eBOKs" that manipulate data (’128 Patent, col. 9:36-52). A defendant may argue that the claimed "connections generator" should be construed as a specific component within this disclosed architecture, not as any generic software that connects a user interface to a database.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Canon induces infringement by advertising its online shopping system and thereby encouraging its customers and end-users to use the allegedly infringing filtering functionalities (Compl. ¶36-37).
  • Willful Infringement: The claim for willful infringement is based on an allegation of willful blindness, asserting that Canon has a "policy or practice against investigating third party patent rights" (Compl. ¶32).

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

  • A core issue will be one of definitional scope: can the term "point of view," which is described in the patent in the context of creating and modifying complex data hierarchies, be construed to cover a user's selection of predefined filter categories on a standard e-commerce website?
  • A key evidentiary question will be one of architectural correspondence: does Canon's backend e-commerce platform contain the specific "connections generator" and "connections database" architecture required by Claim 21, or does it utilize a conventional database and query system that falls outside the claim's technical limitations?