DCT
2:25-cv-01210
Global Connect Technology Inc v. Signify NV
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Global Connect Technology, Inc. (Massachusetts)
- Defendant: Signify N.V. (Japan)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:25-cv-01210, E.D. Tex., 12/11/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because 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 shopping systems, which allow users to filter product searches, infringe a patent related to 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 accessing large datasets, allowing the same underlying data to be structured and viewed in different contexts, a capability relevant to e-commerce, data analysis, and information retrieval systems.
- Key Procedural History: The complaint characterizes the patent-in-suit as a "pioneering patent" that has been cited as relevant prior art in 280 subsequent U.S. patent applications. No prior litigation, licensing, or post-grant proceedings are mentioned.
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"
- Issued: July 17, 2007
The Invention Explained
- Problem Addressed: The patent describes a problem where the proliferation of data, combined with conventional, rigid database structures, makes it difficult for users to make effective use of that data (Compl. ¶13; ’128 Patent, col. 1:21-30). Conventional database "views" often act as "censors," limiting how data can be seen, which forces users to build distinct databases for different uses even when the data content substantially overlaps (’128 Patent, col. 1:55-67, col. 2:8-14).
- The Patented Solution: The invention provides a system that allows a user to establish a "point of view" (iPOV), such as a data hierarchy, and then retrieve, manipulate, and display data according to that specific viewpoint (’128 Patent, col. 2:15-28). This allows multiple, interchangeable hierarchical structures to be applied to the same underlying data, making the system more flexible and context-aware (’128 Patent, col. 2:20-28). Figures 2A-2C, for example, illustrate how a user can define and modify a hierarchy for contact information data (’128 Patent, Figs. 2A-2C).
- Technical Importance: This approach allows data relationships to "show up differently" based on a user's focus, providing enhanced manipulation and analysis capabilities over conventional, static database systems (Compl. ¶15).
Key Claims at a Glance
- The complaint asserts independent claim 21 (’128 Patent, col. 38:21-48; Compl. ¶28).
- The essential elements of independent claim 21 are:
- A system for enabling multiple hierarchical points of view, comprising: 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 and operating on the data sources to determine sets of data elements...having at least pre-selected degrees of matching with the elements in the points of view, the user interface displaying the data elements and degrees of matching...
- Plaintiff reserves the right to assert additional claims and infringement under the doctrine of equivalents (Compl. ¶25).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "Signify's online shopping system," which includes its website (https://www.usa.lighting.philips.com/), its mobile application, and the associated backend servers, software, and network infrastructure (Compl. ¶24).
Functionality and Market Context
The system provides an e-commerce platform for lighting products (Compl. ¶24). The accused functionality is the user interface that allows customers to filter product searches by selecting various attributes, such as "Reflector," "E26," "UltraEfficient," and "EyeComfort" (Compl. ¶24). A screenshot in the complaint shows a user interface for selecting light bulbs where applied filters are displayed, and a list of matching products is returned. (Compl. p. 8). The complaint alleges this system enables users to apply "multiple hierarchical points of view" to find products (Compl. ¶24). The complaint alleges Signify sells millions of products into the stream of commerce via this system (Compl. ¶6).
IV. Analysis of Infringement Allegations
U.S. Patent No. 7,246,128 Infringement Allegations
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a host processor; | Defendant’s backend servers and network infrastructure that host and operate the online shopping system. | ¶24 | col. 32:21-23 |
| a user interface controlled by the host processor for inputting points of view to the system; | The website and mobile application interface that allows users to select product filters, which allegedly constitute "points of view." | ¶24 | col. 16:1-3 |
| a connections generator...to receive the points of view and generate connections between elements in the points of view and metadata of data sources; | The backend software that allegedly processes user-selected filters ("points of view") and connects them to the product database ("data sources"). | ¶24 | col. 32:24-30 |
| a connections database...including degrees of matching between data elements...and the metadata; | The backend database system that allegedly stores the relationships and "degrees of matching" between product metadata and the filter categories. | ¶24 | col. 32:31-37 |
| matching applications...to determine sets of data elements...having at least pre-selected degrees of matching...the user interface displaying the data elements... | The software that executes the filtered search to find matching products and the system component that displays those matching products to the user on the website or mobile app. | ¶24 | col. 32:38-48 |
Identified Points of Contention
- Scope Questions: A central issue may be whether selecting from a predefined list of product attributes in a standard e-commerce filtering interface constitutes "inputting points of view" as that term is used in the patent. The defense may argue that the patent's disclosure, which describes user-driven creation and modification of complex hierarchies, requires a more dynamic and user-configurable system than the accused faceted search functionality.
- Technical Questions: The complaint alleges the existence of a "connections generator" and a "connections database" with "degrees of matching," but provides no specific evidence of the accused system's backend architecture. A key factual question will be whether the accused system's backend performs these functions as claimed, or if it instead utilizes conventional database query logic that may not meet these claim limitations.
V. Key Claim Terms for Construction
Key Term: "points of view"
- Context and Importance: This term is the central concept of the invention. The outcome of the case may depend on whether the accused functionality—selecting from a menu of predefined product filters—falls within the scope of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines a "point of view" as a "HI diagram which expresses itself via groups of hierarchically linked categories" and can "reflect a particular individual's or entity's way of looking at data within a frame of reference" (’128 Patent, col. 7:43-46, col. 12:17-19). Plaintiff may argue that selecting a set of filters is one way for a user to express a "way of looking at data."
- Evidence for a Narrower Interpretation: The patent's detailed examples often show users actively creating, linking, and modifying the structure of hierarchies, such as the contact information example (’128 Patent, col. 17:26-54; Figs. 2B-2C). Defendant may argue this context limits "inputting points of view" to activities more complex than selecting from a static list of filters.
Key Term: "connections generator"
- Context and Importance: This term describes a specific backend component. Infringement will depend on whether the defendant's system contains a component that performs the claimed function. Practitioners may focus on this term because the defendant is likely to contend its system uses standard, off-the-shelf database query tools rather than a specialized component that meets this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim functionally defines the generator as a component that "receive[s] the points of view and generate[s] connections between elements in the points of view and metadata of data sources" (’128 Patent, col. 32:26-28). This functional language could be argued to cover any backend logic that translates user filter selections into a database query.
- Evidence for a Narrower Interpretation: The specification describes the broader system as a "Relativity Database Management System" with complex behaviors analogized to "gravitational forces," which may suggest the "connections generator" is a non-conventional component with capabilities beyond those of a standard query builder (’128 Patent, col. 9:36-51).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, asserting that Signify, through "willful blindness," encourages its customers to use the accused systems in an infringing manner (Compl. ¶¶33-34). It also alleges active steps to induce, such as advertising the infringing use (Compl. ¶36).
- Willful Infringement: Willfulness is alleged based on Signify’s purported "policy or practice against investigating third party patent rights," which the complaint claims constitutes willful blindness (Compl. ¶32).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "points of view," which the patent describes in the context of creating and manipulating complex data hierarchies, be construed broadly enough to read on a user's selection of predefined filters in a conventional e-commerce faceted search system?
- A key evidentiary question will be one of architectural fact: does the accused system's backend contain the specifically claimed "connections generator" and "connections database" that calculate "degrees of matching," or does it operate using standard database query technology that may fall outside the claim's requirements? The complaint’s allegations on this point are not supported by specific factual evidence.