DCT
2:25-cv-01211
Global Connect Technology Inc v. Sony Electronics Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Global Connect Technology, Inc. (Massachusetts)
- Defendant: Sony Electronics Inc. (Delaware)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:25-cv-01211, E.D. Tex., 12/11/2025
- Venue Allegations: Plaintiff alleges venue is proper based on Defendant maintaining regular and established places of business within the Eastern District of Texas and committing acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s online shopping system infringes a patent related to database systems that permit the storage, retrieval, and manipulation of data according to multiple, distinct hierarchical points of view.
- Technical Context: The technology addresses methods for making large databases more flexible by allowing users to organize and query a single set of data using different contextual frameworks or hierarchies.
- Key Procedural History: The complaint asserts the patent is foundational, having been cited in numerous subsequent patent applications by major technology companies. Plaintiff also notes that while the patent may be expired, it remains enforceable for the purpose of seeking damages for past infringement.
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
- Patent Identification: U.S. Patent No. 7,246,128, issued July 17, 2007 (’128 Patent).
The Invention Explained
- Problem Addressed: The patent’s background section states that the proliferation of data can obscure understanding and make it difficult to use effectively. It notes that conventional database systems often force a rigid structure on data, and while they may offer different "views," these views often act as "censors, blotting out information considered irrelevant" rather than providing different "contexts for acting on the data" (’128 Patent, col. 1:21-30, col. 1:65-67). The same data (e.g., a zip code) can have different meanings or relevance depending on the user's goal (e.g., mailing a letter versus getting driving directions), a challenge not well-handled by conventional systems that often require building distinct databases for different uses (’128 Patent, col. 2:1-14).
- The Patented Solution: The invention is a system that permits a user to establish a "point of view," such as a data hierarchy, and then allows the user to retrieve, manipulate, and display data according to that specific point of view. The system is designed to allow users to create and modify multiple such hierarchies and use them interchangeably, regardless of the underlying structure of the source data (’128 Patent, Abstract; col. 2:15-28). The specification describes this using hierarchical maps as a "metaphor of choice for codifying and displaying the relationships between pieces of information" from a particular point of view (’128 Patent, col. 3:9-14).
- Technical Importance: The technology aimed to provide a more flexible, user-centric approach to data management, allowing a single dataset to be organized and queried in various contextually relevant ways without the need to build and maintain separate, purpose-built databases (Compl. ¶¶16-17).
Key Claims at a Glance
- The complaint asserts independent claim 21 (’128 Patent, col. 38:21-50; Compl. ¶28).
- The essential elements of independent claim 21 are:
- A system 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, where the user interface displays the resulting data elements.
- The complaint reserves the right to assert additional claims (Compl. ¶25).
III. The Accused Instrumentality
Product Identification
The "Accused Instrumentalities" are identified as "Sony's online shopping system," which includes its e-commerce website (electronics.sony.com), its mobile application, and the associated backend servers, software, and network infrastructure (Compl. ¶24).
Functionality and Market Context
The complaint focuses on the product filtering functionality of the Sony e-commerce platform. It alleges this system enables "multiple hierarchical points of view" by allowing users to select from various filtering categories to refine product searches (Compl. ¶24). The complaint provides a screenshot from the Sony website showing a product page for interchangeable-lens cameras, which features a "Refine By" sidebar with filtering options organized into categories such as "Price" (Compl. p. 8). This interface allows a user to select criteria (e.g., a specific price range), which then updates the main display to show only the products matching those selections (Compl. ¶25, p. 8).
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 | Defendant's backend servers, software, and network infrastructure that host and operate the online shopping system. | ¶24 | col. 38:22 |
| a user interface controlled by the host processor for inputting points of view to the system | The website and mobile application interface, specifically the "Refine By" sidebar where users select filtering criteria such as price range. | ¶¶24-25, p. 8 | col. 38:23-25 |
| a connections generator controlled by the host processor...to generate connections between elements in the points of view and metadata of data sources | The backend software that processes a user's filter selections (the "points of view") and connects them to the corresponding metadata in the product database. | ¶24 | col. 38:26-31 |
| a connections database...including degrees of matching between data elements in the connections database and the metadata | The backend database system that stores the relationships between filtering criteria and product metadata. | ¶24 | col. 38:32-37 |
| matching applications...to determine sets of data elements...having at least pre-selected degrees of matching...the user interface displaying the data elements...according to the points of view | The backend software that executes the search based on the selected filters and the user interface that then displays the resulting set of matching products. | ¶¶24-25, p. 8 | col. 38:38-50 |
Identified Points of Contention
- Scope Questions: A central question may be whether selecting a checkbox in a predefined, fixed e-commerce filter list constitutes "inputting points of view" as contemplated by the patent. The defense could argue that the patent's disclosure of creating and modifying complex hierarchies (e.g., ’128 Patent, Figs. 2B, 2C) requires more user agency than is present in the accused system, raising the question of whether the claim term reads on conventional filtering.
- Technical Questions: The complaint does not provide specific evidence that the accused system uses "degrees of matching," a limitation in claim 21. The functionality depicted in the complaint's visual evidence appears to be a binary filter (i.e., a product is either in the selected price range or it is not) (Compl. p. 8). This raises the question of whether Sony's backend database performs a function corresponding to the claimed "degrees of matching," which the patent specification links to concepts like "similarity scores" and "near lists" (’128 Patent, col. 5:46-54).
V. Key Claim Terms for Construction
The Term: "points of view"
- Context and Importance: This is the central concept of the invention. Its construction will likely determine whether the patent's scope can extend from a system for user-defined data mapping to cover conventional, pre-defined e-commerce filtering menus. Practitioners may focus on whether this term requires the user to actively define or modify the structure of the hierarchy itself.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests a "point of view" is a general concept for organizing data, stating that it can be established "such as via a hierarchy," which may imply that a hierarchy is just one example of a "point of view" (’128 Patent, col. 2:17-18).
- Evidence for a Narrower Interpretation: The patent’s detailed description and figures heavily emphasize the user’s role in creating, modifying, and linking hierarchical structures (e.g., ’128 Patent, Figs. 2A-2C, Figs. 4-6). This repeated focus on user-driven structural manipulation could support a narrower construction that requires more than selecting options from a static list.
The Term: "degrees of matching"
- Context and Importance: This term appears in the "connections database" and "matching applications" limitations of claim 21. The infringement analysis may turn on whether the accused system, which appears to perform exact filtering, satisfies this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any match is a "degree" of matching (e.g., 100% or 0%), thereby covering binary, exact-match systems.
- Evidence for a Narrower Interpretation: The specification discusses "confidence levels for non-identical matches," "similarity score[s]," and "near list[s]" of associated terms, suggesting a system capable of fuzzy, partial, or probabilistic matching rather than simple binary filtering (’128 Patent, col. 5:46-54, col. 19:35-37).
VI. Other Allegations
- Indirect Infringement: The complaint alleges Sony induced infringement by its customers and end users by providing and advertising the accused online shopping system, allegedly with the intent to cause infringing acts (Compl. ¶¶33, 36-37).
- Willful Infringement: Willfulness is alleged based on Sony’s purported "policy or practice against investigating third party patent rights," which Plaintiff characterizes as "willful blindness" to its infringement (Compl. ¶32).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "inputting points of view," which the patent illustrates through user construction of complex data hierarchies, be construed broadly enough to cover a customer’s selection of options from a standard, pre-defined e-commerce filtering menu?
- A key evidentiary question will be one of technical functionality: does the accused e-commerce system’s backend, which presumably executes standard database queries, implement the claimed "connections generator" and utilize "degrees of matching" as described in the patent, or is there a fundamental mismatch in technical operation?