DCT

4:22-cv-00356

R2 Solutions LLC v. Hilton Intl Holding LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:22-cv-00356, E.D. Tex., 04/28/2022
  • Venue Allegations: Plaintiff alleges venue is proper based on Defendants having regular and established places of business in the district, including numerous hotels and a corporate office, and committing acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s online booking platform and underlying data analytics systems infringe four patents, originally filed by Yahoo! Inc., related to distributed data processing and advanced search engine technologies.
  • Technical Context: The technologies at issue concern methods for processing large, heterogeneous datasets and for improving the relevance and functionality of web search results by understanding user intent and query structure.
  • Key Procedural History: The complaint alleges that Plaintiff engaged in licensing discussions with Defendant for nearly a year prior to filing suit, including multiple letters and emails that identified the patent portfolio. The complaint also notes that Plaintiff has previously licensed or resolved litigation involving the patents-in-suit with other technology and travel companies.

Case Timeline

Date Event
2006-08-10 Earliest Priority Date for ’317 Patent
2006-10-05 Priority Date for ’610 Patent
2007-01-10 Priority Date for ’329 Patent
2009-07-31 Priority Date for ’157 Patent
2010-04-13 ’329 Patent Issued
2012-05-29 ’610 Patent Issued
2012-06-26 ’317 Patent Issued
2012-12-25 ’157 Patent Issued
2021-06-17 Plaintiff sends first letter to Defendant re: licensing
2021-10-15 Plaintiff sends second letter to Defendant re: licensing
2021-11-23 Plaintiff sends third letter and email to Defendant
2022-04-28 Complaint Filed

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

U.S. Patent No. 8,190,610 - "MapReduce for Distributed Database Processing," issued May 29, 2012

The Invention Explained

  • Problem Addressed: The patent asserts that conventional MapReduce implementations lack the facility to efficiently process data from heterogeneous sources, such as joining two relational database tables that have different schemas (Compl. ¶23; ’610 Patent, col. 3:15-20).
  • The Patented Solution: The invention introduces an architecture where input data is organized into "data groups." This allows map and reduce functions to be applied to data from different sources (e.g., different tables) that share a common key. The system can then process the intermediate results from these disparate sources within a single reduce function by applying a different iterator for each data group, enabling an efficient merge or join operation that was not possible with conventional MapReduce. (Compl. ¶¶24, 26; ’610 Patent, col. 8:47-58).
  • Technical Importance: This approach extends the capabilities of large-scale parallel processing frameworks beyond uniform data tasks to include more complex, database-style operations on diverse datasets (Compl. ¶26).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶55).
  • Essential elements of claim 1 include:
    • A method of processing data from a data set comprising a "plurality of data groups."
    • Providing data partitions from each group to mapping functions to form "intermediate data for that data group and identifiable to that data group."
    • The data from a first group has a "different schema" and is "mapped differently" than the data of a second group, but they share a "key in common."
    • Reducing the intermediate data by "processing the intermediate data for each data group in a manner that is defined to correspond to that data group," resulting in a merging of the data based on the common key.
  • The complaint reserves the right to assert claims 2-5 and 17-21, which include dependent claims (Compl. ¶55).

U.S. Patent No. 8,341,157 - "System and Method for Intent-Driven Search Result Presentation," issued December 25, 2012

The Invention Explained

  • Problem Addressed: Traditional search engines often treat a user's query as a simple "bag of words," which can produce results that are technically matching but do not align with the user's underlying purpose or "intent" (Compl. ¶29; ’157 Patent, col. 4:1-5).
  • The Patented Solution: The patented method analyzes a query to determine a "plurality of intents" (e.g., research, purchase, support) and classifies the query into one of them. This determined intent is then used to customize the search results, for example by ranking results relevant to the intent more highly or by constructing a "customized... display entry" for a result that is specifically tailored to that intent (Compl. ¶¶29-31; ’157 Patent, col. 4:16-26).
  • Technical Importance: The technology aims to improve search result quality by moving beyond simple keyword matching to a more semantic analysis of user goals, making search results more relevant and useful (Compl. ¶30).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶63).
  • Essential elements of claim 1 include:
    • Receiving a query and identifying a "query keyword."
    • Determining a "plurality of intents" from the keyword, where each intent indicates a type of information likely desired by the user.
    • "Classifying the query" into at least one of the intents.
    • Identifying data objects that match the keyword.
    • "Assigning" at least one intent to some of the data objects.
    • Ranking the data objects and building a result where "at least one display entry customized to a respective assigned intent is constructed."
  • The complaint reserves the right to assert claims 2-5 and 7-10, which include dependent claims (Compl. ¶63).

U.S. Patent No. 7,698,329 - "Method for Improving Quality of Search Results by Avoiding Indexing Sections of Pages," issued April 13, 2010

Technology Synopsis

The patent addresses the problem of "search engine spamming," where web developers hide content that might lower their page's ranking (e.g., advertisements, low-quality links) in sections that search engines are instructed not to index for recall purposes (Compl. ¶35; ’329 Patent, col. 2:6-17). The invention proposes a method where documents contain sections that are not used for recall, but the content of those "no-recall" sections is still used, at least in part, for ranking the document, thereby preventing the hiding of ranking-diminishing content (Compl. ¶37; ’329 Patent, col. 3:7-27).

Asserted Claims

Independent claim 1 is asserted (Compl. ¶76).

Accused Features

The "Accused Hilton Search Systems" are alleged to practice the method by ranking documents based, at least in part, on sections of those documents that are not used for recall (Compl. ¶¶75-76).

U.S. Patent No. 8,209,317 - "Method and Apparatus for Reconstructing a Search Query," issued June 26, 2012

Technology Synopsis

The patent addresses challenges with rigid search interfaces, particularly on mobile devices where typing full queries is difficult (Compl. ¶40; ’317 Patent, col. 1:44-53). The invention describes a system that receives a "partial query" (e.g., an abbreviation or incomplete phrase) from a user and, in response, determines a "full query" based on both the partial query itself and "information stored in the database about queries previously-submitted by users" (Compl. ¶41; ’317 Patent, col. 2:1-5).

Asserted Claims

Independent claim 1 is asserted (Compl. ¶89).

Accused Features

The "Accused Hilton Search Systems" are alleged to infringe by receiving partial queries from users and determining a full search query based on that input and stored user query data (Compl. ¶¶41, 89).

III. The Accused Instrumentality

Product Identification

The complaint identifies two categories of accused instrumentalities, collectively referred to as the "Hilton Systems" (Compl. ¶10):

  1. The "Accused Hilton Data Analytics Systems," which are allegedly built on technologies including Apache Hadoop, Hive, and Spark. These systems are accused of infringing the ’610 patent (Compl. ¶10).
  2. The "Accused Hilton Search Systems," which comprise the search and booking functionalities on the Hilton.com web platform and associated mobile applications. These systems are accused of infringing the ’157, ’329, and ’317 patents (Compl. ¶10).

Functionality and Market Context

The complaint alleges these systems provide the core functionality for Hilton's online travel booking platform, which serves as the reservation engine for over 6,800 properties globally (Compl. ¶6). The Search Systems include a user-facing interface that prompts users to input search terms, such as location. The complaint includes a screenshot of the Hilton.com homepage showing a search input field labeled "Where to?", which serves as the entry point for a user query (Compl. ¶69, p. 24). The Data Analytics Systems are alleged to perform backend data processing (Compl. ¶10).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theories (Compl. ¶¶56, 64, 77, 90). The analysis below is based on the narrative allegations in the complaint.

’610 Patent Infringement Allegations (Prose Summary)

The complaint alleges that Hilton's Data Analytics Systems, which are built on distributed computing frameworks like Hadoop and Spark, infringe the ’610 patent (Compl. ¶¶10, 55). The infringement theory appears to be that Hilton processes diverse and heterogeneous data sources (e.g., different types of customer, reservation, or hotel data with varying schemas) using a MapReduce-style architecture (Compl. ¶23). To meet the claim limitations, the Plaintiff would need to show that Hilton’s system organizes these different data types into "data groups," applies distinct mapping processes to each, and then merges the intermediate results based on a common key in a manner corresponding to the specific group, as recited in claim 1 (Compl. ¶25).

  • Identified Points of Contention:
    • Technical Question: A central evidentiary question will be whether Hilton's use of standard open-source platforms like Hadoop constitutes an implementation of the specific "data group" and multi-iterator architecture claimed in the patent, or if it is a conventional application of those tools that does not meet the claim limitations.
    • Scope Question: The analysis may turn on whether Hilton's data processing involves merging data with formally "different schema" that share a "key in common," as required by the claim, and whether its architecture performs processing "in a manner that is defined to correspond to that data group."

’157 Patent Infringement Allegations (Prose Summary)

The complaint alleges that Hilton's Search Systems, used for booking hotels on its website and mobile app, infringe the ’157 patent (Compl. ¶¶10, 63). The theory is that when a user enters a query (e.g., "Hilton Dallas"), the system determines the user's likely "intent" (e.g., to find a hotel, check rates, view amenities) and uses this intent to rank results and customize the display entry for each hotel shown (Compl. ¶¶29, 32). The complaint provides a screenshot of the Hilton.com search interface as evidence of the system receiving a user query (Compl. ¶69, p. 24).

  • Identified Points of Contention:
    • Technical Question: A key factual dispute may be whether the accused search system actually performs the discrete steps of determining a "plurality of intents," classifying the query into one, assigning that intent to a data object, and then constructing a "customized" display entry based on the assigned intent.
    • Scope Question: The case may raise the question of whether standard relevancy ranking and result formatting in a modern search engine meet the specific, multi-step "intent-driven" process recited in claim 1, or if the claim requires a more specific, formally-defined intent classification architecture.

V. Key Claim Terms for Construction

  • For the ’610 Patent:

    • The Term: "data group"
    • Context and Importance: This term is the central organizing principle of the asserted independent claim and appears to be the primary point of novelty over conventional MapReduce. The definition of this term will likely determine whether Hilton's alleged use of distributed processing frameworks falls within the scope of the claim. Practitioners may focus on this term because the entire infringement case for this patent rests on mapping Hilton’s system architecture to this claimed concept (Compl. ¶¶23, 26).
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes this as a general "mechanism to associate (group) identifiers with data sets, map functions and iterators," which could be argued to cover any logical data partitioning in a distributed system (’610 Patent, col. 3:58-61).
      • Evidence for a Narrower Interpretation: The problem statement and embodiments repeatedly tie the concept to processing "heterogeneous" data, specifically "relational tables that have different schemas." This may support a narrower construction requiring the joining of formally structured data with explicitly different schemas, not just any two different types of data (’610 Patent, col. 3:15-20, col. 8:47-52).

  • For the ’157 Patent:

    • The Term: "at least one display entry customized to a respective assigned intent is constructed"
    • Context and Importance: This term is critical because it defines the final output of the claimed method. Infringement requires not just ranking by intent, but actively constructing a customized result based on a specifically "assigned intent." The case may turn on whether Hilton's presentation of search results meets this specific functional requirement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification provides a list of potential customizations, including a "customized title or abstract for the result or specialized parameters of a displayed clickable URL." This broad language could support an interpretation where any modification to a standard search result snippet qualifies as "customized" (’157 Patent, col. 4:21-26).
      • Evidence for a Narrower Interpretation: The claim requires the customization to be tied to a "respective assigned intent." A defendant may argue this requires a direct causal link where a specific, pre-defined "intent" (like "purchase") triggers a specific, pre-programmed customization rule, a higher bar than simply generating a relevant search result summary.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement for the ’157, ’329, and ’317 patents (Compl. ¶¶66, 79, 92). The factual basis alleged is that Hilton instructs and encourages its customers and end users to infringe by providing its website and mobile app, which feature a search interface prompting users to perform searches in a manner that allegedly practices the patented methods (Compl. ¶¶69, 82, 95).

Willful Infringement

The complaint alleges that Hilton had pre-suit knowledge of the patents-in-suit, which may support a claim for willfulness. This allegation is based on a series of letters and emails sent by Plaintiff to Hilton's Executive Vice President and General Counsel, beginning on June 17, 2021 (Compl. ¶¶44-45). These communications allegedly identified the patent portfolio and informed Hilton of prior lawsuits involving the patents against other companies, including Workday, Expedia Group, and Samsung (Compl. ¶¶67, 80, 93).

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

  • A core issue will be one of architectural equivalence: For the ’610 patent, what evidence will show that Hilton's data analytics systems, which are based on standard open-source software, implement the specific "data group" and multi-iterator processing architecture required by the claims, rather than a conventional distributed computing configuration?
  • A second key issue will be one of functional specificity: For the search-related patents (’157, ’329, and ’317), does the Hilton search platform perform the discrete, multi-step logical processes recited in the claims—such as formally classifying user "intent" and using it to construct customized results—or does it achieve a similar outcome using conventional search, ranking, and auto-complete functions that fall outside the patent's specific claim language?
  • Finally, a central legal question will concern willfulness: Given the detailed allegations of pre-suit notice, including references to prior litigation, did Hilton's continued operation of the accused systems constitute objective recklessness sufficient to support a finding of willful infringement and potential enhanced damages?