DCT

4:22-cv-00920

Locket IP LLC v. Fortiline LLC

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: [Locket IP LLC](https://ai-lab.exparte.com/party/locket-ip-llc) v. [Fortiline LLC](https://ai-lab.exparte.com/party/fortiline-llc), 4:22-cv-00920, E.D. Tex., 10/27/2022
  • Venue Allegations: Venue is alleged to be proper based on Defendant having a regular and established place of business within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s website infringes two patents related to user interface methods for automatically locating and displaying personalized "regions of interest" within multiple on-screen "cards."
  • Technical Context: The patents address user interface technology for managing and presenting information from multiple sources, aiming to improve user efficiency on devices with limited display area.
  • Key Procedural History: U.S. Patent No. 10,514,832 is a continuation of the application that issued as U.S. Patent No. 9,990,112 and is subject to a terminal disclaimer. This indicates the two patents are not considered patentably distinct, and an adverse judgment on the claims of one could affect the enforceability of the other.

Case Timeline

Date Event
2010-12-22 Priority Date for ’112 and ’832 Patents
2018-06-05 U.S. Patent No. 9,990,112 Issues
2019-12-24 U.S. Patent No. 10,514,832 Issues
2022-10-27 Complaint Filing Date

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

U.S. Patent No. 9,990,112 - "Method and Apparatus for Locating Regions of Interest in a User Interface"

  • Patent Identification: U.S. Patent No. 9,990,112, "Method and Apparatus for Locating Regions of Interest in a User Interface," issued June 5, 2018.

The Invention Explained

  • Problem Addressed: The patent's background describes the task of manually scrolling through multiple on-screen windows or "cards" to find specific topics of interest as "cumbersome," particularly when a display interface can only accommodate a few cards at a time (’112 Patent, col. 1:29-37).
  • The Patented Solution: The invention proposes a method to automatically locate and display "regions of interest" across multiple cards with minimal user input (’112 Patent, col. 1:18-23). In response to a user command, the system identifies relevant sections within various cards based on user preferences and then rearranges the cards on the display to make those specific regions of interest visible, potentially removing irrelevant cards entirely (’112 Patent, col. 1:40-47; FIG. 17).
  • Technical Importance: The technology aims to improve the efficiency of user interaction with information-dense graphical interfaces, such as media guides or content libraries, on devices with limited screen real estate (’112 Patent, col. 1:33-37).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶16).
  • Claim 1 recites a method with three primary steps:
    • "generating a plurality of cards for display;"
    • "in response to a user command, determining regions of interest within each of the plurality of cards by searching information indicating previous user preferences;"
    • "updating for display the plurality of cards" by "repositioning" them to show the regions of interest for a "first group" of cards and "remove cards not included in the first group from the display area."

U.S. Patent No. 10,514,832 - "Method for Locating Regions of Interest in a User Interface"

  • Patent Identification: U.S. Patent No. 10,514,832, "Method for Locating Regions of Interest in a User Interface," issued December 24, 2019.

The Invention Explained

  • Problem Addressed: As a continuation of the '112 Patent, the '832 Patent addresses the same problem of users having to manually and inefficiently scroll through multiple on-screen windows to find desired information (’832 Patent, col. 1:29-37).
  • The Patented Solution: The '832 Patent describes the same solution: a system that automatically identifies and displays "regions of interest" across multiple cards based on a user's preferences and a single command, rearranging the interface to highlight this relevant content (’832 Patent, col. 1:40-47; FIG. 13-14).
  • Technical Importance: The technical goal is identical to that of the '112 Patent—to streamline navigation of crowded user interfaces (’832 Patent, col. 1:33-37).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶25).
  • Claim 1 recites a method with two primary steps:
    • "determining, in response to a user command, regions of interest within each of a plurality of cards by searching information indicating previous user preferences;"
    • "updating for display the plurality of cards" by "repositioning" them to show the regions of interest for a "first group" of cards and "remove cards not included in the first group."
  • This claim is substantively similar to claim 1 of the ’112 Patent but omits the initial step of "generating a plurality of cards for display."

III. The Accused Instrumentality

Product Identification

The Fortiline Website, available at https://www.fortiline.com (Compl. ¶9).

Functionality and Market Context

The complaint alleges that the Accused Instrumentality "provides the user the ability to search for a store in any desired location" (Compl. ¶10). The complaint does not provide further technical details regarding the website's functionality or its market context.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits B and D) that were not provided with the filed complaint document (Compl. ¶17, ¶26). Therefore, the specific allegations mapping claim elements to accused functionality cannot be charted here. The infringement theory is supported only by conclusory narrative statements, such as the allegation that "the Accused Instrumentality satisfies all elements of claim 1 of the '112 Patent" (Compl. ¶17).

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions: The patent specifications for both the ’112 and ’832 Patents provide embodiments focused on user interfaces for navigating media content like television shows and movies, where "cards" are distinct graphical containers for programs (’832 Patent, FIG. 5-6). A central question may be whether the term "plurality of cards" can be construed to read on the search results of a website's store locator, which may be presented as a simple textual list rather than as discrete, manipulable graphical objects.
  • Technical Questions: A key element of the asserted claims is "searching information indicating previous user preferences" to determine "regions of interest." The complaint does not allege any facts about how the accused store locator performs this function. A factual dispute may arise over whether the accused website contains any personalization feature that tracks user preferences and, if so, whether that feature operates to dynamically identify and rearrange content in the manner required by the claims. The functionality of "repositioning" and "remov[ing]" cards to display regions of interest from a "first group" suggests a specific, dynamic UI behavior that will require evidentiary support to map onto the accused website's operation.

V. Key Claim Terms for Construction

"a plurality of cards"

  • Context and Importance: This term's construction is fundamental to the infringement analysis. Practitioners may focus on this term because its interpretation will determine whether the patents, whose embodiments describe graphical media guides, can apply to the store locator search results on the accused website.
  • Intrinsic Evidence for a Broader Interpretation: The term is not explicitly defined in the patents, and the specification occasionally uses it interchangeably with "windows/cards," which could support a broader reading to cover various types of discrete UI containers (’832 Patent, col. 1:21, 1:44).
  • Intrinsic evidence for a Narrower Interpretation: The exemplary embodiments consistently depict "cards" as graphical elements representing specific media content, such as a movie or TV show, complete with associated images and metadata (’832 Patent, FIG. 5-6). This consistent usage may be used to argue for a narrower construction limited to such structured graphical objects.

"regions of interest"

  • Context and Importance: This term defines the content that the patented method is designed to find and display. The viability of the infringement claim depends on whether any aspect of a store location search result can be defined as a "region of interest" based on user preferences.
  • Intrinsic Evidence for a Broader Interpretation: The specification states that regions of interest can be determined from general "user preference information," including implicitly from a user's prior activity, such as which media is accessed more frequently (’832 Patent, col. 10:11-24).
  • Intrinsic Evidence for a Narrower Interpretation: The patents provide specific examples of what might constitute an interest, such as "actors, television shows, directors, sports teams, music, and the like" (’832 Patent, col. 9:22-26). The figures also depict a "region of interest" as a specific, bounded area within a larger card, suggesting it is a sub-part of the card's content, not the entire card itself (’832 Patent, FIG. 13, items 1325, 1335, 1345).

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement.

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

  • A core issue will be one of definitional scope: can the term "plurality of cards", rooted in the patents’ context of graphical media guides, be construed to cover the textual list of locations generated by the accused website’s store locator function?
  • A key evidentiary question will be one of a technical and factual match: does the accused store locator actually perform the claimed steps of "searching information indicating previous user preferences" to identify and then dynamically "repositioning" content to display "regions of interest"? The complaint provides no factual allegations to support that this personalization and UI manipulation functionality exists in the accused website.