DCT

4:22-cv-00921

Locket IP LLC v. DriveTime Automotive Group Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:22-cv-00921, 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 and having committed alleged acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s website infringes two patents related to methods for automatically rearranging graphical user interface elements to display regions of interest based on user preferences.
  • Technical Context: The technology addresses the challenge of navigating user interfaces containing multiple "cards" or "windows" of information by automatically highlighting and repositioning content relevant to the user.
  • 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. The '832 patent is also subject to a terminal disclaimer, which may link its enforceability and term to that of the '112 patent. The complaint does not mention any other prior litigation or administrative proceedings involving these patents.

Case Timeline

Date Event
2010-12-22 Earliest Priority Date for '112 & '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 Filed

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"

The Invention Explained

  • Problem Addressed: The patent describes the task of manually scrolling through multiple on-screen windows or "cards" to find specific topics of interest as "cumbersome," particularly when the content in these cards exceeds the visible display area (’112 Patent, col. 1:26-38).
  • The Patented Solution: The invention proposes a method where, in response to a single user command, the system automatically determines "regions of interest" within multiple cards based on user preferences. It then rearranges or repositions the cards on the display to make these specific regions visible, potentially removing cards without such regions, thereby saving the user from having to manipulate each card individually (’112 Patent, Abstract; col. 1:40-47). Figures 13 and 14 illustrate this process, showing cards being vertically shifted to bring specific interest regions (1325, 1335, 1345) into a common display area (1310) (’112 Patent, col. 9:11-51).
  • Technical Importance: The technology aims to improve user experience and efficiency in navigating content-rich interfaces, such as electronic program guides or media libraries, by reducing the required amount of user input (’112 Patent, col. 1:20-25).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶16).
  • Claim 1 of the ’112 Patent recites 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; and
    • updating for display the plurality of cards to visibly show the at least one region of interest, which includes repositioning the cards to remove those not in a "first group" and to visibly display the region of interest within all cards that are in the "first group."

U.S. Patent No. 10,514,832 - "METHOD FOR LOCATING REGIONS OF INTEREST IN A USER INTERFACE"

The Invention Explained

  • Problem Addressed: The patent addresses the same problem as its parent '112 patent: the cumbersome nature of individually manipulating multiple on-screen windows to find specific information (’832 Patent, col. 1:26-38).
  • The Patented Solution: The described solution is functionally identical to that of the ’112 Patent, involving an "interest feature" that automatically rearranges displayed cards to show regions of interest based on user preferences, as illustrated in Figures 13-16 (’832 Patent, Abstract; col. 9:11-51).
  • Technical Importance: As with the parent patent, this technology seeks to streamline user interaction with dense graphical interfaces like media guides (’832 Patent, col. 7:48-51).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (’832 Patent, col. 11:55-68; Compl. ¶25).
  • Claim 1 of the ’832 Patent recites:
    • determining, in response to a user command, regions of interest within each of a plurality of cards by searching information indicating previous user preferences; and
    • updating for display the plurality of cards to visibly show the at least one region of interest, which includes repositioning the cards to remove those not in a "first group" and to visibly display the region of interest within all cards included in that group.
  • Notably, claim 1 of the ’832 Patent does not include the "generating a plurality of cards for display" limitation present in claim 1 of the ’112 Patent, which may suggest a marginally broader scope.

III. The Accused Instrumentality

Product Identification

The DriveTime Website (www.drivetime.com), referred to as the "Accused Instrumentality" (Compl. ¶9).

Functionality and Market Context

The complaint provides minimal description of the accused functionality, stating only that the website "provides the user the ability to search for a store in any desired location" (Compl. ¶10). The complaint makes no further allegations regarding the specific operation of the website's search and display features, nor does it address the website's commercial importance or market position.

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Instrumentality infringes at least claim 1 of the ’112 Patent and at least claim 1 of the ’832 Patent (Compl. ¶16, ¶25). The pleading states that claim charts comparing the asserted claims to the Accused Instrumentality are attached as Exhibits B and D (Compl. ¶17, ¶26). However, these exhibits were not filed with the public version of the complaint. As such, the complaint itself contains no specific factual allegations detailing how any particular feature of the DriveTime website is purported to meet any specific claim limitation. The infringement allegations rest entirely on the incorporation by reference of these unavailable exhibits (Compl. ¶18, ¶27).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Evidentiary Question: Given the absence of factual detail in the complaint, a central question will be what evidence Plaintiff can produce to demonstrate that the Drive-Time website performs the functions required by the claims. For instance, what evidence shows the website "determin[es] regions of interest" by "searching information indicating previous user preferences," as opposed to simply responding to a real-time search query?
    • Technical Question: Does the accused website's functionality for displaying store locations involve "repositioning the plurality of cards to remove cards not included in the first group," as recited in the claims? The court will need to examine the actual mechanism by which search results are displayed, filtered, and sorted on the website.
    • Scope Question: A dispute may arise over whether the patent claims, which are described and illustrated primarily in the context of media program guides (’112 Patent, FIGS. 5, 6, 11), can be read to cover the functionally different context of a vehicle dealership locator.

V. Key Claim Terms for Construction

  • The Term: "cards"

    • Context and Importance: This term is fundamental to the claimed invention, but it is not explicitly defined. The patents’ exemplary embodiments consistently show "cards" as discrete UI elements representing media content like television shows or movies (’832 Patent, FIG. 5, FIG. 6). The infringement allegation against a website store locator raises the question of whether search results or map pins constitute "cards." The construction of this term will be critical to determining if the accused website's architecture falls within the claim scope.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Parties advocating for a broader scope may argue that the term should be given its plain and ordinary meaning, covering any distinct graphical container for information within a user interface.
      • Evidence for a Narrower Interpretation: Parties advocating for a narrower scope may point to the specification's consistent use of "cards" to represent items in a media library or television guide, arguing that the term is implicitly limited to that context (’832 Patent, col. 7:48-65; col. 8:9-29).

  • The Term: "regions of interest"

    • Context and Importance: The determination and display of "regions of interest" is the core technical contribution. The claims require these regions to be determined by "searching information indicating previous user preferences." The viability of the infringement case may depend on whether the accused website is found to identify a sub-portion of a search result based on stored user data, or whether it simply displays full results based on a user's immediate search terms.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A plaintiff may argue that any part of a result brought into view based on a user's search qualifies as a "region of interest," and that the search itself is an indication of a "user preference."
      • Evidence for a Narrower Interpretation: A defendant may argue that the specification ties "regions of interest" to specific user profile data, such as preferred actors, directors, or sports teams, which are used to find matching text or graphics within a card (’832 Patent, col. 9:11-28). This interpretation would require more than just a standard keyword search functionality.

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

  1. An Evidentiary Question of Operation: The case appears to hinge on a fundamental evidentiary question: Can Plaintiff produce evidence to show that the accused DriveTime website actually operates in the manner required by the claims? The complaint's lack of factual detail puts the immediate focus on whether the website's store locator does more than execute a standard search, and instead performs the specific claimed steps of identifying "regions of interest" from "previous user preferences" and dynamically "repositioning" a set of "cards" to display them.

  2. A Definitional Question of Scope: A core legal issue will be whether the claim terms, born from a technical context of media program guides, can be construed to cover the accused store locator. The court's interpretation of foundational terms like "cards" and "regions of interest" will likely determine whether the accused product's technology is capable of falling within the boundaries of the asserted patents.