Locket IP LLC v. Winsupply Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Locket IP LLC (Texas)
  • Defendant: WinSupply Inc. (Delaware)
  • Plaintiff’s Counsel: Banie & Ishimoto LLP
• Case Identification: 4:22-cv-01017, E.D. Tex., 11/30/2022
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement and maintains a regular and established place of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s website, which includes a store locator feature, infringes two patents related to methods for displaying and organizing information in a user interface based on user interest.
• Technical Context: The patents address user interface design for media devices, focusing on automatically highlighting or repositioning content "cards" to display "regions of interest" determined from user preferences.
• Key Procedural History: The two asserted patents share a common specification and priority claim, originating from provisional applications filed in 2010 and 2011. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings for the asserted patents.

Case Timeline

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," Issued June 5, 2018

The Invention Explained

• Problem Addressed: The patent background describes the task of finding specific items of interest within multiple open windows or "cards" on a media device as "cumbersome," particularly when the user has to scroll through each card individually to find relevant information ('112 Patent, col. 1:26-37).
• 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 on-screen cards by referencing user preference information. The system then updates the display by repositioning the cards to make these regions of interest visible, potentially removing cards that lack such regions ('112 Patent, Abstract; col. 2:40-46). This process is depicted in the flowchart of Figure 17, which outlines steps for determining and displaying these regions ('112 Patent, Fig. 17).
• Technical Importance: This automated approach aimed to reduce the manual user input required to navigate and find relevant content across multiple applications or data streams displayed simultaneously. (Compl. ¶1; '112 Patent, col. 1:21-25).

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 (Compl. ¶16).
• Independent Claim 1 requires a method comprising:
  • 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 displaying the region of interest within all cards that are in the first group. (Compl. ¶15).
• The complaint does not explicitly reserve the right to assert dependent claims.

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 application leading to the '112 Patent, the '832 Patent addresses the same problem of simplifying user navigation across multiple content windows. ('832 Patent, col. 1:26-37).
• The Patented Solution: The solution is functionally identical to that of the '112 Patent, involving the automatic determination and display of "regions of interest" based on user preferences. The specification and figures are substantially the same as the '112 Patent, illustrating the concept with examples of media guides and content libraries ('832 Patent, Figs. 5-6, 13-14).
• Technical Importance: This patent family provides different claim scopes around the same core invention for automatically surfacing relevant content in a graphical user interface. ('832 Patent, col. 2:40-46).

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 (Compl. ¶25).
• Independent Claim 1 requires a method comprising:
  • 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 displaying the region of interest within all cards that are in the first group. (Compl. ¶24).
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is the WinSupply website, located at "https://www.winsupplyinc.com" (Compl. ¶9).

Functionality and Market Context

• The complaint alleges that the accused website "provides the user the ability to search for a store in any desired location" (Compl. ¶10). The complaint does not provide further technical details about the website's operation or its market context. The infringement allegations are based on claim chart exhibits which were not included with the filed complaint (Compl. ¶17, ¶26).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint. The complaint references claim chart exhibits that were not provided with the filing; the following analysis is based on the complaint's narrative allegations.

'112 Patent Infringement Allegations

'832 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A primary question will be whether the accused website's function of displaying a list of store locations in response to a search query falls within the scope of the patent claims. Specifically, does a list of search results constitute a "plurality of cards," and does the filtering of these results based on a search term meet the claim requirement of determining a "region of interest" based on "previous user preferences"?
  • Technical Questions: What evidence does the complaint provide that the accused website performs the specific "repositioning" and "removing" steps as required by the claims? The patents describe a dynamic rearrangement of existing visual cards (e.g., '832 Patent, Figs. 13-14), and it is an open question whether simply generating a new webpage of search results meets this limitation.

V. Key Claim Terms for Construction

• The Term: "cards"

• Context and Importance: This term is foundational to both asserted claims. The patents describe "cards" or "windows" in the context of graphical user interfaces for media content like television guides or movie libraries ('832 Patent, Figs. 5-6). The infringement theory appears to equate a list of business locations on a website with this claimed concept. Practitioners may focus on whether the term is limited to the graphical, window-like containers shown in the patent's embodiments or if it can be read more broadly to cover line-item text results in a standard web search.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that cards can represent "different applications such as electronic program guides, playlists, social media interfaces, games, video, audio, web pages, browsers, rendered media services, and the like" ('832 Patent, col. 8:58-63), which may support application beyond the specific visual examples.
  • Evidence for a Narrower Interpretation: The figures consistently depict "cards" as distinct, bounded graphical objects, such as those in the "Live Guide" (500) or "Library" (600) interfaces ('832 Patent, Figs. 5-6). An argument could be made that the term is tied to these specific visual representations of discrete content containers.

• The Term: "regions of interest"

• Context and Importance: The core of the invention is the automatic identification and display of these regions. Infringement depends on whether the accused website's functionality determines a "region of interest" as the patent conceives of it. The complaint does not specify what feature of the accused store locator results constitutes this region.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests regions of interest can be based on a wide array of "user preference information," including "a user profile where a user explicitly lists keywords or indicates various subjects that the user has interest" ('832 Patent, col. 9:15-18). This could be argued to cover any user-specified search criteria.
  • Evidence for a Narrower Interpretation: The patent describes determining these regions by "a search function looking for such keywords in the text present on cards" ('832 Patent, col. 10:36-38) and then moving the card itself to make that pre-existing text visible. Figures 13 and 14 show this as highlighting a specific portion within a larger card ('832 Patent, Figs. 13-14, elements 1325, 1335, 1345). This may support a narrower construction requiring the identification of a sub-part of an existing element, rather than simply filtering a list of whole elements.

VI. Other Allegations

The complaint does not contain specific factual allegations to support claims of indirect or willful infringement.

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

1. A central issue will be one of definitional scope: can the term "cards," as described and depicted in the patents' media-centric user interfaces, be construed to cover the presentation of store location search results on a commercial website?
2. A key evidentiary question will concern the "user preferences" limitation: does the act of a user entering a search term into a website's store locator constitute a search of "information indicating previous user preferences" as required by the claims, or does this limitation require a more persistent, stored profile of user data?
3. The dispute may also turn on a functional question: does the accused website's generation of a search results page perform the claimed steps of "repositioning the plurality of cards" and "remov[ing] cards not included in the first group," or is there a technical mismatch between the dynamic UI manipulation described in the patent and the standard web behavior of loading a results page?