Consolidated Transaction Processing LLC v. Goodyear Tire & Rubber Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Consolidated Transaction Processing LLC (Nevada)
  • Defendant: The Goodyear Tire & Rubber Company (Ohio)
  • Plaintiff’s Counsel: SHEA | BEATY PLLC
• Case Identification: 4:25-cv-00019, E.D. Tex., 01/08/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant Goodyear maintains established places of business, specifically Goodyear tire stores, within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website, goodyearautoservice.com, infringes two patents related to methods for generating targeted, user-specific product offerings by aggregating product data from multiple distributors and using customer-specific information.
• Technical Context: The technology at issue addresses the personalization of e-commerce by enabling a central system to create dynamic online catalogs based on data from various backend suppliers and individual user profiles.
• Key Procedural History: The patents-in-suit share a common specification and claim priority back to an application filed in 1999. The complaint characterizes the underlying inventions as "pioneering efforts" in electronic transaction processing. U.S. Patent No. 8,712,846 was issued with a terminal disclaimer, which may limit its enforceable term to that of its parent patent, U.S. Patent No. 8,396,743.

Case Timeline

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

U.S. Patent No. 8,712,846 - "Sending Targeted Product Offerings Based on Personal Information," issued April 29, 2014

The Invention Explained

• Problem Addressed: The patent's background section describes the limitations of then-current e-commerce models, which often functioned like static online advertisements or catalogs. These early systems required merchants to maintain their own costly inventory and lacked the flexibility to provide personalized offerings to different customers (Compl. ¶13; ’846 Patent, col. 2:63-3:14).
• The Patented Solution: The invention proposes a centralized system that solves this problem by connecting to a "plurality of distributors." The system receives product data (e.g., product descriptions, price, availability) from these multiple distributors and customer data (e.g., personal and location information) from users. It then processes this combined information to "generate at least one user-specific product offering" which is delivered to the customer via an automated message (’846 Patent, Abstract; col. 4:40-52). This allows a single storefront to dynamically create customized catalogs, for example, showing different pricing to a student versus a corporate user (’846 Patent, col. 6:6-16).
• Technical Importance: The described technology facilitated a move from one-to-many e-commerce (a single static catalog for all users) to a more sophisticated one-to-one model, enabling a single website to act as an aggregator for multiple suppliers and personalize the shopping experience (Compl. ¶17-18).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 3 and 4 (Compl. ¶32).
• The essential elements of independent claim 1 include:
  • A computer-implemented method for targeted product offering;
  • Receiving product data for a plurality of products from a plurality of distributors via a communications network;
  • Receiving customer data, including location information derived from an IP address associated with the customer;
  • Generating, based at least in part on the customer data, user-specific product offerings;
  • Sending automated messages containing the user-specific product offerings to the customers.

U.S. Patent No. 8,396,743 - "Sending Targeted Product Offerings Based on Personal Information," issued March 12, 2013

The Invention Explained

• Problem Addressed: Sharing a specification with the ’846 patent, the ’743 patent addresses the same technical problem: the inflexibility and high overhead costs of early e-commerce platforms that were tied to a single merchant's physical inventory and offered a uniform, non-personalized experience to all users (Compl. ¶23; ’743 Patent, col. 1:28-40).
• The Patented Solution: The patented method involves a system that interfaces with multiple distributors to aggregate product information into a central database. This allows the system to select an optimal distributor for a given order based on criteria like price, shipping speed, or profit margin (’743 Patent, col. 9:8-44). By combining this aggregated product data with customer data, the system can generate dynamic, user-specific catalogs and pricing (’743 Patent, col. 5:61-6:29). Figure 1 of the patent depicts the overall system architecture, showing the data flow between customers, distributors, and the central processing system.
• Technical Importance: This system architecture enabled a broader range of product offerings than a single-merchant system and provided a marketplace for distributors who might otherwise be excluded, all while presenting a personalized interface to the end-user (Compl. ¶21).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claim 4 (Compl. ¶37).
• The essential elements of independent claim 1 include:
  • A computer-implemented method for targeted product offering;
  • Receiving product data for a plurality of products from a plurality of distributors;
  • Receiving customer data, including location information derived from an IP address;
  • Generating, based at least in part on personal information concerning a customer location, a user-specific product offering;
  • Sending automated messages containing the user-specific product offering.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendant’s websites, including but not limited to "https://www.goodyearautoservice.com" (Compl. ¶9).

Functionality and Market Context

• The complaint alleges that the accused website is used for e-commerce transactions and that its operation infringes the patents-in-suit (Compl. ¶32, ¶37). The complaint does not, however, provide specific factual allegations regarding the technical operation of the website. Instead, it references preliminary claim charts in Exhibits 3 and 4, which are not attached to the public-facing complaint (Compl. ¶32, ¶37). Consequently, the complaint does not provide sufficient detail for a full analysis of the accused instrumentality's functionality. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Goodyear directly infringes the ’846 and ’743 patents by "making, using, providing, and/or causing to be used the Accused Instrumentalities" (Compl. ¶32, ¶37). However, the complaint relies on references to external exhibits (Exhibits 3 and 4) to provide the detailed basis for these allegations. As these exhibits were not provided, a claim chart summary cannot be constructed. The narrative theory, inferred from the patents and the general nature of the accused website, is that Goodyear's website aggregates product and service data from its network of retail stores (the alleged "distributors") and uses customer location data to present targeted results.

• Identified Points of Contention:
  • Scope Question: A central question for the court may be whether Goodyear's network of owned and/or franchised service centers constitutes a "plurality of distributors" as required by the claims. The patent's description of selecting distributors based on competing factors like profit margins or shipping methods may suggest independent entities, raising the question of whether Goodyear's own retail locations meet this definition (’743 Patent, col. 9:26-44).
  • Technical Question: Claim 1 of both patents requires the system to "receiv[e] product data... from a plurality of distributors." The complaint does not provide evidence detailing the specific mechanism by which Goodyear's central website obtains data from its individual stores. The analysis will likely focus on whether the website architecture involves actively "receiving" data from distinct store-level systems, as opposed to accessing a single, centrally-managed database.
  • Technical Question: The claims require "generating... at least one user-specific product offering" from customer data. A likely point of dispute is whether the accused website’s functionality—for instance, using a customer's location to display a list of nearby stores and their services—constitutes "generating" a "user-specific product offering" in the manner claimed, or if it is merely a location-based filtering of a universal catalog.

V. Key Claim Terms for Construction

• The Term: "plurality of distributors" (asserted in claim 1 of both patents)

  • Context and Importance: The definition of this term is critical. If "distributors" is construed to mean only independent, third-party entities, Plaintiff may face challenges in proving that Goodyear's network of its own branded stores meets this limitation. Practitioners may focus on this term because it is fundamental to the architecture described in the patent and the infringement theory.
  • Intrinsic Evidence for a Broader Interpretation: The specification uses the term "distributors/vendors" and describes them as the source of products for the system, without explicitly requiring them to be legally separate entities from the system operator (’743 Patent, Fig. 1; col. 5:26-30).
  • Intrinsic Evidence for a Narrower Interpretation: The specification describes selecting a distributor based on competitive criteria such as profit margins and shipping speed, which may imply distinct commercial entities competing with one another, rather than different locations of a single company (’743 Patent, col. 9:26-44).

• The Term: "user-specific product offering" (asserted in claim 1 of both patents)

  • Context and Importance: Whether the output of the accused website qualifies as a "user-specific product offering" will be a key issue. The dispute will likely center on whether displaying a location-filtered list of services constitutes the "generating" of an "offering" as contemplated by the patent.
  • Intrinsic Evidence for a Broader Interpretation: The claims tie the "offering" to customer location data derived from an IP address (’846 Patent, cl. 1). The specification also provides an example of creating different catalogs for different user types (e.g., student vs. business), suggesting that any form of user-based customization could fall within the term's scope (’846 Patent, col. 6:6-16).
  • Intrinsic Evidence for a Narrower Interpretation: The word "generating" may suggest a more dynamic process than simply filtering a list. The patent describes creating customized portfolios to provide "targeted advertising, purchase incentives... or competitive pricing," which could be construed to require more than just showing standard services available at a nearby location (’846 Patent, col. 5:16-20).

VI. Other Allegations

• Willful Infringement: The complaint does not explicitly allege willful infringement. However, the prayer for relief requests a declaration that the case is "exceptional under 35 U.S.C. § 285" and an award of attorneys' fees (Compl. Prayer for Relief ¶C). The complaint does not plead any specific facts to support this request, such as allegations of pre-suit knowledge of the patents or other forms of egregious conduct.

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

• A core issue will be one of definitional scope: can the term "plurality of distributors," which the patent specification appears to frame in the context of independent vendors, be construed to cover a network of retail stores operating under a single corporate brand like Goodyear?
• A key evidentiary question will be one of functional operation: does the accused website's feature of using a customer's location to identify nearby service centers and their available products perform the specific method of "generating" a "user-specific product offering" as required by the claims, or is there a material difference in the technical process?
• A primary procedural question arises from the complaint's structure: given the lack of specific factual allegations of infringement in the body of the complaint and the absence of the referenced claim-chart exhibits, the initial stages of litigation may focus on establishing a plausible factual basis for the infringement claims.