Consolidated Transaction Processing LLC v. Genuine Parts Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Consolidated Transaction Processing LLC (Nevada)
  • Defendant: Genuine Parts Company (Georgia)
  • Plaintiff’s Counsel: SHEA | BEATY PLLC
• Case Identification: 4:25-cv-00020, E.D. Tex., 01/08/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Genuine Parts Company maintains established places of business in the district, including specific retail store locations in Allen and McKinney, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website and its underlying systems infringe patents related to generating and sending targeted product offerings based on aggregated distributor data and user-specific personal information.
• Technical Context: The technology concerns e-commerce systems that create dynamic, personalized customer experiences by integrating product information from multiple suppliers with customer data to customize product catalogs and pricing.
• Key Procedural History: The asserted patents share a common specification and claim a priority date from 1999. U.S. Patent No. 8,712,846 was issued with a terminal disclaimer over its parent, U.S. Patent No. 8,396,743, which means the '846 Patent's term is tied to that of the '743 Patent. The complaint does not mention any prior litigation or administrative proceedings involving the patents-in-suit.

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"

• Patent Identification: U.S. Patent No. 8,712,846, issued April 29, 2014.

The Invention Explained

• Problem Addressed: The patent describes the state of e-commerce in the late 1990s as a simple replacement for print catalogs, where online retailers still operated by maintaining costly physical inventories and offered static, one-size-fits-all product listings (Compl. ¶13; '846 Patent, col. 3:6-23). This model was described as inflexible and inefficient, particularly for products with short life cycles.
• The Patented Solution: The invention proposes a centralized transaction processing system that aggregates product data (e.g., price, availability) from a "plurality of distributors" and combines it with customer data (e.g., purchase history, location information derived from an IP address) ('846 Patent, col. 3:44-52). As illustrated in the system architecture of Figure 1, this allows the system to dynamically generate customized electronic catalogs and "user-specific product offerings" without the merchant needing to hold inventory, thereby creating a more personalized and efficient online shopping experience ('846 Patent, Fig. 1; col. 4:51-58).
• Technical Importance: This approach enabled a shift from e-commerce platforms as simple online storefronts to dynamic marketplaces that could leverage data to personalize the user experience in real-time (Compl. ¶16, ¶17).

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 are:
  • A computer-implemented method for targeted product offering,
  • receiving product data for a plurality of products from a plurality of distributors for the products via a communications network;
  • receiving customer data from a plurality of customers, the customer data comprising location information associated with customers, the location information derived from an IP address associated with one or more of the customers;
  • generating, at least in part from the customer data, user-specific product offerings from the plurality of products; and
  • sending, by a computer, automated messages comprising the user-specific product offerings to the one or more of the customers.

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

• Patent Identification: U.S. Patent No. 8,396,743, issued March 12, 2013.

The Invention Explained

• Problem Addressed: The patent identifies the drawbacks of prior art e-commerce, which failed to use stored personal information to dynamically generate catalogs from multiple distributors, instead offering static listings from individual sources without aggregation or personalization (Compl. ¶20; '743 Patent, col. 3:6-14).
• The Patented Solution: The invention details a method and system where product data from multiple distributors and customer data are processed together in a centralized database ('743 Patent, col. 3:26-28). This integration allows a merchant to generate "user-specific product offering[s]" based on factors like customer location (derived from an IP address) and present a wider, more relevant range of products than a single-merchant system could ('743 Patent, Abstract; col. 12:41-52).
• Technical Importance: The technology provided a computerized framework to improve personalized shopping by enabling a merchant to select from a plurality of distributors based on criteria like price, availability, and shipping speed, thereby expanding market access for distributors and choice for customers (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 are:
  • A computer-implemented method for targeted product offering,
  • receiving product data for a plurality of products from a plurality of distributors for the products via a communications network;
  • receiving customer data from a plurality of customers, the customer data comprising location information associated with customers, the customer location information derived from an IP address associated with the customer;
  • generating, at least in part from the personal information concerning a customer location, at least one user-specific product offering from the plurality of products; and
  • sending, by a computer, automated messages comprising the at least one user-specific product offering to the one or more customers.

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Defendant's website, https://www.napaonline.com, and the associated servers and systems that host and operate it (Compl. ¶9).

Functionality and Market Context

• The complaint alleges that napaonline.com is an e-commerce website through which Defendant offers for sale, sells, and imports products into Texas and elsewhere in the U.S. (Compl. ¶5, ¶9). The complaint frames the accused system in the context of a modern internet economy where "user-specific customization" is a crucial competitive differentiator for online merchants (Compl. ¶22). The complaint does not provide specific technical details about the website's architecture or data sources.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint states that detailed infringement allegations are contained in Exhibits 3 and 4, which were not included with the filed complaint document (Compl. ¶32, ¶37). Therefore, a claim chart summary cannot be constructed.

The narrative infringement theory, based on the body of the complaint, is that the napaonline.com website and its underlying infrastructure perform the methods claimed in the '846 and '743 patents. The complaint alleges that in the course of its normal operation, Defendant's system receives product data, receives customer data (including personal and location information), uses that combined data to generate customized or targeted product offerings, and then conveys those offerings to customers through the website or other automated messages (Compl. ¶14, ¶18, ¶25).

• Identified Points of Contention:
  • Technical Question: The complaint alleges the generation of "user-specific product offerings" based on "location information derived from an IP address" ('846 Patent, cl. 1; '743 Patent, cl. 1). A central question will be what evidence demonstrates that the accused website performs this specific type of dynamic content generation, as opposed to more general forms of geo-targeting (e.g., a "find a local store" feature) that may not meet the claim requirements.
  • Scope Question: The claims require "receiving product data ... from a plurality of distributors" ('846 Patent, cl. 1; '743 Patent, cl. 1). A likely point of dispute is whether Defendant's supply chain for its NAPA-branded products qualifies as a "plurality of distributors." The analysis may turn on whether different internal business units, warehouses, or third-party suppliers are considered distinct "distributors" within the meaning of the claims.

V. Key Claim Terms for Construction

1. The Term: "plurality of distributors"

• Context and Importance: This term appears in the first limitation of the asserted independent claims of both patents. Its construction is critical because infringement requires the accused system to aggregate data from multiple sources defined as "distributors." If Defendant's system is found to source data from what is construed as a single entity, a core element of the infringement allegation may fail.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification is not highly specific in its definition. It mentions that the system provides access to the marketplace for a "wider range of distributors who may otherwise be excluded" (Compl. ¶21; '846 Patent, col. 9:55-58). Plaintiff may argue this supports a broad reading that includes any distinct product source, such as different corporate divisions, warehouses, or affiliated suppliers.
  • Evidence for a Narrower Interpretation: The patent repeatedly refers to "distributors" as external entities from which the system receives data (e.g., '846 Patent, col. 5:26-30). Figure 5 depicts "DISTRIBUTOR 1," "DISTRIBUTOR 2," etc., as separate functional blocks interacting with the "Distributor Selection Logic," which could suggest they are independent entities rather than internal parts of a single organization ('846 Patent, Fig. 5).

2. The Term: "user-specific product offering"

• Context and Importance: This term is the output of the core "generating" step in the asserted independent claims. The dispute may turn on how "specific" the offering must be to a particular user. Whether the accused website's functionality (e.g., targeted advertisements, promotions, or customized search results) meets this definition will be a key issue.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patents provide a broad list of what can constitute an "offering," including "a coupon, an electronic coupon, a promotional offer, an exclusive sale, an incentive, a rebate, and competitive pricing" ('846 Patent, cl. 2; '743 Patent, cl. 2). This list could support an argument that many common e-commerce marketing features qualify.
  • Evidence for a Narrower Interpretation: The specification provides examples of a higher degree of personalization, such as displaying a different catalog for a "student" versus a "business person" based on their profile ('846 Patent, col. 6:6-16). Defendant may argue this implies a requirement for deep, profile-driven customization of the actual product set, not just generic promotions sent to a broad class of users.

VI. Other Allegations

• Indirect Infringement: The complaint does not include counts for indirect or contributory infringement. The allegations are focused on direct infringement by Defendant (Compl. ¶32, ¶37).
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. It does not plead that Defendant had pre-suit knowledge of the patents-in-suit. The prayer for relief includes a request for a declaration that the case is "exceptional" under 35 U.S.C. § 285, which could lead to an award of attorneys' fees (Compl. p. 9, ¶C).

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

The resolution of this case may depend on the court's answers to two central questions:

1. A core issue will be one of definitional scope: Can the term "plurality of distributors", which the patent illustrates with examples of distinct external entities, be construed to cover the internal supply chain, warehouses, or affiliated suppliers of a single, vertically-integrated company like the Defendant?

2. A key evidentiary question will be one of functional proof: What evidence will establish that the accused napaonline.com website performs the specific function of "generating... user-specific product offerings" based on "location information derived from an IP address", as opposed to using more generalized marketing or geo-location features common to e-commerce platforms?