Linfo IP LLC v. Old Navy LLC

Here is the transformed patent infringement complaint analysis, formatted as a senior litigation partner memo.

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Old Navy, LLC (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 6:23-cv-00634, E.D. Tex., 12/31/2023
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Old Navy maintains a regular and established place of business in the district, specifically citing retail store locations in Longview and Tyler, and conducts substantial business in the forum.
• Core Dispute: Plaintiff alleges that Defendant’s system for discovering and presenting information within text content infringes a patent related to user interfaces that analyze and act upon such information.
• Technical Context: The technology concerns natural language processing and user interface design to help users analyze, filter, and display specific information from large volumes of unstructured text, such as online user reviews.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity. No other significant procedural events, such as prior litigation or administrative proceedings involving the patent-in-suit, are mentioned in the complaint.

Case Timeline

Date	Event
2011-12-09	U.S. Patent No. 9,092,428 Priority Date
2015-07-28	U.S. Patent No. 9,092,428 Issue Date
2023-12-31	Complaint Filed

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

U.S. Patent No. 9,092,428 - *"System, methods and user interface for discovering and presenting information in text content"*

• Issued: July 28, 2015

The Invention Explained

• Problem Addressed: The patent identifies the problem of "information overload," where users struggle to find specific, relevant information within large amounts of unstructured text data, such as thousands of online hotel reviews or long medical documents (’428 Patent, col. 1:12-21). It notes the difficulty of not only finding comments related to a specific topic (e.g., "room service") but also of isolating comments with a specific sentiment (e.g., positive vs. negative) within that topic (’428 Patent, col. 1:21-38).
• The Patented Solution: The invention proposes a computer-assisted system that analyzes text to associate words or phrases with specific "semantic attributes" (e.g., positive opinion, negative opinion, topical importance). It then provides "actionable user interface objects" (e.g., buttons, dropdown menus) that allow a user to select an attribute and an action—such as "extract," "display," or "highlight"—to be performed on text possessing that attribute (’428 Patent, Abstract; col. 3:15-28). Figure 11, for example, depicts user interface buttons to "Highlight positive comments" or "Highlight negative comments" in a block of text (’428 Patent, Fig. 11).
• Technical Importance: The technology seeks to provide a more efficient and targeted tool for users to digest large text-based datasets, moving beyond simple keyword searches to enable attribute-based information discovery and presentation (’428 Patent, col. 2:55-63).

Key Claims at a Glance

• The complaint asserts claims 1-20 (’Compl. ¶9). The lead independent claims are 1 (a method) and 14 (a system).
• Independent Claim 1 (Method): The core elements include:
  • obtaining a text content
  • selecting a first and second "semantic attribute" for users to select from
  • identifying words or phrases in the text associated with those attributes
  • displaying an "actionable user interface object" labeled with the attribute's name
  • allowing a user to select an attribute via the interface object
  • performing a user-selected action (e.g., highlighting, extracting) on the identified words or phrases
• Independent Claim 14 (System): This claim largely mirrors the steps of Claim 1, but is directed to a system with a computer processor configured to perform these functions.
• The complaint reserves the right to assert dependent claims (’Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The complaint does not identify a specific accused product by name. It broadly accuses a "system with methods and user interface for discovering information in a text content and extracting and presenting the information" that is maintained, operated, and administered by Defendant Old Navy (Compl. ¶9).

Functionality and Market Context

The complaint alleges in conclusory terms that Defendant's system performs infringing activities but offers no specific details about the system's features or operation (Compl. ¶9). The allegations largely mirror the language of the patent itself, for example, by claiming the system is used for "discovering information in a text content and extracting and presenting the information" (Compl. ¶8). No probative visual evidence provided in complaint. The complaint does not provide sufficient detail for analysis of the product's commercial importance or market positioning.

IV. Analysis of Infringement Allegations

The complaint states that support for its infringement allegations may be found in a "preliminary exemplary table attached as Exhibit B" (Compl. ¶10). However, this exhibit was not included with the filed complaint. As such, a detailed claim-chart analysis is not possible based on the provided documents.

The complaint’s narrative theory is that Defendant’s system, presumably its e-commerce website, infringes the ’428 patent by providing a user interface with objects that allow users to discover, extract, and present information found in text content (Compl. ¶8, ¶9). The complaint lacks factual specifics regarding which features of Defendant’s system correspond to the elements of the asserted claims.

• Identified Points of Contention:
  • Evidentiary Question: A central issue will be whether Plaintiff can produce evidence in discovery to substantiate its allegations. For instance, what specific feature of the Old Navy website or backend systems performs the claimed function of identifying a "semantic attribute" and what "actionable user interface object" allows a user to select this attribute to trigger an action like "highlighting"?
  • Technical Question: The infringement analysis will turn on whether Defendant’s system technically operates in the manner required by the claims. A key question is whether the accused system performs linguistic analysis to identify attributes like "opinion," as taught in the patent, or if it relies on conventional e-commerce functionalities, such as filtering by a numerical star rating, which may not meet the claim limitations.

V. Key Claim Terms for Construction

• The Term: "semantic attribute" (Claim 1)

  • Context and Importance: This term is foundational to the patent, defining the type of information the system is designed to identify and act upon. Its construction will be critical in determining whether the claims cover common website filtering mechanisms or are restricted to more sophisticated linguistic analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is not explicitly limited, referring generally to "a first semantic attribute and a second semantic attribute" without restriction to a particular type, such as sentiment (’428 Patent, col. 16:1-5).
    • Evidence for a Narrower Interpretation: The specification's examples focus heavily on "opinion" (e.g., positive, negative, or neutral) as the primary type of semantic attribute (’428 Patent, col. 8:30-33). The patent also describes using a pre-compiled dictionary to identify these attributes, which may suggest the term is limited to specific, pre-defined linguistic properties rather than general metadata (’428 Patent, Fig. 6; col. 9:29-40).

• The Term: "actionable user interface object" (Claim 1)

  • Context and Importance: This term defines the interactive component of the invention. Practitioners may focus on this term because its scope will determine whether any clickable element qualifies, or if it must be a specific type of control designed for the claimed purpose.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself is general and could be argued to read on any user interface element that can be acted upon to cause a result.
    • Evidence for a Narrower Interpretation: Claim 1 requires the object to be "associated with a label representing the first name or description or the second name or description" of the semantic attribute, suggesting a specific purpose (’428 Patent, col. 16:12-15). The patent figures consistently depict these objects as specific controls like dropdown menus (Fig. 7), checkboxes (Fig. 9A), or radio buttons (Fig. 11) provided for the express purpose of selecting an attribute and an action.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by "actively encourag[ing] or instruct[ing] others (e.g., its customers...)" to use its services in an infringing manner (Compl. ¶11). It also makes a parallel allegation of contributory infringement (Compl. ¶12). Both allegations are made without reference to specific evidence, such as user manuals or marketing materials.
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’428 patent "from at least the filing date of the lawsuit" (Compl. ¶11, ¶12). This allegation supports a claim for post-filing willfulness only. The prayer for relief seeks a finding of willful infringement and treble damages (Compl. p.5, ¶e).

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

• A primary issue will be one of evidence and specificity: The complaint is factually sparse. A threshold question is whether Plaintiff can produce evidence to connect its broad allegations to specific functionalities of Defendant’s systems. The case may depend on whether discovery reveals an Old Navy system that performs the precise steps of identifying and acting upon "semantic attributes" as claimed.
• The case will likely turn on a question of definitional scope: The central legal battle may be over the construction of the term "semantic attribute." Can this term be construed broadly to cover conventional e-commerce filters, such as sorting by a numerical product rating, or is its meaning confined by the specification to a more advanced linguistic analysis of text, such as identifying positive and negative sentiment within user comments? The court’s answer will likely determine the outcome of the infringement analysis.