DCT
3:14-cv-04388
Word To Info Inc v. Google Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Word to Info, Inc. (Texas)
- Defendant: Google, Inc. (Delaware)
- Plaintiff’s Counsel: Farney Daniels PC; Carstens & Cahoon, LLP
- Case Identification: 3:14-cv-04388, N.D. Tex., 12/15/2014
- Venue Allegations: Plaintiff alleges venue is proper because Google conducts business in the Northern District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s Google Search engine (specifically, its Knowledge Graph feature) and Google Now product infringe seven patents related to systems and methods for natural language processing and knowledge retrieval.
- Technical Context: The patents describe a system for understanding natural language by converting it into a structured database of "experience and knowledge," using concepts like "word sense numbers" and "directed graphs" to represent meaning and context.
- Key Procedural History: The complaint notes that at least one of the patents-in-suit has been cited during the prosecution of approximately 158 other U.S. patents related to natural language processing, which may be presented as evidence of the technology's significance and recognition in the field.
Case Timeline
| Date | Event |
|---|---|
| 1994-09-30 | Priority Date for all seven Patents-in-Suit |
| 1998-02-03 | U.S. Patent No. 5,715,468 Issued |
| 2000-10-24 | U.S. Patent No. 6,138,087 Issued |
| 2003-08-19 | U.S. Patent No. 6,609,091 Issued |
| 2008-03-25 | U.S. Patent No. 7,349,840 Issued |
| 2011-01-18 | U.S. Patent No. 7,873,509 Issued |
| 2012-12-04 | U.S. Patent No. 8,326,603 Issued |
| 2014-04-01 | U.S. Patent No. 8,688,436 Issued |
| 2014-12-15 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 5,715,468 - "Memory System for Storing and Retrieving Experience and Knowledge with Natural Language"
Issued February 3, 1998.
The Invention Explained
- Problem Addressed: The patent's background section identifies a deficiency in prior art natural language processing systems, stating they lack the capability to combine multiple sentences to build a representation of experience and knowledge and also lack an effective method for selecting the correct sense of a word in a given context (’468 Patent, col. 2:37-44, 60-63).
- The Patented Solution: The invention claims a system that processes natural language by converting it into a structured, three-dimensional "experience and knowledge" database (’468 Patent, col. 4:2-10). It uses a dictionary and grammar rules to parse language and assigns "word sense numbers" to disambiguate meaning. This allows the system to store information with context and use that stored knowledge to interpret future inputs and generate natural language responses (’468 Patent, Abstract; Fig. 1).
- Technical Importance: This approach represented an effort to create systems that could build and retain contextual understanding from language over time, a foundational concept for later developments in conversational AI and semantic search technologies (’468 Patent, col. 3:23-35).
Key Claims at a Glance
The complaint does not identify specific asserted claims but makes allegations that track the language of several independent claims. As an example, Claim 37, a method claim, includes the following essential elements:
- providing electronically encoded data representative of natural language;
- providing a dictionary database containing entries with syntax usage data and associated "word sense numbers" which in turn have associated "state representation data" and/or "function codes";
- lexically processing the encoded data to access the dictionary;
- providing a grammar specification; and
- using the syntax data with reference to the grammar specification to produce a grammatical parse of the language.
U.S. Patent No. 6,138,087 - "Memory System for Storing and Retrieving Experience and Knowledge with Natural Language Utilizing State Representation Data, Word Sense Numbers, Function Codes and/or Directed Graphs"
Issued October 24, 2000.
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’468 Patent, this patent addresses the same general problem of enabling computers to understand and process natural language by storing information as knowledge and experience (’087 Patent, col. 1:8-13).
- The Patented Solution: The invention focuses on an "experience and knowledge" database structured as a directed graph. Nodes in the graph are associated with "clause implying word sense numbers" and are organized into paths. These paths have "access conditions" that determine whether a path can be traversed, allowing the system to represent and reason about relationships between concepts, events, and states (’087 Patent, Abstract; col. 13:15-28).
- Technical Importance: The patent describes a specific data architecture for a knowledge base that aims to go beyond simple data storage to model processes and logical sequences, enabling more sophisticated language understanding and generation.
Key Claims at a Glance
The complaint does not identify specific asserted claims. The allegations appear to track independent claim 23, a method claim comprising the following essential elements:
- providing an experience and knowledge database comprised of directed graphs, which are themselves comprised of nodes with associated "clause implying word sense numbers" organized into paths; and
- processing the "associated clause implying word sense numbers" from the database.
U.S. Patent No. 6,609,091 - "Memory System for Storing and Retrieving Experience and Knowledge with Natural Language Utilizing State Representation Data, Word Sense Numbers, Function Codes and/or Directed Graphs"
Issued August 19, 2003 (Compl. ¶11).
- Technology Synopsis: This patent, a continuation of the '087 application, describes a system that further refines the process of selecting word senses. It introduces a "data base of requirements" that must be met by the state representation data associated with a word sense number for that number to be selected during parsing (Compl. ¶31).
- Asserted Claims: "one or more claims" (Compl. ¶30).
- Accused Features: Google's Knowledge Graph and/or Google Now product (Compl. ¶30).
U.S. Patent No. 7,349,840 - "Memory System for Storing and Retrieving Experience and Knowledge with Natural Language Utilizing State Representation Data, Word Sense Numbers, Function Codes, Directed Graphs and/or Context Memory"
Issued March 25, 2008 (Compl. ¶12).
- Technology Synopsis: This patent introduces a "context data base" to be used in conjunction with a dictionary and grammar specification. The system utilizes information from this context database to select word sense numbers and/or function codes associated with natural language words (Compl. ¶37).
- Asserted Claims: "one or more claims" (Compl. ¶36).
- Accused Features: Google's Knowledge Graph and/or Google Now product (Compl. ¶36).
U.S. Patent No. 7,873,509 - "Memory System for Storing and Retrieving Experience and Knowledge with Natural Language Utilizing State Representation Data, Word Sense Numbers, Function Codes, Directed Graphs, Context Memory, and/or Purpose Relations"
Issued January 18, 2011 (Compl. ¶13).
- Technology Synopsis: This patent adds the concept of "purpose relation path identification processes" to the system. These processes are used to find paths within the directed graph knowledge base that meet certain access conditions and to select from among the found paths based on specified criteria (Compl. ¶43).
- Asserted Claims: "one or more claims" (Compl. ¶42).
- Accused Features: Google's Knowledge Graph and/or Google Now product (Compl. ¶42).
U.S. Patent No. 8,326,603 - "Memory System for Storing and Retrieving Experience and Knowledge with Natural Language Queries"
Issued December 4, 2012 (Compl. ¶14).
- Technology Synopsis: This patent describes utilizing a natural language processor to provide natural language with associated "clause implying word sense numbers" in memory. This is used with the directed graph knowledge base and a "purpose relation path identification processor" to identify paths that satisfy access conditions (Compl. ¶47).
- Asserted Claims: "one or more claims" (Compl. ¶46).
- Accused Features: Google's Knowledge Graph and/or Google Now product (Compl. ¶46).
U.S. Patent No. 8,688,436 - "Memory System for Storing and Retrieving Experience and Knowledge by Utilizing Natural Language Responses"
Issued April 1, 2014 (Compl. ¶15).
- Technology Synopsis: This patent adds a "natural language plausibility and expectedness processor." This processor is used to initiate access to entries in the dictionary database based on how plausible or expected the words are in the context of the natural language being processed (Compl. ¶51).
- Asserted Claims: "one or more claims" (Compl. ¶50).
- Accused Features: Google's Knowledge Graph and/or Google Now product (Compl. ¶50).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are identified as "the Knowledge Graph feature of its internet search engine product and/or its Google Now product" (Compl. ¶18).
Functionality and Market Context
The complaint alleges that these Google products operate by processing natural language, using databases that contain syntactic and semantic information, and referencing this information to parse language and provide responses (Compl. ¶¶19, 20, 27). The complaint does not provide specific technical details about the architecture or operation of the Knowledge Graph or Google Now beyond mapping their general functions to the language of the patents-in-suit. No specific allegations regarding the products' commercial importance are made, though their association with Google's core search business is noted. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’468 Patent Infringement Allegations
The complaint alleges infringement of one or more claims of the ’468 Patent. The allegations in paragraph 19 appear to map to the elements of at least Claim 37.
| Claim Element (from Independent Claim 37) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of processing natural language, which comprises steps: providing electronically encoded data which is representative of said natural language | Google...providing a system that electronically encodes data representative of natural language... | ¶19 | col. 373:29-32 |
| providing a dictionary data base...comprised of one or more of syntax usage data, associated word sense numbers having associated state representation data and/or function codes | ...includes a database containing a plurality of a syntax usage data entries, associated word sense numbers... | ¶19 | col. 373:33-38 |
| lexically processing said electronically encoded data to access said dictionary data base | ...lexically processing the electronically encoded data and accessing the dictionary data base... | ¶19 | col. 373:39-40 |
| providing a grammar specification | ...providing a grammar specification... | ¶19 | col. 373:41 |
| utilizing said syntax usage data which are from entries of said dictionary data base...with reference to said grammar specification to produce output data... | ...uses the syntax usage data from the database with reference to the grammar specification to produce output... | ¶19 | col. 373:42-47 |
’087 Patent Infringement Allegations
The complaint alleges infringement of one or more claims of the ’087 Patent. The allegations in paragraph 27 appear to map to the elements of at least Claim 23.
| Claim Element (from Independent Claim 23) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of processing experience and knowledge, which comprises steps: providing an experience and knowledge data base which is comprised of directed graphs comprised of nodes with associated clause implying word sense numbers organized into paths of said nodes | Google...providing a system that uses an experience and knowledge data base which is comprised of directed graphs comprised of nodes with associated clause implying word sense numbers organized into paths of said nodes... | ¶27 | col. 369:1-5 |
| processing said associated clause implying word sense numbers of said experience and knowledge database. | ...and processing said associated clause implying word sense numbers of said experience and knowledge database. | ¶27 | col. 370:1-3 |
Identified Points of Contention
- Scope Questions: A primary issue for the court may be construing claim terms rooted in a 1994 priority date—such as "dictionary data base" and "word sense number"—in the context of modern systems like Google's Knowledge Graph, which may use fundamentally different data structures and semantic representation techniques (e.g., knowledge graphs, vector embeddings).
- Technical Questions: The infringement allegations in the complaint are highly conclusory and track the patent claim language without providing specific factual support. A central question will be what evidence Plaintiff can produce to show that Google's accused products actually perform the specific steps as claimed, such as using a "grammar specification" or processing "clause implying word sense numbers" in the manner described by the patents.
V. Key Claim Terms for Construction
The Term: "word sense number" (’468 Patent, Claim 37)
- Context and Importance: This term appears to be a central inventive concept for disambigulating word meaning. The viability of the infringement case may depend on whether this term is construed broadly enough to cover modern semantic representation methods or is limited to the specific numerical structures described in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers to a word sense number as "an address to the meaning of a word," which could suggest any unique identifier for a specific meaning (’468 Patent, col. 5:57-58).
- Evidence for a Narrower Interpretation: The patent provides very detailed formats for these numbers, including components such as "Class Number," "Member Number," "Type Number," "Specificity Number," and "Experience Number," suggesting a specific, hierarchical data structure (’468 Patent, Fig. 17A; col. 6:28-43).
The Term: "experience and knowledge data base" (’087 Patent, Claim 23)
- Context and Importance: Plaintiff's allegation hinges on this term reading on Google's Knowledge Graph. The dispute will likely focus on whether the structure of the Knowledge Graph is equivalent to the specific "directed graph" structure disclosed in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes this database as storing "all experience and knowledge which is accessible for the application," which could arguably encompass a wide variety of knowledge bases (’087 Patent, col. 4:3-5).
- Evidence for a Narrower Interpretation: The patent repeatedly describes the database as being organized into "paths" where nodes have "access conditions," which appears to model sequential or conditional relationships (’087 Patent, Abstract). This may support a narrower construction that requires more than just a general graph of entities and relationships, but one that models processes or realizations of a purpose (’087 Patent, col. 13:28-35).
VI. Other Allegations
Willful Infringement
The complaint alleges that Google was made aware of the '468, '091, and '840 patents and their alleged infringement "at least as early as the filing of this Complaint" (Compl. ¶¶ 23, 33, 39). This forms the basis for an allegation of post-suit willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to present foundational questions of claim scope and evidentiary proof in the context of rapidly evolving technology. The key questions the case will likely turn on are:
- A core issue will be one of definitional scope and temporal translation: Can claim terms describing specific data structures from a 1994-priority patent family (e.g., "word sense number", "experience and knowledge data base" organized into paths) be construed to read on the fundamentally different and more complex architectures of modern systems like Google's Knowledge Graph?
- A key evidentiary challenge for the plaintiff will be to substantiate its conclusory infringement allegations. The case may depend on whether the plaintiff can demonstrate, with specific technical evidence, how Google's proprietary systems implement the precise, multi-step methods and data structures required by the asserted claims.