DCT
3:22-cv-02354
Ridgeview IP LLC v. Anthology Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ridgeview IP LLC (Texas)
- Defendant: Anthology Inc. (Florida)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 3:22-cv-02354, N.D. Tex., 10/19/2022
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas based on Defendant maintaining a "regular and established business presence" in the district, including the employment of remote and district-based staff.
- Core Dispute: Plaintiff alleges that Defendant’s "Connector" software platform infringes a patent related to methods for dynamically guiding a user through a database search to prevent the construction of queries that would yield no results.
- Technical Context: The technology at issue addresses user interfaces for database searching, aiming to improve efficiency and user experience by intelligently restricting a user's choices during query formulation to guarantee a valid output.
- Key Procedural History: The complaint notes that the asserted patent has been cited as prior art in 29 subsequent patents issued to various technology companies. No other significant procedural events, such as prior litigation or administrative proceedings, are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2001-01-24 | '270 Patent Priority Date |
| 2006-01-03 | '270 Patent Issue Date |
| 2022-10-19 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,983,270 - “Method and Apparatus for Displaying Database Search Results”
- Patent Identification: U.S. Patent No. 6,983,270, issued January 3, 2006.
The Invention Explained
- Problem Addressed: The patent addresses the common problem in database searching where a user constructs a query that yields a "null result" (e.g., "no documents found") ('270 Patent, col. 3:1-3). The patent describes prior art methods for avoiding this as being complex or reliant on a user's past search history, making them inefficient for first-time queries ('270 Patent, col. 2:6-11).
- The Patented Solution: The invention proposes a method where the search interface dynamically guides the user. As the user selects search terms ("entries") and logical operators (e.g., AND, OR), the system continuously updates the list of available subsequent options, eliminating any choices that would lead to a null result ('270 Patent, col. 2:30-36). This ensures that any query a user can build is guaranteed to return at least one result, by "elimination from all lists, categories, etc., of all irrelevant and impossible responses" in real-time ('270 Patent, col. 2:63-65).
- Technical Importance: This approach sought to create a more intuitive and error-proof search experience by building logic into the interface itself to prevent user error, rather than simply executing a flawed query and returning an error message ('270 Patent, col. 2:2-3).
Key Claims at a Glance
- The complaint asserts independent Claim 1.
- The essential elements of Claim 1 include:
- Displaying a set of entries and operators from a database.
- Selecting an initial entry.
- Displaying valid results based on the selected entry.
- Updating the set of displayed operators to include only those that, when combined with the selected entry, will produce at least one valid result.
- Selecting an operator from the updated set.
- Updating the set of displayed entries to include only those that, when combined with the previously selected items, will produce at least one valid result.
- Selecting a new entry from the updated set.
- Updating the displayed set of valid results.
- Repeating the updating and selecting steps until a desired result is reached.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The "Accused Instrumentalities" are identified as Defendant's "Connector component" and associated platforms (Compl. ¶17).
Functionality and Market Context
- The complaint alleges the Connector is an optional component that "connects the Constituent Relationship Management (CRM) system with the Student Information System (SIS)" (Compl. ¶17, Fig. 2).
- Its alleged function is to provide a "method for displaying a progress and results of a database search" (Compl. ¶17). This allegedly involves displaying and selecting from filters and Boolean operators (e.g., AND, OR) to form a database query (Compl. ¶22(ii)).
- A screenshot in the complaint describes the Connector's business purpose as achieving "lead life-cycle management and measurement across all stages and statuses: from lead generation to student outcome" (Compl. p. 6, Fig. 2). This screenshot from Defendant's website shows a description of the "Connector" component and its role in integrating two data systems (Compl. p. 6, Fig. 2).
IV. Analysis of Infringement Allegations
'270 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. displaying a set of entries from a database and a set of operators... | Displaying different filters related to a message search from a student database and a set of Boolean row operators such as AND, OR, etc. | ¶22(ii) | col. 2:50-54 |
| b. selecting an initial entry of said displayed set of entries; | Selecting filters such as a property or operator from multiple available filters. | ¶22(iii) | col. 3:50-52 |
| c. displaying a set of valid results from a query based on said selected entry; | Displaying a set of valid results (e.g., message results after filtering) from a query based on the selected entry. | ¶22(iv) | col. 3:52-54 |
| d. updating said set of displayed operators based on said selected entry, wherein said updated set of displayed operators includes only operators...wherein the operators...produce at least one valid result; | Updating the set of displayed operators (e.g., a displayed row operator) to only include operators that, when combined with the selected entry and another entry, will produce at least one valid result. | ¶22(v) | col. 12:1-4 |
| e. selecting an operator from the updated displayed set of operators; | Selecting a row operator, such as an 'AND' operator, from the updated set of displayed operators. | ¶22(vi) | col. 3:56-57 |
| f. updating said displayed set of entries in response to the selected operator, wherein said updated displayed set of entries includes only entries...wherein the entries...produce at least one valid result; | Updating the displayed set of entries (e.g., updated filters) to only include entries from the database that, when combined with the selected entry and operator, produce at least one valid result. | ¶22(vii) | col. 12:4-8 |
| g. selecting one of said updated displayed set of entries; | Selecting one of the updated displayed set of entries (e.g., filters related to the message search). | ¶22(viii) | col. 4:6-8 |
| h. updating said displayed set of valid results according to a query based on the selected entries and the selected operator; | Updating the displayed set of valid results (e.g., message results) based on a query with the selected entries and operator. | ¶22(ix) | col. 12:8-10 |
| i. while said updated displayed set of valid results is not the desired result, repeating steps d. through h. ... | Repeating the filtering steps based on previously selected entries and operators to select additional operators and entries until the desired result is achieved. | ¶22(x) | col. 12:10-17 |
Identified Points of Contention
- Scope Questions: The case may raise the question of whether the claim language, which describes a general-purpose method for constructing database queries, can be properly construed to cover the specific functionality of the accused "Connector" software, which is described as a tool for integrating CRM and SIS data for "lead life-cycle management" (Compl. p. 6, Fig. 2).
- Technical Questions: A key technical question is what evidence the complaint provides that the accused product performs the dynamic filtering recited in the claims. Specifically, it raises the question of whether the "Connector" interface actively "updat[es] said set of displayed operators" (Claim 1d) and "updat[es] said displayed set of entries" (Claim 1f) in real-time to "prevent" the user from creating a null-result query, as opposed to merely validating a query after it has been fully constructed.
V. Key Claim Terms for Construction
The Term: "updating said set of displayed operators" (Claim 1d)
Context and Importance: This term appears central to the inventive concept of guiding the user by dynamically pruning invalid choices. Infringement analysis will likely focus on whether the accused product's interface actively and preemptively removes operators from a displayed list based on a user's prior selections. Practitioners may focus on this term because the difference between dynamically updating a list of choices and simply flagging an error after submission is a critical technical distinction.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent speaks generally of applying the method to various logical operations, including "Boolean and SQL type searches" and others, which may support a construction that is not tied to one specific user interface manifestation ('270 Patent, col. 2:27-33).
- Evidence for a Narrower Interpretation: The specification’s examples show a direct and visible change to the available options, such as when the word "paprika" is "eliminated" from a word-list because it cannot satisfy the "NOT" condition being constructed ('270 Patent, col. 7:35-37). This may support a narrower construction requiring an explicit, real-time removal of options from the user's view.
The Term: "valid results" (Claim 1c, 1h, 1i)
Context and Importance: The meaning of "valid" is fundamental, as the patent’s stated goal is to avoid null results and ensure the user can only construct queries that produce "valid results." The dispute may turn on whether "valid" simply means "not null" or implies a higher standard of relevance.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent repeatedly frames the problem as avoiding "null responses," "null values," or "no documents found" ('270 Patent, col. 2:26-27; col. 3:1-3). This suggests a "valid result" is any result that is not null. Claim 1d requires updating operators to "produce at least one valid result," reinforcing the idea that validity is met by the existence of a single result.
- Evidence for a Narrower Interpretation: The complaint itself uses the phrase "producing valid results (e.g., message results)" (Compl. ¶22(ii)), which could suggest that in the context of the accused product, a "valid result" has a more specific meaning tied to the system's purpose. However, the intrinsic evidence from the patent itself points more strongly toward "valid" meaning non-null.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement, asserting that Defendant encourages infringement by "making, using, importing, offering for sale, and/or selling" the accused services and providing them to end-users (Compl. ¶27). It further alleges Defendant takes active steps such as "advertising an infringing use" (Compl. ¶30).
- Willful Infringement: The complaint alleges willfulness will begin upon Defendant’s receipt of the complaint, establishing post-suit knowledge (Compl. ¶26). It also alleges pre-suit willful blindness, based on an alleged "practice of not performing a review of the patent rights of others" before launching products (Compl. ¶31).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope: can the elements of the asserted method claim, which describe a general-purpose, interactive database query-building process, be construed to read on the specific, purpose-built functionalities of Defendant's CRM and SIS data integration software?
- A key evidentiary question will be one of technical operation: does the accused "Connector" product actually perform the dynamic, preemptive filtering required by the claims—specifically, by updating the visible lists of available operators and entries to guarantee a non-null result—or does it use a different method, such as post-hoc validation, to handle user-created queries?