DCT

3:22-cv-02761

R2 Solutions LLC v. Hilton Domestic Operating Co Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:22-cv-02761, N.D. Tex., 12/12/2022
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district, including making, using, offering to sell, and selling the accused products and services.
  • Core Dispute: Plaintiff alleges that Defendant’s online hotel search and booking platform, along with its backend data analytics systems, infringe six patents related to search engine technology, data analytics, and user interface design.
  • Technical Context: The patents-in-suit, originally filed by Yahoo! Inc., relate to foundational technologies for improving the relevance, presentation, and efficiency of online search and large-scale data processing.
  • Key Procedural History: The complaint alleges that Plaintiff attempted to engage Defendant in licensing discussions for over a year prior to the suit. It also references a prior lawsuit filed by Plaintiff against Hilton-related entities in the Eastern District of Texas concerning four of the same patents, which was dismissed without prejudice by agreement approximately three months before the current action was filed.

Case Timeline

Date Event
2006-08-10 '317 Patent Priority Date
2006-10-05 '610 Patent Priority Date
2007-01-10 '329 Patent Priority Date
2007-09-28 '272 Patent Priority Date
2009-07-31 '157 Patent Priority Date
2010-04-13 '329 Patent Issue Date
2012-05-29 '610 Patent Issue Date
2012-06-26 '317 Patent Issue Date
2012-12-25 '157 Patent Issue Date
2014-12-17 '097 Patent Priority Date
2017-10-31 '097 Patent Issue Date
2019-01-08 '272 Patent Issue Date
2021-06-17 Plaintiff sends first licensing negotiation letter to Defendant
2022-04-28 Plaintiff files prior lawsuit in E.D. Texas
2022-09-15 Prior lawsuit dismissed without prejudice
2022-12-12 Complaint Filing Date

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

U.S. Patent No. 8,341,157 - "System and Method for Intent-Driven Search Result Presentation"

  • Patent Identification: U.S. Patent No. 8,341,157, "System and Method for Intent-Driven Search Result Presentation," issued December 25, 2012.

The Invention Explained

  • Problem Addressed: Traditional search engines that treat a user's query as a simple "bag of words" may return irrelevant results because they fail to understand the user's underlying purpose or goal (Compl. ¶21; ’157 Patent, col. 4:1-15).
  • The Patented Solution: The invention proposes a system that analyzes a query to determine the user's likely "intent" (e.g., to purchase, to research, to find a location). This determined intent is then used to customize how search results are ranked and displayed. For example, a result can be given a custom title, abstract, or URL parameters specifically tailored to the user's inferred intent, thereby making the results more useful (Compl. ¶¶22-23; ’157 Patent, col. 4:16-26). The specification describes an intent as "a mapping from many combinations of keywords to a relatively small set of common goals" pursued by users ('157 Patent, col. 9:44-48).
  • Technical Importance: The technology represents a shift from simple keyword matching toward a more semantic understanding of search queries, aiming to significantly enhance the relevance and utility of search results (Compl. ¶26).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶60).
  • The essential elements of claim 1 include:
    • Receiving a query with at least one token;
    • Analyzing the query to identify a keyword;
    • Determining a "plurality of intents" from the keyword;
    • Classifying the query into at least one of the intents;
    • Identifying data objects that match the keyword;
    • Assigning at least one intent to some of the data objects;
    • Ranking the data objects; and
    • Building a result where at least one display entry is "customized to a respective assigned intent."
  • The complaint also asserts dependent claims 2-5 and 7-10 (Compl. ¶60).

U.S. Patent No. 7,698,329 - "Method for Improving Quality of Search Results by Avoiding Indexing Sections of Pages"

  • Patent Identification: U.S. Patent No. 7,698,329, "Method for Improving Quality of Search Results by Avoiding Indexing Sections of Pages," issued April 13, 2010.

The Invention Explained

  • Problem Addressed: The patent addresses "search engine spamming," where malicious actors use techniques to trick search algorithms into ranking irrelevant or low-quality pages highly (Compl. ¶27; ’329 Patent, col. 2:6-17). A user searching for "digital camera reviews," for example, might be led to a page with no reviews but a "plethora of keywords and links to other stores" ('329 Patent, col. 2:18-27).
  • The Patented Solution: The invention describes a method where a document is parsed into "recall sections" and "no-recall sections." Terms in "no-recall sections" are not used by the search engine to initially find (or "recall") the document. However, the content of these "no-recall sections" is subsequently used as an input for ranking the document. This dual-use structure prevents spammers from hiding negative ranking factors (like excessive ads or low-quality links) in a section of the page that is still analyzed for ranking purposes (Compl. ¶¶28, 31; ’329 Patent, col. 3:7-31).
  • Technical Importance: This approach provides a more robust method for evaluating page quality by separating the signals used for document recall from the full set of signals used for final ranking, thereby thwarting a common spamming technique (Compl. ¶¶30-31).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶73).
  • The essential elements of claim 1 include:
    • Ranking a plurality of documents recalled by a search engine;
    • Wherein some of the documents contain at least one section "not used by said search engine for recall" and at least one section that is used for recall; and
    • Wherein the ranking is based, at least in part, on the section "not used by said search engine to recall documents."
  • The complaint also asserts dependent claims 4-5, 8, and 11-12 (Compl. ¶73).

U.S. Patent No. 8,209,317 - "Method and Apparatus for Reconstructing a Search Query"

  • Patent Identification: U.S. Patent No. 8,209,317, "Method and Apparatus for Reconstructing a Search Query," issued June 26, 2012.
  • Technology Synopsis: The patent addresses the difficulty of entering full search queries on devices with limited input capabilities, like mobile phones (Compl. ¶32; ’317 Patent, col. 1:44-53). It describes a system that receives an abbreviated or incomplete "partial query" and reconstructs the intended "full query" by referencing a database of previously submitted queries (Compl. ¶33).
  • Asserted Claims: Independent claim 1 is asserted, along with dependent claims 2, 8-10, and 12 (Compl. ¶86).
  • Accused Features: The complaint alleges that Hilton's search platform, which accepts user search terms for hotels, infringes by reconstructing full queries from partial user inputs (Compl. ¶¶85-86, 92).

U.S. Patent No. 9,805,097 - "Method and System for Providing a Search Result"

  • Patent Identification: U.S. Patent No. 9,805,097, "Method and System for Providing a Search Result," issued October 31, 2017.
  • Technology Synopsis: The patent addresses the problem of limited user engagement with traditional, top-to-bottom list-based search results (Compl. ¶35; ’097 Patent, col. 1:30-40). The proposed solution is to display content items in a "framed structure" (e.g., a grid of thumbnails) where a correspondence is determined between the content items and sub-components of the frame, thereby creating a more visually engaging presentation (Compl. ¶36).
  • Asserted Claims: Independent claim 1 is asserted, along with dependent claims 3, 8-10, and 17-20 (Compl. ¶99).
  • Accused Features: The complaint alleges that Hilton's search result display, which is depicted as including a map and list of hotels, infringes by presenting results in a framed structure (Compl. ¶¶98-99, 105).

U.S. Patent No. 10,176,272 - "System and Method of Automatically Sizing and Adapting a Widget to Available Space"

  • Patent Identification: U.S. Patent No. 10,176,272, "System and Method of Automatically Sizing and Adapting a Widget to Available Space," issued January 8, 2019.
  • Technology Synopsis: The patent addresses the issue of fixed-size web widgets causing layout problems on pages with variable dimensions (Compl. ¶38; ’272 Patent, col. 1:40-54). The invention is a "smart-sizing" widget that dynamically adapts by receiving structural data (like browser size), and then reducing its size, removing elements, and enlarging remaining elements to optimally fit the available space based on pre-defined constraints (Compl. ¶39).
  • Asserted Claims: Independent claims 1 and 10 are asserted (Compl. ¶112).
  • Accused Features: The complaint alleges that Hilton's booking widget, which allows users to select dates and other options, infringes by automatically resizing and adapting its display elements (Compl. ¶¶111-112, 118).

U.S. Patent No. 8,190,610 - "MapReduce for Distributed Database Processing"

  • Patent Identification: U.S. Patent No. 8,190,610, "MapReduce for Distributed Database Processing," issued May 29, 2012.
  • Technology Synopsis: The patent addresses the inefficiency of conventional MapReduce frameworks in processing data from heterogeneous sources with different data schemas (Compl. ¶41; ’610 Patent, col. 3:9-20). The solution is an architecture using "data groups" that allows different mapping functions to be applied to data from different sources, while enabling a single reduce function to process the combined intermediate data based on a common key, thus facilitating joins across disparate datasets (Compl. ¶¶42-43).
  • Asserted Claims: Independent claims 1-5 and 17-21 are asserted (Compl. ¶125).
  • Accused Features: The complaint accuses Hilton's "Data Analytics Instrumentalities," which allegedly employ technologies like Apache Hadoop and Spark, of infringing by processing and merging data from heterogeneous sources (Compl. ¶¶6, 124-125).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two broad categories of accused instrumentalities:
    1. Accused Hilton Search Instrumentalities: The front-end and back-end systems of Hilton's online hotel locator and travel booking services, as implemented on its website and mobile application (Compl. ¶5).
    2. Accused Hilton Data Analytics Instrumentalities: Backend data analytics systems allegedly utilizing technologies such as Cloudera, Apache Hadoop, Hive, and Spark to process and analyze data (Compl. ¶6).

Functionality and Market Context

  • The Search Instrumentalities provide the core functionality for Hilton's online business, allowing users to input search queries (e.g., location, travel dates) and receive ranked, interactive results for booking hotel stays (Compl. ¶5). The complaint provides a screenshot of the Hilton website's search interface, which prompts the user with "Where to?" and provides fields for location and dates (Compl. ¶66, p. 24). A second screenshot shows a search results page with a map view alongside a list of hotels, including sorting and filtering options (Compl. ¶118, p. 33).
  • The Data Analytics Instrumentalities are alleged to perform backend data processing, including mapping, reducing, merging, and joining data that may have different schemas (Compl. ¶6). The complaint alleges these instrumentalities are integral to Hilton's operations as a major participant in the travel industry (Compl. ¶52).

IV. Analysis of Infringement Allegations

The complaint asserts infringement of all six patents-in-suit but relies on incorporating by reference external claim chart exhibits (Ex. 7-12) that are not attached to the filed complaint (Compl. ¶¶ 61, 74, 87, 100, 113, 126). The body of the complaint itself contains only high-level and conclusory allegations of infringement without providing a detailed, element-by-element mapping of accused functionalities to the claims.

  • Narrative Infringement Theories and Points of Contention:
    • For the '157 Patent (Intent-Driven Search), '329 Patent (No-Recall Ranking), and '317 Patent (Query Reconstruction), the complaint's narrative theory is that the standard operation of the Hilton search platform infringes. For each of these, the complaint provides as evidence a nearly identical screenshot of the Hilton website's main search bar (Compl. ¶¶ 66, 79, 92). A primary point of contention will be evidentiary: what proof can be shown that Hilton's backend systems perform the specific and distinct technical steps recited in each patent—such as classifying queries into a "plurality of intents" ('157 Patent), or using "no-recall sections" for ranking ('329 Patent)—when the only evidence provided is a generic, public-facing user interface?
    • For the '097 Patent (Framed Structure) and '272 Patent (Adaptive Widget), the infringement theory is more directly supported by visual evidence. The complaint alleges that the layout of Hilton's search results page, which presents a map and hotel listings, constitutes the claimed "framed structure" ('097 Patent), and that the booking interface elements constitute the claimed adaptive "widget" ('272 Patent). The screenshot on page 33 of the complaint, showing a results page with a map, a list, and sorting options, provides a visual basis for these allegations (Compl. ¶118). The key technical question will be whether the functionality of Hilton's interface precisely matches the specific structural and functional limitations defined in the claims.
    • For the '610 Patent (MapReduce), the infringement theory is directed at Hilton's backend data analytics systems. The complaint alleges these systems use tools like Hadoop and Spark to merge heterogeneous data, thereby practicing the claimed method (Compl. ¶¶ 6, 124-125). The central point of contention here will be technical and evidentiary: does the operation of standard big-data tools like Hadoop inherently practice the specific "data group" architecture and processing flow claimed in the patent, and what evidence can be produced to demonstrate this?

V. Key Claim Terms for Construction

U.S. Patent No. 8,341,157

  • The Term: "a plurality of intents" (from claim 1)
  • Context and Importance: This term is the central concept of the '157 Patent. Its construction will determine whether a general query categorization system infringes, or if a more specific, structured approach is required. Practitioners may focus on this term because the patent's novelty rests on moving beyond keyword matching to a system that understands and acts on user "intent."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a wide-ranging list of example intents, such as "research, purchase, dealer, support, or reviews" and "directions, reviews, phone, hours-of-operation" ('157 Patent, col. 9:51-55, cited in Compl. ¶22). This could support an argument that any system that categorizes user goals meets the limitation.
    • Evidence for a Narrower Interpretation: The specification explicitly states that "An intent is a mapping from many combinations of keywords to a relatively small set of common goals" ('157 Patent, col. 9:44-48, cited in Compl. ¶22). This language suggests a specific technical structure—a "mapping"—rather than a general concept, potentially narrowing the claim's scope to systems that implement such a defined structure.

U.S. Patent No. 7,698,329

  • The Term: "section that is not used by said search engine for recall" (from claim 1)
  • Context and Importance: This term defines the core mechanism of the '329 Patent. The dispute will likely center on whether Hilton's data processing architecture creates and uses such delineated "no-recall sections."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification notes that a "no-recall section may be identified by analyzing section content rather than examining only delimiters" ('329 Patent, col. 3:15-18, cited in Compl. ¶28). This may support a theory that functionally separating data sources (e.g., using one database for an initial keyword search and a different one for ranking signals) meets the definition, even without explicit tags in a single document.
    • Evidence for a Narrower Interpretation: The primary embodiment described and illustrated involves demarcating sections within a single HTML document using a specific tag, such as <div class="robots-noindex"> ('329 Patent, Fig. 2; col. 3:13-15). This could support a narrower construction requiring a deliberate, structural partitioning within a single data object.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for all six patents. The alleged inducing acts consist of Hilton instructing and encouraging its customers to use the accused search platform by prominently displaying the search interface on its website and directing users to its "official" booking channels (Compl. ¶¶ 66-67, 79-80, 92-93, 105-106, 118-119).
  • Willful Infringement: The complaint alleges Defendant had pre-suit knowledge of the '157, '329, '317, and '610 patents based on a series of licensing outreach communications beginning in June 2021 and notice from a prior lawsuit filed in April 2022 (Compl. ¶¶ 49-55). For the '097 and '272 patents, the complaint alleges knowledge only as of the filing of the current lawsuit, which would only support a claim for post-suit willfulness (Compl. ¶¶ 103, 116).

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

  • Evidentiary Sufficiency: The complaint's primary reliance on conclusory allegations and unattached exhibits raises a fundamental evidentiary question: what specific, non-public evidence can Plaintiff discover and present to demonstrate that Hilton's internal, backend systems actually perform the complex, multi-step processes recited in the claims, particularly for patents like the '157 (intent-driven search) and '329 (no-recall ranking)?
  • Technical Scope and Equivalence: A core technical question will be one of scope, especially for the data processing patents. For the '610 patent, can the specific "data group" architecture for MapReduce be read onto the general use of modern big-data tools like Hadoop and Spark, or is there a fundamental mismatch between the patented architecture and the accused systems?
  • Interface vs. Functionality: The complaint repeatedly uses screenshots of Hilton's public-facing user interface to support infringement allegations for patents covering distinct backend technologies. A key legal and factual question will be whether this high-level interface provides a plausible basis for inferring the existence of the specific, complex, and non-visible backend functions required by the claims.