Linfo IP LLC v. Carpartscom Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: CarParts.com, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 3:24-cv-00199, N.D. Tex., 01/26/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas because Defendant maintains a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s system and user interface for presenting product information infringe a patent related to discovering, organizing, and displaying information within text content.
• Technical Context: The technology at issue involves computer-assisted methods for analyzing unstructured text, such as user reviews, to identify and categorize information based on semantic attributes, and presenting it to users in an organized manner.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity with no products to mark.

Case Timeline

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 volumes of unstructured text, such as numerous online product or hotel reviews (’428 Patent, col. 1:12-25). For instance, a user may wish to find all negative comments about "room service" at a hotel but finds it time-consuming to manually read hundreds of reviews to do so (’428 Patent, col. 1:25-38).
• The Patented Solution: The invention describes a computer-based system that analyzes text to identify grammatical, semantic, or contextual attributes of words and phrases. It then provides user interface objects that allow a user to select a specific attribute (e.g., "positive opinion") and an action (e.g., "highlight" or "extract"), causing the system to manipulate the display of text meeting that criterion (’428 Patent, Abstract; col. 3:16-29). Figure 1 illustrates a system where a user interface (150) contains an "Attribute Selector" (160) and an "Action Selector" (170) that act on labeled text content (’428 Patent, Fig. 1).
• Technical Importance: This approach provides a tool to help users quickly locate and digest specific information from large text corpora, making user-generated content more efficiently accessible and analyzable (’428 Patent, col. 1:55-64).

Key Claims at a Glance

• The complaint asserts claims 1-20 (Compl. ¶8). Independent claim 1 is representative.
• Independent Claim 1 recites a computer-assisted method comprising the steps of:
  • Obtaining a text content comprising words or phrases.
  • Selecting a first semantic attribute and a second semantic attribute for user selection, where each is associated with a name or description.
  • Identifying words or phrases in the text content associated with the selected semantic attributes.
  • Displaying an actionable user interface object associated with a label representing the name/description of the attributes.
  • Allowing the user to select one of the names/descriptions as a user-specified attribute.
  • Performing an action (e.g., extracting, displaying, hiding, highlighting) on the words or phrases associated with the user-specified attribute.
• The complaint does not explicitly reserve the right to assert dependent claims, but the general assertion of claims 1-20 implies they are at issue (Compl. ¶8).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Defendant’s "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶8). This appears to be the CarParts.com website and associated services.

Functionality and Market Context

The complaint alleges that Defendant "maintains, operates, and administers" a system that infringes the ’428 patent (Compl. ¶8). However, the complaint does not provide specific details on the technical functionality of the accused system or how its features operate. It alleges Defendant benefits commercially from using the claimed inventions (Compl. ¶8). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s system infringes one or more of claims 1-20 of the ’428 patent (Compl. ¶8). The complaint states that support for these allegations may be found in a preliminary claim chart attached as Exhibit B (Compl. ¶9). As this exhibit was not provided with the complaint, a claim chart summary cannot be constructed.

The narrative infringement theory is that Defendant's system for discovering and presenting information performs the patented method (Compl. ¶8). The complaint does not, within its narrative body, map specific features of the accused CarParts.com system to the elements of the asserted claims.

Identified Points of Contention

• Scope Questions: A central question will be whether any feature of the accused system can be characterized as allowing a user to select from a "first semantic attribute and a second semantic attribute" as required by claim 1. The dispute may focus on whether general search filters (e.g., by product type or brand) meet this limitation, or if the claim requires more sophisticated linguistic or opinion-based choices as described in the patent's specification.
• Technical Questions: A key evidentiary question is what specific element of the accused system constitutes the "actionable user interface object" for selecting between two distinct semantic attributes. The complaint does not identify any such object, raising the question of whether the accused system performs this claimed step at all.

V. Key Claim Terms for Construction

"semantic attribute" (Claim 1)

• Context and Importance: This term is the core of the invention. Its construction will determine the types of information filtering and display systems that fall within the scope of the claims. Practitioners may focus on this term because the infringement case depends on whether features of the accused system can be fairly characterized as operating on "semantic attributes."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states the invention associates "grammatical, semantic, and contextual attributes to the tokens" (’428 Patent, col. 3:20-22). It provides varied examples of semantic attributes, including a drug name, its function as a "pain-reliever," or its status as an "over-the-count drug" (’428 Patent, col. 8:25-29), which could support a broad definition covering various types of categorization.
  • Evidence for a Narrower Interpretation: Dependent claim 3 narrows the "semantic category" to "sentiment or opinion" and the attributes to "positive opinion versus a negative option" (’428 Patent, col. 16:26-32). A defendant may argue that this, along with the specification's heavy focus on analyzing user opinions (e.g., "good" vs. "bad"), suggests the term "semantic attribute" should be construed to require this type of qualitative or linguistic analysis, rather than simple topical classification.

"actionable user interface object" (Claim 1)

• Context and Importance: This term defines the mechanism through which a user interacts with the system to trigger the patented method. The existence and function of such an object in the accused system will be a critical factual issue.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes this element broadly, stating it "can also be a set of radio buttons, a slider, or any sort of object that allows a user to selectively indicate an option" (’428 Patent, col. 9:1-3). This language suggests a wide variety of standard UI components could meet the limitation.
  • Evidence for a Narrower Interpretation: Claim 1 requires the object to be associated with labels "representing the first name or description or the second name or description" of two distinct semantic attributes. A defendant might argue this requires a specific UI that explicitly presents at least two named, selectable choices (e.g., a button for "show positive comments" and a button for "show negative comments," as in Fig. 9A), and that a general-purpose search bar or a single-purpose filter would not meet this limitation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant "actively encouraged or instructed others (e.g., its customers...)" to use its services in a way that infringes the ’428 Patent (Compl. ¶10). It also alleges contributory infringement on a similar basis (Compl. ¶11).
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’428 patent "from at least the filing date of the lawsuit" (Compl. ¶10, ¶11). The complaint makes no allegation of pre-suit knowledge but reserves the right to amend if such knowledge is discovered (Compl. ¶10, n.1).

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

1. A central issue will be one of definitional scope: can the claim term "semantic attribute" be construed broadly enough to read on the types of product or category filtering allegedly used by CarParts.com, or will the court limit its meaning to the more complex, opinion-based analysis (e.g., positive vs. negative sentiment) detailed in the patent’s specification?
2. A key evidentiary question will be one of operational correspondence: can the plaintiff demonstrate that the accused system possesses a specific "actionable user interface object" that allows users to select between at least two distinct, named semantic attributes to perform an action, or is there a fundamental mismatch between the system’s actual operation and the specific steps required by the asserted claims?