Linfo IP LLC v. Air Oasis LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Air Oasis, LLC (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 3:24-cv-03190, N.D. Tex., 12/19/2024
• 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, has committed alleged acts of infringement there, and conducts substantial business in the forum.
• Core Dispute: Plaintiff alleges that the user review platform on Defendant’s website infringes a patent related to systems and methods for automatically analyzing, categorizing, and presenting information from text content.
• Technical Context: The technology at issue falls within the field of natural language processing, addressing the challenge of extracting specific, structured information (such as user opinions) from large volumes of unstructured text.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity. It also notes that Plaintiff and its predecessors have entered into prior settlement licenses and proactively argues that these agreements do not trigger patent marking obligations under 35 U.S.C. § 287(a).

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"

The Invention Explained

• Problem Addressed: The patent’s background section identifies the problem of "data overload," where it is difficult and time-consuming for a user to find specific information within large amounts of unstructured text, such as locating all negative comments about a particular feature in hundreds of online product reviews (ʼ428 Patent, col. 1:12-38).
• The Patented Solution: The invention is a computer-assisted system that automatically analyzes text to identify and associate terms with specific attributes (e.g., positive or negative sentiment). It then provides a user with interface objects (e.g., buttons or menus) to select an attribute and perform an action, such as filtering a long list of reviews to "show only the positive comments" or highlighting all terms related to a specific topic, thereby making relevant information easier to find and digest (ʼ428 Patent, col. 3:1-15; Abstract).
• Technical Importance: The patented approach provides a tool for automated sentiment analysis and topic extraction, addressing a key challenge in managing and deriving insights from the growing volume of user-generated online content (ʼ428 Patent, col. 1:12-47).

Key Claims at a Glance

• The complaint asserts independent claims 1, 14, and 18. The elements of independent method claim 1 are:
  • obtaining, by a computer system, a text content comprising one or more words or phrases or sentences, each being a term or an instance of a term;
  • selecting a first semantic attribute and a second semantic attribute for users to select from, wherein the first semantic attribute or the second semantic attribute includes an attribute type or attribute value; wherein the first semantic attribute is associated with a first name or description, and the second semantic attribute is associated with a second name or description;
  • identifying a words or phrases in the text content associated with the first semantic attribute or the second semantic attribute;
  • displaying an actionable user interface object, wherein the actionable user interface object is associated with a label representing the first name or description or the second name or description;
  • allowing the user to select the first name or description or the second name or description as a user-specified or user-desired attribute; and
  • performing, by the computer system, an action on the word or phrase associated with the user-specified or user-desired semantic attribute, wherein the action includes at least extracting, displaying, storing, showing or hiding, or highlighting or un-highlighting the word or phrase.
• The complaint asserts claims 1-20, which includes all dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The "review platforms" located on Defendant's website, specifically citing the webpage for the "iAdaptAir-2-0-medium" product (Compl. ¶12).

Functionality and Market Context

• The complaint alleges the accused instrumentality is a "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶9). It further alleges the system provides users with "interface objects to act on the discovered information, such as extracting, displaying, or hiding, or highlighting, or un-highlighting words or phrases in a text content" (Compl. ¶8). The complaint does not provide further technical detail regarding the specific operation of the accused review platform. It also does not provide sufficient detail for analysis of the accused instrumentality's commercial importance or market positioning.

IV. Analysis of Infringement Allegations

The complaint references a "preliminary exemplary table" as Exhibit B to support its infringement allegations but does not include the exhibit in the filing (Compl. ¶10). The complaint’s narrative infringement theory is that Defendant’s operation of its website's review platform constitutes use of a system that practices the patented method (Compl. ¶9). The allegations are framed in general terms, asserting that Defendant’s system performs functions such as "discovering information in a text content and extracting and presenting the information" (Compl. ¶9). No specific features of the accused platform, such as screenshots of filtering options or descriptions of interactive elements, are provided to substantiate how the platform meets the specific limitations of the asserted claims.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Question: The primary point of contention will be factual and evidentiary. The complaint makes conclusory allegations of infringement without providing specific facts showing how the accused review platform on Defendant’s website actually operates. A key question for discovery will be whether the platform possesses the specific functionality recited in the claims, such as the ability to identify and act upon distinct "semantic attributes."
  • Scope Questions: A central dispute may arise over whether the functionality of the accused system, once revealed, falls within the scope of the claims. For instance, a question for the court may be whether a generic "sort by star rating" feature, common on e-commerce sites, meets the claim limitation of selecting between a "first semantic attribute and a second semantic attribute" (e.g., 'positive opinion' and 'negative opinion') and performing an action thereon.

V. Key Claim Terms for Construction

• The Term: "semantic attribute"

• Context and Importance: This term is fundamental to the invention, as the entire method is predicated on identifying and acting upon these attributes. The outcome of the case may depend on whether the features of the accused system are found to constitute "semantic attributes." Practitioners may focus on this term because its construction will determine whether the claims cover simple data sorting or require more sophisticated linguistic analysis.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that attributes can be "grammatical, semantic, contextual, or topical, etc.," suggesting a wide of categories (ʼ428 Patent, col. 6:8-9). Examples include not just opinions but also whether a term is the name of a drug (ʼ428 Patent, col. 7:25-29).
  • Evidence for a Narrower Interpretation: The patent’s background and numerous examples focus heavily on the specific problem of analyzing user opinions, repeatedly using "positive" and "negative" comments as the primary embodiment (ʼ428 Patent, col. 9:1-4; Figs. 9A, 11). This could support an argument that the term should be construed more narrowly in the context of sentiment analysis.

• The Term: "actionable user interface object"

• Context and Importance: This term defines the mechanism through which a user interacts with the system to implement the patented method. The infringement analysis will turn on whether the UI elements on Defendant's website meet this definition.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes the object broadly as a "dropdown menu, clickable buttons, radio buttons, or any sort of interface objects that allow a user to specify an option" (ʼ428 Patent, col. 11:47-50).
  • Evidence for a Narrower Interpretation: The figures depict specific, labeled controls for performing complex actions, such as a button to "Extract important terms and display in topic tree" (ʼ428 Patent, Fig. 4, 420) or checkboxes to "Show positive comments only" (ʼ428 Patent, Fig. 9A, 910). This may support a narrower construction requiring a dedicated control element whose label explicitly corresponds to the claimed attributes and actions.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant encourages and instructs customers on how to use its services in an infringing manner (Compl. ¶11). It also alleges contributory infringement, stating that the accused platform is not a staple commercial product and that its only reasonable use is an infringing one (Compl. ¶12).
• Willful Infringement: Plaintiff alleges that Defendant has known of the ʼ428 patent "from at least the filing date of the lawsuit" and seeks a declaration of willful infringement and treble damages based on this post-suit knowledge (Compl. ¶11; Prayer for Relief ¶e).

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

• A central issue will be one of evidentiary sufficiency: does the accused user review platform, as it actually operates, practice the specific steps of the asserted claims? The complaint’s conclusory allegations will require substantiation through discovery to demonstrate that the defendant's system performs functions beyond generic content display.
• The case may also turn on a question of definitional scope: can the term "semantic attribute", which the patent illustrates with examples of linguistic sentiment analysis, be construed to cover more conventional e-commerce sorting functions, such as filtering by a numerical star rating? The court’s construction of this and other key terms will be critical in defining the boundaries of the patent’s claims.