DCT

3:24-cv-03193

Linfo IP LLC v. TEKZOOM Inc

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Key Events
Complaint
complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:24-cv-03193, N.D. Tex., 12/19/2024
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Texas corporation with a regular and established place of business in the district, conducts substantial business in the forum, and has committed alleged acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s website, which offers products for sale and includes user review functionalities, infringes a patent related to methods for discovering and presenting information within text content.
  • Technical Context: The technology concerns computer-assisted methods for analyzing large volumes of text (such as product reviews) to identify, categorize, and selectively display or highlight information based on specific attributes like sentiment.
  • Key Procedural History: The complaint notes that Plaintiff and its predecessors have entered into settlement licenses related to its patents with other entities, but asserts these licenses did not grant rights to produce a patented article and thus do not trigger marking requirements under 35 U.S.C. § 287. Plaintiff is identified as a non-practicing entity.

Case Timeline

Date Event
2011-12-09 U.S. Patent No. 9,092,428 Earliest Priority Date
2015-07-28 U.S. Patent No. 9,092,428 Issued
2024-12-19 Complaint Filed

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 addresses the problem of "information overload," where users face difficulty finding specific, needed information within large amounts of unstructured text, such as numerous online product reviews for a single item. (’428 Patent, col. 1:12-25). For example, a user may want to find all negative comments about a hotel's "room service" without reading hundreds of reviews. ('428 Patent, col. 1:25-38).
  • The Patented Solution: The invention is a computer-assisted method that analyzes text by tokenizing it, associating grammatical, semantic, and contextual attributes to the tokens, and providing a user interface to act upon them. ('428 Patent, Abstract). The system allows a user to select an attribute (e.g., "positive opinion") and an action (e.g., "highlight"), and then automatically performs that action on all relevant text segments, including analyzing the context to correctly interpret phrases like "not good." ('428 Patent, col. 3:16-29; col. 13:12-32). This is illustrated in a flowchart where the system determines if a term's context alters its pre-assigned connotation. ('428 Patent, Fig. 6).
  • Technical Importance: This approach provides a tool for users to more quickly and accurately locate specific information, particularly subjective opinions, within large text datasets, thereby saving considerable time and effort compared to manual review or simple keyword searching. ('428 Patent, col. 2:55-62).

Key Claims at a Glance

  • The complaint asserts infringement of one or more of claims 1-20. (Compl. ¶9). Independent claim 1 is central.
  • Independent Claim 1:
    • obtaining a text content comprising words or phrases;
    • selecting a first semantic attribute and a second semantic attribute for users to select from;
    • identifying words or phrases in the text content associated with the first or second semantic attribute;
    • displaying an actionable user interface object associated with a label representing the name of the attribute;
    • allowing the user to select an attribute; and
    • performing an action (e.g., extracting, displaying, hiding, or highlighting) on the word or phrase associated with the user-selected attribute.

III. The Accused Instrumentality

Product Identification

Functionality and Market Context

  • The complaint alleges Defendant "maintains, operates, and administers a system with methods and user interface for discovering information in a text content and extracting and presenting the information." (Compl. ¶9). It further references "review platforms" on Defendant's website and "product instruction manuals" that allegedly instruct customers on how to use the infringing services. (Compl. ¶12). The complaint does not provide specific details on how these review platforms or other website features operate. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a "preliminary exemplary table attached as Exhibit B" to support its infringement allegations, but this exhibit was not included with the public filing. (Compl. ¶10). The complaint itself does not contain a claim chart or detailed factual allegations mapping specific features of the accused website to the elements of the asserted claims. The infringement theory is described in general terms, alleging that Defendant's system for discovering and presenting information in text content on its website infringes claims of the ’428 patent. (Compl. ¶9).

  • Identified Points of Contention:
    • Scope Questions: A central question will be whether the accused website’s search, filtering, or review-sorting functionalities perform the specific steps of claim 1. For example, does a standard e-commerce filter (e.g., sort by "brand" or "price") qualify as selecting a "semantic attribute" in the manner claimed by the patent, which provides examples centered on linguistic analysis like opinion and sentiment?
    • Technical Questions: What evidence does the complaint provide that the accused website performs context-aware analysis, a key feature described in the patent? The patent distinguishes its invention by its ability to understand that "not good" is a negative opinion, a more complex operation than simple keyword matching. ('428 Patent, col. 13:20-41). The complaint does not allege facts demonstrating that the accused system performs this type of contextual analysis.

V. Key Claim Terms for Construction

  • The Term: "semantic attribute"
  • Context and Importance: This term is the core of the claimed invention, defining the basis upon which information is categorized and acted upon. The breadth of its construction will be critical; a narrow definition may exclude the functionality of many standard e-commerce websites, while a broad one could potentially read on common filtering tools. Practitioners may focus on this term because the infringement case appears to depend on whether Defendant's website functionality falls within its scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that attributes "can be grammatical, semantic, contextual, or topical, etc." ('428 Patent, col. 6:8-9). It also lists "drug names" as an attribute example, which could suggest a broader, topic-based interpretation beyond sentiment. ('428 Patent, col. 6:18-19).
    • Evidence for a Narrower Interpretation: The patent's abstract, detailed description, and figures heavily emphasize "opinion" as the primary example of a semantic attribute, with values like "positive" or "negative." ('428 Patent, col. 8:29-34; col. 9:1-6; Figs. 7, 9A, 9B, 11). A defendant could argue that the term, in the context of the overall disclosure, is limited to this type of linguistic or sentiment analysis, rather than general data filtering.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is premised on Defendant allegedly encouraging and instructing customers on how to use its services to infringe. (Compl. ¶11). Contributory infringement is alleged on the basis that Defendant's product is not a staple commercial product and that Defendant had reason to believe its customers' use would be infringing. (Compl. ¶12).
  • Willful Infringement: The complaint alleges Defendant has known of the ’428 patent "from at least the filing date of the lawsuit." (Compl. ¶11, fn. 1; ¶12, fn. 2). This allegation appears to support a claim for post-filing willfulness, with Plaintiff reserving the right to amend if pre-suit knowledge is discovered. (Compl. ¶11, fn. 1).

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

  1. A core issue will be one of definitional scope: Can the term "semantic attribute," which is heavily exemplified in the patent through linguistic and sentiment analysis (e.g., positive/negative opinions), be construed broadly enough to cover the more conventional product filtering or sorting functionalities typically found on an e-commerce website?
  2. A key issue will be one of evidentiary sufficiency: As the complaint lacks specific factual allegations mapping accused features to claim limitations, the case will turn on whether Plaintiff can produce evidence in discovery demonstrating that the accused website performs the specific, multi-step process of claim 1, particularly the context-aware analysis that distinguishes the invention from simple keyword searching.