Linfo IP LLC v. Hempz Tech LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Hempz Technologies, LLC (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 3:25-cv-01903, N.D. Tex., 07/22/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has 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 Defendant’s e-commerce system and user interface infringe a patent related to organizing and presenting unstructured data objects based on relevance.
• Technical Context: The technology addresses information overload by providing systems to filter, sort, and display large amounts of data (e.g., search results, social media feeds, files) according to user-defined or system-inferred importance.
• Key Procedural History: Plaintiff states that it and its predecessors-in-interest have entered into settlement licenses with other entities, but asserts these licenses did not involve the production of a patented article and were executed to end litigation without an admission of infringement, which Plaintiff argues obviates any patent marking requirement. Plaintiff also notes it is a non-practicing entity.

Case Timeline

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

U.S. Patent No. 9,430,131 - System, Methods, And User Interface for Organizing Unstructured Data Objects (issued Aug. 30, 2016)

The Invention Explained

• Problem Addressed: The patent's background section identifies the problem of "information overload" where users are presented with vast quantities of data from sources like social network feeds, emails, or search engine results, making it difficult and time-consuming to discern valuable information from irrelevant information (’131 Patent, col. 1:18-35).
• The Patented Solution: The invention provides a system for organizing collections of "electronic objects" (e.g., files, contacts, search results). The system allows a user to assign or specify an "importance value" to objects or to criteria associated with them. Based on this value, the system then organizes and displays the objects, for instance by placing more important objects in a more prominent position or display area, thereby distinguishing them from less relevant ones (’131 Patent, Abstract; col. 2:5-15, col. 8:43-56). Figure 1 illustrates a workflow where user interest (120) is used by a relevance calculation module (140) to apply different visual effects (170) or separate display areas (165) to message objects.
• Technical Importance: The technology aims to provide a more effective solution to information filtering than conventional methods by introducing a granular, user-specifiable degree of relevance, rather than relying on simple chronological or alphabetical sorting (’131 Patent, col. 1:42-48).

Key Claims at a Glance

• The complaint asserts claims 1-20 of the ’131 Patent (Compl. ¶9).
• Independent Claim 1:
  • obtaining a plurality of electronic objects (e.g., files, folders, contacts);
  • displaying the electronic objects or their names/icons in a user interface;
  • receiving an importance value associated with at least one object, where the value is entered by a user (via direct numerical entry, text input, or UI object selection);
  • determining a position to place the object in the user interface directly from the importance value; and
  • placing the electronic object (or its name/icon) in that determined position.
• The complaint does not specify which dependent claims are asserted but reserves the right to do so (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is identified as Defendant's "system with methods and user interface for discovering information in a text content and extracting and presenting the information," as implemented on its websites, such as hempz.com (Compl. ¶9, ¶12).

Functionality and Market Context

• The complaint alleges that Defendant "maintains, operates, and administers" a system for electronic commerce (Compl. ¶8-9). This system is accused of using infringing methods, including "review platforms" that allow for user interaction to present information (Compl. ¶12). The complaint does not provide specific technical details about how the accused websites operate beyond these general allegations. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an "exemplary table attached as Exhibit B" for support of its infringement allegations but does not include the exhibit (Compl. ¶10). In its absence, the infringement theory must be inferred from the complaint's narrative. Plaintiff alleges that Defendant's e-commerce system, including its review platforms, directly infringes claims 1-20 of the ’131 Patent by performing the claimed methods for organizing and presenting information (Compl. ¶9). The complaint does not provide sufficient detail for a limitation-by-limitation analysis in a claim chart format.

• Identified Points of Contention:
  • Scope Questions: A central question will be whether the functionality of Defendant's website, which is designed for e-commerce, falls within the scope of the claims, which are described in the patent in the context of organizing general "unstructured data objects" like files, folders, and contacts (’131 Patent, col. 17:31-35).
  • Technical Questions: The complaint does not specify what user actions on the Hempz website correspond to "entering an importance value." A key factual question will be what evidence, if any, demonstrates that Defendant’s system receives a user-specified, non-binary importance value and then determines an object's display position "directly from" that value, as required by claim 1.

V. Key Claim Terms for Construction

The Term: "importance value" (Claim 1)

• Context and Importance: This term is the core of the claimed invention. The infringement analysis will depend on whether any feature of the accused system can be characterized as receiving a user-entered "importance value." Practitioners may focus on this term because its construction will define the specific type of user input required to infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the importance value as specifiable in multiple ways, including as a "non-binary numerical value" or through text descriptions, suggesting it is not limited to a single, predefined format (’131 Patent, col. 5:48-55, col. 18:8).
  • Evidence for a Narrower Interpretation: Claim 1 explicitly requires the importance value to be "entered by a user" through one of three specific mechanisms: "a numerical value directly entered by a user, a numerical value transformed from a text specified by a user, [or] a numerical value transformed from a selection of a user interface object" (’131 Patent, col. 18:38-44). This language may be construed to require an explicit, discrete user action to set the value, as opposed to a value inferred from general user behavior.

The Term: "placing the electronic objects ... in the position in the user interface" (Claim 1)

• Context and Importance: This term defines the infringing output of the claimed method. The dispute may turn on whether simple re-sorting of a list constitutes "placing" an object in a "position."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discloses displaying objects with "different visual effects" or in "separate display areas" based on relevance, which could encompass a variety of UI changes, including changes in font size or location within a feed (’131 Patent, col. 8:43-56, col. 9:30-44).
  • Evidence for a Narrower Interpretation: Figures 3, 4, and 5 consistently depict high- and low-relevance objects being placed into physically separate and distinct areas of the display (e.g., 310 and 320 in FIG. 3). This could support an argument that "placing...in the position" requires more than just reordering items within a single, contiguous list.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant actively encourages and instructs customers on how to use its products and services in an infringing manner (Compl. ¶11). It alleges contributory infringement on the basis that the accused services are not staple commercial products and that Defendant had reason to know customers' use would be infringing (Compl. ¶12).
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’131 Patent "from at least the filing date of the lawsuit," suggesting a theory of post-filing willfulness (Compl. ¶11-12; p. 7, ¶e).

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

1. A core issue will be one of definitional scope: Can the term "importance value", which claim 1 requires to be "entered by a user," be construed to cover the mechanisms available on Defendant’s e-commerce website, such as sorting by "Best Selling" or "Featured," or does the claim require a more explicit, granular, and user-defined numerical input as depicted in the patent's embodiments?
2. A key evidentiary question will be one of technical operation: As the complaint lacks specific factual allegations or visual evidence, a central question for discovery will be whether Plaintiff can demonstrate that the accused system actually performs the claimed steps. Specifically, what evidence will show that Defendant's system (a) receives a user-specified importance value and (b) "directly" uses that value to "determine a position" for an object, as opposed to using a conventional, pre-programmed sorting algorithm?