GeoSymm Ventures LLC v. Osp Labs Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GeoSymm Ventures LLC (Texas)
  • Defendant: OSP Labs, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC; DNL Zito
• Case Identification: 4:25-cv-00640, N.D. Tex., 06/22/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Northern District of Texas and has allegedly committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products, described as "Exemplary Defendant Products," infringe a patent related to digital assistive agents that interpret user requests and interact with web services.
• Technical Context: The technology concerns software-based "assistive agents," akin to modern digital assistants, which parse natural language commands to interface with various external and internal services to fulfill user tasks.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Patent No. 9,130,900, Assistive agent, issued September 8, 2015.
• The Invention Explained:
  • Problem Addressed: The patent describes a shortcoming of then-existing Personal Information Managers (PIMs), which consolidated functions like calendars and contacts but "failed to take full advantage of the information" available to them, requiring significant manual user input (e.g., discerning reminder times for appointments). (’900 Patent, col. 1:22-29). Early virtual assistants were likewise described as being "in [their] infancy." (’900 Patent, col. 2:49-52).
  • The Patented Solution: The invention proposes a system and method for a more intelligent "assistive agent." The core process involves receiving a user request, "determining semantics" of that request by identifying a specific domain, task, and parameter, and then accessing one or more "semantic web services" through an Application Programming Interface (API) to obtain a relevant answer or perform an action. (’900 Patent, Abstract; Fig. 2). This architecture is designed to integrate disparate services in a structured way to fulfill complex user requests. (’900 Patent, col. 3:3-9).
  • Technical Importance: The patent describes a framework that moves beyond siloed applications by creating an intermediary agent capable of understanding user intent and orchestrating multiple, independent web services to provide a unified response. (’900 Patent, col. 9:11-18).
• Key Claims at a Glance:
  • The complaint asserts infringement of "one or more claims" and refers to "Exemplary '900 Patent Claims" but does not identify specific claims in the body of the complaint, instead referring to an external exhibit (Compl. ¶11). The asserted independent claims appear to be at least Claim 1 (a method) and Claim 19 (a system).
  • Independent Claim 1 (method) requires, in essence:
    • Receiving a user request from a mobile device.
    • Determining semantics of the request by identifying a domain, task, and parameter, using personal and location information from the device.
    • Accessing semantic web services via an API to retrieve matching data.
    • Confirming user responses by accessing a text messaging or phonebook API.
    • Determining a responsive answer and responding to the user.
  • Independent Claim 19 (system) requires, in essence:
    • A computing device that captures user profile and interests.
    • A server that communicates with the device and accesses semantic web services via an API to perform functions initiated on the device, such as adding a contact, setting an alarm, or sending a message.

III. The Accused Instrumentality

• Product Identification: The complaint does not identify any specific accused products, methods, or services by name, referring to them only as "Exemplary Defendant Products." (Compl. ¶11).
• Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused products' functionality. It makes only conclusory allegations that the products "practice the technology claimed" without describing how they operate. (Compl. ¶16). No allegations are made regarding the products' market position or commercial importance.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are contained entirely within an "Exhibit 2," which is referenced but was not filed with the complaint itself (Compl. ¶¶ 16-17). The body of the complaint offers no narrative explanation or factual support for how the "Exemplary Defendant Products" are alleged to meet the limitations of the asserted claims. It states only that the products "satisfy all elements of the Exemplary '900 Patent Claims." (Compl. ¶16). Consequently, a detailed claim-by-claim analysis is not possible based on the provided documents.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the language of the patent, any future infringement analysis may center on several key technical and legal questions:
  • Scope Questions: Claim 1 requires "confirming user responses by accessing a text messaging API or a phonebook API." (’900 Patent, col. 28:9-11). A potential dispute is whether this requires a discrete confirmation step using those specific APIs for any user response, or if it applies more narrowly to tasks directly involving messaging or contacts.
  • Technical Questions: The patent claims a process of "determining semantics" that involves parsing a request into a "domain," "task," and "parameter." (’900 Patent, col. 27:60-64). A central question will be what evidence demonstrates that the accused products' natural language understanding engine performs this specific, structured three-part analysis, as opposed to using a more generalized or different machine learning model to interpret user intent.

V. Key Claim Terms for Construction

• The Term: "semantic web services"

• Context and Importance: This term appears in both independent claims 1 and 19 and defines the universe of services the patented agent interacts with. Its construction is critical, as it will determine whether the claims cover interactions with any generic web API or are limited to a more specific class of services.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification gives examples of "third-party service providers" that include "Facebook, Amazon, Yahoo, eBay, and the like sources," which at the time largely used conventional, non-semantic APIs. (’900 Patent, col. 4:30-35). This may support a construction covering a wide range of external, API-accessible web services.
  • Evidence for a Narrower Interpretation: The term "semantic web" has a specific meaning in computer science. The specification explicitly mentions technologies associated with the semantic web, such as "e web ontology language" and "Resource Description Framework (RDF)." (’900 Patent, cl. 2-3, col. 13:20-22). This suggests the possibility of a narrower construction limited to services that employ formal ontologies and structured semantic data models, rather than any general-purpose API.

• The Term: "determining semantics"

• Context and Importance: This phrase from Claim 1 describes the core analytical step of the invention. Whether an accused product infringes will depend heavily on whether its method of processing user commands falls within the scope of this term.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent background discusses interpreting "user intent" and disambiguating requests in general terms, which might support a broader definition covering any process that ascertains the user's goal. (’900 Patent, col. 5:9-16).
  • Evidence for a Narrower Interpretation: Claim 1 itself appears to define the term by requiring the identification of "at least one domain, at least one task, and at least one parameter." (’900 Patent, col. 27:60-64). The specification provides examples and diagrams illustrating this structured, tripartite breakdown of a user request, which could support a narrower construction that requires this specific analytical framework. (’900 Patent, Fig. 2; col. 6:1-21).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users... to use its products in the customary and intended manner that infringes." (Compl. ¶14). The complaint again relies on the unattached Exhibit 2 to provide the evidentiary basis for this allegation. (Compl. ¶14).
• Willful Infringement: The willfulness claim is based exclusively on alleged post-suit knowledge. The complaint alleges that "At least since being served by this Complaint," Defendant has had "actual knowledge" of its infringement and has continued its allegedly infringing activities. (Compl. ¶¶ 13-15). No facts suggesting pre-suit knowledge are alleged.

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

• Pleading Sufficiency: A threshold procedural issue will be whether the complaint, which outsources its entire factual basis for infringement to an unfiled exhibit, meets federal pleading standards that require a plausible statement of a claim for relief.
• Claim Scope: The case will likely turn on a question of definitional scope: can the term "semantic web services", which is associated in the patent with specific technologies like ontologies and RDF, be construed broadly enough to read on the general-purpose, non-semantic APIs commonly used by modern digital assistant platforms?
• Technical Equivalence: A key evidentiary question will concern operational correspondence: does the accused technology’s method for processing user requests perform the specific, three-part semantic analysis (domain, task, parameter) required by the patent’s claims, or does it operate on a fundamentally different and non-infringing technical architecture for natural language understanding?