Linfo IP LLC v. CSC Generation Holdings Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: CSC Generation Holdings, Inc. (Delaware), also referred to as "Sur la Table"
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 4:24-cv-00561, S.D. Tex., 02/16/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the Southern District of Texas and has committed the alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s system for discovering, extracting, and presenting information from text content infringes a patent related to analyzing and displaying textual information based on user-selected semantic attributes.
• Technical Context: The technology at issue addresses information overload by automatically analyzing unstructured text, such as online product reviews, to identify and present specific information based on topic or sentiment, enhancing user experience in e-commerce and data review.
• Key Procedural History: The complaint identifies the Plaintiff as a non-practicing entity. No other significant procedural events, such as prior litigation or administrative proceedings involving the patent-in-suit, are mentioned.

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"

• Patent Identification: 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 seeks to solve the problem of "information overload," where users face vast amounts of unstructured text, such as hundreds of online hotel reviews, making it difficult and time-consuming to locate specific, relevant information (e.g., comments about "room service" or opinions that are specifically "negative") ('428 Patent, col. 1:12-38).
• The Patented Solution: The invention provides a computer-assisted system that automatically analyzes text to identify various attributes of words and phrases, including their semantic meaning (e.g., positive or negative opinion). It then provides a user interface that allows a user to select a desired attribute (like "positive comments") and an action (like "extract" or "highlight"). The system then processes the text to present only the information matching the user's selection, often in organized formats like lists or topic trees, thereby saving the user from manual review ('428 Patent, Abstract; col. 3:16-34).
• Technical Importance: The technology provides a method for making large volumes of user-generated content and other text data more navigable and useful, automating aspects of topic extraction and sentiment analysis for consumers and businesses ('428 Patent, col. 9:6-21).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 ('Compl. ¶10). Independent claim 1 is central to the asserted system.
• Independent Claim 1 requires:
  • Obtaining text content.
  • Presenting a user with a choice between at least a first and a second "semantic attribute."
  • Identifying words or phrases in the text associated with those semantic attributes.
  • Displaying an "actionable user interface object" that allows a user to select one of the semantic attributes.
  • Performing an action (e.g., extracting, hiding, highlighting) on the words or phrases associated with the user-selected attribute.
• The complaint reserves the right to assert dependent claims, which add further limitations, such as the semantic attributes being contrasting opinions (e.g., positive vs. negative) ('428 Patent, cl. 3).

III. The Accused Instrumentality

Product Identification

• The complaint does not name a specific accused product or service. It generally alleges infringement by a "system with methods and user interface for discovering information in a text content and extracting and presenting the information" that is maintained, operated, and administered by the Defendant, "Sur la Table" (Compl. ¶1, ¶10).

Functionality and Market Context

• The complaint alleges, in general terms, that the accused system infringes by providing "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. ¶9). The complaint does not provide specific details about the functionality, operation, or market context of the accused system beyond these general allegations that track the patent's own language.

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart exhibit. The following summary is based on the narrative allegations.

No probative visual evidence provided in complaint.

'428 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The complaint's allegations are general and track the claim language. A central question will be whether the functionality of the accused "Sur la Table" system, once detailed in discovery, actually meets the claim limitations. For example, does the system offer choices based on "semantic attributes" as understood in the patent, or does it use more conventional filtering methods (e.g., keyword search, star ratings) that may fall outside the claim scope?
  • Technical Questions: The complaint provides no specific evidence of how the accused system operates. A key question for the court will be whether the Plaintiff can produce evidence that the accused system performs the specific process of (1) identifying words/phrases associated with a semantic attribute (like "positive opinion"), (2) presenting that attribute as a selectable option in a UI, and (3) performing an action on the text based on the user's selection of that option.

V. Key Claim Terms for Construction

• The Term: "semantic attribute"

  • Context and Importance: This term is the technological core of Claim 1. Its construction will likely determine the breadth of the patent. The dispute may center on whether this term covers any kind of data-based filter or is limited to the more complex, meaning-based analysis (e.g., sentiment) that is a focus of the patent's specification.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that "meanings of a word or a phrase can also be named as 'connotation' or 'semantic attributes'" ('428 Patent, col. 8:23-25). This broad definition could be argued to encompass a wide range of classifications beyond just sentiment.
    • Evidence for a Narrower Interpretation: The specification heavily emphasizes "opinion" as a key type of semantic attribute, often in contrasting pairs like "positive" vs. "negative" ('428 Patent, cl. 3; col. 9:1-5; Fig. 7). Embodiments like Figure 7, which shows options to "Extract positive opinions" and "Extract negative opinions," could be used to argue that the term is primarily directed at sentiment analysis, not all possible data classifications.

• The Term: "actionable user interface object"

  • Context and Importance: This term defines the interactive component of the invention. Its construction is important for determining what kind of user control is required to infringe. Practitioners may focus on this term to distinguish the claimed invention from passive displays of information.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discloses common UI elements like "a dropdown menu," "clickable buttons," and "radio buttons" as examples ('428 Patent, col. 9:67-68; col. 12:47-49), suggesting the term could cover many standard interactive controls.
    • Evidence for a Narrower Interpretation: Claim 1 requires the object to be "associated with a label representing the first name or description or the second name or description" of the semantic attributes ('428 Patent, col. 16:11-14). An argument could be made that this requires the UI element's label to explicitly name the semantic function (e.g., a button labeled "Show positive comments"), potentially excluding more generic controls (e.g., a simple "Filter" button).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant "actively encouraged or instructed others (e.g., its customers...)" to use its services in an infringing manner. It also makes a parallel allegation for contributory infringement (Compl. ¶12, ¶13). The complaint does not, however, point to specific instructions, user manuals, or marketing materials to support these claims.
• Willful Infringement: Plaintiff alleges willfulness based on Defendant’s knowledge of the patent "from at least the filing date of the lawsuit" (Compl. ¶12, ¶13). The complaint reserves the right to amend if discovery reveals evidence of pre-suit knowledge.

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

• An Evidentiary Question of Operation: The complaint's allegations are conclusory and lack factual detail about the accused system. A threshold issue for the case will be whether discovery yields evidence that the accused "Sur la Table" system actually performs the specific, multi-step process of identifying text based on semantic attributes and allowing users to manipulate the display of that text via an "actionable user interface object," as recited in Claim 1.
• A Definitional Question of Scope: The case will likely hinge on the claim construction of "semantic attribute". The central legal question will be whether this term can be broadly interpreted to read on conventional e-commerce filtering tools, or if intrinsic evidence limits its scope to the more sophisticated, context-aware sentiment and topic analysis detailed in the patent’s embodiments.