GeoSymm Ventures LLC v. Relinns Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GeoSymm Ventures LLC (Texas)
  • Defendant: Relinns Technologies, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 4:24-cv-01707, S.D. Tex., 05/08/2024
• Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business within the Southern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to an "assistive agent" that interprets user requests and interacts with various web services via an API to provide a response.
• Technical Context: The technology falls within the domain of virtual personal assistants, which use natural language processing and service integration to perform tasks for a user on a mobile device.
• Key Procedural History: The complaint appears to be the first legal action between the parties concerning the patent-in-suit. The complaint notes that Plaintiff is the assignee of the patent.

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 deficiency in prior art personal information managers (PIMs), which, despite having access to a user's data (e.g., calendar, contacts), "failed to take full advantage of the information" to provide proactive or context-aware assistance. (’900 Patent, col. 1:21-24). For instance, a user setting a calendar reminder would still have to manually determine an appropriate lead time, and a triggered reminder might be "wasted" if the user is away from their desk. (’900 Patent, col. 1:25-30).
• The Patented Solution: The invention proposes a system where a user's request on a computing device is analyzed to determine its "semantics," including a domain, task, and parameters. (’900 Patent, Abstract). The system then accesses one or more "semantic web services" through an Application Program Interface (API) to obtain information, determine a responsive answer, and reply to the user. (’900 Patent, Fig. 2). This architecture acts as an intelligent intermediary, translating a user's natural language intent into programmatic actions across various services.
• Technical Importance: The technology aims to provide a more integrated "Virtual Personal Assistant (VPA)" capable of handling complex tasks that require interfacing with multiple data sources and online services, distinguishing it from simpler, siloed applications. (’900 Patent, col. 1:46-52).

Key Claims at a Glance

• The complaint states it is asserting "exemplary claims" identified in an external exhibit but does not identify any specific claims in the body of the complaint. (Compl. ¶11). Independent claim 1 is the patent's broadest method claim.
• The essential elements of independent claim 1 include:
  • Receiving a user request from a mobile device.
  • Determining the request's semantics (domain, task, parameter) by parsing it "along with location and user personal information captured by the mobile device including telephone, texting, and user activity."
  • Accessing "semantic web services" via an API to retrieve matching data.
  • Providing personalized recommendations.
  • Presenting responses by calling services through the API and "confirming user responses by accessing a text messaging API or a phonebook API."
  • Determining a responsive answer and responding to the user.
• The complaint reserves the right to assert other claims, including dependent claims. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any accused products or services in its text. It refers to "Exemplary Defendant Products" that are purportedly identified in an external document, Exhibit 2, which is incorporated by reference. (Compl. ¶¶11, 16). This exhibit was not filed with the complaint.

Functionality and Market Context

The complaint does not provide any description of the functionality, operation, or market context of the accused products. It makes only the conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '900 Patent." (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint does not contain narrative infringement allegations or claim charts within its body. Instead, it incorporates by reference the "claim charts of Exhibit 2," which is an external document not provided with the publicly filed complaint. (Compl. ¶¶16-17). Consequently, the complaint itself does not articulate a specific theory of how the accused products meet the limitations of the asserted claims. No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the language of independent claim 1 of the ’900 Patent, the infringement analysis may raise several technical and legal questions:
  • Scope Questions: Claim 1 requires "accessing one or more semantic web services." A central dispute may arise over the definition of this term. A key question for the court will be whether this term is limited to services that use specific semantic technologies mentioned in the specification (e.g., RDF, web ontology language), or if it can be construed more broadly to cover any third-party service accessible via a modern API.
  • Technical Questions: The second limitation of claim 1 requires determining semantics by parsing a user request "along with location and user personal information captured by the mobile device including telephone, texting, and user activity." An evidentiary question is what proof the Plaintiff has that the accused products capture and utilize this specific combination of personal data (telephone and texting activity, in addition to location and general activity) as part of their semantic analysis process.

V. Key Claim Terms for Construction

• The Term: "semantic web services"

• Context and Importance: This term appears in the core "accessing" step of the claimed method and is foundational to how the invention interacts with external data sources. Its construction will be critical in defining the breadth of the patent's coverage over modern digital assistant technologies.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides examples of third-party service providers that could be considered "semantic web services," such as "Facebook, Amazon, Yahoo, eBay, and the like sources," as well as APIs for on-device applications like contacts and calendars. (’900 Patent, col. 4:30-34, 4:40-43). This could support an interpretation that the term covers a wide range of services accessible via an API.
  • Evidence for a Narrower Interpretation: The specification also states that "the semantic web services 106 described herein may include Resource Description Framework (RDF)" and "web ontology language." (’900 Patent, col. 15:18-22). This language might be used to argue that the term should be limited to services that employ these specific, formal semantic web technologies.

• The Term: "confirming user responses by accessing a text messaging API or a phonebook API"

• Context and Importance: This term appears in the fifth step of claim 1 and specifies a particular mechanism for user interaction. Practitioners may focus on this term because it appears to require a specific action (confirmation) tied to a specific type of API (texting or phonebook), which may not be present in all digital assistant architectures.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent's Figure 4A and accompanying text describe an embodiment where a user request to "play Led Zeppelin" is sent to a contact named "Siri Tunes" via a text message, and the system presents the message for confirmation before sending. (’900 Patent, Fig. 4A; col. 11:41-44). This could be argued to be one example of a broader principle of confirming user intent through established communication channels.
  • Evidence for a Narrower Interpretation: The claim language explicitly recites "confirming user responses" and ties this action to a "text messaging API or a phonebook API." This could support an argument that the claim requires an explicit confirmation step presented to the user after a response is formulated and before final action, and that this confirmation must be mediated specifically through a texting or phonebook API, rather than a general user interface prompt.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to operate the accused products in an infringing manner. (Compl. ¶14). It also bases inducement on knowledge gained from the complaint itself. (Compl. ¶15).
• Willful Infringement: The complaint does not use the word "willful." However, it alleges that the service of the complaint constitutes "Actual Knowledge of Infringement" and that Defendant's continued infringing activities thereafter are done despite this knowledge. (Compl. ¶¶13-14). These allegations lay the groundwork for a claim of post-filing willfulness.

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

1. Plausibility and Pleading Sufficiency: The complaint's complete reliance on an unprovided external exhibit to identify the accused products and the mechanism of infringement raises a threshold question of pleading sufficiency. A primary issue will be whether the complaint, standing alone, contains enough factual matter to state a plausible claim for relief or if it is susceptible to a motion to dismiss.
2. Definitional Scope: The case will likely hinge on a battle over claim construction, particularly the scope of "semantic web services." The central question is whether this term can be interpreted broadly to encompass the general-purpose APIs common in today's technology, or if it is restricted to a narrower, more specialized class of services defined by specific semantic technologies referenced in the patent.
3. Operational Proof: A key evidentiary question will be one of functional operation: can Plaintiff demonstrate that the accused products perform the specific, multi-part data analysis recited in claim 1, which requires parsing a user request "along with" captured data that explicitly includes "telephone, texting, and user activity"? Proving the use of this precise data combination for semantic interpretation will be a critical hurdle.