Linfo IP LLC v. Stellar Data Recovery Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Stellar Data Recovery Inc. (New Jersey / India)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 4:24-cv-04932, S.D. Tex., 12/16/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a "regular and established place of business" in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s system for discovering, extracting, and presenting information from text content infringes a patent related to computer-assisted text analysis and user interfaces.
• Technical Context: The technology at issue involves methods for automatically analyzing unstructured text to identify and categorize information based on semantic attributes (e.g., positive or negative sentiment) and presenting it to a user.
• Key Procedural History: Plaintiff states it is a non-practicing entity and that it and its predecessors have entered into confidential settlement licenses with other entities related to its patents, which it argues did not trigger marking requirements.

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 describes the problem of "information overload," where finding specific, needed information within large volumes of unstructured text (such as numerous online hotel reviews) is difficult and time-consuming using conventional search methods (ʼ428 Patent, col. 1:12-38). For instance, a user may struggle to locate all negative comments specifically concerning "room service" from hundreds of reviews (ʼ428 Patent, col. 1:26-38).
• The Patented Solution: The invention provides a computer-assisted system that analyzes text to identify grammatical, semantic, or contextual attributes of words and phrases. It then provides user interface objects (e.g., buttons, menus) that allow a user to select an attribute (e.g., "positive comments") and an action (e.g., "highlight" or "extract"), thereby filtering or reformatting the text to present the desired information in an "easy-to-digest way" (ʼ428 Patent, Abstract; col. 3:16-29; col. 1:56-64). The system can use dictionaries and pre-written rules to determine if a term's context, such as negation ("not good"), changes its inherent meaning (ʼ428 Patent, Fig. 6).
• Technical Importance: The technology claims to provide a more efficient tool than simple keyword searching for digesting and analyzing large amounts of user-generated content or other text by allowing users to filter and view information based on its meaning and sentiment (ʼ428 Patent, col. 1:56-64).

Key Claims at a Glance

• The complaint asserts claims 1-20 (Compl. ¶9). Independent claim 1 is excerpted below.
• Independent Claim 1 requires:
  • Obtaining a text content.
  • Selecting a first and second semantic attribute for a user to choose from.
  • Identifying words or phrases in the text associated with those semantic attributes.
  • Displaying an "actionable user interface object" associated with the attributes.
  • Allowing a user to select one of the attributes via the user interface.
  • Performing an action (e.g., extracting, displaying, hiding, highlighting) on the words or phrases associated with the user-selected attribute.
• The complaint reserves the right to assert all claims, including dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The complaint accuses Defendant’s "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶9). It points to Defendant's website, "https://www.stellarinfo.com/", as being related to the accused products and services (Compl. ¶12).

Functionality and Market Context

The complaint alleges that Defendant "maintains, operates, and administers" the accused system and puts the claimed inventions into service (Compl. ¶9). The complaint does not provide specific details on the functionality of the accused system beyond alleging that it performs infringing methods (Compl. ¶9). It is alleged that Defendant offers products and services with instructions that suggest an infringing use (Compl. ¶12).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a preliminary claim chart in "Exhibit B," which was not included with the public filing (Compl. ¶10). The following analysis is based on the narrative allegations in the complaint against independent claim 1.

’428 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question will be whether the functionality offered by Defendant’s system, which appears to focus on data recovery, falls within the scope of the claims, which are described in the patent with examples from user review and sentiment analysis (ʼ428 Patent, col. 1:18-38).
• Technical Questions: The complaint does not provide evidence showing "how" the accused system performs the claimed steps. A key question for the court will be whether Plaintiff can demonstrate that Defendant's system identifies "semantic attributes" (as opposed to file types or data structures), provides an "actionable user interface object" tied to those attributes, and performs the claimed actions based on a user's selection of an attribute.

V. Key Claim Terms for Construction

• The Term: "semantic attribute"

• Context and Importance: This term is the core of the invention, defining the basis upon which information is categorized and acted upon. Its construction will be critical to determining infringement, as the Plaintiff will need to show that Defendant's system operates on "semantic attributes" as claimed. Practitioners may focus on this term because its breadth will likely be disputed.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that attributes can be "grammatical, semantic, contextual, or topical" (ʼ428 Patent, col. 6:8-9). Claim 1 itself refers to a "first" and "second" semantic attribute without express limitation, suggesting the term is not confined to a single type of meaning.
  • Evidence for a Narrower Interpretation: The patent's detailed examples and figures focus heavily on "opinion" and sentiment analysis (e.g., positive/negative comments, "good" vs. "not as good") (ʼ428 Patent, Figs. 8, 9A, 9B, 11; col. 8:29-34). A defendant may argue the term should be construed in light of these specific embodiments.

• The Term: "actionable user interface object"

• Context and Importance: This term defines the mechanism by which a user interacts with the system to select an attribute and trigger an action. The dispute will likely center on what types of UI elements meet this limitation and how directly they must be tied to the claimed "semantic attributes."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent mentions various UI elements that could be considered "actionable," such as buttons, dropdown menus, and checkboxes (ʼ428 Patent, Figs. 7, 9A). The general language suggests any UI element that accepts user input for the claimed purpose could suffice.
  • 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 attribute (ʼ428 Patent, col. 16:12-16). A defendant may argue this requires a tight, explicit link between a specific UI button/label (e.g., a button labeled "Show positive comments") and the underlying semantic analysis, potentially excluding more general-purpose UI controls.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced and contributory infringement, asserting Defendant "actively encouraged or instructed" customers on how to use its products in an infringing manner through its website and product instruction manuals (Compl. ¶11, ¶12).
• Willful Infringement: The complaint alleges knowledge of the ’428 patent "from at least the filing date of the lawsuit," forming the basis for a claim of post-filing willful infringement (Compl. ¶11, ¶12).

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

1. An Evidentiary Question of Functionality: The complaint provides no specific evidence of how the accused data recovery products work. A central issue will be whether Plaintiff can demonstrate that Defendant’s system performs the specific, multi-step method of the claims, particularly the identification and user-selection of "semantic attributes" as taught in the patent, rather than other forms of data filtering or categorization.
2. A Definitional Question of Claim Scope: The case may turn on the construction of "semantic attribute." The key question for the court will be whether this term, illustrated in the patent primarily through linguistic and sentiment analysis, can be construed broadly enough to read on the types of information classification and filtering functions allegedly performed by Defendant’s products.
3. A Strategic Question of Damages and Willfulness: Plaintiff has identified itself as a non-practicing entity and based its willfulness claim on post-suit notice. The litigation will likely focus heavily on establishing a reasonable royalty, and the viability of the willfulness claim will depend on Defendant's conduct after receiving the complaint.