Linfo IP LLC v. MariGold Foods LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: MariGold Foods LLC (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 4:25-cv-02387, S.D. Tex., 05/27/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in Texas, has committed acts of infringement in the district, and has a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s website, which includes a system for presenting information, infringes a patent related to methods for organizing and displaying unstructured data objects based on relevance.
• Technical Context: The technology addresses the problem of information overload by providing systems to automatically sort and visually distinguish electronic data objects (e.g., files, contacts, messages) based on a calculated "importance" score rather than simple chronological or alphabetical order.
• Key Procedural History: Plaintiff and its predecessors-in-interest have previously entered into settlement licenses with other entities for patents including the patent-in-suit. Plaintiff asserts these were settlements to end litigation and did not involve an admission of infringement or a license to produce a patented article, which may be relevant to potential damages and marking defenses.

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 August 30, 2016
  • The Invention Explained:
    • Problem Addressed: The patent describes the problem of "information overload" where users are presented with large amounts of unstructured data—such as social network feeds, emails, search results, or long lists of personal files and contacts—making it difficult and time-consuming to find the most relevant information ('131 Patent, col. 1:20-44). Conventional methods of sorting alphabetically or chronologically are described as insufficient ('131 Patent, col. 13:51-59).
    • The Patented Solution: The invention provides a system where electronic objects are assigned an "importance measure" or "relevance score" ('131 Patent, Abstract; col. 2:5-10). This score can be based on user-specified criteria, content analysis, or metadata ('131 Patent, col. 2:1-4). The system then uses this score to organize the objects, for example by displaying higher-relevance objects more prominently, in a separate area, or with different visual effects (e.g., a larger font size) to distinguish them from less relevant objects ('131 Patent, col. 8:56-62; FIG. 1, 3-5).
    • Technical Importance: The technology sought to improve user efficiency by moving beyond simple sorting to a more dynamic, relevance-based presentation of information, allowing users to more quickly identify critical data ('131 Patent, col. 1:45-51).
  • Key Claims at a Glance:
    • The complaint asserts infringement of claims 1-20 (Compl. ¶9). Independent claim 1 is representative.
    • Independent Claim 1: A computer-implemented method comprising the steps of:
      • obtaining a plurality of electronic objects (e.g., existing files, folders, or 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 (e.g., as a numerical value, text, or UI selection);
      • determining a position for 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 reserves the right to assert other claims, including dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is a "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶9). This system is allegedly operated by Defendant MariGold Foods, LLC, through its website, including its "review platforms" (Compl. ¶12).

Functionality and Market Context

The complaint alleges that Defendant "maintains, operates, and administers" this system, which it puts into service (Compl. ¶9). The functionality is broadly described as enabling the discovery, extraction, and presentation of information, with specific reference to "review platforms" on its commercial website (Compl. ¶12). The complaint does not provide specific technical details on how the accused review platform operates beyond these general allegations.

IV. Analysis of Infringement Allegations

The complaint alleges that support for its infringement allegations is detailed in a "preliminary exemplary table attached as Exhibit B" (Compl. ¶10). However, Exhibit B was not filed with the complaint. Therefore, the infringement theory must be inferred from the complaint’s narrative allegations. The core theory is that Defendant’s system, including its website’s review platform, directly infringes claims 1-20 of the ’131 Patent by performing the claimed methods (Compl. ¶9, ¶12).

The complaint does not provide sufficient detail for a specific element-by-element analysis in a claim chart format.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Technical Questions: A primary question will be whether the accused "review platform" performs the specific functions required by the claims. For example, what evidence demonstrates that the platform receives a user-entered "importance value" as distinct from a review rating or a "helpful" vote? Further, does the platform "determine a position" and "place" objects based "directly from the importance value," as the claim requires?
  • Scope Questions: The dispute may turn on the scope of the claimed method in the context of a food product review website. A question for the court could be whether a standard "sort by" feature (e.g., sort by rating, sort by most helpful) on a commercial website constitutes the specific method of receiving a user-defined "importance value" and repositioning objects as taught in the ’131 Patent.

V. Key Claim Terms for Construction

• The Term: "importance value"
• Context and Importance: This term is central to every independent claim and forms the core of the patented invention. The definition of what constitutes an "importance value" and how it must be "received" from a user will be critical to the infringement analysis. Practitioners may focus on this term because its construction will determine whether common web features, like sorting reviews by helpfulness, fall within the scope of the claims.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the value can be derived from various user inputs, stating it can be a "numerical value transformed from a text specified by a user, a numerical value transformed from a selection of a user interface object indicated by a user" ('131 Patent, col. 17:41-45). This could support an argument that actions other than direct numerical entry, such as clicking a "helpful" button, can be transformed into a qualifying "importance value."
  • Evidence for a Narrower Interpretation: The patent’s figures and embodiments frequently depict the "importance value" as an explicit, granular, and often numerical score that a user consciously assigns to an item or attribute, such as a value of "0.95" for a search term or a "5" on a 1-5 scale for a contact ('131 Patent, FIG. 2A, 2C, 9). This could support a narrower construction requiring a more direct and quantitative user input, rather than an implicit one derived from user behavior.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendant actively encourages and instructs customers on how to use its "review platforms" in an infringing manner via its website and instruction manuals (Compl. ¶11, ¶12). Contributory infringement is alleged on the basis that the accused product is not a staple commercial product and that its only reasonable use is an infringing one (Compl. ¶12).
• Willful Infringement: The complaint alleges Defendant has known of the ’131 Patent "from at least the filing date of the lawsuit" and that its continued infringement is therefore willful (Compl. ¶11, ¶12). Plaintiff also seeks a declaration of willfulness and treble damages should discovery reveal pre-suit knowledge (Compl. ¶VI.e).

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

1. A Core Evidentiary Question: Given the lack of specific factual allegations in the complaint, a central issue will be whether Plaintiff can produce evidence showing that Defendant’s food product review platform actually practices each element of the asserted claims. The case will depend on demonstrating a technical correspondence between the accused platform’s features and the patent's specific requirements for receiving and using an "importance value."
2. A Key Question of Claim Scope: The case will likely hinge on the construction of the term "importance value". The critical question for the court will be one of definitional scope: can this term, which is exemplified in the patent as a discrete, user-assigned score, be construed broadly enough to read on the functionality of a conventional "sort by helpfulness" or "sort by rating" feature on a commercial website?