GeoSymm Ventures LLC v. Streebo Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GeoSymm Ventures LLC (Texas)
  • Defendant: Streebo, Inc. (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 4:25-cv-02859, S.D. Tex., 06/19/2025
• Venue Allegations: Venue is alleged to be proper because the Defendant has an established place of business in the Southern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to an "assistive agent" system that interprets a user's request, determines its semantic meaning, and interacts with external web services via an API to provide a response.
• Technical Context: The technology pertains to the field of virtual personal assistants, which interpret natural language commands to perform tasks and retrieve information by orchestrating various applications and data sources.
• 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 deficiency in prior personal information managers (PIMs) which, despite having access to a user's data (contacts, calendar, etc.), "have failed to take full advantage of the information" and require significant user effort to perform integrated tasks ('900 Patent, col. 1:22-30). For instance, a user manually setting a meeting reminder must still independently determine the necessary travel time, an inefficiency the invention seeks to resolve.
• The Patented Solution: The invention proposes a system and method for an intelligent "assistive agent" that automates and integrates tasks. The system receives a user request from a mobile device, determines the "semantics" of the request by identifying a domain, task, and parameters, and then accesses one or more "semantic web services" through an Application Program Interface (API) to retrieve data and formulate a response ('900 Patent, Abstract; Fig. 2). This creates a smart intermediary that can understand a user's goal and programmatically interact with various independent services (e.g., calendar apps, review websites, mapping services) to achieve it ('900 Patent, col. 4:1-24).
• Technical Importance: The technology describes a more sophisticated architecture for virtual assistants by moving beyond simple data aggregation to a system that actively interprets user intent and orchestrates multiple, disparate services to fulfill complex requests ('900 Patent, col. 2:46-52).

Key Claims at a Glance

• The complaint alleges infringement of "exemplary claims" but does not specify them in the body of the complaint, instead referring to an external exhibit (Compl. ¶11). Independent claim 1 is representative of the asserted technology.
• Independent Claim 1 (Method):
  • receiving a user request for assistance from a mobile device;
  • determining semantics of the user request by identifying at least one domain, task, and parameter, which involves parsing the request to identify its meaning along with location and personal information (e.g., telephone, texting activity) captured by the device;
  • accessing one or more "semantic web services" via an API to retrieve data matching the determined domain, task, and parameter;
  • identifying, generating, or providing personalized recommendations;
  • presenting possible responses to the user by interacting with the semantic web services and "confirming user responses by accessing a text messaging API or a phonebook API";
  • determining a responsive answer; and
  • responding to the user request.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, methods, or services. It refers generically to "at least the Defendant products identified in the charts incorporated into this Count below (among the “Exemplary Defendant Products”)" (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market context, as these details are allegedly contained within an external exhibit not attached to the publicly filed complaint (Compl. ¶16-17).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts provided as Exhibit 2 (Compl. ¶16). As this exhibit was not provided with the complaint, the specific factual basis for the infringement allegations cannot be analyzed in a tabular format.

The narrative infringement theory is that the "Exemplary Defendant Products practice the technology claimed by the '900 Patent" and "satisfy all elements of the Exemplary '900 Patent Claims" (Compl. ¶16). The complaint alleges direct infringement through Defendant's making, using, selling, and testing of the products (Compl. ¶11-12). The complaint further references "product literature and website materials" to support allegations of induced infringement (Compl. ¶14). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question will be whether the accused products' interactions with third-party applications or services qualify as accessing "semantic web services" as that term is used in the patent. Another point of contention may arise from the claim requirement to confirm user responses by "accessing a text messaging API or a phonebook API," raising the question of whether the accused products use this specific mechanism or an alternative method.
  • Technical Questions: A key technical question is what evidence Plaintiff will present to demonstrate that the accused products perform the internal step of "determining semantics" by identifying a "domain," "task," and "parameter." The dispute may center on whether the accused system performs this claimed multi-part semantic analysis or uses a simpler, non-infringing technique such as basic keyword matching to trigger actions.

V. Key Claim Terms for Construction

• The Term: "semantic web services"

  • Context and Importance: This term is central to defining the type of external data sources the claimed invention must interact with. Its construction will determine whether the claims are limited to services employing formal Semantic Web technologies (e.g., RDF, OWL) or broadly cover any modern, API-driven service that provides structured data.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides examples of third-party service providers that include "Facebook, Amazon, Yahoo, eBay, and the like sources," which are not necessarily formal semantic web implementations ('900 Patent, col. 4:30-35).
    • Evidence for a Narrower Interpretation: Dependent claim 2 recites that the "web service comprises the web ontology language," and dependent claim 3 recites that it "comprises RDF." A defendant may argue these dependent claims suggest the independent claim term should be construed consistently with these specific technologies, or that the term was intended to invoke its formal meaning in the art.

• The Term: "determining semantics of the user request"

  • Context and Importance: This phrase describes the core intelligence of the claimed agent. Practitioners may focus on this term because the validity and infringement analyses will depend on the level of analytical sophistication required to meet this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent abstract describes the step simply as "determining semantics of the user request and identifying at least one domain, at least one task, and at least one parameter," which could be argued to cover a range of interpretive methods ('900 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The specification describes a system that may use a "grammatical analyzer" and a detailed "ontology" with defined models for domains, tasks, and dialog flows ('900 Patent, col. 9:11-14; Fig. 7). This could support a narrower construction requiring a structured, model-based analysis rather than simple keyword matching.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that allegedly infringes the '900 Patent (Compl. ¶14).
• Willful Infringement: The complaint alleges that Defendant has had "actual knowledge of infringement" since the service of the complaint and has continued its allegedly infringing activities despite this knowledge, forming the basis for a claim of post-filing willfulness (Compl. ¶13-15).

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

• A core issue will be one of definitional scope: can the term "semantic web services," which has a formal technical meaning, be construed to cover the general-purpose APIs of modern applications like those allegedly used by the Defendant, or is it limited to a narrower set of technologies like RDF and OWL?
• A key evidentiary question will be one of operational proof: given the complaint's reliance on an unfiled exhibit, a central focus will be on what discovery reveals about the internal workings of the accused products. Can the Plaintiff produce evidence that the system performs the specific, multi-step process of "determining semantics" as claimed, or does it operate on a different, potentially non-infringing technical principle?
• The case may also turn on a point of technicality: does the accused system "confirm... user responses by accessing a text messaging API or a phonebook API" as required by claim 1? Infringement may hinge on whether the accused product literally performs this specific step or uses an alternative confirmation method that falls outside the claim's scope.