Linfo IP LLC v. Chewy Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Chewy, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 4:25-cv-03839, S.D. Tex., 08/14/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Southern District of Texas because Defendant maintains a "regular established place of business, a fulfillment center," within the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce websites and related services infringe a patent concerning systems and methods for organizing and presenting unstructured data objects based on user-defined relevance criteria.
• Technical Context: The technology at issue addresses the problem of information overload by enabling users to assign importance values to data, which a system then uses to sort and display content in a more relevant manner.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and has never sold a product practicing the patent-in-suit. It also notes that Plaintiff and its predecessors have entered into prior settlement licenses with other entities, and preemptively argues that patent marking requirements under 35 U.S.C. § 287(a) do not apply to limit damages.

Case Timeline

Date	Event
2013-03-25	’131 Patent Earliest Priority Date
2016-08-30	’131 Patent Issued
2025-08-14	Complaint Filed

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"

• Patent Identification: 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 addresses the problem of "information overload" where users are confronted with a large volume of data (e.g., social media feeds, emails, search results, files) and find it difficult to locate relevant information efficiently (’131 Patent, col. 1:19-34). Conventional sorting methods, such as by date or alphabetical order, are described as inadequate for large collections of objects (’131 Patent, col. 13:51-59).
• The Patented Solution: The invention provides a system where a user can assign a specific, non-binary "importance value" to electronic objects like files, folders, or contacts (’131 Patent, Abstract; col. 14:6-15). This user-entered value allows for a granular ranking of importance. The system then uses these values to organize and display the objects, for instance by sorting them in a list according to importance or by presenting high-importance and low-importance objects in separate, concurrently visible display areas (’131 Patent, col. 8:51-61; Fig. 3).
• Technical Importance: The claimed approach moves beyond simple binary filtering ("important" vs. "not important") to a more nuanced, user-driven system for personalizing the presentation of large datasets (’131 Patent, col. 14:30-49).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-20 (Compl. ¶9). Claim 1 is the first independent claim.
• Claim 1 Elements:
  • A computer-implemented method for presenting information, comprising:
  • obtaining a plurality of electronic objects (e.g., existing files, folders, contacts);
  • displaying the electronic objects or their names/icons in a user interface;
  • receiving an importance value associated with at least one electronic object, wherein the importance value is entered by a user;
  • determining a position to place the electronic objects in the user interface directly from the importance value; and
  • placing the electronic objects in that position.
• The complaint reserves the right to assert all claims, including dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendant Chewy's "products and services," specifically its websites, which allegedly include a "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶3, ¶9).

Functionality and Market Context

• The complaint alleges that Chewy operates, sells, and offers products through its websites throughout Texas and the judicial district (Compl. ¶3). The complaint does not describe specific features of Chewy's website. However, it references URLs for "marinerfinance.com" as examples of Defendant's websites where infringing activity occurs (Compl. ¶3, ¶12).
• The complaint alleges the accused products and services are not staple commercial products and that their only reasonable use is an infringing one (Compl. ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that support for its infringement allegations can be found in a "preliminary exemplary table attached as Exhibit B" (Compl. ¶10). This exhibit was not included with the filed complaint. In the absence of a claim chart, the infringement theory must be inferred from the complaint's narrative allegations.

The complaint alleges that Chewy "maintains, operates, and administers a system with methods and user interface for discovering information in a text content and extracting and presenting the information that infringes one or more claims of the ’131 patent" (Compl. ¶9). This broad allegation does not specify how Chewy’s e-commerce platform is alleged to meet the specific limitations of any asserted claim.

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the functionality of a commercial e-commerce website, which typically uses automated algorithms to sort products based on proprietary relevance metrics (e.g., popularity, sales data, user browsing history), falls within the scope of a claim requiring the system to receive an "importance value... entered by a user" to organize objects.
  • Technical Questions: The complaint does not identify any feature on Chewy's website that allows a user to input a specific, non-binary numerical value to rank or sort "electronic objects" as recited in claim 1. A key factual question will be what evidence, if any, demonstrates that Chewy's system receives and uses a user-entered importance value to determine the display position of an object. The complaint's reference to an unrelated financial services company's website ("marinerfinance.com") raises further questions about the specificity and accuracy of the infringement allegations (Compl. ¶3, ¶12).

V. Key Claim Terms for Construction

• The Term: "an importance value... entered by a user" (from Claim 1).
• Context and Importance: This term appears to be the central novel element of the claim. The case may hinge on whether this phrase requires direct, explicit user input of a value (e.g., typing a number, selecting from a ranked scale) or if it can be construed more broadly to cover implicit user feedback that an algorithm translates into a value. Practitioners may focus on this term because standard e-commerce sorting features are typically algorithmic and not based on direct numerical input from users for individual items.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the value can be transformed from other user inputs, such as from a "text description" or "a selection of a user interface object" (’131 Patent, col. 18:6-9). This could support an argument that user actions other than direct numerical entry (e.g., clicking a "like" button, selecting a filter) could constitute "entering" a value.
  • Evidence for a Narrower Interpretation: The patent consistently provides examples of explicit user input. Figure 2A shows a user interface with fields for entering numerical importance scores (e.g., "0.95," "0.8") (’131 Patent, Fig. 2A, col. 8:28-34). The claim language itself specifies the value is "entered by a user" and then used "directly" to determine an object's position, suggesting a direct causal link rather than an inferred one from general user behavior (’131 Patent, col. 18:40-45).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Chewy actively encourages and instructs customers on how to use its products and services in an infringing manner (Compl. ¶11). It also alleges contributory infringement based on the same conduct, further alleging the accused product is not a staple commercial product and has no substantial non-infringing use (Compl. ¶12).
• Willful Infringement: Willfulness is alleged based on Defendant's knowledge of the ’131 patent "from at least the filing date of the lawsuit" (Compl. ¶11-12). The complaint reserves the right to amend if pre-suit knowledge is discovered, and the prayer for relief requests a finding of willfulness if such knowledge is proven (Compl. ¶11 n.1; Prayer for Relief ¶e).

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

1. A primary evidentiary question will be one of factual support: Can Plaintiff produce evidence that the accused Chewy websites and services perform the specific functions required by the claims, particularly the limitation of "receiving an importance value... entered by a user" for the purpose of organizing electronic objects? The complaint’s high level of generality and apparent citation errors present an initial hurdle.
2. A core issue will be one of definitional scope: How will the court construe the term "importance value... entered by a user"? The resolution of this issue will likely determine the outcome, as it defines the line between the patent's requirement for explicit, user-driven ranking and the automated, algorithm-driven personalization common to modern e-commerce platforms.