Linfo IP LLC v. Sitzco LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: SitzCo LLC d/b/a Versacarry (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 4:25-cv-05211, S.D. Tex., 10/31/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in Texas, has a regular and established place of business in the district, has committed alleged acts of infringement in the district, and conducts substantial business in the forum.
• Core Dispute: Plaintiff alleges that a system maintained and operated by Defendant for discovering, extracting, and presenting information infringes a patent related to organizing unstructured data objects based on relevance.
• Technical Context: The technology addresses the problem of information overload by providing systems to analyze unstructured electronic data, assign relevance or importance scores, and display the data in a manner that prioritizes more relevant items for the user.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity. It also notes that Plaintiff and its predecessors have entered into prior settlement licenses related to its patents, but alleges that none of these licenses were for the production of a patented article, a statement likely intended to address potential patent marking defenses under 35 U.S.C. § 287.

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 addresses the problem of "information overload" faced by users of systems like social networks, email, and search engines, where a high volume of information makes it difficult to discern valuable or relevant content (ʼ131 Patent, col. 1:20-39).
• The Patented Solution: The invention provides a system that analyzes a collection of "unstructured data objects" (e.g., emails, files, contacts), determines a "relevance measure" for those objects based on user-defined criteria, and then displays the objects in different visual formats or separate areas to distinguish more relevant items from less relevant ones (ʼ131 Patent, Abstract; Fig. 1). For example, objects with a higher relevance score may be displayed in a larger font or in a primary display area, while lower-relevance objects are shown in a smaller font or a secondary area (ʼ131 Patent, col. 2:9-16).
• Technical Importance: The technology aims to provide a more effective method for filtering and presenting information that moves beyond simple chronological or alphabetical sorting to a cognitively-aligned display based on user-specified importance (ʼ131 Patent, col. 1:48-53).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-20, which includes independent claims 1, 9, and 18 (Compl. ¶72).
• Independent Claim 1 recites a method comprising:
  • obtaining a plurality of electronic objects, specified as "currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book";
  • displaying the objects in a user interface;
  • receiving a user-entered "importance value" associated with at least one object;
  • determining a display position for the objects "directly from the importance value"; and
  • placing the objects in that determined position.
• Independent Claim 9 recites a method of associating a user-specified "importance value" with an electronic object based on an identified "attribute or attribute value" of that object (e.g., the number of times it was accessed).
• Independent Claim 18 recites a method of associating a user-specified "importance value" with a group of electronic objects that share a common attribute.
• The complaint reserves the right to assert dependent claims (Compl. ¶72).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentality as a "system with methods and user interface for discovering information in a text content and extracting and presenting the information" that Defendant "maintains, operates, and administers" (Compl. ¶72). It further identifies "review platforms" on Defendant's website, as an example of an infringing system (Compl. ¶75).

Functionality and Market Context

The complaint alleges the accused system provides functionality for "discovering information in a text content and extracting and presenting the information" to users and customers (Compl. ¶72, ¶74). The market context is electronic commerce, as Defendant is alleged to sell and offer to sell products through its website throughout Texas and the United States (Compl. ¶65, ¶71). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of the ’131 Patent but refers to a non-proffered "Exhibit B" for detailed support (Compl. ¶73). The following chart summarizes the infringement theory for representative claim 1 as implied by the complaint's general allegations against Defendant's system.

9,430,131 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A primary question may be whether the "electronic objects" on Defendant's accused "review platforms" (e.g., customer reviews) meet the specific definition required by Claim 1: "currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book" (ʼ131 Patent, col. 18:32-35). The complaint does not explain how web-based text content like product reviews qualifies under this specific claim language.
  • Technical Questions: What specific feature of the accused system constitutes "receiving an importance value... entered by a user"? (ʼ131 Patent, col. 18:38-40). The complaint does not identify any particular user control (such as a sorting menu or filtering option) and provides no facts to suggest that any such control, if it exists, functions as the claimed "importance value."

V. Key Claim Terms for Construction

• The Term: "importance value"

• Context and Importance: This term is central to the patent's claimed functionality. Its construction will determine what kind of user input is required to infringe. A broad definition might encompass common web UI features like selecting an option from a "sort by" dropdown menu, whereas a narrower definition could require a more specific, granular input.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Claim 1 describes the value as potentially being "transformed from a text specified by a user" or from "a selection of a user interface object" (ʼ131 Patent, col. 18:43-47), language that could support arguing that selecting a standard sorting criterion is sufficient.
  • Evidence for a Narrower Interpretation: The specification repeatedly illustrates the "importance value" as a non-binary, numerical score (e.g., values of 0.95, 0.8, etc., in Fig. 2A) or a selection from multiple weighted tiers (e.g., "High normal low" in Fig. 2B) (ʼ131 Patent, Fig. 2A-C, Fig. 6A-B). This may support an interpretation requiring a more granular or quantitative user input than a simple binary choice.

• The Term: "electronic objects"

• Context and Importance: The infringement analysis for Claim 1 will depend entirely on whether the content on Defendant's accused website (e.g., product reviews) falls within the scope of this term as explicitly limited in that claim.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent’s detailed description uses broader, exemplary language, referring to "message objects, or information objects, such as items in a feed or emails" ('131 Patent, col. 2:7-9) and "unstructured data objects" generally (ʼ131 Patent, Abstract).
  • Evidence for a Narrower Interpretation: Claim 1 contains a "wherein" clause that explicitly restricts the term for purposes of that claim: "wherein the electronic objects comprise currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book" (ʼ131 Patent, col. 18:32-35). This language appears to narrow the term’s scope significantly from the broader usage in the specification.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement based on Defendant allegedly instructing customers on how to use the accused services, including through "product instruction manuals" (Compl. ¶74, ¶75). It also pleads contributory infringement, alleging the accused service is not a staple commercial product and has no substantial non-infringing use (Compl. ¶75).
• Willful Infringement: Willfulness is alleged based on Defendant's knowledge of the ’131 Patent acquired "from at least the filing date of the lawsuit" (Compl. ¶74, ¶75). The plaintiff reserves the right to amend if pre-suit knowledge is found in discovery (Compl. p. 4, n.1).

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

• A core issue will be one of definitional scope: can the term "electronic objects," which Claim 1 explicitly limits to "files or file folders... [or] contacts," be construed to cover the user-generated content (e.g., product reviews) on the accused e-commerce website?
• A key evidentiary question will be one of factual sufficiency: what evidence will the plaintiff provide to demonstrate that the accused system actually performs the claimed steps of "receiving an importance value... entered by a user" and reordering content accordingly, as the complaint offers only conclusory allegations on this technical point?