DCT
1:25-cv-01202
Spaji Inc v. Community Resource Credit Union
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Spaji, Inc. (Nevada)
- Defendant: Community Resource Credit Union (Texas)
- Plaintiff’s Counsel: Friedland Cianfrani LLP; Wilson Robertson & Vandeventer, P.C.
- Case Identification: 1:25-cv-01202, W.D. Tex., 08/01/2025
- Venue Allegations: Venue is alleged to be proper based on Defendant having multiple regular and established places of business in the district, including shared branch locations in Austin, and committing the alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Community Resource Alexa Skill infringes a patent related to systems that use voice commands to automatically select a specific application from a plurality of options and retrieve domain-specific information.
- Technical Context: The technology at issue addresses the challenge of accessing information from multiple distinct services (e.g., different financial institutions) through a single, unified natural-language voice interface on a consumer device.
- Key Procedural History: The complaint notes that the patented technology has been licensed to ENACOMM, Inc. since at least 2018, which suggests commercial activity and a potential basis for damages calculations. The complaint also quotes the patent examiner's reasoning during prosecution, indicating an argument that the claims were allowed over prior art based on the specific combination of selecting an application and retrieving/filtering data from domain-specific sources.
Case Timeline
| Date | Event |
|---|---|
| 2012-03-30 | '878 Patent Priority Date |
| 2016-06-07 | '878 Patent Issue Date |
| By 2018-12-31 | ENACOMM, a SPAJI licensee, began marketing related technology |
| Since 2020 | Defendant began offering the Accused Product |
| 2021 | Amazon Echo Show 15, an exemplary device, was released |
| 2025-08-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,361,878 - COMPUTER-READABLE MEDIUM, SYSTEM, AND METHOD OF PROVIDING DOMAIN-SPECIFIC INFORMATION
- Patent Identification: U.S. Patent No. 9,361,878, COMPUTER-READABLE MEDIUM, SYSTEM, AND METHOD OF PROVIDING DOMAIN-SPECIFIC INFORMATION, issued on June 7, 2016. (Compl. ¶8).
The Invention Explained
- Problem Addressed: The patent describes a limitation in conventional interactive voice response (IVR) systems, which were typically "enterprise specific (domain-specific)." This meant a user could only use a voice system to retrieve information from a single business entity, such as a particular credit card company or bank, at a time. (’878 Patent, col. 1:14-27).
- The Patented Solution: The invention describes a system, typically on a portable device like a smartphone, that can receive a single natural language voice request and automatically determine which application (from among multiple available applications) corresponds to the request. The system then uses that selected application to retrieve specific data from the correct external data source (e.g., a bank's server) and provides it to the user. (’878 Patent, Abstract; col. 3:47-53). This architecture aims to create a "one-stop location for the user to retrieve account information from various accounts associated with different companies." (’878 Patent, col. 2:51-55).
- Technical Importance: This approach provided a method for a single user interface on a device to act as a gateway to numerous, otherwise siloed, third-party data services, a concept foundational to modern digital assistant platforms and their third-party application ecosystems. (Compl. ¶¶9-10).
Key Claims at a Glance
- The complaint asserts one or more claims, "including at least Claim 1." (Compl. ¶26).
- Independent Claim 1 of the ’878 Patent is for a computer-readable storage device for a portable communications device, with instructions to perform a method comprising the following essential elements:
- receiving a natural language request corresponding to an audio input associated with a user;
- automatically selecting an application from a plurality of applications based on the natural language request, the selected application configured to retrieve account information from selected ones of a plurality of domain-specific data sources;
- retrieving account information associated with the user from a domain-specific data source of the plurality of domain-specific data sources through a network based on the natural language request;
- filtering the account information based on the natural language request to produce output information, the output information including a portion of the account information according to the natural language request; and
- providing the output information to an output interface.
III. The Accused Instrumentality
- Product Identification: The "Community Resource Alexa Skill" ("Accused Product") offered for use with Amazon Alexa products. (Compl. ¶13).
- Functionality and Market Context:
- The Accused Product is an application (a "Skill") that customers can enable on their Alexa-enabled devices to interact with their Community Resource Credit Union (CRCU) accounts via voice command. (Compl. ¶¶14-15).
- CRCU allegedly provides the necessary "invocation words, sample utterances, and 'intents'" to the Alexa platform, which instructs the system on how to recognize user commands and what actions to perform in response. (Compl. ¶14).
- When a user speaks a command, such as "Alexa, ask Community Resource how much I have in my checking account," the Alexa system is alleged to use the CRCU-provided instructions to select the CRCU skill, connect to CRCU's (or its vendor's) servers over the internet, retrieve the specific requested data, and provide it to the user. (Compl. ¶¶16-21).
- The complaint alleges CRCU markets the skill as a convenient, "around-the-clock option" for customers and that it reduces demand on traditional customer service channels like call centers. (Compl. ¶22). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’878 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving a natural language request corresponding to an audio input associated with a user; | The Alexa system receives a user's utterance (e.g., "Alexa, ask Community Resource...") and converts the audio input into a natural language request. | ¶16 | col. 7:63-65 |
| automatically selecting an application from a plurality of applications based on the natural language request, the selected application configured to retrieve the account information from selected ones of a plurality of domain-specific data sources; | The Alexa system uses the invocation name ("Community Resource") and CRCU-provided intents to automatically select the Community Resource Alexa Skill from the plurality of applications available on the Alexa platform. | ¶17 | col. 8:1-5 |
| retrieving account information associated with the user from a domain-specific data source of the plurality of domain-specific data sources through a network based on the natural language request; | The Alexa system uses the intents provided by CRCU to retrieve the user's account information (e.g., balances, transactions) from CRCU's or its vendor's (e.g., Fiserv) servers via the internet. | ¶¶18-19 | col. 8:6-10 |
| filtering the account information based on the natural language request to produce output information, the output information including a portion of the account information according to the natural language request; | The Alexa system filters the retrieved account data to provide only the specific information requested by the user (e.g., a balance), excluding other non-responsive data such as account numbers or profile metadata. | ¶20 | col. 8:11-16 |
| providing the output information to an output interface. | The Alexa device provides the requested information to the user, for example, by speaking the account balance. | ¶21 | col. 8:16-17 |
- Identified Points of Contention:
- Scope Questions: Claim 1 is directed to a storage medium for a "portable communications device." The complaint alleges infringement by the "Alexa system," a distributed architecture involving a local device and remote cloud servers. A central question will be whether the claim scope is limited to actions performed by the processor on the local portable device itself, or if it can read on a system where key steps (like retrieving and filtering data) are performed on remote servers that communicate with the local device.
- Technical Questions: The infringement theory hinges on whether the Alexa platform's method of invoking a skill via a specific name ("Community Resource") constitutes "automatically selecting an application... based on the natural language request" as required by the claim. The court may need to determine if this function is technically distinct from the "application selection logic" described in the patent, which may suggest a more holistic analysis of the user's request rather than simple keyword recognition. (Compl. ¶17; ’878 Patent, col. 3:49-53).
V. Key Claim Terms for Construction
"portable communications device"
- Context and Importance: This term, appearing in the preamble of Claim 1, is critical for defining the physical and logical boundaries of the claimed invention. Its construction will determine whether the claim can cover the distributed, client-cloud architecture of the accused Alexa system or if it is confined to a self-contained device.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's specification discloses an embodiment in Figure 1 where the "portable communications device" (104) explicitly communicates with a separate, remote "Data Retrieval System" (102) that performs significant data processing. (’878 Patent, Fig. 1, col. 4:6-17). This may support an interpretation where the claimed "device" is part of a larger system.
- Evidence for a Narrower Interpretation: The claim language recites "instructions that, when executed by a processor of a portable communications device, cause the processor to perform a method..." This could be interpreted to require the processor of the portable device to perform all the subsequent steps. The embodiment in Figure 2 depicts the key logic ("Data Retrieval Logic" 140) as residing in the memory of the portable device itself. (’878 Patent, Fig. 2, col. 5:58-65).
"automatically selecting an application ... based on the natural language request"
- Context and Importance: This limitation defines the core inventive concept of choosing the correct service from many. Practitioners may focus on this term because the infringement case depends on equating the Alexa platform's skill invocation mechanism with the patent's "application selection logic."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes "application selection logic 124" that "select[s] an application based on the natural language text input." (’878 Patent, col. 3:49-52). A party could argue that any system that parses spoken words to choose one application out of many meets this general description, including a system that relies on a specific invocation name contained within the request.
- Evidence for a Narrower Interpretation: The patent references "Siri®" as an example of an intelligent assistant. (’878 Patent, col. 1:40-44). A party may argue that this context implies a more sophisticated selection process than merely matching a predefined invocation name, perhaps one that analyzes the semantics of the entire request to infer the correct application.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement.
- Inducement is based on allegations that CRCU actively encourages and instructs its customers on how to enable and use the accused skill, for instance by providing "exemplary prompts." (Compl. ¶¶23, 32).
- Contributory infringement is based on the allegation that the Community Resource Alexa Skill is a material component especially made for use in the infringing system and is not suitable for a substantial non-infringing use. (Compl. ¶33).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged knowledge of the ’878 Patent "since at least the filing of this Complaint and/or the date this Complaint was served upon CRCU." (Compl. ¶¶29, 36). There are no allegations of pre-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case may depend on the court's determination of the following open questions:
A core issue will be one of architectural scope: Can the claim term "portable communications device," which serves as the foundation for the asserted claim, be construed to read on the distributed client-cloud architecture of the accused Alexa system? The patent’s disclosure of both client-server and standalone device embodiments will be central to this dispute.
A key evidentiary question will be one of technical interpretation: Does the accused system’s process for launching a skill via a specific "invocation name" perform the same function as the claimed limitation of "automatically selecting an application... based on the natural language request," or is there a fundamental mismatch between the patent’s "application selection logic" and the accused method of operation?