Locket IP LLC v. TJX Companies Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Locket IP LLC (Texas)
  • Defendant: TJX Companies, Inc. (Delaware)
  • Plaintiff’s Counsel: The Mort Law Firm, PLLC
• Case Identification: 6:22-cv-00549, W.D. Tex., 05/31/2022
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement and has regular and established places of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s TJX.com website infringes patents related to methods for automatically rearranging and displaying information in a user interface based on user interest.
• Technical Context: The patents address user interfaces that display multiple "cards" of information, such as in an electronic program guide, and aim to simplify navigation by automatically highlighting relevant content.
• Key Procedural History: U.S. Patent No. 10,514,832 is a continuation of the application that led to U.S. Patent No. 9,990,112, indicating a shared specification and a direct lineage between the asserted patents.

Case Timeline

Date	Event
2010-12-22	Earliest Priority Date (’112 & ’832 Patents)
2018-06-05	Issue Date, U.S. Patent No. 9,990,112
2019-12-24	Issue Date, U.S. Patent No. 10,514,832
2022-05-31	Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,990,112, METHOD AND APPARATUS FOR LOCATING REGIONS OF INTEREST IN A USER INTERFACE, Issued June 5, 2018

The Invention Explained

• Problem Addressed: The patent describes the task of individually scrolling through multiple windows or "cards" of content on a media device as "cumbersome," particularly when the user wants to quickly find specific items of interest and the display area is limited (’112 Patent, col. 1:26-38).
• The Patented Solution: The invention proposes a method where, in response to a user command, the system automatically determines "regions of interest" within multiple cards by searching user preference data. It then updates the display to show these regions of interest, which may involve rearranging the cards and removing cards that lack a region of interest from the view (’112 Patent, Abstract; col. 1:40-47). The process is depicted in a flowchart, which includes steps for determining regions of interest based on user preferences and updating the display accordingly (’112 Patent, FIG. 17).
• Technical Importance: The technology aims to improve user experience on content-heavy platforms by reducing manual navigation and proactively surfacing personalized content.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶14).
• The essential elements of Claim 1 include:
  • generating a plurality of cards for display;
  • in response to a user command, determining regions of interest within each of the plurality of cards by searching information indicating previous user preferences; and
  • updating for display the plurality of cards to visibly show in a display area... the at least one region of interest of multiple cards... wherein said updating includes repositioning the plurality of cards to remove cards not included in the first group... and to visibly display the at least one region of interest within all of the multiple cards included in the first group. (’112 Patent, col. 11:54-col. 12:4).

U.S. Patent No. 10,514,832, METHOD FOR LOCATING REGIONS OF INTEREST IN A USER INTERFACE, Issued December 24, 2019

The Invention Explained

• Problem Addressed: As a continuation of the '112 Patent, this patent addresses the same problem: the inefficiency of a user having to manually manipulate each window or card to find specific topics of interest on a media device (’832 Patent, col. 1:31-38).
• The Patented Solution: The solution is a method to automatically show regions of interest in response to an "interest feature" being activated. The system rearranges multiple cards so that the specific region of interest for each card is shown, without requiring the user to manipulate them individually (’832 Patent, col. 1:41-47). For example, FIG. 14 illustrates how cards (1320, 1330, 1340) are vertically shifted to bring their respective regions of interest (1325, 1335, 1345) into a shared display area (’832 Patent, FIG. 14).
• Technical Importance: The technology provides an automated method for focusing a user's view on relevant portions of content across multiple separate information containers.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶23).
• The essential elements of Claim 1 include:
  • determining, in response to a user command, regions of interest within each of a plurality of cards by searching information indicating previous user preferences; and
  • updating for display the plurality of cards to visibly show in a display area... the at least one region of interest of multiple cards... wherein said updating includes repositioning the plurality of cards to remove cards not included in the first group... and to visibly display the at least one region of interest within all of the multiple cards included in the first group. (’832 Patent, col. 11:57-col. 12:12).
• Notably, Claim 1 of the ’832 Patent does not include the initial "generating a plurality of cards for display" step found in Claim 1 of the ’112 Patent.

III. The Accused Instrumentality

Product Identification

The "TJX Website" at https://www.tjx.com (Compl. ¶7).

Functionality and Market Context

The complaint alleges that the Accused Website provides users with "the ability to search for a store in any desired location" (Compl. ¶8). The complaint does not contain further technical details about the website's functionality or allegations regarding its market position. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that claim charts comparing the asserted claims to the Accused Website are attached as exhibits (Compl. ¶¶15, 24). However, these exhibits were not filed with the complaint document. The complaint itself offers only a conclusory statement that the Accused Website "satisfies all elements of claim 1" of each patent, without providing specific factual allegations mapping website features to claim elements (Compl. ¶¶15, 24).

Given the absence of claim charts or detailed infringement allegations in the complaint body, a tabular analysis is not possible. The core narrative theory appears to be that the website's store locator function practices the patented methods.

Identified Points of Contention

• Factual Question: What specific feature of the TJX website is alleged to search "information indicating previous user preferences"? The complaint does not plead facts establishing that the store locator function considers a user's history, profile, or other preference indicators as required by the claims.
• Scope Question: Does a website store locator function, which responds to a user's explicit search for a location, constitute the claimed method of automatically repositioning a "plurality of cards" to display "regions of interest" based on "previous user preferences"? The patents' specification heavily describes the invention in the context of personalized media guides for television shows and movies (’112 Patent, FIGs. 5, 6; col. 7:51-col. 8:8). The applicability of the claims to a different technical environment like a store locator will likely be a central issue.
• Technical Question: Does the store locator generate and manipulate a "plurality of cards" as that term is used in the patents, or does it display results in a different format (e.g., a list or a single map view)? The complaint does not provide the necessary detail to analyze this technical correspondence.

V. Key Claim Terms for Construction

For both the ’112 and ’832 patents, the construction of the following terms, which appear in their respective asserted independent claims, may be critical.

"information indicating previous user preferences"

• Context and Importance: This term is the basis for how the system identifies what content is of interest. The infringement allegation hinges on whether the information used by the Accused Website's store locator (e.g., a user-entered zip code) meets this definition. Practitioners may focus on whether this term requires stored, historical user data or if it can be read to cover a preference expressed in a single, real-time command.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification mentions determining user preferences based on how a user interfaces with a device, where "video and audio media that are accessed more are assumed to be more relevant to a user than video and audio media that are accessed infrequently" (’112 Patent, col. 10:18-24). This could suggest that any user interaction is a preference.
  • Evidence for a Narrower Interpretation: The specification repeatedly links preferences to a "user profile where a user explicitly lists keywords or indicates various subjects that the user has interest" or attributes stored in a database, such as interests in "actors, television shows, directors, sports teams, music, and the like" (’112 Patent, col. 9:15-26). The embodiments focus on media guides, suggesting the "preferences" relate to entertainment content choices over time.

"regions of interest"

• Context and Importance: The definition of this term will determine what part of the displayed content must be surfaced by the accused method. It is central to whether a store address in a list of search results constitutes a "region of interest" in the claimed sense.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term is defined broadly as "topics, metadata, graphics, and the like" that are determined to be of interest based on the "user preference information" (’112 Patent, col. 9:12-14).
  • Evidence for a Narrower Interpretation: The patent figures consistently depict the "region of interest" as a specific graphical element or text block within a larger "card" that contains other information (’112 Patent, FIGs. 13, 14, elements 1325, 1335, 1345). This may support an argument that the term requires identifying a sub-component of a larger information container, not the entire search result itself.

VI. Other Allegations

Indirect Infringement

The complaint does not provide sufficient detail for analysis of indirect infringement. It does not allege specific facts to support that Defendant had knowledge of the patents or intended for its users to infringe.

Willful Infringement

The complaint does not provide sufficient detail for analysis of willful infringement. It contains no allegations regarding pre- or post-suit knowledge of the patents or conduct rising to the level of willfulness.

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

1. Plausibility of Infringement: A primary threshold issue will be whether the complaint pleads sufficient factual matter to make its infringement claim plausible under the Iqbal/Twombly standard. Specifically, the court will have to assess whether the bare allegation that a store locator infringes—without explaining how it meets key limitations like searching "previous user preferences"—is sufficient to proceed.

2. Definitional Scope and Applicability: The case will likely turn on a question of claim construction: can the claims, which are described and exemplified in the context of personalized media content guides, be interpreted to cover the fundamentally different application of a generic store locator on a retail website? The resolution of terms like "regions of interest" and "previous user preferences" will be dispositive.

3. Evidentiary Support: Assuming the case proceeds, a key evidentiary question will be whether Plaintiff can demonstrate that the Accused Website technically performs the claimed steps. This will require evidence showing that the website's backend considers historical user data or profiles to re-rank or reposition a plurality of distinct information "cards," a function not immediately apparent from the public-facing store locator described in the complaint.