DCT
6:22-cv-00585
M4siz Ltd v. Wayfair
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: M4siz Limited (United Kingdom)
- Defendant: Wayfair, Inc. (Delaware)
- Plaintiff’s Counsel: Ramey LLP
- Case Identification: 6:22-cv-00585, W.D. Tex., 06/08/2022
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business in the Western District of Texas, including a specific facility located in San Antonio.
- Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to a method for initiating a database search by submitting a composite, intentionally invalid address that generates an error signal, which in turn triggers a search process.
- Technical Context: The technology concerns user interface methods for web-based searching, a fundamental aspect of internet navigation and e-commerce platforms.
- Key Procedural History: The complaint alleges an issue date for the patent-in-suit of October 11, 2016. However, the patent document attached as Exhibit A to the complaint shows an issue date of February 25, 2003. The complaint also notes that the patent was assigned to the current plaintiff in a transaction recorded with the USPTO on May 28, 2010.
Case Timeline
| Date | Event |
|---|---|
| 2000-10-27 | '402 Patent Priority Date |
| 2003-02-25 | '402 Patent Issue Date |
| 2010-05-28 | Assignment of '402 Patent to Plaintiff recorded |
| 2022-06-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,526,402 - "Searching procedures"
- Patent Identification: U.S. Patent No. 6,526,402, "Searching procedures", issued February 25, 2003.
The Invention Explained
- Problem Addressed: The patent describes conventional internet searching (circa 2000) as a cumbersome, multi-step process. Users were required to navigate to a search engine's homepage, enter search terms into specific fields, and then manually sort through large volumes of returned results, which the patent characterizes as an inefficient user experience (ʼ402 Patent, col. 1:8-23).
- The Patented Solution: The invention proposes a streamlined search method where a user enters a single, composite "request string" directly into a browser's address or location field. This string combines a valid pointer to a search engine (its URL) with a search string (the query terms). Because this composite string represents an invalid or non-existent web address, it causes the server to generate an "error signal." A program or script then "traps" this error, parses the original request string to separate the search engine's URL from the query terms, submits the query to the specified search engine, and returns the results to the user (ʼ402 Patent, Abstract; col. 4:39-col. 5:2). Figure 3 of the patent provides a flowchart illustrating this error-trapping and parsing process.
- Technical Importance: The described technique sought to make the search process more "seamless" for a user by reducing the number of required steps and integrating the search function directly into the browser's primary address input field (ʼ402 Patent, col. 2:26-29).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶17).
- The essential elements of independent claim 1 are:
- submitting a request string comprising a valid pointer to a specified search engine and a search string for specified data;
- monitoring for the generation of an error signal from the search engine;
- using the error signal to trigger parsing of the request string into the pointer and the search string;
- submitting the search string to the search engine; and
- passing at least some of the returned data back to the user.
- The complaint reserves the right to assert additional claims (Compl. ¶25).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are "Wayfair-branded websites," with https://www.wayfair.com provided as an example (Compl. ¶15).
Functionality and Market Context
- The complaint identifies the accused instrumentality as Wayfair's e-commerce website, which allows customers to search for and purchase products (Compl. ¶3, ¶15). The complaint does not provide specific details regarding the underlying technical architecture of the website's search functionality. The infringement theory appears to be based on the operation of the search features provided to users on this website (Compl. ¶17-19). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint states that a claim chart is attached as Exhibit B, but this exhibit was not included in the provided filing. The following chart summarizes the infringement theory as implied by the complaint's allegations against an e-commerce website, based on the language of claim 1.
'402 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| submitting a request string comprising a valid pointer to a specified search engine and a search string for specified data; | The complaint alleges that the Accused Products, Wayfair's websites, are used to perform the claimed method. This suggests an allegation that a user's search query on the website constitutes the claimed "request string." | ¶17 | col. 6:52-55 |
| monitoring for the generation of an error signal, from the search engine; | The complaint’s allegation of infringement implies that Wayfair's system monitors for an "error signal" that is generated as part of its search process. | ¶17 | col. 6:56-57 |
| using the error signal to trigger parsing of the request string into the pointer to the search engine and the search string to be searched by the search engine; | The infringement allegation implies that the aforementioned "error signal" triggers a parsing action within Wayfair's system to isolate the user's search query. | ¶17 | col. 6:58-62 |
| submitting the search string to the search engine; and | The allegation suggests that the parsed search query is then submitted to Wayfair's internal product database, which functions as the "search engine." | ¶17 | col. 6:63-64 |
| passing at least some of the returned data returned from the search engine, back to the user. | The Wayfair website displays product search results to the user, which is alleged to satisfy this limitation. | ¶17 | col. 6:65-col. 7:2 |
Identified Points of Contention
- Technical Question: A central technical question is whether the Wayfair website's search architecture actually operates by generating and trapping an "error signal" from an invalid URL. The complaint does not provide facts to support this, and modern web applications often use other methods (e.g., dedicated API endpoints, client-side scripting) to handle search queries, which may not involve the specific error-generation mechanism described in the patent.
- Scope Questions: The dispute may raise the question of whether a modern website's internal logic for routing a search query to a database constitutes an "error signal" as required by the claim. The patent repeatedly frames the invention in the context of an "invalid" address and the trapping of a "standard error message" (ʼ402 Patent, col. 3:11, col. 4:30).
V. Key Claim Terms for Construction
The Term: "error signal"
Context and Importance: This term is the lynchpin of the claimed method, as it is the trigger for the entire parsing and searching process. The viability of the infringement claim may depend on whether the internal workings of Wayfair's search function can be characterized as generating an "error signal." Practitioners may focus on this term because the accused technology, a modern e-commerce platform, may not generate a literal "error" in the way a 2003-era system would when encountering an unrecognized URL.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states the signal "may comprise an error code or message," which could suggest that it is not limited to a specific type of error (ʼ402 Patent, col. 2:7-8).
- Evidence for a Narrower Interpretation: The specification consistently links the "error signal" to the submission of a "deliberately invalid" or "non-existent" web address (ʼ402 Patent, col. 4:30-32). The process is described as "trapping of the standard error" that would otherwise be displayed to a user, suggesting a formal error condition like an HTTP 404 "Not Found" message (ʼ402 Patent, col. 4:61-64).
The Term: "request string comprising a valid pointer to a specified search engine and a search string"
Context and Importance: This term defines the specific structure of the input that initiates the claimed process. Infringement requires showing that the accused system receives and processes a single, composite string with these distinct components.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is general. One could argue it covers any data transmission that includes both locator and query information, regardless of format.
- Evidence for a Narrower Interpretation: The specification provides a specific example of the string's format:
www.searchengine.com/fishing/float, which is entered "in the address or location field of an Internet or intranet browser" (ʼ402 Patent, col. 2:29-32; col. 5:58-64). This suggests the term may be limited to a URL-like string entered into a browser's address bar, not a query entered into a search box on a webpage.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. The basis for these claims is the allegation that Wayfair provides materials such as "manuals, brochures, videos, demonstrations, and website materials" that instruct and encourage its customers to use the accused website in a manner that directly infringes the ’402 Patent (Compl. ¶18-19).
- Willful Infringement: The complaint alleges that Defendant made "no attempt to design around the claims" and lacked a "reasonable basis for believing" the patent was invalid (Compl. ¶20-21). These allegations are not supported by specific factual assertions regarding pre-suit knowledge of the patent or its infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of technical mechanism: what is the actual architecture of the Wayfair website's search function? The case will depend on evidence demonstrating whether it operates by intentionally generating and trapping a server "error signal" from a composite, invalid URL, as claimed in the patent, or if it utilizes a fundamentally different and non-infringing technology (such as dedicated APIs and client-side scripting) to process search queries.
- The dispute will also likely involve a core question of definitional scope: can the claim term "error signal," which the patent specification ties to a "deliberately invalid" address and a "standard error message," be construed broadly enough to read on the internal data-handling logic of a sophisticated, modern e-commerce platform that is designed to accept and process search queries as a primary function, not as an error condition?