M4siz Ltd v. Williams Sonoma

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: M4siz Limited (England)
  • Defendant: Pottery Barn, Inc. (California); Williams-Sonoma, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 6:22-cv-00607, W.D. Tex., 06/10/2022
• Venue Allegations: Venue is based on Defendants having regular and established places of business within the Western District of Texas, including a specific retail location in Austin, Texas.
• Core Dispute: Plaintiff alleges that Defendants’ e-commerce websites infringe a patent related to a method for initiating an online search by entering a composite search query into a browser's address bar.
• Technical Context: The technology concerns a process for simplifying web searches by trapping the error signal generated from an invalid URL and using it to parse and execute a search query.
• Key Procedural History: The complaint notes that the patent-in-suit was conveyed to Plaintiff M4siz Limited on May 14, 2007, with the assignment recorded at the USPTO on May 28, 2010.

Case Timeline

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

U.S. Patent No. 6,526,402, "Searching procedures," Issued Feb. 25, 2003

The Invention Explained

• Problem Addressed: The patent describes conventional internet searching as a multi-step process requiring a user to first navigate to a search engine's homepage, enter search terms into designated fields, and then manually sift through the often-voluminous results, which the patent characterizes as time-consuming and inefficient (’402 Patent, col. 1:7-23).
• The Patented Solution: The invention proposes a streamlined procedure where a user enters a single "request string" directly into a browser's address field. This string is a composite, containing both a pointer to a search engine (its URL) and the desired search terms, making the overall address syntactically invalid. The system is designed to monitor for and "trap" the resulting error signal that this invalid address generates. This trapped error then triggers a program to parse the original string, separating the search engine's address from the search terms. The extracted search terms are then submitted to the specified search engine, and the results are returned to the user, bypassing the need to first visit the search engine's homepage (’402 Patent, Abstract; col. 2:33-47; Fig. 2).
• Technical Importance: The described method sought to create a more "seamless" user experience for web searching by reducing the number of user actions required to obtain search results (’402 Patent, col. 1:26-29).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶18).
• The essential elements of independent claim 1 are:
  • A database searching procedure using a search engine.
  • Submitting a request string that comprises both a valid pointer to a search engine and a search string.
  • 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 parsed search string to the search engine.
  • Passing at least some of the returned data back to the user.
• The complaint reserves the right to assert additional claims (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are the Pottery Barn-branded website (potterybarn.com) and the Williams-Sonoma branded website (williams-sonoma.com) (Compl. ¶16).

Functionality and Market Context

The complaint identifies the accused instrumentalities as e-commerce websites and alleges that Defendants make, use, sell, and offer for sale infringing products and services through them (Compl. ¶¶4, 16, 18). The complaint does not provide specific details regarding the technical implementation of the search functionality on these websites, instead referring to claim chart exhibits that were not attached to the filed complaint (Compl. ¶26).

IV. Analysis of Infringement Allegations

The complaint references claim charts in Exhibits B and C to describe the alleged infringement of claim 1, but these exhibits were not provided with the complaint (Compl. ¶26). In their absence, the complaint’s narrative theory is that the accused websites directly infringe by practicing the method of at least claim 1 of the ’402 patent (Compl. ¶18). The complaint does not, however, describe how the search functions on the accused websites allegedly perform the claimed steps of generating and trapping an error signal to initiate a search.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Technical Questions: A primary question for the court will be an evidentiary one: does the search functionality on the accused websites actually operate by generating an "error signal" from an invalid address, or does it use other common web technologies (e.g., HTML form submissions, JavaScript/AJAX requests) that do not rely on trapping an error? The complaint does not provide evidence to resolve this question.
• Scope Questions: The dispute may turn on whether the accused websites' operations can be said to involve submitting a single "request string" containing both a "valid pointer" and a "search string." How a user's input in a website's search bar is processed and whether it constitutes the composite string required by the claim will be a point of analysis.

V. Key Claim Terms for Construction

• The Term: "error signal"

  • Context and Importance: This term is the central mechanism of the claimed invention; the entire process is triggered by it. The viability of the infringement case depends on whether any programmatic trigger used by the accused websites can be construed as an "error signal."
  • Intrinsic Evidence for a Broader Interpretation: The specification states the "error signal may comprise an error code or message," which could suggest a broader class of signals beyond a standard HTTP error (’402 Patent, col. 2:7-8). The patent also describes the syntax as "deliberately invalid," forcing an "error message" that is then "trapped," potentially covering any non-standard input that is programmatically handled (’402 Patent, col. 4:30-36).
  • Intrinsic Evidence for a Narrower Interpretation: The figures and description strongly link the "error signal" to the process that would otherwise lead to a "standard error page," such as an HTTP 404 error page (’402 Patent, Fig. 2; col. 4:38-42). This context suggests the term refers specifically to the interception of a signal that indicates a failure to locate a web resource, not a general-purpose programmatic trigger.

• The Term: "request string comprising a valid pointer to a specified search engine and a search string"

  • Context and Importance: The structure of the user's input is a key limitation. Practitioners may focus on this term because modern on-site search typically involves a user entering only the search query into a dedicated box, not a composite string with the search engine's URL into the browser's address bar.
  • Intrinsic Evidence for a Broader Interpretation: The patent describes the input as a "composite" string that could be entered "as if it were a sub-page of a traditional web address," which a party might argue could encompass modern URL query parameters (e.g., /search?q=query) constructed by the browser or server (’402 Patent, col. 4:21-25).
  • Intrinsic Evidence for a Narrower Interpretation: The specification provides specific examples like "www.searchengine.com/search string" and "www.searchengine.com/fishing/float," which imply a specific, user-entered format combining a domain and path-like search terms in a single string, distinguishing it from text entered into a webpage's form field (’402 Patent, col. 4:25, col. 5:4-11).

VI. Other Allegations

• Indirect Infringement: The complaint alleges active inducement, asserting that Defendants provide "product manuals, brochures, videos, demonstrations, and website materials" that instruct customers on how to use the accused products, allegedly causing infringement (Compl. ¶20). It also pleads contributory infringement, alleging Defendants supply a material part of the invention that is not a staple article of commerce (Compl. ¶19).
• Willful Infringement: The complaint does not use the term "willful," but it includes allegations that may support such a claim, stating on information and belief that Defendants "made no attempt to design around the claims" and "did not have a reasonable basis for believing that the claims of the ‘402 patent were invalid" (Compl. ¶¶21-22). The allegations do not specify whether this conduct is based on pre- or post-suit knowledge.

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

This case appears to present several fundamental questions for the court:

• A core issue will be one of technical operation: Can Plaintiff produce evidence that the accused websites’ search functions operate by generating and trapping an "error signal" from an invalid, composite URL as claimed, or is there a fundamental mismatch with the accused technology, which may use standard, non-error-based web protocols?
• The case will also turn on a question of definitional scope: Can the term "error signal," as described in the patent in the specific context of an invalid web address, be construed to cover the server-side logic or client-side scripts that power a modern e-commerce site's search bar?
• Finally, a key evidentiary question will be whether the user action on the accused websites—typing a query into a search field—can be equated with the claimed step of "submitting a request string comprising a valid pointer... and a search string," an action the patent illustrates as occurring within the browser's main address bar.