DCT

6:22-cv-00716

Locket IP LLC v. Zara USA Inc

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:22-cv-00716, W.D. Tex., 06/30/2022
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant has committed acts of infringement and maintains regular and established places of business within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes three patents related to user interface technology, including methods for dynamically repositioning content cards to show regions of interest and for matching product images to a user's viewing environment.
  • Technical Context: The patents address user experience challenges in content-rich digital environments by aiming to reduce the effort required to find relevant information and to improve the accuracy of online product visualization.
  • Key Procedural History: U.S. Patent No. 10,514,832 is a continuation of the application that resulted in U.S. Patent No. 9,990,112, indicating a shared specification and a close technological relationship between the two patents. The complaint does not mention any other significant procedural events.

Case Timeline

Date Event
2010-12-22 Priority Date for '112 and '832 Patents
2013-06-13 Priority Date for '568 Patent
2018-06-05 U.S. Patent No. 9,990,112 Issued
2018-10-16 U.S. Patent No. 10,102,568 Issued
2019-12-24 U.S. Patent No. 10,514,832 Issued
2022-06-30 Complaint Filed

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 finding specific items of interest as "cumbersome" when a user must manually scroll through multiple windows or "cards" on a display, especially when those cards contain more information than can be viewed at once (’112 Patent, col. 1:29-37).
  • The Patented Solution: The invention provides a method to automatically address this issue. In response to a user command, the system determines "regions of interest" within multiple cards based on the user's preferences and then rearranges or repositions the cards to make those specific regions visible within the display area, potentially removing cards that lack such regions (’112 Patent, col. 2:40-45; Abstract). Figures 13 and 14 illustrate this by showing cards being shifted vertically to bring previously obscured "interest regions" (1325, 1335, 1345) into a central display area.
  • Technical Importance: This technology aims to improve the efficiency of user interfaces for content discovery on devices like tablets or computers, reducing the need for manual scrolling and manipulation.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶13).
  • Essential elements of Claim 1:
    • A method comprising: 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 included in a first group of the plurality of cards, wherein said updating includes repositioning the plurality of cards to remove cards not included in the first group from the display area and to visibly display the at least one region of interest within all of the multiple cards included in the first group within the display area of the display device.
  • The complaint does not explicitly reserve the right to assert dependent claims.

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 application leading to the ’112 Patent, this patent addresses the identical problem: the cumbersome nature of individually scrolling through multiple on-screen cards or windows to locate specific information (’832 Patent, col. 1:29-37).
  • The Patented Solution: The described solution is also a method for automatically rearranging multiple cards in a displayable area to show a "region of interest for each card or window" in response to a user's command, eliminating the need for individual manipulation (’832 Patent, col. 2:40-45). The method relies on a user profile or other preference information to identify the relevant regions (’832 Patent, col. 9:15-25).
  • Technical Importance: This patent refines the claims related to the user interface technology for automated content discovery introduced in the parent patent family.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶22).
  • Essential elements of Claim 1:
    • A method comprising: 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 included in a first group of the plurality of cards, wherein said updating includes repositioning the plurality of cards to remove cards not included in the first group from the display area and to visibly display the at least one region of interest...
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,102,568 - SYSTEM AND METHODS FOR MATCHING IMAGES WITH VIEWING ENVIRONMENT, Issued October 16, 2018

  • Technology Synopsis: The patent addresses the problem of color and brightness mismatches in online shopping, where an item's appearance on-screen differs from its actual look due to variations in user devices and ambient lighting (’568 Patent, col. 1:28-36). The proposed solution is a method where a user device accesses a shopping site, determines a characteristic of its own viewing environment using its camera, and receives a product image that is specifically selected from a plurality of pre-captured images to match that determined environment (’568 Patent, Abstract; col. 2:1-9).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶31).
  • Accused Features: The complaint alleges that the "Accused Website" infringes this patent but provides no specific factual allegations regarding how, instead incorporating by reference an exhibit not attached to the pleading (Compl. ¶33-34).

III. The Accused Instrumentality

Product Identification

Functionality and Market Context

  • The complaint provides minimal detail about the technical functionality of the Accused Website. It alleges that the website provides users "the ability to search for a store in any desired location" (Compl. ¶8). No other specific features relevant to the patents-in-suit are described in the body of the complaint. The pleading does not contain allegations regarding the website's commercial importance or market position.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain narrative infringement allegations or any claim chart exhibits. For all three asserted patents, the Plaintiff quotes an independent claim and then states that a chart comparing the claim to the Accused Website is attached as an exhibit (Compl. ¶15, ¶24, ¶33). These exhibits were not filed with the complaint. Therefore, a claim chart summary cannot be constructed.

  • Identified Points of Contention:
    • Factual Questions: A threshold issue for all asserted patents is whether the Accused Website performs the functions required by the claims. The complaint does not allege facts demonstrating that the Zara website (1) automatically repositions a "plurality of cards" based on "previous user preferences" as recited in the '112 and '832 Patents, or (2) uses a device's "camera" to determine the user's "viewing environment" to select a matching product image, as required by claim 1 of the '568 Patent.
    • Scope Questions: The dispute may raise questions about the scope of the claims relative to the functionality of a standard e-commerce website. For the '112 and '832 Patents, a key question may be whether a list of store locations in a search result qualifies as a "plurality of cards" that are "reposition[ed]" in the claimed manner.

V. Key Claim Terms for Construction

For U.S. Patent Nos. 9,990,112 and 10,514,832:

  • The Term: "regions of interest"
  • Context and Importance: This term is central to the core inventive concept of both the '112 and '832 patents. Its definition will determine what must be identified and made visible by the accused method. Practitioners may focus on this term because its scope—whether it means a specific graphical element within a larger container or the container itself—is critical to mapping the claim onto the accused website's features.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that regions of interest can be developed from user interests in "actors, television shows, directors, sports teams, music, and the like" ('832 Patent, col. 9:22-25), which could suggest the "region" is the entire content item (e.g., the entire card for a movie).
    • Evidence for a Narrower Interpretation: The figures consistently depict the "region of interest" as a distinct, smaller rectangle within a larger "card" or window (e.g., '832 Patent, FIG. 13, elements 1325, 1335, 1345). The summary of the invention describes rearranging cards so that the "region of interest for each card or window is shown," implying the region is a sub-part of the card (’832 Patent, col. 2:43-45).

For U.S. Patent No. 10,102,568:

  • The Term: "determining a characteristic of the viewing environment... using a camera in the user device"
  • Context and Importance: This limitation is the mechanism for the automatic image matching recited in claim 1. Infringement of this claim appears to depend entirely on whether the accused method performs this specific action.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language does not specify the manner or duration of the camera's use. A party could argue this is met by any process that leverages the camera, even indirectly, to ascertain environmental characteristics like ambient light levels.
    • Evidence for a Narrower Interpretation: The detailed description explains that this step can be part of an automated process where "the camera on the user's device" is used to "measure the characteristics of the environment" ('568 Patent, col. 5:7-9). Step 515 in Figure 5 explicitly recites "DETERMINE THE CHARACTERISTICS OF THE VIEWING ENVIRONMENT OF THE USER DEVICE, USING A CAMERA IN THE USER DEVICE," suggesting an active measurement step.

VI. Other Allegations

  • Indirect Infringement: The complaint does not allege facts to support claims of induced or contributory infringement. The counts are limited to direct infringement under 35 U.S.C. § 271 (Compl. ¶12, ¶21, ¶30).
  • Willful Infringement: The complaint does not plead willfulness or allege any facts related to pre- or post-suit knowledge of the patents that would support a claim for enhanced damages.

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

  1. Evidentiary Sufficiency: A primary issue will be whether Plaintiff can produce evidence to substantiate its infringement allegations. The complaint's lack of specific factual assertions raises the question of whether the Zara website performs the core technical steps of the patents, such as repositioning content based on user preferences or using a device camera to match images to an environment.

  2. Definitional Scope: The case may turn on claim construction, particularly the scope of key terms. A central question will be whether concepts from the patents' media-guide context, such as "plurality of cards" and "regions of interest", can be construed to read on the features of a conventional e-commerce store locator or product page.

  3. Pleading Plausibility: Given the complaint’s complete reliance on external, un-filed exhibits for its infringement contentions, a key procedural question is whether the pleading itself provides sufficient factual matter to state a plausible claim for relief, particularly for the highly specific technical requirements of the '568 patent.