DCT
6:22-cv-01088
Ridgeview IP LLC v. Cvent Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ridgeview IP LLC (Texas)
- Defendant: Cvent Inc. (Delaware)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 6:22-cv-01088, W.D. Tex., 10/19/2022
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established business presence in the Western District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s event management platform, which includes database search functionalities, infringes a patent related to methods for dynamically displaying database search results to guide a user and prevent invalid queries.
- Technical Context: The technology addresses user interface design for database searches, aiming to prevent users from constructing queries that yield no results by proactively filtering the available search terms and operators at each step.
- Key Procedural History: The complaint notes that the patent-in-suit has been cited during the prosecution of 29 other patents issued to various technology companies. No other procedural history, such as prior litigation or administrative challenges, is mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2001-01-24 | ’270 Patent Priority Date |
| 2006-01-03 | ’270 Patent Issue Date |
| 2022-10-19 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,983,270 - "Method and Apparatus for Displaying Database Search Results"
- Patent Identification: U.S. Patent No. 6,983,270, "Method and Apparatus for Displaying Database Search Results," issued January 3, 2006.
The Invention Explained
- Problem Addressed: The patent's background section identifies a need for a database search method that avoids "null results," such as a "no documents found" message, which can occur when users combine search terms in a way that yields no matches (’270 Patent, col. 2:7-11). Conventional systems often require a user to execute a query before discovering it is invalid (’270 Patent, col. 1:21-24).
- The Patented Solution: The invention describes a method that interactively guides the user during the construction of a search query. After a user makes an initial selection (e.g., a search term), the system "continuously edit[s]" the available database responses and possible subsequent search terms and operators (’270 Patent, col. 2:31-34, Abstract). By eliminating options that would lead to a null result, the system ensures that any query the user can construct will yield a valid result, thereby preventing user frustration and improving efficiency (’270 Patent, col. 3:1-12).
- Technical Importance: This approach makes complex database navigation more intuitive by providing real-time feedback and preventing users from going down "dead-end" search paths (’270 Patent, col. 2:1-3).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶22).
- The essential elements of Claim 1 include:
- Displaying a set of database entries and a set of operators.
- Selecting an initial entry.
- Updating the set of displayed operators based on the selected entry, so that the updated set only includes operators that will produce at least one valid result.
- Selecting an operator from the updated set.
- Updating the set of displayed entries in response to the selected operator, so that the updated set only includes entries that will produce at least one valid result.
- Selecting an entry from the updated set.
- Repeating the updating and selecting steps until a desired result is achieved.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "Accused Instrumentalities" as Cvent's event management platforms, including the "Cvent database search" and its associated functionalities (Compl. ¶17).
Functionality and Market Context
- The accused products constitute an "engagement platform" for managing events, which includes features for event registration and searching databases of invitees or attendees (Compl. ¶17, p. 5). The complaint specifically highlights an "Advanced Search" feature, which it alleges simplifies the process of searching invitee lists (Compl. p. 6). A screenshot from a Cvent support page depicts a user interface for managing events that includes an "Advanced Search" button and a table of event data (Compl. p. 6). Another screenshot shows a filterable "Attendee List" (Compl. p. 7). The complaint alleges these features allow users to form a database query by selecting from filters and operators to produce results (Compl. ¶22(ii)).
IV. Analysis of Infringement Allegations
’270 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. displaying a set of entries from a database and a set of operators... | Displaying a set of entries (e.g., filters) and a set of operators (e.g., AND, OR) from the Cvent database. | ¶22(ii) | col. 2:55-58 |
| b. selecting an initial entry of said displayed set of entries; | A user selects an initial entry, such as a filter for a specific property. | ¶22(iii) | col. 3:49-51 |
| d. updating said set of displayed operators based on said selected entry, wherein said updated set of displayed operators includes only operators from the set of operators... produce at least one valid result; | The set of displayed operators (e.g., AND, OR) is updated to include only those that, when combined with the selected entry and another entry, will produce at least one valid result. | ¶22(v) | col. 3:7-10 |
| e. selecting an operator from the updated displayed set of operators; | A user selects an operator, such as 'AND', from the updated list of available operators. | ¶22(vi) | col. 7:13-16 |
| f. updating said displayed set of entries in response to the selected operator, wherein said updated displayed set of entries includes only entries from the database... produce at least one valid result; | The set of displayed entries (e.g., available filters) is updated to include only those that, when combined with the prior selections, will yield a valid result. | ¶22(vii) | col. 7:33-41 |
| g. selecting one of said updated displayed set of entries; | A user selects an entry from the newly updated set of available entries. | ¶22(viii) | col. 7:59-62 |
| h. updating said displayed set of valid results according to a query based on the selected entries and the selected operator; | The displayed search results are updated based on the combination of selected entries and operators. | ¶22(ix) | col. 8:5-10 |
| i. while said updated displayed set of valid results is not the desired result, repeating steps d. through h. ... to select an additional operator and an additional entry... | The process of selecting operators and entries is repeated until the user obtains the desired search result. | ¶22(x) | col. 8:22-24 |
Identified Points of Contention
- Technical Questions: A primary factual question will be whether the accused Cvent platform actually performs the proactive "updating" steps required by the claims. The complaint alleges that after a user makes a selection, the system updates the available operators (claim 1(d)) and subsequent entries (claim 1(f)) to exclude any choice that would lead to a null result. The provided screenshots show a search interface but do not offer direct evidence of this dynamic, preventative filtering of future options. The core of the dispute may rest on whether the Cvent system merely returns an empty result set after an invalid query is built, or if it actively prevents the user from building such a query in the first place.
- Scope Questions: The dispute may raise the question of whether the functionality of the accused "Advanced Search" meets the specific, sequential process laid out in Claim 1. The claim recites a precise, iterative loop of selecting an entry, updating operators, selecting an operator, and updating entries. The evidence will need to show that the accused system follows this particular command structure.
V. Key Claim Terms for Construction
- The Term: "updating said set of displayed operators" (and "updating said displayed set of entries")
- Context and Importance: These terms are central to the patent's asserted novelty—the "guidance" mechanism that prevents null results. The outcome of the case may depend on whether the accused system's filtering functionality constitutes "updating" in the manner claimed. Practitioners may focus on this term because it distinguishes the invention from conventional search systems that process a complete query and then return results, which may be null.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any change to the list of displayed options in response to a user's action meets the "updating" requirement. The patent describes the process broadly as "continuously editing the available database responses" (’270 Patent, col. 2:31-32).
- Evidence for a Narrower Interpretation: A party could argue that "updating" requires a specific technical function: the proactive "audit[ing] or scan[ning of] all possible response terms" to "eliminate[] the irrelevant and impossible responses" before they can be selected by the user (’270 Patent, col. 3:7-10). The patent repeatedly frames this in the context of avoiding null values, suggesting the update must guarantee a non-null result (’270 Patent, col. 3:13-22).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by claiming Defendant took active steps such as "advertising an infringing use" and making infringing services available, which allegedly shows an intent for its customers to use the product in an infringing manner (Compl. ¶¶27, 30).
- Willful Infringement: Willfulness is alleged based on Defendant's presumed knowledge of the patent upon service of the complaint (post-suit willfulness) (Compl. ¶26). The complaint also alleges pre-suit "willful blindness," asserting that Defendant has a practice of "not performing a review of the patent rights of others... prior to launching products" (Compl. ¶31).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case will likely depend on the answers to two central questions:
- A key evidentiary question will be one of functional operation: Does the accused Cvent search functionality proactively constrain the user's available choices at each step (e.g., by removing operators or filters that would lead to a null result), as described in the patent, or does it operate as a conventional filter that simply returns an empty result set if a user's combined selections have no match?
- A core issue will be one of definitional scope: How will the court construe the term "updating"? Will it require the specific, computationally intensive process of pre-emptively eliminating all null-result pathways as taught in the patent's specification, or can the limitation be met by more general UI behaviors that dynamically alter displayed options in response to user input?