DCT
6:23-cv-00007
HyperQuery LLC v. Samsung Electronics America Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: HyperQuery LLC (Delaware)
- Defendant: Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Ramey LLP
- Case Identification: 6:23-cv-00007, W.D. Tex., 01/06/2023
- Venue Allegations: Venue is alleged to be proper in the Western District of Texas because Defendant maintains an established place of business in the district and has allegedly committed acts of patent infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s device search functionalities infringe patents related to determining a user's search intent to provide tailored application downloads and optimized web addresses.
- Technical Context: The patents address methods for improving user experience in mobile search by moving beyond simple keyword matching to understand user intent and device characteristics, thereby providing more relevant and accessible content.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2010-06-11 | Earliest Priority Date for ’611 Patent |
| 2011-03-28 | Earliest Priority Date for ’918 Patent |
| 2016-12-27 | ’918 Patent Issued |
| 2017-05-02 | ’611 Patent Issued |
| 2023-01-06 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,529,918 - System and methods thereof for downloading applications via a communication network
Issued December 27, 2016
The Invention Explained
- Problem Addressed: The patent’s background section describes the process of searching for mobile applications in repositories as "very time consuming," often requiring users to navigate through hundreds of irrelevant applications that are "commonly promoted by the repository's owner" rather than being ranked by relevancy to the user's actual needs ('918 Patent, col. 2:4-11).
- The Patented Solution: The invention proposes a system that receives a search query from a user, determines the user’s "search intent" (i.e., the underlying topic of interest), and selects one or more applications from a central repository based on that intent. It then displays an icon for the selected application in a "display segment" over the device's screen and, upon user interaction, establishes a direct link to download the application ('918 Patent, Abstract). This process is designed to streamline app discovery by proactively identifying and presenting what the user is truly looking for ('918 Patent, col. 4:41-57).
- Technical Importance: The technology represents a shift from keyword-based app store searches to intent-driven recommendations, aiming to reduce user effort and provide more accurate results in a crowded application marketplace ('918 Patent, col. 2:11-14).
Key Claims at a Glance
- The complaint refers to "Exemplary '918 Patent Claims" in an attached exhibit not provided with the complaint, so the specific asserted claims are not identified in the pleading itself (Compl. ¶12). Independent claim 11 (a system claim) is representative of the technology.
- Independent Claim 11 elements:
- A network interface to receive an input search query.
- A processor and memory containing instructions to:
- Determine a "search intent" based on the query, indicating a user's topic of interest.
- Select at least one application from a repository based on that intent.
- Cause an icon for the selected application to be displayed.
- Establish a "direct communication link" to a location hosting the application in response to user input.
- Cause the download of the application to be initiated.
- The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of "one or more claims" (Compl. ¶12).
U.S. Patent No. 9,639,611 - System and method for providing suitable web addresses to a user device
Issued May 2, 2017
The Invention Explained
- Problem Addressed: The patent identifies that a user accessing a website via a search engine on a mobile device may be directed to a URL optimized for a personal computer, resulting in a "sub-optimal" user experience. The content might be better viewed through a different, mobile-specific URL or a dedicated mobile app ('611 Patent, col. 1:56-65).
- The Patented Solution: The invention describes a system that receives a user's query and identifies the "configuration parameter" of the user's device (e.g., device type, OS, screen size). It then determines the user's "search intent" and uses this information to "modify" an identified web address to "generate a suitable web address" that is optimized for that specific device and intent, ensuring optimal display of the content ('611 Patent, Abstract; col. 2:15-29).
- Technical Importance: This technology addresses the challenge of content delivery in a multi-device ecosystem by creating a system to intelligently route users to the version of content (web page or app) best suited for their specific device ('611 Patent, col. 2:8-11).
Key Claims at a Glance
- The complaint references "Exemplary '611 Patent Claims" in an attached exhibit not provided with the complaint (Compl. ¶21). Independent claim 12 (a system claim) is representative.
- Independent Claim 12 elements:
- An interface, processing unit, and memory with instructions to:
- Receive a query from a user device.
- Identify at least one "configuration parameter" of the device.
- Determine a "search intent" based on the query.
- Select an "information resource" (e.g., a website or app) to serve the intent.
- Identify the web address for that resource.
- "Modify" the identified web address to "generate a suitable web address" based on the original address, the intent, and the device's configuration parameter.
- An interface, processing unit, and memory with instructions to:
- The complaint alleges infringement of "one or more claims" of the ’611 Patent (Compl. ¶21).
III. The Accused Instrumentality
Product Identification
The complaint does not name specific Samsung products or services. It refers generally to "Exemplary Defendant Products" that are identified in claim chart exhibits not attached to the filed complaint (Compl. ¶12, ¶21).
Functionality and Market Context
The allegations target functionalities within Samsung's products that allow users to search for and access applications or web content (Compl. ¶¶ 12, 17, 21, 26). Based on the technology described in the patents-in-suit, these functionalities would likely involve interpreting user search queries to provide results, potentially including application recommendations or links to websites. The complaint alleges that Defendant makes, uses, sells, and imports these products, and that its employees internally test and use them (Compl. ¶¶ 12-13, 21-22). Given Samsung's market position, these functionalities would be present on a large number of consumer electronic devices such as smartphones and tablets.
IV. Analysis of Infringement Allegations
The complaint alleges infringement but incorporates by reference external claim chart exhibits (Exhibits B and D) that were not provided. The following analysis is based on the patents and the general infringement theories articulated in the complaint.
No probative visual evidence provided in complaint.
’918 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a network interface configured to receive... an input search query from a user device | Samsung devices include software (e.g., device search bars, virtual assistants) that receives user-entered text or voice queries. | ¶12, ¶17 | col. 11:6-9 |
| determine the search intent based on the input search query, wherein the search intent indicates a topic of interest of a user of the user device | The accused functionalities allegedly analyze the user's query to determine its underlying purpose or topic, beyond simple keyword matching. | ¶12, ¶17 | col. 11:13-16 |
| select, based on the search intent, at least one application from at least one applications central repository | Based on the determined intent, Samsung's services (e.g., Galaxy Store search) allegedly select relevant applications from an app repository. | ¶12, ¶17 | col. 11:17-19 |
| cause an icon corresponding to the at least one selected application to be displayed on a display of the user device | The user interface on Samsung devices allegedly displays icons for the recommended applications as part of the search results. | ¶12, ¶17 | col. 11:20-23 |
| responsive to an input... cause a direct communication link to be established between the user device and a location hosting the... application | When a user taps on a recommended application icon, the device allegedly establishes a direct connection to the application's download source (e.g., a server for the Galaxy Store). | ¶12, ¶17 | col. 11:24-29 |
| cause initiation of a download of the particular one of the at least one selected application to the user device | Following the establishment of the link, the system allegedly initiates the download of the chosen application onto the user's device. | ¶12, ¶17 | col. 11:30-32 |
- Identified Points of Contention:
- Technical Question: What evidence demonstrates that the accused products "determine the search intent" using a process analogous to the patent's multi-engine, probability-based method ('918 Patent, col. 7:1-col. 8:43), as opposed to a more conventional keyword-matching algorithm?
- Scope Question: Does the presentation of an app recommendation in a standard list of search results constitute "caus[ing] an icon... to be displayed" in a manner consistent with the "display segment" described in the patent's specification ('918 Patent, col. 2:27-28)?
’611 Patent Infringement Allegations
| Claim Element (from Independent Claim 12) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receive a query from the user device | Samsung devices and their associated search services receive queries from users. | ¶21, ¶26 | col. 13:21 |
| identify at least one configuration parameter of the user device | The accused system allegedly identifies device-specific attributes, such as device model, operating system version, or screen size, to inform search results. | ¶21, ¶26 | col. 13:22-23 |
| determine a search intent based on the received query | The system allegedly analyzes the query to discern the user's underlying intent (e.g., informational, transactional). | ¶21, ¶26 | col. 13:24-25 |
| select at least one information resource from a plurality of information resources to serve the search intent | Based on the intent, the system allegedly selects a relevant information resource, such as a specific website or web-based service. | ¶21, ¶26 | col. 13:26-28 |
| modify at least one identified web address to generate a suitable web address based on the identified web address, the search intent, and the at least one configuration parameter | The accused system allegedly transforms a standard URL into an optimized URL tailored for the user's specific device and intent, ensuring the content is displayed optimally. | ¶21, ¶26 | col. 13:30-37 |
- Identified Points of Contention:
- Technical Question: Does the accused system actively "modify" a web address to "generate a suitable" one, or does it simply select the most appropriate URL from a pre-existing list of alternatives (e.g., a desktop URL, a mobile URL, an app deep-link)? The claim language suggests an active transformation process.
- Scope Question: What is the scope of "configuration parameter"? The patent provides examples like device type and OS ('611 Patent, col. 5:59-62). The dispute may focus on what specific parameters are identified by the accused system and whether they are used in the manner claimed.
V. Key Claim Terms for Construction
The Term: "search intent" (’918 Patent, Claim 11; ’611 Patent, Claim 12)
Context and Importance: This term is central to both asserted patents and distinguishes the claimed invention from simple keyword searching. The outcome of the case may depend on whether Samsung's accused systems are found to "determine" intent as a distinct "topic of interest," or if their functionality is characterized as conventional search. Practitioners may focus on this term because its construction will define the technological threshold for infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines search intent broadly as a "topic of interest of a user" ('918 Patent, col. 2:25-26) and notes it can be determined "implicitly" based on environmental or personal variables, not just an explicit query ('918 Patent, col. 4:9-16).
- Evidence for a Narrower Interpretation: The detailed description discloses a specific, complex process for determining intent involving tokenizing a query, processing it through a "plurality of engines" that handle different topics (locations, people, etc.), and computing "certainty scores" to find the most coherent result ('918 Patent, col. 7:1-col. 8:16). A party could argue the term is limited to this disclosed embodiment.
The Term: "modify at least one identified web address to generate a suitable web address" (’611 Patent, Claim 12)
Context and Importance: The active verbs "modify" and "generate" are critical. Infringement will turn on whether the accused system is proven to perform an active transformation of a URL, rather than merely selecting from a list of pre-defined, alternative URLs.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent’s abstract states the method includes "generating a suitable web address based on each identified web address, the search intent, and the... configuration parameter," which could be argued to encompass any process that results in a new, suitable address, including intelligent selection.
- Evidence for a Narrower Interpretation: The specification provides an exemplary format for a generated URL that combines multiple distinct pieces of information, such as the query, intent, and device parameters ('611 Patent, col. 7:7-13). This suggests a constructive or programmatic process of building a new URL string, which could support a narrower definition that excludes mere selection.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by distributing "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the patents-in-suit (Compl. ¶15, ¶16, ¶24, ¶25).
- Willful Infringement: Willfulness allegations are based on Defendant’s alleged continuation of infringing activities after gaining actual knowledge of the patents and the infringement allegations through the service of the complaint (Compl. ¶15, ¶16, ¶24, ¶25).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of definitional scope: can the term "modify... to generate a suitable web address" in the ’611 patent be construed to cover a system that selects an optimal URL from a pre-existing list, or is it limited to a system that programmatically constructs a new URL string? The answer will determine whether a common industry practice falls within the claim's scope.
- A key evidentiary question will be one of technical mechanism: what proof will be offered to show that Samsung’s accused systems perform the specific, multi-step "search intent" determination process described in the patents, as opposed to functionally different, non-infringing search and recommendation algorithms?
- Finally, the case may raise a question of infringement locus: given that the claims recite systems with server-side components (e.g., a processor and memory that determine intent), the parties may dispute whether all steps of the claimed methods are performed or controlled by Samsung within the United States, particularly for claims involving interactions between a user's device and remote servers.