HyperQuery LLC v. TCL Electronics Holdings Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HyperQuery LLC (Delaware)
  • Defendant: TCL Electronics Holdings, Ltd. (China)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 6:23-cv-00206, W.D. Tex., 03/22/2023
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district, has committed acts of patent infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that certain of Defendant's products infringe a patent related to methods for providing device-appropriate web addresses in response to user search queries.
• Technical Context: The technology addresses the problem of delivering optimized web content to a wide variety of user devices (e.g., smartphones, tablets) by dynamically generating a suitable URL based on the user's query, inferred intent, and device characteristics.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit. The patent-in-suit is noted as a continuation-in-part of several earlier applications.

Case Timeline

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

U.S. Patent No. 9,639,611 - "System and method for providing suitable web addresses to a user device"

• Patent Identification: U.S. Patent No. 9,639,611, issued May 2, 2017.

The Invention Explained

• Problem Addressed: The patent’s background section describes an issue where 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 due to mismatched formatting or functionality (U.S. Patent No. 9,639,611, col. 1:56-64).
• The Patented Solution: The invention is a system and method that receives a query from a user device, identifies the device's configuration parameters (e.g., device type, OS), and determines the user's "search intent." Based on these inputs, it selects an appropriate information resource (e.g., a website, an app) and generates a "suitable web address" specifically tailored to provide an "optimal display" on that particular device ('611 Patent, Abstract; col. 2:15-28). The process aims to deliver not just a relevant result, but a result formatted for the user's specific context.
• Technical Importance: The technology aimed to improve the user experience of web searching across a diversifying ecosystem of internet-connected devices with different screen sizes and capabilities ('611 Patent, col. 1:46-55).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" without specifying them, instead referencing an external exhibit (Compl. ¶11). The patent’s independent claims are Claim 1 (a method claim) and Claim 12 (a system claim).
• Independent Claim 1 (Method):
  • receiving a query from the user device;
  • identifying at least one configuration parameter of the user device;
  • determining a search intent based on the received query;
  • selecting at least one information resource from a plurality of information resources to serve the search intent;
  • identifying a web address for each of the at least one selected information resource; and
  • modifying 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.
• Independent Claim 12 (System): A system comprising an interface, a processing unit, and a memory containing instructions to perform the steps recited in the method of Claim 1.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not name specific accused products in its main body. It refers to "Exemplary Defendant Products" that are identified in charts within an "Exhibit B," which is incorporated by reference but not attached to the filed complaint (Compl. ¶¶ 11, 16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market position. It alleges in general terms that the "Exemplary Defendant Products practice the technology claimed by the '611 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s products infringe the ’611 Patent but incorporates the element-by-element infringement contentions by reference to an external document, Exhibit B, which was not filed with the complaint (Compl. ¶¶ 16-17). The complaint’s narrative theory is that the "Exemplary Defendant Products" practice the claimed technology and "satisfy all elements of the Exemplary '611 Patent Claims" (Compl. ¶16). Without access to the specific product identifications and infringement contentions in Exhibit B, a detailed claim chart analysis is not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent claims and the general nature of the technology, the infringement analysis may raise several key questions.

• Scope Questions:
  • A central dispute may concern the meaning of "modifying at least one identified web address." The question is whether this requires an active transformation or construction of a URL string, as depicted in the specification ('611 Patent, col. 7:9-12), or if it can be read more broadly to cover the selection of a pre-existing, device-appropriate URL from a list.
  • Another question involves the scope of "determining a search intent." Does this require the complex, multi-engine probabilistic analysis described in the patent's detailed description (e.g., '611 Patent, Fig. 6; col. 8:5-26), or can it be met by a simpler keyword-based categorization?
• Technical Questions:
  • What evidence will show that the accused products "identify at least one configuration parameter of the user device" (e.g., OS, display size, installed apps) as required by the claims?
  • How, technically, do the accused products use the identified device configuration and determined "search intent" to generate the final web address presented to the user?

V. Key Claim Terms for Construction

"modifying at least one identified web address" (Claim 1)

Context and Importance

This active verb is a critical step in the claimed method. The case may turn on whether the accused system performs an act that qualifies as "modifying," or if its functionality is better described as selecting or redirecting, which might fall outside the claim's scope.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: A party could argue that any process that takes a base resource location and produces a device-specific URL constitutes "modifying," even if it involves selecting from a set of pre-defined options. The claim language itself does not specify the mechanism of modification.
• Evidence for a Narrower Interpretation: The specification provides an exemplary format for a "suitable URL" constructed from multiple components: http://<information resource address>/<input query><intent><device parameters><app parameters> ('611 Patent, col. 7:9-12). A party could argue this suggests "modifying" requires a direct assembly or transformation of the URL string itself, not merely choosing a pre-made one.

"determining a search intent" (Claim 1)

Context and Importance

This term is potentially subjective and its construction will define the complexity of the analysis required to infringe. Practitioners may focus on this term because if it requires a sophisticated analysis, it may be more difficult for the plaintiff to prove infringement.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification notes that query categories can include broad topics like "informational," "transactional," and "navigational" ('611 Patent, Fig. 2; col. 4:55-61). A party might argue that simply classifying a query into one of these high-level buckets is sufficient to "determine" the intent.
• Evidence for a Narrower Interpretation: The specification details a specific method for determining search intent that involves tokenizing a query, processing it with multiple probability engines, and analyzing resulting "certainty scores" ('611 Patent, Fig. 6; col. 8:5-26). A party could argue that the patent defines "determining a search intent" as this more complex, probabilistic process, and that a simple lookup or keyword match is insufficient.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14).

Willful Infringement

The willfulness allegation is based on alleged knowledge of infringement acquired "at least since being served by this Complaint and corresponding claim charts" (Compl. ¶15). This frames the allegation as being based on post-suit conduct.

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

Given the limited detail in the complaint, the litigation will likely focus on developing a factual record and then arguing the scope of the claims. The key questions appear to be:

• An initial and fundamental evidentiary question: What specific products are accused of infringement, and what is the technical evidence of their operation? The complaint’s reliance on an unprovided exhibit leaves this as the most immediate open question.
• A core issue will be one of claim construction: Can the term "modifying" a web address be construed to cover the selection of a device-specific URL from a list, or does it require the active construction of a URL string as detailed in the patent’s specification?
• A second critical issue of claim construction will be: What level of analytical sophistication is required to meet the "determining a search intent" limitation? The case may turn on whether a simple topic categorization suffices, or if the claim requires the complex, multi-engine probabilistic analysis described in the patent.