DCT

6:23-cv-00521

DoDots Licensing Solutions LLC v. Best Buy Stores LP

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:22-cv-00533, W.D. Tex., 09/12/2022
  • Venue Allegations: Venue is alleged based on Apple's regular and established places of business within the Western District of Texas, including corporate campuses and retail stores where accused products are sold.
  • Core Dispute: Plaintiff alleges that Defendant’s iOS-enabled devices (iPhones, iPads, Apple Watches) and the iOS operating system infringe patents related to systems for accessing and displaying network content in standalone applications, or "widgets," separate from a traditional web browser.
  • Technical Context: The technology concerns a method for delivering focused internet content to users in small, browser-independent frames, a concept that predates and parallels the modern mobile application ecosystem.
  • Key Procedural History: The complaint notes that all three patents-in-suit were challenged in inter partes review (IPR) proceedings before the Patent Trial and Appeal Board (PTAB) and that the PTAB found the challenged claims not unpatentable. These decisions were subsequently affirmed by the U.S. Court of Appeals for the Federal Circuit. Such affirmations may influence the case by strengthening the patents' presumption of validity.

Case Timeline

Date Event
1999-04-26 Earliest Priority Date ('545, '083, '407 Patents)
1999-01-01 DoDots, Inc. founded
2007-01-01 Accused Apple Software (iOS) launched
2011-09-13 '083 Patent Issued
2013-08-13 '407 Patent Issued
2013-10-18 Alleged pre-suit knowledge of patents by Apple
2016-06-14 '545 Patent Issued
2020-09-09 PTAB Final Written Decision on '545 Patent
2021-01-05 PTAB Final Written Decision on '407 Patent
2021-01-19 PTAB Final Written Decision on '083 Patent
2021-12-08 Federal Circuit affirms PTAB decisions
2022-09-12 Complaint Filed

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

U.S. Patent No. 9,369,545 - "Accessing and Displaying Network Content"

The Invention Explained

  • Problem Addressed: The patent's background describes user and developer dissatisfaction with traditional web browsers, noting that content was "trapped within the frame of the browser" and that users had "limited control over the user experience" when trying to view multiple sources of information ('545 Patent, col. 1:39-42).
  • The Patented Solution: The invention proposes a method where a client device requests a "networked information monitor template" from a server. This template defines a graphical user interface (a "widget" or "Dot") that is presented "separate from and outside of any other graphical user interface" like a browser. The template also contains a reference to a network location from which the actual content is fetched and displayed within the widget's frame ('545 Patent, Abstract; col. 4:56-65).
  • Technical Importance: This browser-less approach allowed for more lightweight and targeted delivery of internet content, which was significant in an era of slower internet connections and less powerful client devices (Compl. ¶25, 30).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 1 (Compl. ¶61, 114).
  • The essential elements of Claim 1 are:
    • A computer-implemented method of obtaining and displaying content on a client device.
    • Transmitting a request to a server for a "networked information monitor template."
    • Receiving the requested template, which comprises:
      • A definition of a viewer graphical user interface (GUI) for presenting content.
      • A definition of a first content element that references a network location from which the content is served.
    • Presenting the viewer GUI on the client device's display, separate from and outside of any other GUI that has user controls for specifying the network location.
    • Transmitting a request for the first content element to its specified network location.
    • Receiving the first content element.
    • Presenting the received content element within the viewer GUI, where the GUI definition itself defines all user interaction controls.
  • The complaint also asserts infringement of claims 2, 9-10, 12, and 13 (Compl. ¶114-116).

U.S. Patent No. 8,020,083 - "System and Methods for Creating and Authoring Internet Content Using Application Media Packages"

The Invention Explained

  • Problem Addressed: The patent addresses the desire for individual users to "fully control the aggregation and presentation of content and web applications," which was limited by the full-page, browser-centric model of the early internet ('083 Patent, col. 1:49-53).
  • The Patented Solution: The invention describes a client device that stores "networked information monitor templates." The core of this patented solution is a device having a graphical user interface that "lacks controls for manually navigating a network" (such as a browser's address bar) and instead includes a dedicated frame for displaying content retrieved from a predefined network location specified in the template ('083 Patent, Abstract; Claim 1).
  • Technical Importance: This patent focuses on the structure of the client device itself, claiming the system that enables the browser-less "widget" model of content consumption.

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 1 (Compl. ¶81, 123).
  • The essential elements of Claim 1 are:
    • A client device.
    • Electronic storage containing a plurality of "networked information monitor templates."
    • A first template comprising:
      • A content reference with a network location for content accessible via TCP/IP.
      • A definition of a GUI that "lacks controls for manually navigating a network" and includes a frame for displaying the content.
      • Instructions to request the content from the network location and generate the GUI with the received content inside the frame.
    • An electronic display.
    • One or more processors configured to access the template and present the GUI to a user on the display.
  • The complaint also alleges infringement of claims 1-8 (Compl. ¶137).

U.S. Patent No. 8,510,407 - "Displaying Time-Varying Internet Based Data Using Application Media"

  • Technology Synopsis: This patent claims a client device configured to display time-varying content (such as stock prices) within a widget-like frame. A key aspect is that the frame "lacks controls for enabling a user to specify a network location" for the content, and the frame is presented "outside of and separate from any graphical user interface of any other application" (Compl. ¶93, 103).
  • Asserted Claims: Independent Claim 1 (Compl. ¶93).
  • Accused Features: The accused features are Apple devices executing applications like the Stocks app, which allegedly store a template, request and receive time-varying data from a network server, and present it in a standalone application window separate from other apps (Compl. ¶95-104).

III. The Accused Instrumentality

Product Identification

The "Accused Apple Devices," including iPhones, iPads, Apple Watches, and iPod Touches, and the "Accused Apple Software," which includes the iOS operating system and applications downloaded from the Apple App Store ("Apple-Supported Apps") (Compl. ¶55-57).

Functionality and Market Context

The complaint alleges that Apple's entire App Store ecosystem embodies the patented technology. When a user selects an app, the device requests and receives an application package (an .ipa file) from Apple's servers. The complaint alleges this .ipa file is the claimed "networked information monitor template" (Compl. ¶66-67). This file allegedly contains the definition of the app's graphical user interface and references to network locations for dynamic content (Compl. ¶68). The app, when launched, is presented as a standalone GUI, separate from a web browser, and proceeds to fetch and display content from the internet as defined in the .ipa file (Compl. ¶73-74). An image in the complaint shows various iPhone models, illustrating the hardware that executes the accused software (Compl. ¶63, image). Another image details the technical specifications of different iPhone models, highlighting the electronic storage, display, and processor components used to perform the accused methods (Compl. ¶65, image).

IV. Analysis of Infringement Allegations

'545 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
transmitting a request to the server over the network, the request requesting networked information monitor template; The Accused Apple Software sends a request to an App Store server for an application package (an .ipa file). ¶66 col. 2:40-43
receiving the requested networked information monitor template from the server... the networked information monitor template comprising: The device receives the .ipa file from the App Store server. ¶67 col. 2:44-46
a definition of a viewer graphical user interface within which content in a web browser-readable language may be presented...; and The .ipa file contains data structures that define the app's user interface, such as menus and buttons. A screenshot of a stock tracking app illustrates such an interface. ¶68, 70, 72 (image) col. 2:50-54
a definition of a first content element...referencing a first network location from which the first content element...is served over the network; The .ipa file contains definitions for content elements (e.g., stock price data) and references the network locations (e.g., URLs) from which that data is served. ¶68, 71 col. 2:55-60
presenting the viewer graphical user interface...separate from and outside of any other graphical user interface that includes user controls for specifying the first network location...; An Apple-Supported App is presented on the device's display as a standalone application, separate from a web browser that would have an address bar for specifying a network location. ¶73 col. 2:61-67
transmitting over the network a first content request to the first network location...; The app transmits a request over the internet to the source of its dynamic content (e.g., a request for stock market data). ¶76 col. 3:1-5
presenting the received the first content element in the viewer graphical user interface defined by the networked information monitor template... The app presents the received content (e.g., stock prices) within its own GUI. A screenshot shows different selection features within a mobile app, illustrating user interaction controls. ¶78-79 (image) col. 3:9-17

Identified Points of Contention

  • Scope Questions: A primary question will be whether a compiled application package (.ipa file) constitutes a "networked information monitor template." The defense may argue the patent envisions a simpler, data-centric template, not a complete, executable software application. The construction of "template" will be a central point of dispute.
  • Technical Questions: What level of separation is required for the GUI to be "separate from and outside of any other graphical user interface that includes user controls for specifying the first network location"? The defense could argue that the iOS home screen or other operating system elements constitute a GUI that, at some level, allows a user to select the app and therefore indirectly "specify" the network location of its content.

'083 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
electronic storage having stored thereon a plurality of networked information monitor templates defining a plurality of networked information monitors... Accused Apple Devices have electronic storage which stores downloaded Apple-Supported Apps, which are alleged to be constructed from the claimed templates. A screenshot illustrates the iPhone's storage management screen. ¶83-84 (image) col. 2:15-18
a content reference that comprises a network location at which content for the first networked information is accessible via a TCP/IP protocol; The app's data structures contain a content reference (e.g., a URL) pointing to a network location where content like stock price data is available. ¶85 col. 2:19-22
a definition of a graphical user interface...that lacks controls for manually navigating a network, and that includes a frame within which content received from the network location can be displayed... The app presents a GUI that does not have a browser's address bar or navigation buttons. It includes a frame for displaying content received from the network, as shown in screenshots of a stock app. ¶86-87, 90 (image) col. 2:23-27
instructions configured (i) to cause the first networked information monitor to request content...and (ii) to cause the...monitor to generate the graphical user interface...with the content received... The data structures in the .ipa file include instructions that cause the device to request content (e.g., stock data) via TCP/IP and to generate the app's GUI with that content displayed inside its frame. ¶88-89 col. 2:32-40
an electronic display; and one or more processors configured to access the first networked information monitor template such that the graphical user interface...is presented to a user... Accused devices have the necessary display and processors to execute the app code, access the template, and present the resulting GUI with its content to the user. ¶91 col. 2:41-47

Identified Points of Contention

  • Scope Questions: The case may turn on the meaning of "lacks controls for manually navigating a network." Apple could argue that while its apps lack a URL address bar, they contain other features (search bars, menus, hyperlinks) that allow a user to navigate the network, thereby falling outside the claim's scope.
  • Technical Questions: Does an app, constructed from an .ipa file, function as the claimed "networked information monitor"? The defense may argue that the claimed monitor is a simple content display mechanism, whereas a modern app is a complex, interactive software program with functionality far beyond what is described in the patent.

V. Key Claim Terms for Construction

The Term: "networked information monitor template" ('545 Patent, Claim 1)

Context and Importance: This term is the central object of the asserted method. Its construction is critical because the plaintiff alleges it reads on a modern .ipa application file, while the patent was filed in an era of simpler web technologies. Practitioners may focus on whether this term can be interpreted broadly enough to cover a complete, compiled application package.

  • Intrinsic Evidence for a Broader Interpretation: The specification describes the template as defining a "fully configurable frame" and its "viewer and control characteristics," which could suggest a broad scope of possible configurations ('545 Patent, col. 7:32-35).
  • Intrinsic Evidence for a Narrower Interpretation: The patent's examples and figures depict the template as a structured data file (e.g., XML) with defined fields for URLs and appearance, not a self-contained executable program ('545 Patent, Fig. 13; col. 8:18-32). The word "template" itself implies a pattern to be filled rather than a complete entity.

The Term: "lacks controls for manually navigating a network" ('083 Patent, Claim 1)

Context and Importance: This negative limitation is crucial for distinguishing the invention from a conventional web browser. The dispute will likely focus on whether the various interactive elements within a modern app (e.g., search bars that query external servers, embedded links) constitute "controls for manually navigating a network."

  • Intrinsic Evidence for a Broader Interpretation (i.e., lacking controls): The patent's background consistently contrasts the invention with full browsers that allow users to direct the viewer to any "destination address" ('083 Patent, col. 1:21-23). This may support an interpretation where "navigating a network" means having an open-ended address bar, which apps lack.
  • Intrinsic Evidence for a Narrower Interpretation (i.e., having controls): The term itself is not limited to address bars. The specification describes a goal of giving developers more control and limiting user access to "previously viewed content," suggesting that any user-initiated navigation to new network content could be considered "manually navigating a network" ('083 Patent, col. 2:1-3).

VI. Other Allegations

Indirect Infringement

The complaint alleges that Apple actively induces infringement by providing the App Store, encouraging developers to create apps that operate in the accused manner, and providing marketing materials and user manuals that instruct customers on how to download and use these apps (Compl. ¶109, 116). Apple's control over the App Store ecosystem and its developer guidelines are cited as evidence of intent (Compl. ¶69-70).

Willful Infringement

The complaint alleges that Apple had pre-suit knowledge of the patents-in-suit as early as October 18, 2013, citing communications with members of Apple's Patent Acquisitions team (Compl. ¶51-54, 110-111). This specific allegation, if proven, could support a finding of willful infringement.

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

  • A central issue will be one of technological translation: can the term networked information monitor template, conceived in the context of early-2000s web widgets, be construed to encompass a modern, compiled application package (.ipa file) delivered via an App Store?
  • A key question of functional scope will be whether a modern smartphone application, which often includes internal search functions and hyperlinks, lacks controls for manually navigating a network as required by the ’083 patent, or if such features constitute the very navigation the patent sought to exclude.
  • Given the specific allegations of pre-suit knowledge dating to 2013 and the patents' survival of PTAB review, a significant question for damages will be whether Apple's conduct constitutes willful infringement, potentially exposing it to enhanced damages.