Linfo IP LLC v. G2com Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: G2com, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:24-cv-00049, W.D. Tex., 02/16/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s software review platform infringes a patent related to systems and user interfaces for analyzing, organizing, and presenting information from text content.
• Technical Context: The technology at issue involves automated topic extraction and sentiment analysis from unstructured text, a core functionality for online platforms that aggregate and display user reviews.
• Key Procedural History: The complaint identifies the Plaintiff as a non-practicing entity. Willfulness allegations are based on Defendant's alleged knowledge of the patent as of the complaint's filing date.

Case Timeline

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

U.S. Patent No. 9,092,428

• Patent Identification: U.S. Patent No. 9,092,428, System, methods and user interface for discovering and presenting information in text content, issued July 28, 2015.

The Invention Explained

• Problem Addressed: The patent's background section describes the problem of "information overload," particularly the difficulty and time-consuming nature of finding specific information within large volumes of unstructured text, such as sifting through hundreds of hotel reviews to find comments on a particular topic (e.g., room service) or with a specific sentiment (e.g., negative opinions) (ʼ428 Patent, col. 1:13-38).
• The Patented Solution: The invention proposes a computer-assisted method that analyzes text to identify and associate specific attributes (such as grammatical role, topic, or sentiment) with words or phrases. It then provides user interface objects that allow a user to select an attribute and perform an action—such as extracting, hiding, or highlighting—on all text sharing that attribute. The results can be presented in organized formats, such as the hierarchical topic tree shown in Figure 8, which groups user comments under topics like "Room" and "Bathroom" (ʼ428 Patent, col. 3:16-34; Fig. 8).
• Technical Importance: The patented approach provides a method for automating the digestion of large-scale, user-generated text, enabling users to more efficiently identify relevant feedback and discern patterns within the data (ʼ428 Patent, col. 1:55-64).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-20 (Compl. ¶9).
• Independent Claim 1 (method) includes the following essential elements:
  • obtaining a text content comprising words or phrases;
  • selecting a first and a second semantic attribute for a user to select from;
  • identifying words or phrases in the text content associated with the selected attributes;
  • displaying an actionable user interface object associated with a name for the attributes;
  • allowing the user to select one of the attributes; and
  • performing an action (e.g., extracting, displaying, hiding, or highlighting) on the words or phrases associated with the user's selection.
• Independent Claim 14 (system) largely mirrors the method of Claim 1 in system format. The complaint does not explicitly reserve the right to assert dependent claims but makes a general assertion of claims 1-20.

III. The Accused Instrumentality

Product Identification

• The complaint accuses a "system with methods and user interface for discovering information in a text content and extracting and presenting the information" that is maintained, operated, and administered by Defendant G2.com, Inc. (Compl. ¶9).

Functionality and Market Context

• The complaint broadly alleges that Defendant sells and offers products and services throughout Texas (Compl. ¶2, ¶3). The complaint does not describe the specific functionality of the accused G2.com platform, instead referencing a "preliminary exemplary table attached as Exhibit B" to support its allegations (Compl. ¶10). This exhibit was not filed with the public version of the complaint. Based on the patent's subject matter, the accused functionality likely pertains to features on the G2.com software review website that allow users to filter, sort, or analyze user reviews based on criteria such as topic or user sentiment.

IV. Analysis of Infringement Allegations

The complaint references an infringement claim chart in an "Exhibit B" which was not provided with the complaint (Compl. ¶10). Therefore, a detailed element-by-element analysis is not possible based on the provided documents.

The narrative theory of infringement suggests that Plaintiff will argue that the G2.com platform performs the patented method. This theory would require showing that the accused system obtains text from user reviews, provides users with interface options (e.g., filters for positive/negative sentiment or for reviews mentioning specific product features) that correspond to the claimed "semantic attributes," identifies the portions of review text that match those user-selected attributes, and then performs an action such as displaying only the matching reviews or highlighting the relevant text.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The Term: "semantic attribute"

• Context and Importance: This term is central to the scope of the claims, as it defines the type of information the system is designed to identify and act upon. Its construction will determine whether the claims cover a broad range of data filters or are limited to specific linguistic properties.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides varied examples of semantic attributes, including "opinion" (e.g., positive or negative), a term's topical category (e.g., "drug"), or other conceptual meanings (ʼ428 Patent, col. 8:14-29). This may support an interpretation that covers any conceptual or topical tag that can be applied to text.
  • Evidence for a Narrower Interpretation: Claim 5 recites "importance of a word or phrase," while Claim 1 recites "semantic attribute." This distinction may suggest that a calculated metric like "importance" is separate from an inherent "semantic attribute." Furthermore, Claim 4 carves out "named entities," potentially suggesting that "semantic attribute" is meant to be constrained to meanings other than proper nouns or predefined entities (ʼ428 Patent, col. 16:34-42, 16:43-47).

The Term: "actionable user interface object"

• Context and Importance: The definition of this term is critical for determining what types of user interactions constitute infringement. The dispute may turn on whether a general-purpose filter or search bar qualifies, or if a more specific, dedicated UI element is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent discloses a wide range of UI elements, including "selectable buttons," "dropdown menu," and "radio buttons," suggesting the term could encompass any common UI element through which a user can make a selection to trigger an action (ʼ428 Patent, col. 7:21-22, col. 9:62-64, col. 11:47-49).
  • Evidence for a Narrower Interpretation: The patent figures consistently depict UI objects with labels that describe a specific, pre-defined action on a specific attribute (e.g., "Extract all opinions," "Show positive comments only"). A party could argue this requires a UI element dedicated to a particular semantic action, rather than a generic, user-configurable filter (ʼ428 Patent, Fig. 7, Fig. 9A).

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement, asserting that Defendant "actively encouraged or instructed" its customers on how to use its services in an infringing manner (Compl. ¶11, ¶12). The allegations are general and do not specify the nature of the instructions.
• Willful Infringement: The complaint alleges willful infringement based on Defendant having knowledge of the ’428 patent "from at least the filing date of the lawsuit" (Compl. ¶11, ¶12). This frames the willfulness claim as being based on alleged post-filing conduct.

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

• A core issue will be one of definitional scope: can the term "semantic attribute", which is exemplified in the patent with linguistic properties like sentiment, be construed broadly enough to read on the various sorting and filtering options available on a modern software review platform?
• A key evidentiary question will be one of infringement mapping: as the complaint's supporting evidence (Exhibit B) is not public, the case will turn on what specific features of the G2.com platform are accused of infringement and whether Plaintiff can demonstrate that those features meet every element of the asserted claims, particularly the requirement for an "actionable user interface object" that allows users to perform actions based on pre-selected attributes.