DCT
7:24-cv-00097
Linfo IP LLC v. Steve Madden Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Linfo IP, LLC (Texas)
- Defendant: Steve Madden, Ltd. (Delaware)
- Plaintiff’s Counsel: Ramey LLP
- Case Identification: 7:24-cv-00097, W.D. Tex., 04/12/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district, has committed acts of infringement in the district, and conducts substantial business in the forum.
- Core Dispute: Plaintiff alleges that Defendant’s system for discovering and presenting information within text content infringes a patent related to user interfaces for text analysis.
- Technical Context: The technology addresses information overload by providing tools to automatically identify, categorize, and selectively display or highlight portions of text based on their semantic meaning, such as positive or negative sentiment.
- Key Procedural History: The complaint states that Plaintiff is a non-practicing entity. No prior litigation, licensing, or inter partes review proceedings are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2011-12-09 | ’428 Patent Priority Date |
| 2015-07-28 | '428 Patent Issue Date |
| 2024-04-12 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
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 describes the problem of "data overload," where users face large amounts of unstructured text, such as online product reviews, making it difficult and time-consuming to find specific information or discern overall sentiment ('428 Patent, col. 1:12-38). For example, a user wanting to find negative comments about a hotel's "room service" would have to manually read through potentially hundreds of reviews ('428 Patent, col. 1:18-38).
- The Patented Solution: The invention is a computer-assisted system that analyzes text to identify grammatical, semantic (e.g., positive/negative opinion), and contextual attributes of words or phrases ('428 Patent, Abstract; col. 3:16-25). It then provides a user interface with selectable options (e.g., "show only the positive comments") that allow a user to perform an action—such as extracting, hiding, or highlighting—on the text segments that match the selected attribute ('428 Patent, col. 3:20-29). The system architecture is depicted in Figure 1, showing how text content (105) is processed by a linguistic analysis module (120) and then manipulated via a user interface (150).
- Technical Importance: This approach aimed to make digesting large volumes of user-generated content more efficient by allowing readers to quickly filter or focus on specific aspects or sentiments without keyword searching, thereby "saving the reader a considerable amount of time" ('428 Patent, col. 3:12-15).
Key Claims at a Glance
- The complaint asserts infringement of one or more of claims 1-20 ('Compl. ¶9).
- Independent Claim 1 is a computer-assisted method comprising the essential elements of:
- Obtaining a text content.
- Selecting a first and second semantic attribute for a user to choose from.
- Identifying words or phrases in the text associated with those attributes.
- Displaying an "actionable user interface object" associated with the attributes.
- Allowing a user to select one of the attributes via the user interface.
- Performing an action (e.g., extracting, displaying, highlighting) on the words or phrases associated with the user-selected attribute.
- The complaint does not specify which dependent claims may be asserted.
III. The Accused Instrumentality
Product Identification
The complaint does not identify any specific product by name. It broadly accuses an unspecified "system with methods and user interface for discovering information in a text content and extracting and presenting the information" that Defendant "maintains, operates, and administers" (Compl. ¶9).
Functionality and Market Context
The complaint alleges that the accused instrumentality provides an interface for users to act on discovered information, including "extracting, displaying or hiding, or highlighting or un-highlighting words or phrases in a text content" (Compl. ¶8). The complaint does not provide screenshots, marketing materials, or further technical descriptions of how the accused system operates or its position in the market. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint references a "preliminary exemplary table" in Exhibit B purporting to support its infringement allegations; however, Exhibit B was not included with the filed complaint (Compl. ¶10). The analysis below is based on the narrative allegations. The complaint does not provide sufficient detail for a granular, element-by-element analysis against a specific product.
'428 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A computer-assisted method for discovering information in a text content and extracting and presenting the information, comprising: obtaining, by a computer system, a text content... | The complaint alleges Defendant operates a system that discovers and presents information in text content (Compl. ¶9), which implies the system obtains text. | ¶9 | col. 16:62-65 |
| selecting a first semantic attribute and a second semantic attribute for users to select from... wherein the first semantic attribute is associated with a first name or description, and the second semantic attribute is associated with a second name or description | The complaint alleges Defendant's system provides users with "interface objects to act on the discovered information" (Compl. ¶8), but provides no detail on semantic attribute selection. | ¶8 | col. 16:1-8 |
| identifying a words or phrases in the text content associated with the first semantic attribute or the second semantic attribute | The complaint alleges Defendant's system discovers information in text content (Compl. ¶9), but does not specify how it identifies words or phrases with semantic attributes. | ¶9 | col. 16:9-11 |
| displaying an actionable user interface object, wherein the actionable user interface object is associated with a label representing the first name or description or the second name or description | The complaint alleges the system provides "interface objects" for users (Compl. ¶8), but does not describe any specific object or its labels. | ¶8 | col. 16:12-16 |
| allowing the user to select the first name or description or the second name or description as a user-specified or user-desired attribute | The complaint alleges the system provides users with interface objects to "act on" information (Compl. ¶8), implying user selection, but provides no further detail. | ¶8 | col. 16:17-20 |
| performing, by the computer system, an action on the word or phrase associated with the user-specified or user-desired semantic attribute, wherein the action includes at least extracting, displaying, storing, showing or hiding, or highlighting... | The complaint alleges the accused system performs actions such as "extracting, displaying or hiding, or highlighting or un-highlighting words or phrases" (Compl. ¶8). | ¶8 | col. 16:21-25 |
Identified Points of Contention
- Specificity Question: A primary issue will be whether Plaintiff can produce evidence that Defendant’s unspecified system performs the specific steps of Claim 1. The highly general allegations in the complaint raise the question of whether they meet the plausibility standard for pleading patent infringement.
- Technical Question: What evidence demonstrates that Defendant's system identifies text based on "semantic attributes" (e.g., sentiment, opinion) as taught in the patent, rather than through simple keyword matching or other conventional filtering techniques?
- Scope Question: Does the accused system’s user interface contain an "actionable user interface object" that allows users to select from pre-defined semantic categories, as depicted in the patent (e.g., Fig. 7, "Extract positive opinions"), or does it provide a more general function like a search box that may not meet this limitation?
V. Key Claim Terms for Construction
The Term: "first semantic attribute" / "second semantic attribute"
Context and Importance: This term is the core of the invention. Its definition will determine whether the patent covers only specific types of text analysis (like the sentiment analysis heavily featured in the specification) or a broader range of content filtering. Practitioners may focus on this term because its construction will define the technological scope of the patent and whether it reads on conventional search and filter functionalities.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is broad, not limiting "semantic attribute" to a particular type. The specification refers generally to "grammatical, semantic, and contextual attributes" (Compl. ¶8; ’428 Patent, col. 3:20-22), which could be argued to encompass a wide variety of meanings.
- Evidence for a Narrower Interpretation: The specification's examples focus heavily on "opinion" as the key semantic attribute, with values like "positive," "negative," or "neutral" ('428 Patent, col. 9:1-5). An embodiment describes a dictionary-based approach for identifying opinions ('428 Patent, Fig. 6). A defendant may argue that the term should be limited to this disclosed context of sentiment analysis.
The Term: "actionable user interface object"
Context and Importance: This term connects the back-end analysis to the user's control. The dispute will likely center on what types of UI elements meet this limitation. The outcome is critical because if the term is construed broadly to include any filter or search box, the claim scope expands significantly.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is not intrinsically limiting. Plaintiff may argue any UI element that causes the system to "perform an action" (e.g., a "filter" button) qualifies.
- Evidence for a Narrower Interpretation: The specification consistently depicts specific UI elements like dropdown menus (Fig. 7), selectable checkboxes (Fig. 9A), and radio buttons (Fig. 11) that present discrete, pre-defined semantic choices to the user. A defendant may argue the term should be construed to require such a discrete, pre-categorized selection mechanism, rather than a free-form text input field.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by asserting Defendant "actively encouraged or instructed others (e.g., its customers...)" on how to use its products and services in an infringing manner (Compl. ¶11). It also pleads contributory infringement on a similar basis (Compl. ¶12).
- Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the '428 patent from "at least the filing date of the lawsuit" (Compl. ¶11 & fn. 1). This allegation, as pleaded, would only support a claim for enhanced damages based on post-suit conduct.
VII. Analyst’s Conclusion: Key Questions for the Case
- A Threshold Pleading Question: Given the complaint’s failure to identify a specific accused product or provide any substantive detail on its operation (beyond echoing the patent's own language), a central initial issue will be whether the allegations are sufficient to state a plausible claim for relief or if they are subject to dismissal.
- A Core Definitional Question: The case will likely turn on the construction of "semantic attribute". Can the term be broadly construed to cover general content properties used in conventional filtering, or will the court limit it to the patent's specific examples of subjective opinion and sentiment analysis, which may not be present in the accused system?
- An Evidentiary Question of Functionality: Assuming the case proceeds, a key evidentiary battle will be one of technical operation: what proof can Plaintiff offer that Defendant’s system actually performs the claimed multi-step method of identifying text based on semantic attributes and then allowing users to perform actions on that identified text via a dedicated "actionable user interface object", as distinct from a standard keyword search or faceted navigation system?