Linfo IP LLC v. Knot Worldwide Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: THE KNOT WORLDWIDE, INC. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00025, W.D. Tex., 01/23/2025
• Venue Allegations: Venue is based on Defendant having a regular and established place of business in the Western District of Texas and having allegedly committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s TheKnot.com online marketplace and its related services infringe a patent directed to systems and methods for organizing and displaying unstructured data objects based on user-defined "importance values."
• Technical Context: The technology at issue addresses information overload in digital environments by allowing for the sorting and presentation of data based on calculated relevance scores, rather than by conventional alphabetical or chronological methods.
• Key Procedural History: The complaint identifies the Plaintiff as a non-practicing entity. It also discloses that Plaintiff and its predecessors have entered into prior settlement licenses, while arguing these do not trigger marking obligations under 35 U.S.C. § 287(a) because they did not authorize the production of a patented article. The complaint reserves the right to limit its infringement claims to method claims, which may be a strategy to further insulate against a marking defense.

Case Timeline

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

U.S. Patent No. 9,430,131 - "System, Methods, And User Interface For Organizing Unstructured Data Objects"

• Patent Identification: U.S. Patent No. 9,430,131, "System, Methods, And User Interface For Organizing Unstructured Data Objects," issued August 30, 2016.

The Invention Explained

• Problem Addressed: The patent describes the problem of "information overload," where users of social networks, email, and search engines are faced with a large volume of data, making it difficult and time-consuming to find truly relevant information (ʼ131 Patent, col. 1:20-35). Conventional methods for filtering information are described as providing only "limited functionality" (ʼ131 Patent, col. 1:43-44).
• The Patented Solution: The invention proposes a system that organizes unstructured electronic objects (e.g., files, contacts, search results) by assigning "importance measures" to them based on various attributes ('131 Patent, Abstract). Instead of simple binary sorting (e.g., favorite/not favorite), the system allows a user to specify a granular degree of relevance, which is then used to organize and present the information in a more useful way, such as by separating high-relevance items from low-relevance items in the user interface ('131 Patent, col. 1:55-col. 2:15; FIG. 1).
• Technical Importance: This approach provides for a more nuanced, user-centric method of information management than conventional sorting by fixed criteria (e.g., date, name) by introducing a user-defined, non-binary relevance score as the basis for organization ('131 Patent, col. 13:35-42).

Key Claims at a Glance

• The complaint asserts claims 1-20, including independent claims 1, 9, and 18 (Compl. ¶9).
• Independent Claim 1, a method claim, includes the following essential elements:
  • Obtaining a plurality of electronic objects (e.g., files, folders, contacts).
  • Displaying the electronic objects or their names/icons in a user interface.
  • Receiving an "importance value" associated with at least one of the objects, which is entered by a user.
  • Determining a position to place the object in the user interface "directly from the importance value."
  • Placing the object or its name/icon in the determined position.
• The complaint reserves the right to assert dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendant's website, https://www.theknot.com, and its related "Products," including its marketplace and review platforms (Compl. ¶3, ¶12).

Functionality and Market Context

• The complaint alleges that Defendant operates a system with a "user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶9). This appears to refer to the functionality on TheKnot.com that allows users to search for, filter, and sort wedding-related vendors, venues, and services. The complaint does not provide sufficient detail for a more granular analysis of the accused system's specific operations. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a "preliminary exemplary table attached as Exhibit B" to support its infringement allegations, but this exhibit was not included with the filed complaint (Compl. ¶10). The following summary is based on the narrative allegations in the complaint.

’131 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question for the court will be whether standard e-commerce sorting options (e.g., sort by "rating," "most reviews") constitute receiving a user-entered "importance value" as that term is used in the patent. The defense may argue that selecting a pre-defined sorting algorithm is distinct from a user entering a granular, non-binary value as depicted in several patent embodiments ('131 Patent, FIG. 2A).
• Technical Questions: The complaint does not specify how the accused system's ranking logic operates. A key evidentiary issue will be whether the display position of a vendor is determined "directly from" the user's selection, as required by the claim, or if the selection is merely one input into a more complex, multi-factor ranking algorithm that may also consider factors like advertising tiers or other proprietary metrics.

V. Key Claim Terms for Construction

The Term: "importance value"

• Context and Importance: This term is foundational to all independent claims. Its construction will likely determine whether the patent's scope can read on conventional web-based sorting and filtering functionalities or is limited to interfaces that allow for more explicit, granular relevance scoring. Practitioners may focus on this term because the infringement case appears to depend on equating standard user filter selections with the "importance value" of the claims.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that an importance measure can be specified through "a selection of a user interface object corresponding to a predefined importance value" ('131 Patent, col. 8:17-20), which a plaintiff could argue covers clicking a filter button.
  • Evidence for a Narrower Interpretation: The patent repeatedly provides examples where the "importance value" is a specific numerical score (e.g., "0.95," "0.8") assigned to a relevance criterion, or selected from a multi-level scale ('131 Patent, FIG. 2A, FIG. 2C). This could support an interpretation requiring a more quantitative and granular user input than a simple sort command.

The Term: "determining a position ... directly from the importance value"

• Context and Importance: This term dictates the causal relationship between the user's input and the resulting display. The infringement analysis will depend on whether the accused system's ranking logic meets the "directly from" requirement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification does not appear to explicitly define "directly from," which may allow for an argument that it means the importance value is the primary or initiating cause for the re-positioning, even if other background factors exist.
  • Evidence for a Narrower Interpretation: The plain meaning of "directly from" could be argued to preclude intervening or confounding factors. This would suggest that the object's position must be a function of the importance value alone, which could be a difficult standard to prove against a commercial e-commerce ranking system.

VI. Other Allegations

Indirect Infringement

• The complaint alleges inducement by asserting that Defendant instructs its customers on how to use the allegedly infringing features of its website (Compl. ¶11). It also pleads contributory infringement, alleging the service is not a staple commodity and has no substantial non-infringing use (Compl. ¶12).

Willful Infringement

• Willfulness is alleged based on Defendant’s knowledge of the '131 patent from "at least the filing date of the lawsuit" (Compl. ¶11). The prayer for relief requests that the case be declared exceptional and that damages be trebled (Compl. p. 6-7, ¶d-e).

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

• A core issue will be one of definitional scope: can the term "importance value," which the patent illustrates with specific, user-assigned numerical scores, be construed broadly enough to cover a user's selection of pre-defined sorting categories (e.g., "sort by user rating") on a commercial website?
• A key evidentiary question will be one of technical mechanism: can the Plaintiff provide evidence that the accused system determines the display position of a listed item "directly from" a user's selection, as required by the claim, or does the final display order result from a proprietary, multi-factor algorithm where the user's choice is only one of many inputs?