Linfo IP LLC v. Waimate B LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Waimate B, LLC., d/b/a Soludos (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00072, W.D. Tex., 02/17/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the Western District of Texas and has committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website and associated systems infringe a patent related to methods for organizing and displaying unstructured data objects based on user-defined relevance.
• Technical Context: The technology addresses information overload by enabling systems to sort and present data objects, such as files or contacts, according to a calculated "importance value" rather than by simple alphabetical or chronological order.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and has entered into prior settlement licenses with other entities. Plaintiff makes preemptive arguments regarding compliance with the patent marking statute, 35 U.S.C. § 287(a), noting that its settlement licenses did not require the production of a patented article.

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", issued August 30, 2016

The Invention Explained

• Problem Addressed: The patent addresses the problem of "information overload" in the "Big Data" era, where users of social networks, email systems, and search engines are often distracted by a large volume of irrelevant information, making it difficult to discern the value of any single piece of data (ʼ131 Patent, col. 1:19-35). Conventional methods for filtering information are described as having limited effectiveness (ʼ131 Patent, col. 1:43-47).
• The Patented Solution: The invention provides a system for organizing a collection of electronic objects (e.g., files, folders, contacts) by assigning "importance measures" to them based on various attributes (ʼ131 Patent, Abstract). A user can specify a relevance criterion and an associated importance score; the system then uses this information to determine how and where to display the objects, for instance by separating high-relevance and low-relevance items into different, concurrently viewable display areas (ʼ131 Patent, col. 2:5-15; Fig. 1).
• Technical Importance: The technology provides a method for organizing large sets of data based on granular, user-defined relevance, moving beyond the limitations of traditional sorting by fixed attributes like name or date (ʼ131 Patent, col. 1:48-57).

Key Claims at a Glance

• The complaint asserts claims 1-20 (Compl. ¶9). The patent contains three independent claims (1, 9, and 18).
• Independent Claim 1:
  • A computer-implemented method for presenting information, comprising:
  • obtaining a plurality of electronic objects (e.g., files, folders, contacts);
  • displaying the electronic objects in a user interface;
  • receiving a user-entered "importance value" associated with at least one object, where the value is a numerical value or transformed from a user's text or UI selection;
  • determining a position to place the object in the user interface directly from the importance value; and
  • placing the object in that determined position.
• The complaint reserves the right to assert any of claims 1-20, which would include all dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is the website https://www.soludos.com and its associated "Products," which the complaint describes as a "system with methods and user interface" (Compl. ¶3, ¶9).

Functionality and Market Context

• The complaint alleges that the accused instrumentality provides for "discovering information in a text content and extracting and presenting the information" (Compl. ¶9). It further references "review platforms" and "product instruction manuals" as means by which Defendant instructs customers on how to use the allegedly infringing systems (Compl. ¶12). The complaint does not provide specific details about the technical operation of the accused website's features or its market position, beyond identifying it as an e-commerce platform.

IV. Analysis of Infringement Allegations

The complaint alleges that support for its infringement allegations is contained in a "preliminary exemplary table attached as Exhibit B" (Compl. ¶10). This exhibit was not included with the filed complaint. The complaint's narrative theory alleges that Defendant’s system for "discovering information in a text content and extracting and presenting the information" infringes claims of the ’131 patent (Compl. ¶9). However, the complaint does not contain specific factual allegations that map features of the accused https://www.soludos.com website to the specific elements of any asserted claim.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A primary question will be whether the sorting and filtering options commonly found on e-commerce websites (e.g., "Sort by: Best Selling," "Sort by: Price") meet the definition of receiving a user-entered "importance value" as required by claim 1. The patent specification provides examples of users assigning specific numerical weights to abstract criteria like "Enterprise Sales" or "Skill A" (ʼ131 Patent, Figs. 2A, 6B), raising the question of whether a simple menu selection for a predefined sort order falls within the claim's scope.
  • Technical Questions: The complaint does not provide evidence demonstrating that the accused website performs the claimed step of "determining a position to place the electronic objects... directly from the importance value." A key factual dispute may be whether the website's display logic is equivalent to the specific method taught in the patent, or if it operates on a different technical basis.

V. Key Claim Terms for Construction

• The Term: "importance value" (from Claim 1)
• Context and Importance: This term is central to the invention and the infringement dispute. Its construction will likely determine whether standard e-commerce sorting functions can be found to infringe. The patent requires this value to be "entered by a user" and used to "determin[e] a position" for an object, making its definition critical.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 itself defines the term broadly as "an element selected from the group consisting at least of a numerical value directly entered by a user, a numerical value transformed from a text specified by a user, [or] a numerical value transformed from a selection of a user interface object indicated by a user" (ʼ131 Patent, col. 23:20-27). This language could support an argument that selecting a sort option from a dropdown menu constitutes a "selection of a user interface object" that is transformed into a value used for sorting.
  • Evidence for a Narrower Interpretation: The patent’s detailed description and figures consistently depict the "importance value" as a granular, non-binary measure that a user assigns to specific criteria to express a degree of relevance (e.g., assigning "0.85" to the topic "Enterprise Sales" or "0.7" to "Marketing") (ʼ131 Patent, Fig. 2A, col. 8:20-33). This context suggests the term may require a user to define a custom, weighted relevance score, rather than simply selecting a pre-programmed sort order.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement (Compl. ¶11, ¶12). Inducement is alleged based on Defendant "actively encourag[ing] or instruct[ing] others" on how to use the services in an infringing manner. Contributory infringement is alleged on the basis that the accused service is not a staple commercial product and that Defendant had reason to believe its customers' use would be infringing (Compl. ¶12).
• Willful Infringement: The complaint alleges willfulness based on knowledge of the ’131 patent "from at least the filing date of the lawsuit" (Compl. ¶11, ¶12). The pleading explicitly reserves the right to amend if pre-suit knowledge is discovered (Compl. ¶11 n.1).

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

• A core issue will be one of definitional scope: Can the term "importance value," as defined and used in the ’131 patent, be construed to cover the selection of conventional, predefined sorting options on an e-commerce website (e.g., "Sort by Price"), or is it limited to a more granular, user-assigned numerical weight intended to reflect a nuanced degree of relevance?
• A key evidentiary question will be what facts Plaintiff can develop to demonstrate that the accused website's underlying software architecture performs the specific steps of the claimed method. Given the absence of detailed technical allegations in the complaint, the case will depend on discovery to reveal whether the accused system "receive[s]" a user-entered value and uses it "directly" to "determin[e] a position" in the manner claimed by the patent.