Linfo IP LLC v. Legendairy Milk LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Legendairy Milk, LLC (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00112, W.D. Tex., 03/07/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement and maintains a regular and established place of business in the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website and its product review system infringe a patent related to methods for organizing and displaying unstructured data based on user-defined importance.
• Technical Context: The technology addresses information overload by providing systems to assign relevance scores to data objects (e.g., messages, files, reviews) and display them in a manner that prioritizes more important content for the user.
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity. The complaint notes that Plaintiff and its predecessors have entered into prior settlement license agreements, arguing these do not trigger patent marking requirements under 35 U.S.C. § 287 because they were litigation settlements without admissions of infringement and did not authorize the production of a patented article.

Case Timeline

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

• 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 addresses the problem of "information overload" where users are presented with a large volume of unstructured data, such as in social network feeds, email inboxes, or search results, making it difficult to discern valuable information from irrelevant information (ʼ131 Patent, col. 1:20-35).
• The Patented Solution: The invention provides a system and user interface for organizing collections of electronic objects (e.g., files, contacts, messages). The system allows a user to assign an "importance measure" or "relevance score" to these objects. Based on this score, the system then displays the objects in different formats or in different, concurrently viewable areas to visually distinguish more relevant items from less relevant ones, thereby improving the user's ability to locate needed information ('131 Patent, Abstract; col. 3:30-44).
• Technical Importance: The described methods offer a more granular, flexible approach to information management than conventional sorting (e.g., alphabetical or chronological), which can be inadequate for large datasets ('131 Patent, col. 1:42-48).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-20 (Compl. ¶10). The independent claims are 1, 9, and 18.
• Independent Claim 1 (Method) includes the following essential elements:
  • Obtaining a plurality of electronic objects (e.g., files, folders, contacts).
  • Displaying the electronic objects or their representations in a user interface.
  • Receiving an importance value for at least one object, where the value is entered by a user and is an element selected from a group including a non-binary numerical value.
  • Determining a display position for the object in the user interface "directly from the importance value."
  • Placing the object at the determined position.
• The complaint reserves the right to assert dependent claims (Compl. ¶10).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's "Products," identified as its website, https://www.legendairymilk.com/products/liquid-gold-organic-lactation-blend, and the associated systems and user interfaces for "discovering information in a text content and extracting and presenting the information" (Compl. ¶4, ¶10). The complaint specifically mentions "review platforms" as part of the accused system (Compl. ¶13).

Functionality and Market Context

The complaint alleges Defendant operates a system that allows for the discovery, extraction, and presentation of information from text content (Compl. ¶10). This is alleged to include the systems used to manage and display customer reviews on its product pages (Compl. ¶13). The complaint does not provide further technical detail on how the accused review platform operates.

IV. Analysis of Infringement Allegations

The complaint references a preliminary exemplary infringement table in "Exhibit B," but this exhibit was not included with the pleading (Compl. ¶11). The following analysis is based on the narrative allegations. No probative visual evidence provided in complaint.

The complaint does not provide sufficient detail for a complete element-by-element analysis. For many claim elements, the complaint makes only general allegations that Defendant's system "infringes one or more of claims of the '131 patent" (Compl. ¶10) without identifying the specific corresponding functionality.

’131 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: A primary question will be evidentiary: what specific feature on Defendant's website corresponds to "receiving an importance value ... entered by a user"? The complaint does not identify a feature, such as a sorting mechanism or rating input, and explain how it meets this limitation.
  • Scope Questions: The infringement analysis may turn on the construction of key claim terms. For example, a question arises as to whether a conventional e-commerce sorting function (e.g., a button to sort reviews by rating) falls within the scope of "receiving an importance value," particularly given the patent's emphasis on non-binary, user-specified inputs.

V. Key Claim Terms for Construction

• The Term: "importance value"

• Context and Importance: This term is central to the invention's novelty. The viability of the infringement claim depends on whether any function of the accused website can be characterized as receiving a user-entered "importance value" as claimed. Practitioners may focus on this term because its scope will likely determine the outcome of the infringement analysis.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests that an importance measure can be specified indirectly, stating that when a user acts on a UI object like a button, "a numerical value can be predetermined corresponding to the text or user interface object selection, or transformed from such text or UI object selection" ('131 Patent, col. 5:48-55).
  • Evidence for a Narrower Interpretation: The patent’s detailed description and figures repeatedly provide examples of explicit, granular, and often numerical user inputs, such as specifying a value on a 0-to-1 scale or from a list of values from 1 to 5 ('131 Patent, col. 12:28-34; FIG. 2A, 2C). This may support an interpretation that requires a more direct, non-binary input from the user rather than a simple selection of a predefined sort order.

• The Term: "entered by a user"

• Context and Importance: This term is linked to "importance value" and is critical for determining what user action constitutes infringement. The dispute may focus on whether selecting a pre-defined option (e.g., clicking a "sort by helpfulness" button) constitutes a value being "entered by a user."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes a user specifying relevance by selecting from presented options, such as choosing from suggested terms or selecting example message objects, which the system then uses to determine relevance ('131 Patent, col. 6:11-17, col. 5:17-21).
  • Evidence for a Narrower Interpretation: The specification also uses language suggesting more active input, such as allowing a user to "enter a keyword or a description" ('131 Patent, col. 5:4-6). This could support a narrower construction requiring a user to type or otherwise provide a specific value, rather than merely selecting a pre-programmed function.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. The inducement claim is based on allegations that Defendant instructs its customers on how to use the accused services in a way that causes infringement (Compl. ¶12). The contributory infringement claim alleges the accused products are not staple articles of commerce and have no substantial non-infringing use (Compl. ¶13).
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’131 patent "from at least the filing date of the lawsuit" (Compl. ¶12, ¶13). Plaintiff explicitly reserves the right to amend the complaint if pre-suit knowledge is discovered (Compl. ¶12, n.1).

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

1. Evidentiary Sufficiency: A threshold issue for the case will be whether the complaint's general allegations can survive a motion to dismiss. What specific, identifiable feature of the accused website and its "review platforms" performs the central claimed function of "receiving an importance value... entered by a user," and what evidence will Plaintiff present to substantiate this allegation?
2. Definitional Scope: The case will likely hinge on claim construction, specifically whether the term "importance value," as used in the patent, can be construed broadly enough to encompass the functionality of a standard e-commerce sorting or filtering tool, or if it is limited to the more granular, user-specified numerical inputs heavily featured in the patent's examples.
3. Damages and Marking: Given Plaintiff's stated status as a non-practicing entity and its disclosure of prior litigation settlements, a key legal question will concern damages. The court may need to evaluate Plaintiff’s detailed arguments that its prior settlement licenses did not trigger the patent marking requirements of 35 U.S.C. § 287 (Compl. ¶15-20).