Linfo IP LLC v. Texas Hill Country Olive Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Texas Hill Country Olive Co. (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00124, W.D. Tex., 03/13/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district, has committed alleged acts of infringement in the district, and conducts substantial business in the forum.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website, which allows for the organization and presentation of product information, infringes a patent related to systems for organizing and displaying unstructured data objects based on relevance.
• Technical Context: The technology relates to user interface methods for managing information overload by automatically filtering and displaying data objects (such as messages, files, or contacts) based on user-defined or system-inferred importance.
• Key Procedural History: The complaint notes that Plaintiff and its predecessors-in-interest have entered into prior settlement licenses for its patents. It argues these licenses did not trigger marking requirements under 35 U.S.C. § 287(a) because the licensees were not producing a "patented article." This suggests that a potential dispute over pre-suit damages and marking compliance may arise.

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 identifies the problem of "information overload" where users are confronted with a large volume of unstructured data, such as social network feeds, emails, or long lists of personal files and contacts, making it difficult to discern valuable information from irrelevant data (ʼ131 Patent, col. 1:20-47).
• The Patented Solution: The invention proposes a system where electronic data objects are assigned an "importance measure" and then displayed to the user in a manner that reflects this measure. The importance can be determined based on user-specified criteria (e.g., assigning a numerical value to a keyword), content analysis, or metadata. The system then displays objects with higher relevance differently from those with lower relevance, for example by placing them in separate, concurrently viewable areas or by using different visual effects like font size, to help the user focus on what matters most ('131 Patent, Abstract; col. 2:5-15; Fig. 1).
• Technical Importance: The technology seeks to improve the efficiency of information processing by creating a more intuitive and relevance-driven user interface, thereby reducing the cognitive burden on users and minimizing the chance of missing critical information concealed within large datasets ('131 Patent, col. 1:48-52).

Key Claims at a Glance

• The complaint asserts claims 1-20 of the '131 patent (Compl. ¶9). Independent claim 1 is representative.
• Independent Claim 1 (Method):
  • Obtaining a plurality of electronic objects, where the objects include existing files, folders, or contacts.
  • Displaying the electronic objects or their names/icons in a user interface.
  • Receiving an importance value associated with at least one object, where the value is entered by a user (e.g., as a direct numerical value, transformed from text, or from selecting a UI object).
  • Determining a position for the objects in the user interface directly from the importance value.
  • Placing the objects (or their names/icons) in the determined position.
• The complaint does not explicitly reserve the right to assert dependent claims, but the general assertion of claims 1-20 implies they are at issue.

III. The Accused Instrumentality

• Product Identification: The accused instrumentalities are Defendant’s "Products," "services," and "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶3, ¶9). The complaint specifically identifies the Defendant's website, Defendant's website, and its "review platforms" as involved in the alleged infringement (Compl. ¶12).
• Functionality and Market Context: The complaint alleges that Defendant, an olive oil company, "maintains, operates, and administers a system" that allows for the presentation of information (Compl. ¶9). This appears to refer to the e-commerce functionality of its website, where products are displayed and can presumably be sorted or filtered by users. The complaint does not provide specific details on the operational features of the website, such as available sorting options or filtering criteria. It broadly accuses Defendant of using the patented methods to present information to customers (Compl. ¶11). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an "exemplary table attached as Exhibit B" to support its infringement allegations but does not include the exhibit (Compl. ¶10). Therefore, a detailed claim chart analysis is not possible based on the provided documents.

The narrative infringement theory is that Defendant's website and related systems practice the patented method for organizing and presenting information (Compl. ¶9). The Plaintiff alleges that when Defendant offers its products and services, it puts the patented inventions into service by operating a user interface that allows for the discovery, extraction, and presentation of information in a manner that infringes claims of the ’131 Patent (Compl. ¶9). The complaint suggests this occurs when customers use features on Defendant's website, such as "review platforms" (Compl. ¶12). However, the complaint lacks specific factual allegations that map discrete features of the accused website to the specific limitations of the asserted claims.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a full analysis of likely claim construction disputes. However, based on the patent and the nature of the parties, the following terms from independent claim 1 may become central to the case.

• The Term: "electronic objects"
• Context and Importance: Claim 1 states these objects "comprise currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book" ('131 Patent, col. 18:32-36). The core question will be whether this definition can encompass product listings on a commercial website. Practitioners may focus on this term because the patent's examples heavily feature personal information management (emails, contacts, local files), not e-commerce product catalogs.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue the list of object types is exemplary, not exhaustive, and that a product listing is a type of "electronic object" in a database, which is analogous to a "file" in a "file system."
  • Evidence for a Narrower Interpretation: A party could point to the consistent use of "files," "folders," "contacts," "emails," and "social network" feeds throughout the specification as context limiting the scope to personal data, not commercial product data ('131 Patent, col. 1:31-41, col. 14:1-4).
• The Term: "importance value"
• Context and Importance: This term is critical because infringement will depend on whether the accused website receives a value corresponding to a user’s subjective sense of importance. The dispute will likely center on whether standard e-commerce sort functions (e.g., "Sort by Price," "Sort by Popularity") meet this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that selecting any sort option is effectively a user specifying what is important to them, and this selection is received by the system as an "importance value."
  • Evidence for a Narrower Interpretation: The patent specification provides examples of users assigning specific, granular, non-binary numerical values to criteria (e.g., importance of "0.95" for a term, "0.8" for a region) ('131 Patent, Fig. 2A, col. 8:21-33). This may support an argument that a simple, predefined sort command is not the "importance value" contemplated by the patent.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. For inducement, it asserts that Defendant encourages infringement by instructing customers "on how to use its products and services" to perform the infringing acts (Compl. ¶11). For contributory infringement, it alleges that Defendant instructs customers on using "review platforms" and that the accused service "is not a staple commercial product" with substantial non-infringing uses (Compl. ¶12).
• Willful Infringement: The complaint alleges Defendant "has known of the ’131 patent and the technology underlying it from at least the filing date of the lawsuit" (Compl. ¶11, ¶12). This forms the basis for a claim of post-suit willful infringement. The Plaintiff explicitly reserves the right to amend if pre-suit knowledge is discovered (Compl. ¶11, fn. 1).

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

1. Definitional Scope: A core issue will be whether the patent's claim terms, such as "electronic objects" and "importance value", which are described in the specification primarily in the context of personal information management and granular user input, can be construed to cover generic product listings and standard sorting functions on an e-commerce website.
2. Evidentiary Sufficiency: A key question will be whether the Plaintiff can produce evidence that Defendant's website performs the specific method steps of claim 1. This will require showing not just that the site can sort a list, but that it receives a user-defined "importance value" and uses it to determine a "position" in the user interface in the manner taught by the patent.
3. Viability of Conclusory Allegations: The infringement allegations are pleaded at a high level of generality, without a supporting claim chart. A central procedural question will be whether these allegations, particularly for indirect and willful infringement, meet the plausibility standard required to survive a motion to dismiss.