DCT
7:25-cv-00125
Linfo IP LLC v. DYLN Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Linfo IP, LLC (Texas)
- Defendant: DYLN Inc. (California)
- Plaintiff’s Counsel: Ramey LLP
- Case Identification: 7:25-cv-00125, W.D. Tex., 03/13/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a "regular and established place of business" in the district, conducts substantial business there, and has committed alleged 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, rank, and visually distinguish electronic data objects (e.g., messages, files, products) according to granular importance values, rather than simple binary filters.
- Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and has entered into settlement license agreements with other entities in the past. It includes pre-emptive arguments that the patent marking statute should not limit damages, contending that prior licenses did not involve the production of a patented article and that it may limit its assertion to method claims.
Case Timeline
| Date | Event |
|---|---|
| 2013-03-25 | Earliest Priority Date for U.S. Patent No. 9,430,131 |
| 2016-08-30 | U.S. Patent No. 9,430,131 Issued |
| 2025-03-13 | Complaint Filed |
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: In an era of "Big Data," users are often overwhelmed by information from sources like social network feeds, emails, and search engine results, making it difficult to discern valuable information from irrelevant data (ʼ131 Patent, col. 1:18-34). Existing methods for filtering information are described as providing only "limited functionality" (ʼ131 Patent, col. 1:43-44).
- The Patented Solution: The patent describes systems and methods for organizing collections of "unstructured electronic objects" (e.g., files, contacts, messages) by assigning them an "importance measure" ('131 Patent, Abstract). This measure can be determined based on various attributes, including user-specified criteria like keywords or topics, and the system can then display the objects in different formats or areas based on their calculated relevance, such as separating high-relevance and low-relevance items into concurrently viewable display areas (ʼ131 Patent, Fig. 3; col. 2:5-15).
- Technical Importance: The invention provides a more granular and user-tunable approach to information management than conventional binary (i.e., show/hide) filtering, allowing users to prioritize content more effectively (ʼ131 Patent, col. 13:59-65).
Key Claims at a Glance
- The complaint asserts infringement of one or more of claims 1-20 (Compl. ¶10). Independent claims 1, 9, and 18 are asserted.
- Independent Claim 1 (Method):
- 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;
- determining a position for the object in the user interface "directly from the importance value"; and
- placing the object in the determined position.
- The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶10).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant's "system with methods and user interface for discovering information in a text content and extracting and presenting the information," including its website (https://www.dyln.co/) and associated "review platforms" (Compl. ¶¶ 4, 10, 13).
Functionality and Market Context
- The complaint alleges that Defendant operates a system that performs infringing methods, which are put into service for Defendant's commercial benefit (Compl. ¶10). The system is used in connection with the advertisement, marketing, and sale of water bottles and other products (Compl. ¶4). The complaint alleges the system involves "discovering information in a text content and extracting and presenting the information" (Compl. ¶10), but provides no further technical detail on how the accused website or its features operate.
IV. Analysis of Infringement Allegations
The complaint references a preliminary claim chart in "Exhibit B" but does not attach it (Compl. ¶11). The infringement allegations in the body of the complaint are conclusory and lack specific factual detail mapping accused functionality to the claim limitations. The following chart is constructed based on the general infringement theory presented.
'131 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A computer-implemented method for presenting information, comprising: obtaining a plurality of electronic objects... | The complaint alleges Defendant operates a system that presents information related to its products. | ¶¶4, 10 | col. 17:31-36 |
| displaying the electronic objects or their names or icons in a user interface; | Defendant's website, https://www.dyln.co/, displays products and related information to users. | ¶4 | col. 17:37-38 |
| receiving an importance value associated with at least one of the electronic objects, wherein the importance value is entered by a user... | The complaint does not provide sufficient detail for analysis of how Defendant's system allegedly receives a user-entered "importance value." | N/A | col. 17:39-47 |
| determining a position to place the electronic objects or their names or icons in the user interface directly from the importance value; | The complaint does not provide sufficient detail for analysis of how a position is determined "directly from" an importance value. | N/A | col. 17:48-51 |
| and placing the electronic objects or their names or icons in the position in the user interface. | The complaint does not provide sufficient detail for analysis of this element. | N/A | col. 17:52-53 |
- Identified Points of Contention:
- Scope Questions: A primary issue will be the interpretation of "importance value." The question is whether this term, described in the patent as enabling "granular" and "non-binary" relevance (ʼ131 Patent, col. 13:60-62; Claim 8), can be construed to read on conventional e-commerce sorting and filtering options (e.g., "sort by price," "filter by category"), or if it requires a more sophisticated, user-tunable relevance input.
- Technical Questions: The complaint lacks factual allegations explaining how the accused DYLN website functions. A key technical question for the court will be what evidence, if any, demonstrates that Defendant's system (1) receives a user-entered, non-binary numerical "importance value" and (2) "directly" uses that value to determine the display "position" of an object, as required by the claim, rather than simply filtering or re-sorting a list based on predefined categories.
- No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
The Term: "importance value"
Context and Importance: This term is the central inventive concept of Claim 1. The outcome of the case may depend on whether the defendant’s system can be shown to receive an "importance value." Practitioners may focus on this term because its construction will define the line between the patented invention and conventional, unpatentable sorting/filtering functionalities common in e-commerce.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that a user can "specify a non-binary numerical value... to be associated with such keywords or example objects" (ʼ131 Patent, col. 5:42-45). This could be argued to encompass any user action that results in a numerical weighting, however simple.
- Evidence for a Narrower Interpretation: The patent repeatedly frames the invention as an improvement over "conventional binary method[s]" (ʼ131 Patent, col. 9:48-50) and discloses embodiments where users can specify a "granular degree of importance" (ʼ131 Patent, col. 13:60-62). Claim 8 specifies the value is "a non-binary numerical value." This evidence may support a narrower construction that excludes simple, categorical sorting options and requires a system that accepts fine-grained relevance inputs from a user.
The Term: "determining a position... directly from the importance value"
Context and Importance: This term dictates the functional relationship between the user's input and the system's output. Infringement hinges on whether the accused system's logic for arranging content meets this "directly from" requirement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any system that re-orders a list based on a user's selection of an "important" category is "directly" determining position from that value, as the position changes as a direct result of the user's input.
- Evidence for a Narrower Interpretation: The term "directly from" may be construed to require a specific computational link where the position is a calculated function of the numerical importance value, as opposed to a system that merely uses the user's selection to apply a predefined sorting rule to a list.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by asserting that Defendant "actively encouraged or instructed" customers on how to use its infringing products and services (Compl. ¶12). It also pleads contributory infringement, alleging the accused product is not a staple article of commerce and has no substantial non-infringing use (Compl. ¶13). These allegations are not supported by specific factual averments, such as citations to user manuals or marketing materials.
- Willful Infringement: Willfulness is alleged based on knowledge of the '131 patent "from at least the filing date of the lawsuit" (Compl. ¶12). This supports a claim for post-filing willfulness only. The plaintiff explicitly "reserves the right to amend if discovery reveals an earlier date of knowledge" (Compl. ¶12, n.1).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the claim term "importance value", which the patent specification associates with a "granular" and "non-binary" measure of relevance, be construed broadly enough to cover the conventional sorting and filtering options commonly found on e-commerce websites?
- A key evidentiary question will be one of factual sufficiency: The complaint provides only conclusory allegations of infringement. The case will likely turn on whether the Plaintiff can produce specific evidence during discovery to demonstrate that the accused DYLN website actually performs the claimed methods, particularly the receipt of a user-defined, non-binary "importance value" and the direct use of that value to determine an object's display position.