Cedar Lane Tech Inc v. Choice Hotels Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Choice Hotels International, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00147, W.D. Tex., 03/28/2025
• Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business within the Western District of Texas and having committed alleged acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s online hotel search and booking system infringes a patent related to methods for visually displaying and analyzing layered graphic information.
• Technical Context: The technology concerns interactive graphical user interfaces designed to allow non-technical users to seamlessly access, manipulate, and compare complex, layered data sets, particularly in a map-based format.
• Key Procedural History: The complaint alleges that Defendant gained actual knowledge of the patent-in-suit and the infringement allegations upon service of a prior complaint on or about March 11, 2021, a fact which may be used to support a claim for enhanced damages or a finding of an exceptional case.

Case Timeline

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

U.S. Patent No. 8,397,177 - Graphic-information flow method and system for visually analyzing patterns and relationships

• Patent Identification: U.S. Patent No. 8397177, issued March 12, 2013.

The Invention Explained

• Problem Addressed: The patent asserts that prior art computer graphics and Geographic Information Systems (GIS) were difficult for non-technicians to use, did not provide "seamless access to subset combinations from extensive data sets," and broke the user's analytical flow by requiring navigation to separate web pages or windows to view additional information ('177 Patent, col. 2:3-7, col. 2:24-42). This constrained complex data exploration and made it difficult for users to build a "mental model of the findings of their inquiry" (Compl. ¶¶11-13; '177 Patent, col. 3:54-58).
• The Patented Solution: The invention is a client-server system that provides an interactive graphical user interface (GUI) for displaying and manipulating layered information, such as maps ('177 Patent, Abstract). It claims to solve the prior art's problems by combining "hypermedia and layering technologies" to allow a user to selectively control and view complex data in "layered and slotted formats" without leaving the primary interface ('177 Patent, col. 6:45-46; Compl. ¶14). The system is designed to enable a "continuous, focused concentration so that the computer screen becomes an extension of the mind's eye" ('177 Patent, col. 6:28-30).
• Technical Importance: The claimed approach sought to improve computer functionality by making the analysis of complex, multi-source data more efficient and intuitive, particularly for non-expert users, by keeping "the diagram pertinent to the moment" free of distracting information (Compl. ¶17; ’177 Patent, col. 6:33-34).

Key Claims at a Glance

• The complaint asserts independent method claim 5 and reserves the right to assert other claims (Compl. ¶¶19, 23).
• Independent Claim 5 recites a method with the following essential elements:
  • Performing server-side operations to generate and serve web page content to a web browser client.
  • Presenting a web page view that includes a control panel area with a list of hotels and a map display area.
  • The map display area presents an interactive map with a base map layer and "at least one additional layer overlaid over the base map layer," where the additional layer(s) contain hotel location symbols.
  • The graphical interface enables a user to "show or hide subsets of the hotel location symbols in a particular layer of the map display area."

III. The Accused Instrumentality

Product Identification

• The "Exemplary Defendant Products" are identified in "Exhibit 2" to the complaint, which was not filed with the public document (Compl. ¶¶23, 26). Based on the infringement allegations, the accused instrumentality is the online hotel search and mapping functionality available through Defendant's website(s) (Compl. ¶¶19-20).

Functionality and Market Context

• The complaint alleges the accused functionality involves a back-end database that serves hotel information to a user's web browser for display on an interactive map (Compl. ¶20). The user interface allegedly allows a user to view hotel locations as symbols on one or more layers overlaid on a base map. A key accused feature is the system's ability to allow a user to "show or hide subsets of the hotel location symbols," which the complaint contrasts with prior art systems that could not perform this function (Compl. ¶19). The complaint does not provide sufficient detail for analysis of the product's commercial importance or market positioning.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim charts detailing its infringement theory (Compl. ¶26). The narrative allegations state that Defendant’s website directly infringes at least Claim 5 of the ’177 Patent (Compl. ¶¶19, 23). The core of the infringement theory is that Defendant’s online hotel search system performs the patented method by providing an interactive map where users can filter results, which Plaintiff equates to the claimed step of enabling a user to "show or hide subsets of the hotel location symbols in a particular layer" (Compl. ¶19). This capability is framed as an inventive concept that was "not previously known in the prior art" (Compl. ¶19). The complaint further alleges that the back-end architecture of Defendant's website performs the claimed "server-side operations to support interaction with a web browser client" (Compl. ¶20).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central dispute will concern whether the filtering functions on a modern web application (e.g., checking or unchecking boxes for hotel amenities or brands) constitute enabling a user to "show or hide subsets" of symbols within a "particular layer," as those terms are used in the patent. The patent describes a specific "z-layer" architecture, raising the question of whether the accused system's functionality is technically equivalent ('177 Patent, col. 11:40).
  • Technical Questions: What evidence does the complaint provide that the accused website implements distinct data "layers" as opposed to simply re-querying a central database and rendering a new, filtered set of results? The infringement analysis will likely require a detailed examination of the accused system's architecture to determine if it aligns with the structure described in the patent's specification and figures.

V. Key Claim Terms for Construction

• The Term: "at least one additional layer overlaid over the base map layer" (Claim 5)

• Context and Importance: The existence of a "layer" is a prerequisite for the allegedly inventive step of showing or hiding subsets within that layer. The definition will be critical to determining if the accused website's display of hotel icons on a map meets this limitation. Practitioners may focus on this term because its construction could either limit the patent to the specific "x,y,z coordinate" architecture shown in the figures or allow it to cover a broader range of modern web-based filtering technologies.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification generally describes using layers for "overlapping and for showing and hiding before being output as a printed or digital illustration," which could support a functional definition ('177 Patent, col. 1:56-60).
  • Evidence for a Narrower Interpretation: The detailed description and figures repeatedly reference a structured system of "x,y,z coordinate slotting" and distinct "z-layer[s]" (e.g., '177 Patent, FIG. 2B; col. 11:40). An argument could be made that a "layer" requires this specific technical implementation, not just a logical grouping of filtered data points.

• The Term: "show or hide subsets of the hotel location symbols in a particular layer" (Claim 5)

• Context and Importance: The complaint identifies this capability as a key inventive concept distinguishing the patent from prior art where "a particular subset within a theme cannot be shown or hidden" (Compl. ¶19, citing '177 Patent, col. 2:31-32). The infringement determination will depend heavily on whether the accused system's filtering functionality performs this specific action.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent's objective is to provide a "seamless" and "simplified and intuitive process" for viewing complex information, which could support interpreting this phrase to cover any user action that results in filtering map symbols without a full page reload ('177 Patent, col. 4:6-12, col. 3:63-65).
  • Evidence for a Narrower Interpretation: The patent contrasts its invention with prior art that required going to a "separate Web page or window," suggesting the "show or hide" action must occur within a persistent, client-side data structure rather than through a new server query that returns a different set of results ('177 Patent, col. 2:39-42).

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendant has had "Actual Knowledge of Infringement" since being served with a prior complaint on or about March 11, 2021 (Compl. ¶25). These allegations form the basis for a potential claim for enhanced damages for any post-notice infringement under 35 U.S.C. § 284, and for a finding that the case is "exceptional" under 35 U.S.C. § 285 (Prayer for Relief ¶¶ D, E.i.).

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

• A central issue will be one of technical scope: Can the term "layer," as described in the context of the patent's specific "x,y,z coordinate" data architecture, be construed to cover the dynamic filtering and display-rendering functions of a modern web-based mapping application? The outcome may depend on whether the patent is seen as claiming a specific implementation or the broader concept of interactive, layered data visualization.
• A key evidentiary question will be one of functional implementation: Assuming the claim terms are construed broadly enough, what evidence will demonstrate that the accused website’s architecture performs the claimed method of manipulating "subsets" within a "particular layer," as opposed to conventionally re-querying a database to generate an entirely new set of map data for each user filtering action?