DCT
7:25-cv-00148
Cedar Lane Tech Inc v. Booking Holdings Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Cedar Lane Technologies Inc. (Canada)
- Defendant: Booking Holdings, Inc. (DE)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 7:25-cv-00148, W.D. Tex., 03/30/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the district and has committed acts of infringement resulting in harm within the district.
- Core Dispute: Plaintiff alleges that Defendant’s online services, which allow users to view and filter hotel locations on an interactive map, infringe a patent related to methods for displaying and managing graphic information.
- Technical Context: The technology relates to graphical user interfaces for interactive maps, specifically systems that allow users to dynamically layer and filter complex data sets without disrupting the analytical flow.
- Key Procedural History: The complaint alleges that Defendant gained actual knowledge of the patent-in-suit and the alleged infringement upon service of a prior complaint on or about March 8, 2021, a fact which may form the basis for a future claim of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2005-01-11 | U.S. Patent No. 8,397,177 Earliest Priority Date |
| 2013-03-12 | U.S. Patent No. 8,397,177 Issues |
| 2021-03-08 | Alleged Service of Original Complaint on Defendant |
| 2025-03-30 | Complaint Filed |
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"
- Issued: March 12, 2013
The Invention Explained
- Problem Addressed: The patent describes prior art computer graphics and Geographic Information Systems (GIS) as being difficult for non-technicians to use, failing to provide "seamless access to subset combinations from extensive data sets," and breaking the user's analytical "flow of data selection" by requiring scrolling or navigating to separate web pages for additional information (Compl. ¶¶10-11; ’177 Patent, col. 2:3-7, 2:24-42). This forced users to mentally assemble information sequences, rather than having the computer do so (’177 Patent, col. 3:54-58).
- The Patented Solution: The invention is a "computer technology employing a next-generation computer interface, multi-media databases, and a user-tracking system to dynamically build a customized, interactive mapset" (’177 Patent, col. 6:8-12). It combines layering and hypermedia technologies to allow a user to manipulate "map" components, layers, and annotations to study patterns and relationships without losing context, enabling a "continuous, focused concentration so that the computer screen becomes an extension of the mind's eye" (’177 Patent, col. 6:28-34). This is achieved by generating a display with layered data and control panels that allow for selective viewing of data subsets (’177 Patent, col. 4:46-60).
- Technical Importance: The described technology aimed to enhance the usability of complex, image-intensive web applications by improving interactivity and reducing the cognitive load on users trying to analyze layered data (’177 Patent, col. 3:36-42).
Key Claims at a Glance
- The complaint asserts at least independent claim 5 (Compl. ¶19).
- The essential elements of independent claim 5 are:
- Performing server-side operations to support interaction with a web browser client by generating and serving web page content.
- 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, where the additional layer contains at least one "hotel location symbol."
- 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."
- The complaint notes it is asserting "one or more claims" and refers to "Exemplary '177 Patent Claims," reserving the right to assert additional claims (Compl. ¶23).
III. The Accused Instrumentality
Product Identification
- The complaint does not name specific products, instead referring to "the Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')" (Compl. ¶23). The referenced claim chart exhibit is not provided with the complaint.
Functionality and Market Context
- The accused functionality involves a web-based system that provides a display with "multiple, context-sensitive control panels for manipulating the information presented" (Compl. ¶15). The system is alleged to include a "back-end database that continuously or periodically gathers and stores new and changeable information" and serves web page content to a client computer (Compl. ¶20). Functionally, the system is alleged to provide a graphical interface over a map that "enables a user to show or hide subsets of the hotel location symbols in a particular layer" (Compl. ¶19).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
The complaint does not include its referenced claim chart exhibit. The following summary is based on the narrative infringement theory presented in the complaint.
’177 Patent Infringement Allegations
| Claim Element (from Independent Claim 5) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| performing server-side operations to support interaction with a web browser client by generating and serving web page content to a client computer | Defendant's system allegedly includes a "back-end database that continuously or periodically gathers and stores new and changeable information" and a "user-tracking database," which supports interaction with a web browser client. | ¶20 | col. 4:60-65 |
| a map display area presenting a portion of an interactive map comprising a base map layer and at least one additional layer overlaid over the base map layer wherein each additional layer contains at least one hotel location symbol | Defendant's products allegedly provide a display with information in "layered and slotted formats" and overlay at least one layer containing hotel location symbols on a base map. | ¶14, ¶19 | col. 30:38-44 |
| 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 | The accused products allegedly provide an interface where subsets of information can be shown or hidden, a feature the complaint contrasts with prior art in which a "particular subset within a theme cannot be shown or hidden." | ¶19 | col. 30:45-48 |
Identified Points of Contention
- Scope Questions: A primary question will be whether the phrase "enables a user to show or hide subsets," as claimed in the patent, can be construed to cover the now-commonplace filtering functionalities of modern web applications (e.g., filtering search results by price or amenities). The defense may argue this is a conventional database query, whereas the patent describes a specific, "unconventional" method for manipulating discrete data layers (’177 Patent, col. 6:45-51).
- Technical Questions: Claim 5 is a method claim. The complaint alleges direct infringement by the defendant's system. An issue may arise as to whether Defendant performs every step of the claimed method, or if certain steps are performed by the end-user's browser, which could raise questions of divided infringement not addressed in the complaint.
V. Key Claim Terms for Construction
- The Term: "show or hide subsets of the hotel location symbols"
- Context and Importance: The complaint frames this capability as the key distinction over prior art, which allegedly could not show or hide subsets within a thematic layer (Compl. ¶19; ’177 Patent, col. 2:31-32). The construction of this term will be central, as it will determine whether standard, modern web filtering mechanisms fall within the scope of what the patent claims as its invention.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's summary describes a high-level goal of providing "special control apparatus for organizing complex information sets and for user-retrieval of selections as layered or slotted maps and diagrams" (’177 Patent, col. 4:19-22). This could support a reading that encompasses any interface that allows a user to selectively retrieve and display data subsets.
- Evidence for a Narrower Interpretation: The specification describes overcoming prior art limitations related to "scrolling of palette scroll bars" and proposes an interface with specific components like clickable keys and extenders (’177 Patent, col. 2:34-36; Figs. 8A-h). A defendant may argue that "show or hide subsets" is limited to the specific user interface paradigms disclosed, not the general concept of filtering results.
VI. Other Allegations
- Willful Infringement: The complaint does not contain a formal count for willful infringement. However, it alleges that Defendant obtained "Actual Knowledge of Infringement" from the service of a prior complaint on or about March 8, 2021 (Compl. ¶25). This allegation of pre-suit knowledge provides the factual basis for a potential claim of willfulness and a request for enhanced damages under 35 U.S.C. § 284, which Plaintiff includes in its prayer for relief (Compl. p. 7, ¶D).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and the prior art: Can the patent's claims, which describe its layered interface as "unconventional" and an "architectural advancement" in the context of early-2000s technology, be interpreted to cover the now-ubiquitous filtering and display functionalities of modern interactive mapping services? The case will likely require a detailed analysis of what was truly conventional at the time of the invention.
- A second central question will be one of technical implementation: Does the accused system's architecture, presumably a standard web application stack, actually perform the specific method steps recited in Claim 5? The infringement analysis will depend on whether Plaintiff can prove a direct correspondence between the accused system's operation and the patent's description of combining "hypermedia and layering technologies" in a specific, integrated manner.