HyperQuery LLC v. Ansys Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HyperQuery LLC (Delaware)
  • Defendant: Ansys, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00174, W.D. Tex., 04/17/2025
• Venue Allegations: Venue is alleged to be proper because Defendant is a foreign corporation and has committed acts of patent infringement in the district, causing harm to the Plaintiff.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for downloading software applications based on a user's determined "search intent" rather than simple keyword matching.
• Technical Context: The technology operates in the field of mobile application discovery, aiming to improve the relevance of search results within application marketplaces or similar platforms.
• Key Procedural History: Plaintiff is the assignee of the patent-in-suit. No prior litigation, licensing, or other procedural events are mentioned in the complaint.

Case Timeline

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

U.S. Patent No. 9,529,918 - "System and methods thereof for downloading applications via a communication network," issued December 27, 2016

The Invention Explained

• Problem Addressed: The patent's background section describes conventional application search methods as "very time consuming" because they require users to navigate through numerous categories or use keyword searches that return irrelevant or promoted results not aligned with the user's specific needs ('918 Patent, col. 2:5-10). The problem is that search results are often not based on relevance to the user's actual intent ('918 Patent, col. 2:3-10).
• The Patented Solution: The invention proposes a system that goes beyond simple keywords to determine a user's "search intent" ('918 Patent, col. 4:3-7). It receives a query, analyzes it to determine this underlying intent (which can incorporate context like location or time of day), selects an application from a repository based on that intent, and then causes an icon for the selected application to be displayed in a "display segment" on the user's device ('918 Patent, Abstract; Fig. 2). A user's interaction with the icon then establishes a direct link to download the application ('918 Patent, col. 4:56-64).
• Technical Importance: This approach sought to provide an application search solution that overcomes the limitations of traditional keyword-based systems by delivering more relevant, context-aware application suggestions, thereby reducing search friction for the user ('918 Patent, col. 2:8-12).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" of the '918 Patent, without specifying particular claims (Compl. ¶11). Independent claim 1 is representative of the patented method.
• Independent Claim 1:
  • receiving, via the communication network, an input search query from a user device;
  • determining the search intent based on the input search query;
  • selecting, based on the search intent, at least one application from at least one applications central repository;
  • causing an icon corresponding to the at least one selected application to be displayed on a display of the user device;
  • receiving via the communication network an input from the user device indicating a particular one of the at least one selected application;
  • causing establishment of a direct communication link between the user device and a location hosting the particular one of the at least one selected application; and
  • causing initiation of a download of the particular one of the at least one selected application to the user device.
• The complaint incorporates by reference an Exhibit 2 containing charts for the "Exemplary '918 Patent Claims," but does not explicitly reserve the right to assert other claims (Compl. ¶16).

III. The Accused Instrumentality

• Product Identification: The complaint does not specifically name any accused products in its main body. It refers to "Exemplary Defendant Products" that are purportedly identified in charts within Exhibit 2, which is not attached to the publicly filed complaint (Compl. ¶11, ¶16).
• Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It alleges only that the "Exemplary Defendant Products practice the technology claimed by the '918 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are contained entirely within an external document, Exhibit 2, which was not provided with the filed complaint (Compl. ¶16, ¶17). The complaint itself offers no specific factual allegations mapping any feature of an accused product to the elements of the patent’s claims. It states only that "the Exemplary Defendant Products practice the technology claimed by the '918 Patent" and that they "satisfy all elements of the Exemplary '918 Patent Claims" (Compl. ¶16). Without the referenced exhibit, a detailed analysis of the infringement allegations is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "search intent"

• Context and Importance: This term is the core of the invention, distinguishing it from conventional keyword searching. The central infringement question will be whether the accused products perform a simple keyword search or the more complex "intent" determination as claimed. Practitioners may focus on this term because its scope will likely determine whether the accused system falls inside or outside the claims.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that "search intent represents the type of content, the content, and/or actions that currently may be of an interest to the user" ('918 Patent, col. 4:4-7), which could be argued to encompass any system that attempts to understand a user's goal.
  • Evidence for a Narrower Interpretation: The patent provides a detailed process for determining "implicit intent" that involves analyzing "environmental variables" (e.g., temperature, location, GPS coordinates) and "personal variables" (e.g., user profile, demographics) to derive a "category of interest" ('918 Patent, col. 4:9-26). A defendant could argue this specific, context-driven process defines the required "search intent."

• The Term: "display segment"

• Context and Importance: This term appears in the abstract and is explicitly claimed in dependent claim 19, which requires "instigating a display segment to be created." The nature of this "segment" is critical. If it requires a special UI element, like an overlay or a distinct widget, infringement may be harder to prove than if it reads on any area of a standard search results page.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Independent claim 1 merely requires "causing an icon... to be displayed on a display," which could be interpreted broadly to mean displaying an icon anywhere on the screen ('918 Patent, col. 10:62-64).
  • Evidence for a Narrower Interpretation: The summary describes "creating a display segment over a display of the user device" ('918 Patent, col. 2:27-28), and claim 19 requires that a display segment be "created" ('918 Patent, col. 12:40-44). This language may support an argument that the term requires the generation of a new, distinct, and possibly overlaid UI element, not just the population of a pre-existing results list.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '918 Patent" (Compl. ¶14). The specific content of this literature is referenced as being in Exhibit 2 (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based on alleged knowledge of infringement acquired upon service of the complaint and the attached claim charts (Compl. ¶13, ¶15). This constitutes an allegation of post-suit willfulness.

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

1. A core issue will be one of definitional scope: can the term "search intent", as described in the patent through a complex process involving contextual variables, be construed to cover the search and recommendation algorithms used in the accused products? The outcome may depend on whether the defendant's system performs simple keyword matching or a more sophisticated analysis of user context that aligns with the patent's teachings.

2. A fundamental question will be one of evidentiary sufficiency: The complaint's infringement theory relies entirely on an unfiled exhibit. A central challenge for the plaintiff will be to produce specific evidence demonstrating that the accused products actually perform each step of the claimed method, particularly the determination of "search intent" and the creation of a "display segment" in the manner required by a proper construction of the claims.