7:25-cv-00177
HyperQuery LLC v. Planview Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: HyperQuery LLC (Delaware)
- Defendant: Planview, Inc. (Texas)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 7:25-cv-00177, W.D. Tex., 04/18/2025
- Venue Allegations: Venue is alleged to be proper in the Western District of Texas because the defendant, Planview, Inc., maintains an established place of business within the district.
- Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods for identifying and presenting downloadable software applications to a user based on a determination of the user's "search intent."
- Technical Context: The technology operates in the field of mobile application search and discovery, addressing methods to improve the relevance of search results beyond simple keyword matching.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2011-03-28 | Earliest Priority Date ('918 Patent) |
| 2013-12-11 | Application Filing Date ('918 Patent) |
| 2016-12-27 | Issue Date (U.S. Patent No. 9,529,918) |
| 2025-04-18 | Complaint Filing Date |
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 describes the process of searching for mobile applications in conventional repositories (e.g., app stores) as "very time consuming" because results are often not based on relevance to the user's specific topic of interest, but are instead promoted by the repository's owner (’918 Patent, col. 2:3-12). This requires users to navigate through potentially hundreds of irrelevant applications to find a suitable one (’918 Patent, col. 2:5-8).
- The Patented Solution: The invention proposes a method and system that receives a search query from a user, determines the user's "search intent," and uses that intent to select a relevant application from a repository (’918 Patent, Abstract). The system then causes an icon for the selected application to be displayed in a "display segment" on the user's device and, upon user input, establishes a direct communication link to download the application (’918 Patent, col. 2:20-33). The process of determining intent can involve analyzing the query itself ("explicit intent") or environmental and personal variables like location, time, and user profile ("implicit intent") (’918 Patent, col. 4:5-16).
- Technical Importance: The technology purports to offer an application search solution that overcomes the limitations of keyword-based search by inferring a user's underlying goal or interest, aiming to provide more accurate and efficient application discovery (’918 Patent, col. 2:8-12).
Key Claims at a Glance
- The complaint alleges infringement of "exemplary claims" without specifying claim numbers (Compl. ¶11). Independent claim 1 is a representative method claim.
- Independent Claim 1:
- A method, implemented by a computing device, for causing at least one application to be downloaded via a communication network, comprising:
- 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 does not explicitly reserve the right to assert dependent claims, but the prayer for relief requests a judgment that Defendant has infringed "one or more claims" (Compl. p. 4, ¶B).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" (Compl. ¶11). No specific products, methods, or services are named.
Functionality and Market Context
- The complaint does not provide any description of the accused products' features, functionality, or market positioning. It alleges that Defendant makes, uses, sells, and imports these unidentified products (Compl. ¶11).
IV. Analysis of Infringement Allegations
The complaint alleges that infringement is detailed in claim charts provided as Exhibit 2 (Compl. ¶16). However, Exhibit 2 was not filed with the complaint. The body of the complaint does not contain a narrative infringement theory or a description of how the "Exemplary Defendant Products" practice the technology claimed by the '918 Patent. The complaint states only that the accused products "practice the technology claimed by the '918 Patent" and "satisfy all elements of the Exemplary '918 Patent Claims" (Compl. ¶16). Without the referenced exhibit or a descriptive theory, 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 central concept of the asserted claims. The patent's validity and the scope of infringement will depend heavily on its definition. Practitioners may focus on this term because the patent describes determining intent both "explicitly" from a query and "implicitly" from environmental variables, creating ambiguity as to what level of analysis is required to meet the limitation (’918 Patent, col. 4:5-11, col. 4:35-41). The definition will be critical to distinguishing the claimed invention from conventional search engine technology.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the 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. 4:4-6). This language could support a broader definition encompassing any determination of user interest.
- Evidence for a Narrower Interpretation: The patent provides detailed descriptions of determining "implicit intent" by analyzing and correlating personal and environmental variables, such as location and time, to derive a "category of interest" (’918 Patent, col. 4:19-28). A defendant could argue this detailed process defines the required scope of "search intent."
The Term: "display segment"
Context and Importance: This term describes the user interface element where the icon for the suggested application is presented. Its construction is important for determining whether an accused product's user interface infringes. A key question will be whether a standard list of search results within an application window constitutes a "display segment."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims require only "causing an icon... to be displayed on a display of the user device," which could be read broadly to cover any form of display (’918 Patent, col. 10:63-65). The summary also mentions displaying an icon "in the display segment" (’918 Patent, col. 2:28-29).
- Evidence for a Narrower Interpretation: The summary describes "creating a display segment over a display of the user device," suggesting an overlay or a distinct, separate portion of the screen, rather than results integrated into an existing interface (’918 Patent, col. 2:27-28). The specification also refers to this as a "dynamic display segment" (’918 Patent, col. 5:37-38).
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).
- Willful Infringement: The willfulness allegation is based on knowledge of infringement obtained "at least since being served by this Complaint and corresponding claim charts" (Compl. ¶15). The complaint also alleges that service of the complaint itself constitutes "actual knowledge" for ongoing infringement (Compl. ¶13).
VII. Analyst’s Conclusion: Key Questions for the Case
A threshold evidentiary question will be the identification of the accused products. As the complaint fails to name any specific "Exemplary Defendant Products," discovery will be required to establish the basic facts needed to ground any infringement analysis.
A central issue will be one of definitional scope: what technical processes are required to meet the "determining the search intent" limitation of claim 1? The case may turn on whether this requires the complex "implicit intent" analysis detailed in the specification or if it can be met by more conventional search-term-to-category mapping.
The infringement analysis will also raise a structural question regarding the user interface: can the term "display segment", which the specification suggests is an overlay, be construed to cover the user interface of the accused products, whatever they may be? The answer will determine if the accused functionality is presented in a manner that falls within the claim scope.