HyperQuery LLC v. Siemens Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HyperQuery LLC (Delaware)
  • Defendant: Siemens Corporation (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00178, W.D. Tex., 04/18/2025
• Venue Allegations: Venue is asserted based on Defendant being a foreign corporation under 28 U.S.C. § 1391(c) and having committed alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that unidentified products from Siemens Corporation infringe a patent related to systems and methods for downloading software applications based on a user's determined search intent.
• Technical Context: The technology concerns application discovery, aiming to improve upon traditional keyword-based app store searches by analyzing user queries to infer underlying intent and recommend relevant applications.
• Key Procedural History: The complaint is the initiating document in this litigation. Plaintiff HyperQuery LLC is identified as the assignee of the patent-in-suit. No 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"

• Patent Identification: 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 conventional methods for finding applications in repositories like the Apple App Store® as "very time consuming," requiring users to navigate through numerous applications that are often promoted by the repository's owner rather than being relevant to the user's specific needs or intent. (’918 Patent, col. 2:4-12).
• The Patented Solution: The invention proposes a system that receives a search query, determines the user's "search intent" to understand the "topic of interest," selects a relevant application from a central repository based on that intent, and then presents an icon for the selected application. (’918 Patent, Abstract). When a user interacts with the icon, the system establishes a direct communication link to a location hosting the application to initiate the download, streamlining the discovery and installation process. (’918 Patent, col. 4:55-68).
• Technical Importance: The described technology sought to enhance the efficiency and relevance of application discovery by shifting from simple keyword matching to a model based on interpreting a user's underlying intent. (’918 Patent, col. 2:8-12).

Key Claims at a Glance

• The complaint alleges infringement of "Exemplary '918 Patent Claims" identified in an external exhibit but does not specify claim numbers in the body of the complaint. (Compl. ¶11). The patent’s first independent method claim is Claim 1.
• Independent Claim 1 requires:
  • receiving 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 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 application.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are purportedly identified in charts within an external document, Exhibit 2, which was not filed with the complaint. (Compl. ¶¶11, 16).

Functionality and Market Context

The complaint provides no description of the accused products' functionality, features, or market position. It makes only conclusory allegations that the unidentified products "practice the technology claimed by the '918 Patent." (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint’s infringement theory is presented through reference to external claim charts in "Exhibit 2," which is not publicly available. (Compl. ¶17). The complaint alleges that these charts compare the "Exemplary '918 Patent Claims to the Exemplary Defendant Products" and demonstrate that the products "satisfy all elements" of those claims. (Compl. ¶16). No specific factual allegations mapping product features to claim limitations are included in the body of the complaint.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Technical Questions: Given the lack of detail, a foundational question for the court will be to determine what the accused products are and how they operate. A subsequent technical question will be what evidence, if any, demonstrates that these products perform the specific steps of "determining the search intent" and "caus[ing] establishment of a direct communication link" as required by the claims and described in the patent.
  • Scope Questions: The dispute may center on the scope of the claim language. For example, a question will be whether the accused products' search functionality performs the sophisticated, multi-engine, probabilistic "intent determination" detailed in the ’918 Patent’s specification, or a more conventional form of search refinement that Plaintiff alleges falls within the claim scope.

V. Key Claim Terms for Construction

• The Term: "determining the search intent"

• Context and Importance: This term is the central inventive concept distinguishing the patent from conventional keyword searching. Its construction will be critical to the infringement analysis, as it will define the threshold of technical sophistication a search feature must possess to fall within the scope of the claims. Practitioners may focus on this term because its definition could either limit the patent to the complex embodiment disclosed or allow it to cover a wider range of modern search technologies.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The language of Claim 1 itself is high-level, merely requiring "determining the search intent based on the input search query." (’918 Patent, col. 9:62-63). This could support an argument that any process inferring user purpose beyond literal keyword matching meets the limitation.
  • Evidence for a Narrower Interpretation: The specification describes a detailed method for determining intent, which involves "tokenizing the input search query," processing it with a "plurality of engines" that compute "certainty score[s]," and performing statistical and semantic analysis on the results. (’918 Patent, col. 10:30-55). This detailed description in the preferred embodiment could be used to argue for a narrower construction that requires these specific functional steps.

• The Term: "direct communication link"

• Context and Importance: This term is important for defining the required download mechanism. The construction will determine whether a standard hyperlink to an app store page infringes, or if a more specific connection is required that bypasses such intermediate pages.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term could be interpreted broadly to mean any link that initiates the download process without requiring the user to perform a new search.
  • Evidence for a Narrower Interpretation: The claim requires a link "between the user device and a location hosting the particular one of the at least one selected application." (’918 Patent, col. 10:5-7). This could be argued to require a connection to the server hosting the application file itself, rather than a link to an intermediary informational or product webpage.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that allegedly infringes the ’918 Patent. (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based on post-suit conduct. The complaint asserts that the "service of this Complaint... constitutes actual knowledge of infringement" and that Defendant's continued alleged infringement despite this knowledge is willful. (Compl. ¶¶13-14).

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

1. Definitional Scope: A core issue will be one of claim construction, specifically: can the term "determining the search intent," as described in the patent’s detailed embodiments involving multiple engines and certainty scores, be construed broadly enough to read on the search and recommendation features of the yet-unidentified accused Siemens products?
2. Pleading Sufficiency: An initial question for the court may be whether a complaint that outsources all substantive infringement allegations to a non-proffered external exhibit meets federal pleading standards. The case’s progression may depend on the details revealed in these forthcoming infringement contentions.
3. Evidentiary Proof: Assuming the case proceeds, a key evidentiary question will be one of functionality: what technical evidence will be presented to prove that the accused products perform the specific multi-step method of receiving a query, determining intent, selecting an application, displaying an icon, and then establishing a "direct communication link" for download, as recited in the claims?