Linfo IP LLC v. Beard Brand LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Beard Brand LLC (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00237, W.D. Tex., 05/21/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant has a regular and established place of business in the district and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website and associated systems infringe a patent related to methods for organizing and displaying unstructured data objects based on user-defined relevance.
• Technical Context: The technology addresses the problem of information overload by providing systems to organize large collections of electronic data, such as files or contacts, based on calculated "importance" scores rather than conventional alphabetical or chronological sorting.
• Key Procedural History: The complaint identifies Plaintiff as a non-practicing entity. It notes that Plaintiff and its predecessors have entered into prior settlement license agreements and preemptively addresses potential defenses related to patent marking requirements under 35 U.S.C. § 287, stating its intention to limit its claims to method claims if necessary to obviate any marking requirement.

Case Timeline

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

• Patent Identification: U.S. Patent No. 9,430,131, "System, Methods, And User Interface for Organizing Unstructured Data Objects," issued August 30, 2016.

The Invention Explained

• Problem Addressed: The patent describes the problem of "information overload" in the "Big Data" era, where users are faced with an overwhelming amount of information from sources like social network feeds, emails, and large collections of personal files, making it difficult to discern value and locate relevant items efficiently (’131 Patent, col. 1:18-47).
• The Patented Solution: The invention proposes a system for organizing unstructured collections of "electronic objects" (e.g., files, folders, contacts) by assigning "importance measures" to them. This importance can be determined based on various attributes, such as user-specified criteria, content analysis, or metadata. The system then displays these objects in a manner that visually distinguishes them based on relevance, such as by grouping, sorting by importance, or applying different visual effects, thereby moving beyond simple alphabetical or chronological lists (’131 Patent, Abstract; col. 2:54-66). The overall system architecture is illustrated in Figure 1, which shows user inputs and content analysis feeding into a "Relevance Calculation" module that dictates the final display (’131 Patent, Fig. 1).
• Technical Importance: The technology aims to provide a more effective solution for navigating large datasets by introducing a granular, relevance-based organization method that is more aligned with a user's specific interests or tasks (’131 Patent, col. 1:48-52).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 (Compl. ¶10). Independent claims 1, 9, and 18 are asserted.
• Independent Claim 1 recites a method with the following essential elements:
  • Obtaining a plurality of electronic objects, specified as comprising "currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book."
  • Displaying the electronic objects or their names/icons in a user interface.
  • Receiving an "importance value" associated with at least one object, where the value is entered by a user and is a "non-binary numerical value."
  • Determining a position for the object in the user interface "directly from the importance value."
  • Placing the object (or its name/icon) in the determined position.
• The complaint reserves the right to assert dependent claims (Compl. ¶10).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's website, "https://www.beardbrand.com/", and its associated "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶¶4, 10).

Functionality and Market Context

The complaint alleges Defendant operates a website that sells "beard-related beauty products" (Compl. ¶4). The allegedly infringing functionality is described at a high level as a system for information discovery and presentation, including "review platforms" (Compl. ¶¶10, 13). The complaint does not provide specific details about the technical operation of the website's search, filtering, or review-display features. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an "Exhibit B" containing a "preliminary exemplary table" of infringement allegations, but this exhibit was not attached to the publicly filed document (Compl. ¶11). Therefore, a claim chart summary cannot be created. The infringement theory must be drawn from the narrative allegations.

The complaint’s narrative theory is that Defendant’s e-commerce website and its underlying systems for presenting product and review information meet the limitations of the asserted claims (Compl. ¶10). The allegations are conclusory and do not specify which features of the Beardbrand website are alleged to perform the steps of the claimed methods.

• Identified Points of Contention:
  • Factual Sufficiency: A threshold issue may be whether the complaint's high-level allegations meet the plausibility standard for pleading patent infringement. The complaint does not identify specific features of the accused website and map them to the elements of the asserted claims.
  • Scope Questions: The infringement theory raises a significant question about claim scope: whether product listings and customer reviews on an e-commerce website fall within the definition of "electronic objects" as recited in claim 1, which provides the examples of "files or file folders or directories in a computer file system, contacts in a contact list or address book" (’131 Patent, col. 18:32-36).
  • Technical Questions: A key technical question will be whether the accused website provides a mechanism for a user to input a "non-binary numerical" importance value that is then used "directly" to position an object. It remains an open question what evidence the complaint provides that the accused website’s functionality (e.g., sorting by star rating or price) is equivalent to the specific method required by the claims.

V. Key Claim Terms for Construction

• The Term: "importance value"

• Context and Importance: This term is central to the invention's contribution over conventional sorting methods. Its construction will be critical in determining whether standard e-commerce interactions, such as leaving a star rating, meet the claim limitation. Practitioners may focus on this term because the infringement allegation appears to equate conventional e-commerce features with the patent's specific relevance-ranking system.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests that an importance value can be derived from various user inputs, including selections from a list or acting on a user interface object, which are then transformed into a numerical value (’131 Patent, col. 5:47-55). This could support an argument that a 1-to-5 star rating qualifies as a user-entered numerical value.
  • Evidence for a Narrower Interpretation: Claim 1 requires the value to be "non-binary numerical" and used "directly" to determine position. Figures 6A and 6B depict explicit user interfaces where a user assigns a numerical score (e.g., 0.8 on a 0-1 scale) to a specific search keyword or parameter for the express purpose of influencing relevance ranking (’131 Patent, Figs. 6A, 6B). This may support a narrower construction requiring an explicit, granular numerical input for ranking, distinct from a generic product rating.

• The Term: "electronic objects" (wherein the electronic objects comprise currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book)

• Context and Importance: The definition of what constitutes an "electronic object" is fundamental to the scope of the patent. The dispute will center on whether this term, defined with examples from personal information management (PIM) and operating systems, can be read to cover commercial data like product listings on a public website.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue that the list following "comprise" is illustrative and not exhaustive, allowing the term "electronic objects" to encompass other forms of digital data, such as product entries in a database that are rendered on a webpage.
  • Evidence for a Narrower Interpretation: The explicit list of "files," "folders," "directories," and "contacts" strongly ties the invention to the context of personal or local data management. The patent’s background section reinforces this context by focusing on problems with social network feeds, emails, and personal files, not e-commerce product discovery (’131 Patent, col. 1:23-44). This could support a reading that limits the claim to the types of objects enumerated.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both inducement and contributory infringement. The inducement claim is based on allegations that Defendant instructs its customers on how to use its website in an infringing manner (Compl. ¶12). The contributory infringement claim alleges the accused service is not a staple product and that its only reasonable use is an infringing one (Compl. ¶13).
• Willful Infringement: The complaint alleges knowledge of the ’131 patent as of the filing date of the lawsuit, establishing a basis for post-filing willfulness and induced infringement (Compl. ¶12). It also includes a conditional prayer for enhanced damages for willful infringement, contingent on discovery revealing pre-suit knowledge of the patent (Compl. ¶VI.e).

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

• A core issue will be one of definitional scope: can the term "electronic objects," which the patent defines with examples like "files," "folders," and "contacts," be construed to cover product listings or customer reviews on a commercial e-commerce website? The resolution of this question will likely determine whether the patent is applicable to the accused instrumentality.
• A key evidentiary question will be one of technical implementation: assuming the definitional scope is met, does the accused Beardbrand website actually perform the claimed method? Specifically, does it provide a mechanism for a user to enter a "non-binary numerical... importance value" that is then used "directly" to determine an object's display position, or does it employ conventional sorting and filtering techniques that are technically distinct from the patented method?
• A threshold procedural question will be one of pleading sufficiency: given the complaint's lack of specific factual allegations mapping accused features to claim elements, the court may first need to address whether the complaint plausibly alleges a claim for patent infringement sufficient to proceed to discovery.