Linfo IP LLC v. Interactive Life Forms LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Interactive Life Forms, LLC (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00238, W.D. Tex., 05/21/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant, a Texas-based company, has a regular and established place of business in the district and has committed the alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s electronic commerce systems, including its product review platforms, infringe a patent related to methods for organizing and displaying unstructured electronic data based on user-defined relevance.
• Technical Context: The technology addresses information overload by providing systems to assign "importance" scores to digital objects and display them in a manner that prioritizes more relevant items for the user.
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity and discloses that it and its predecessors have entered into settlement licenses with other entities in prior disputes. The complaint notes that these settlements did not include admissions of infringement or agreements to produce patented articles, which may be intended to preemptively address potential patent marking defenses under 35 U.S.C. § 287.

Case Timeline

Date	Event
2013-03-25	U.S. Patent No. 9,430,131 Earliest Priority Date
2016-08-30	U.S. Patent No. 9,430,131 Issue Date
2025-05-21	Complaint Filing Date

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

U.S. Patent No. 9,430,131 - “System, Methods, And User Interface For Organizing Unstructured Data Objects” (Issued Aug. 30, 2016)

The Invention Explained

• Problem Addressed: The patent describes the problem of "information overload" where users are confronted with vast amounts of unstructured data—such as social network feeds, emails, search results, or personal files—making it difficult to discern valuable information from irrelevant information using conventional sorting or filtering tools (’131 Patent, col. 1:20-35).
• The Patented Solution: The invention provides a system for organizing collections of "electronic objects" (e.g., files, contacts) by allowing a user to assign a specific, granular "importance value" to an object. The system then uses this value to determine the object's display position, for instance by sorting a list to place more important items at the top or by displaying objects in different visual formats based on their assigned importance (’131 Patent, Abstract; col. 2:6-14). This allows for a more nuanced organization than simple binary (important/not important) or alphabetical sorting.
• Technical Importance: The technology provides a more flexible and user-driven method for managing large datasets, which was a growing challenge with the rise of "Big Data" and information-intensive applications (’131 Patent, col. 1:20-23).

Key Claims at a Glance

• The complaint asserts claims 1-20 of the ’131 Patent (Compl. ¶9).
• Independent Claim 1 recites the core elements of a method:
  • Obtaining a plurality of electronic objects, specified as comprising files, folders, or contacts.
  • Displaying the electronic objects or their representations in a user interface.
  • Receiving a user-entered "importance value" associated with at least one object, where this value can be directly entered, transformed from text, or selected via a UI element.
  • Determining a display position for the object "directly from the importance value."
  • Placing the object at the determined position in the user interface.
• The complaint reserves the right to assert dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The complaint accuses Defendant’s "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶9). It specifically identifies "review platforms" on Defendant's websites, such as https://www.fleshlight.com/products/medium-starter, as infringing instrumentalities (Compl. ¶12).

Functionality and Market Context

• The complaint does not provide a detailed technical description of how the accused review platforms operate. The allegations are framed at a high level, stating the systems "discover[], extract[], and present[]" information (Compl. ¶9, ¶11).
• The functionality appears to relate to the presentation and sorting of user-generated product reviews on an e-commerce website (Compl. ¶12). The complaint does not contain specific allegations about the commercial importance of these platforms beyond their use in selling products.

IV. Analysis of Infringement Allegations

The complaint states that support for its infringement allegations is found in a "preliminary exemplary table attached as Exhibit B" (Compl. ¶10). However, this exhibit was not included with the filed complaint. The narrative allegations in the complaint body are conclusory and do not map specific features of the accused instrumentality to the elements of the asserted claims.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over whether the accused "review platforms" on an e-commerce site fall within the scope of the claims. For example, does a collection of user-submitted product reviews constitute the claimed "plurality of electronic objects," which Claim 1 specifies as comprising "files or file folders or directories... contacts in a contact list or address book" (’131 Patent, col. 18:1-4)? The patent's focus on organizing personal files and contacts may suggest a different context from public e-commerce reviews.
  • Technical Questions: The infringement theory will depend on demonstrating that the accused system performs the specific functions recited in the claims. Key questions may include: What feature of the accused review platform corresponds to the "importance value" received from a user? Does a user rating or a "helpful" vote on a review meet the definition of this term as used in the patent? How does the system "determine a position... directly from the importance value," and what evidence does the complaint provide of this direct functional link?

V. Key Claim Terms for Construction

• The Term: "importance value"

• Context and Importance: This term is the central mechanism of the claimed invention. Its construction will be critical to determining whether common e-commerce features, such as star ratings or sorting by "most helpful," meet the claim limitation. Practitioners may focus on whether the term requires a user to explicitly assign a granular value for organizational purposes, or if it can broadly cover any user input that influences display order.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Claim 1 itself describes multiple ways the value can be received, including as a "numerical value directly entered by a user," a value "transformed from a text specified by a user," or a value from a "selection of a user interface object" (’131 Patent, col. 18:13-21). This suggests flexibility beyond simple numerical entry.
  • Evidence for a Narrower Interpretation: Many embodiments in the specification depict a user interface where a user assigns a specific numerical score (e.g., 0.95, 0.8) for the explicit purpose of organizing a personal collection of items, such as contacts or files (’131 Patent, Fig. 2A, Fig. 9). This context could support a narrower construction tied to personal information management.

• 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: This term defines the subject matter being organized. The viability of the infringement allegation against an e-commerce review platform hinges on whether product reviews can be considered "electronic objects" as defined here.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The use of the open-ended term "comprising" means the list that follows is not necessarily exhaustive. The specification also discusses "message objects in feeds" and "emails" as targets for organization, which could be argued as analogous to product reviews posted on a website (’131 Patent, col. 3:40-42).
  • Evidence for a Narrower Interpretation: The explicit recitation of "files," "folders," and "contacts" in Claim 1, combined with repeated references in the specification to organizing "personal data" and a "user's contact list," strongly points to a personal information management context, which a party could argue is distinct from a public-facing e-commerce review system (’131 Patent, col. 1:40-42, col. 14:3-4).

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. It asserts that Defendant provides instructions to customers on how to use the accused systems through its website and "product instruction manuals" (Compl. ¶11, ¶12). It further alleges that the accused product is not a staple good and has no substantial non-infringing use (Compl. ¶12).
• Willful Infringement: The complaint alleges Defendant has known of the ’131 patent "from at least the filing date of the lawsuit" (Compl. ¶11). This allegation, as pleaded, would only support a claim for post-filing willfulness. Plaintiff expressly reserves the right to amend if pre-suit knowledge is discovered (Compl. ¶11, fn. 3).

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

1. A core issue will be one of definitional scope: can the term "electronic objects," which is exemplified in Claim 1 with items of personal data like files and contacts, be construed to cover user-generated product reviews on a public e-commerce platform? The outcome of this claim construction question may be dispositive.

2. A second central issue will be one of technical implementation: assuming the claims are found to cover the accused platform, what evidence will show that the system's features map to the claim elements? Specifically, does a user action like a star rating or a "helpful" vote function as the claimed "importance value," and can Plaintiff demonstrate that the display position of a review is determined "directly from" that value as required by the patent?

3. Finally, a key question for damages and willfulness will be one of knowledge and notice: can Plaintiff establish that Defendant had knowledge of the ’131 patent prior to the filing of the lawsuit? The current pleading only alleges knowledge as of the complaint's filing date, limiting the initial exposure for enhanced damages.