Linfo IP LLC v. Summer Moon Franchising LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Summer Moon Franchising LLC (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00239, W.D. Tex., 05/21/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed alleged acts of infringement and maintains a regular and established place of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to organizing and displaying unstructured data objects based on user-defined relevance.
• Technical Context: The technology addresses the problem of information overload by enabling systems to sort and visually distinguish data items (e.g., files, messages, contacts) according to user-specified importance, rather than by conventional alphabetical or chronological sorting.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity. It also notes that Plaintiff and its predecessors have entered into prior settlement licenses with other entities, arguing these do not trigger marking requirements under 35 U.S.C. § 287(a) because the licenses did not involve the production of a patented article or an admission of infringement.

Case Timeline

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 faced with an overwhelming amount of unstructured data from sources like social network feeds, emails, and large sets of personal files, making it difficult to discern valuable information from irrelevant data (’131 Patent, col. 1:19-44).
• The Patented Solution: The invention proposes a system where users can organize a collection of electronic objects (e.g., files, contacts) by assigning a non-binary "importance value" to them. This value, which can be a numerical score or a selection from a scale, is then used to determine the display position or visual presentation of the objects, thereby highlighting more relevant items over less relevant ones (’131 Patent, Abstract; Fig. 1). The system separates high-relevance and low-relevance objects for display, for instance, by placing them in different areas of the screen or applying different visual effects (’131 Patent, col. 4:4-9).
• Technical Importance: This approach seeks to provide a more granular and user-centric method for filtering and prioritizing digital information beyond simple chronological or alphabetical sorting, which was becoming less effective with the growth of "Big Data" (’131 Patent, col. 1:49-52).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 (Compl. ¶9). The lead independent claim is Claim 1.
• Independent Claim 1 (Method Claim) requires:
  • Obtaining electronic objects, specified as "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 in a user interface.
  • Receiving a user-entered "importance value" for at least one object, where the value can be a direct numerical entry, derived from a text description, or from a UI object selection.
  • Determining a display position for the objects "directly from the importance value".
  • Placing the objects at that determined position in the user interface.
• The complaint reserves the right to assert additional claims, including dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Defendant's system for e-commerce, which includes its website (e.g., summermooncoffee.com) and associated functionalities like "review platforms" (Compl. ¶9, ¶12).

Functionality and Market Context

The complaint alleges Defendant "maintains, operates, and administers a system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶9). This appears to refer to the e-commerce portions of Defendant's website, where products are listed and customer reviews are displayed (Compl. ¶12). The complaint does not provide specific details on how these website features technically operate. Defendant operates and franchises retail coffee stores, and the website facilitates online sales and marketing (Compl. ¶3).

IV. Analysis of Infringement Allegations

The complaint references a preliminary claim chart in "Exhibit B" but does not include the exhibit itself (Compl. ¶10). The infringement theory must therefore be inferred from the complaint's narrative allegations.

The core allegation is that Defendant’s website, which presents product information and reviews, infringes the ’131 Patent (Compl. ¶9, ¶12). The complaint suggests that Defendant’s system allows for the discovery and presentation of information in a way that maps onto the patent's claims (Compl. ¶9). However, the complaint does not specify which feature of the accused website corresponds to the critical claim element of "receiving an importance value entered by a user" to determine the display position of an object. The infringement theory may depend on characterizing user actions like applying a search filter or a sort-order option (e.g., "sort by popularity") as the input of an "importance value."

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

"importance value"

• Context and Importance: This term is central to the invention and the infringement dispute. The viability of the plaintiff's case may depend on whether a standard e-commerce function, such as sorting or filtering, can be construed as "receiving an importance value."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification states the importance value can be transformed from a "text specified by a user" or a "selection of a user interface object" (’131 Patent, col. 17:39-44). Practitioners may argue this supports a broad construction covering user selections of predefined sorting or filtering options.
  • Evidence for a Narrower Interpretation: The patent’s figures and embodiments consistently depict the importance value as an explicit, granular rating, such as a numerical score (e.g., "0.95") or a selection from a multi-level scale (e.g., "High normal low") (’131 Patent, Fig. 2A, Fig. 2B). This could support a narrower construction requiring a more direct and expressive form of user input than typical e-commerce interactions.

"electronic objects"

• Context and Importance: Claim 1 explicitly defines the "electronic objects" as "currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book" (’131 Patent, col. 17:30-34). The case will hinge on whether this definition can encompass product listings on a commercial website.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discusses the invention in the broader context of "unstructured collection of electronic objects," "message objects," and items in a "news feed" (’131 Patent, col. 1:60-61, col. 4:41-42). Plaintiff may argue these broader descriptions inform the claim and that product listings are analogous to such "message objects."
  • Evidence for a Narrower Interpretation: Defendant will likely argue that the explicit definition in Claim 1 is limiting. The specific enumeration of files, folders, and contacts suggests the invention is directed at personal information management or file system organization, not public-facing e-commerce product pages.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement based on Defendant encouraging customers to use its website features in an infringing manner (Compl. ¶11). It alleges contributory infringement by asserting that Defendant's services have no substantial non-infringing use (Compl. ¶12). The factual support cited for these allegations is the Defendant's website itself, which is alleged to contain "instruction or advertisement that suggests an infringing use" (Compl. ¶12).
• Willful Infringement: Willfulness allegations are based on Defendant’s alleged knowledge of the ’131 patent from at least the filing date of the complaint (Compl. ¶11, ¶12). Plaintiff reserves the right to amend the complaint if pre-suit knowledge is discovered (Compl. p. 4, n.3).

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

1. A central issue will be one of definitional scope: Can the term "electronic objects," which Claim 1 defines as files, folders, and contacts, be construed to cover product listings and reviews on a commercial e-commerce website? The outcome of this question could be dispositive.

2. A second key issue will be one of functional mapping: Does any feature of the accused website meet the claim requirement of "receiving an importance value entered by a user" that is then used to "determine a position" for display? The case may turn on whether conventional e-commerce sorting and filtering functions can be equated to the patent's more explicit, user-driven importance-rating system.