7:25-cv-00244
Linfo IP LLC v. Gossamer Gear Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Linfo IP, LLC (Texas)
- Defendant: Gossamer Gear Inc. (Texas)
- Plaintiff’s Counsel: Ramey LLP
- Case Identification: 7:25-cv-00244, W.D. Tex., 10/09/2025
- Venue Allegations: Venue is alleged to be proper as Defendant is a resident of Texas that has committed 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 website, including its product review platforms, infringes a patent related to systems and user interfaces for organizing unstructured data objects by assigning them importance values.
- Technical Context: The technology addresses information overload by enabling the organization and display of electronic data based on user-defined or system-inferred relevance, a central challenge in modern user interface and data management systems.
- Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and has previously entered into settlement licenses related to its patents. This First Amended Complaint was filed following a Motion to Dismiss from the Defendant, suggesting an early dispute over the sufficiency of the initial pleadings.
Case Timeline
| Date | Event |
|---|---|
| 2013-03-25 | ’131 Patent Priority Date |
| 2016-08-30 | ’131 Patent Issue Date |
| 2025-09-25 | Defendant's Motion to Dismiss Filed |
| 2025-10-09 | First Amended 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
The Invention Explained
- Problem Addressed: The patent's background describes the problem of "information overload" where users are inundated with data from sources like social network feeds, emails, and search engine results, making it difficult to discern valuable information from irrelevant content ( Compl. ¶9; ’131 Patent, col. 1:19-47).
- The Patented Solution: The invention provides a system and methods to organize collections of "unstructured data objects" (e.g., files, contacts, emails) by assigning an "importance measure" to each item. This measure, which can be specified by the user, is based on various attributes of the data. The system then displays the objects in a way that reflects their calculated importance, for instance, by grouping more relevant items in a primary display area or applying different visual effects to distinguish them from less relevant items (’131 Patent, Abstract; col. 2:6-15; Fig. 1).
- Technical Importance: The described approach provides a method for data organization that moves beyond conventional chronological or alphabetical sorting to a more dynamic, user-centric model based on granular relevance (’131 Patent, col. 13:50-67).
Key Claims at a Glance
- The complaint asserts infringement of one or more of claims 1-20 (Compl. ¶10). The patent contains three independent claims (1, 9, and 18). Claim 1 is representative:
- Obtaining a plurality of electronic objects, such as files, folders, or contacts.
- Displaying the electronic objects or their representations in a user interface.
- Receiving a non-binary "importance value" associated with at least one object, where the value is entered by a user.
- Determining a position in the user interface for the object directly from the importance value.
- Placing the object in the determined position.
- The complaint alleges infringement of both method and system claims, either literally or under the doctrine of equivalents (Compl. ¶10).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is identified as Defendant's "system with methods and user interface for discovering information in a text content and extracting and presenting the information," which includes "review platforms" on its website, https://www.gossamergear.com/ (Compl. ¶10, ¶13).
Functionality and Market Context
The complaint alleges that Defendant "maintains, operates, and administers" this system for electronic commerce (Compl. ¶9-10). The specific functionality centers on the presentation of information within text content, with "review platforms" cited as an example (Compl. ¶13). The complaint does not provide further technical details on how the accused platforms operate. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges that Defendant's system infringes the ’131 patent but does not specify which features of the accused review platforms map to the claim elements (Compl. ¶10-11). The following table summarizes the infringement theory for representative Claim 1 based on the general allegations in the complaint.
’131 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A computer-implemented method for presenting information, comprising: obtaining a plurality of electronic objects... | The complaint alleges Defendant operates a system that presents information, such as product reviews, which are alleged to be electronic objects. | ¶10 | col. 17:31-36 |
| displaying the electronic objects or their names or icons in a user interface; | Defendant's website and review platforms are alleged to display information to users via a user interface. | ¶10, ¶13 | col. 17:37-38 |
| receiving an importance value associated with at least one of the electronic objects, wherein the importance value is entered by a user... | Defendant's system is alleged to include a user interface for presenting information in a manner that infringes the patent's claims. | ¶10 | col. 17:39-49 |
| determining a position to place the electronic objects or their names or icons in the user interface directly from the importance value; and | The complaint alleges Defendant's system presents information in a manner that infringes the claims. | ¶10 | col. 17:50-53 |
| placing the electronic objects or their names or icons in the position in the user interface. | The complaint alleges Defendant’s system places and presents information in an infringing manner. | ¶10 | col. 17:54-56 |
- Identified Points of Contention:
- Scope Questions: A primary issue may be whether standard e-commerce features, such as sorting product reviews by "most helpful" or "highest rating," constitute "receiving an importance value ... entered by a user" as contemplated by the patent. The defense may argue that such pre-defined sorting options are distinct from the user-defined, granular values described in the patent's specification.
- Technical Questions: The complaint's allegations are general. A key question for discovery will be identifying the specific functionality within Gossamer Gear's review platform that allows a user to "enter" a "non-binary numerical value" (as required by dependent claim 8) or its equivalent to re-order or re-position electronic objects.
V. Key Claim Terms for Construction
- The Term: "importance value"
- Context and Importance: This term is the central inventive concept and appears in every independent claim. The outcome of the case will likely depend on whether the court construes this term broadly enough to cover functionalities on the accused website or narrowly, as the defense may advocate, to require more specific user input than typical web-based sorting filters provide.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the term broadly as a "degree of relevance" and a "quantitative measure" that can be specified in various ways, including through a "text description" or the "selection of a user interface object" (’131 Patent, col. 5:32-34; col. 8:16-20). This language may support an argument that selecting a sort option like "most helpful" constitutes providing an importance value.
- Evidence for a Narrower Interpretation: The patent's figures and exemplary embodiments frequently depict the "importance value" as a specific numerical score that a user enters or selects from a multi-level scale (e.g., 0.95, 0.8, or a selection from 1-5) (’131 Patent, Fig. 2A, Fig. 2C). This could support a narrower construction limited to explicit, user-quantified relevance inputs.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant encourages and instructs its customers on how to use its products and services (such as its review platforms) in a way that directly infringes the ’131 patent (Compl. ¶12).
- Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’131 patent from "at least the filing date of the lawsuit" (Compl. ¶12). The plaintiff reserves the right to amend if pre-suit knowledge is discovered (Compl. p. 6, ¶e).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "importance value," which the patent illustrates with explicit, user-entered numerical rankings, be construed to encompass pre-defined sorting and filtering options common to e-commerce product review platforms?
- A key evidentiary question will be one of factual sufficiency: can the Plaintiff, through discovery, identify specific features on the Defendant’s website that perform the claimed steps, particularly the requirement that a user "enter" a non-binary value that is then used to "determine a position" for a data object in the user interface? The complaint's current lack of specificity suggests this will be a central battleground.