Linfo IP LLC v. Tecovas Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Tecovas, Inc. (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00248, W.D. Tex., 05/27/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Texas corporation that has committed acts of infringement and has a regular and established place of business in the district, conducts substantial business there, and derives revenue from goods and services provided in the district.
• 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 a user-defined measure of importance.
• Technical Context: The technology addresses information overload by enabling systems to sort and display data objects (such as files, contacts, or other information items) according to a granular, user-specified relevance score, rather than by conventional methods like alphabetical or chronological order.
• Key Procedural History: The complaint notes that Plaintiff and its predecessors have entered into settlement licenses with other entities for its patents. It also preemptively argues that these licenses did not create a marking requirement under 35 U.S.C. § 287(a) because the licensees did not admit infringement or agree to produce a patented article.

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: In an era of "Big Data," users are faced with information overload from sources like social network feeds, emails, and large collections of personal files and contacts. Conventional methods for managing this information are often limited to simple filtering or sorting, making it difficult to discern the most relevant items. (’131 Patent, col. 1:20-47).
• The Patented Solution: The invention provides a system where a user can assign a specific, non-binary "importance value" to an electronic object (e.g., a file, folder, or contact) or to an attribute associated with objects. (’131 Patent, Abstract; col. 18:28-49). This value is then used by the system to determine the object's display position, allowing for a more granular and user-centric organization of information than traditional sorting methods. The system can display high-relevance and low-relevance objects concurrently but in different visual formats or areas to draw the user's attention appropriately. (’131 Patent, col. 8:43-51; FIG. 1).
• Technical Importance: The technology offers a method to manage large datasets by introducing a user-defined, granular relevance metric, which moves beyond the binary "important/not important" or simple alphabetical/chronological sorting common in many applications. (’131 Patent, col. 13:30-49).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-20. (Compl. ¶9). The patent contains three independent claims: 1, 9, and 18.
• Independent Claim 1 (Method):
  • obtaining a plurality of 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 or their names/icons in a user interface;
  • receiving an "importance value" for at least one object that is "entered by a user" (where the value can be a directly entered numerical value, or transformed from a text description or UI selection);
  • determining a display position for the object "directly from the importance value"; and
  • placing the object at that determined position in the user interface.
• The complaint reserves the right to assert dependent claims. (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendant’s website (https://www.tecovas.com), its e-commerce systems, and specifically its "review platforms". (Compl. ¶2, ¶9, ¶12).

Functionality and Market Context

• The complaint alleges that 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 system is part of an e-commerce platform for selling boots and other apparel. (Compl. ¶2). The complaint provides a link to a product page as an example of where infringing activity, such as the use of review platforms, occurs. (Compl. ¶12). The allegations suggest that features on this website, which may involve sorting or organizing information like products or customer reviews, perform the patented methods.

IV. Analysis of Infringement Allegations

The complaint does not contain an embedded claim chart, instead referring to a non-public "Exhibit B". (Compl. ¶10). The following chart is constructed based on the narrative allegations in the complaint and the language of asserted independent claim 1.

No probative visual evidence provided in complaint.

’131 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A primary issue will be whether the term "electronic objects," which is explicitly defined in Claim 1 as "files or file folders or directories... [or] contacts," can be construed to read on the product listings or customer reviews of an e-commerce website. The defense may argue for a narrow construction based on the claim's plain language, while the plaintiff may point to broader language in the specification.
  • Technical Questions: The complaint lacks specific factual allegations explaining how the accused Tecovas website performs the crucial step of "receiving an importance value... entered by a user" to organize content. A key question for the court will be what specific functionality on the Tecovas website is alleged to meet this limitation and whether that functionality operates in a manner consistent with the patent's teachings, which describe assigning a granular, non-binary score.

V. Key Claim Terms for Construction

• The Term: "electronic objects"
• Context and Importance: The scope of this term is central to the entire dispute. Infringement hinges on whether product data and customer reviews on an e-commerce site can be considered "electronic objects" as claimed. Practitioners may focus on this term because the claim itself provides a narrow, explicit definition ("files or file folders or directories... contacts..."), creating a potential mismatch with the accused instrumentality.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plaintiff may argue that the examples in the claim are illustrative, not exhaustive. The patent's summary of the invention refers more broadly to organizing "a large number of objects such as files, folders, emails, and contacts" (’131 Patent, col. 1:55-57), and the abstract mentions organizing an "unstructured collection of electronic objects". (’131 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The defense may argue that the definition provided directly within Claim 1—"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"—is a deliberate and limiting definition that controls the scope of the claim. (’131 Patent, col. 18:32-36).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant actively encourages and instructs customers on how to use its website and review platforms in an infringing manner. (Compl. ¶11, ¶12). It also alleges contributory infringement on the basis that the accused services are not staple commercial products and that their "only reasonable use... is an infringing use". (Compl. ¶12).
• Willful Infringement: The complaint alleges knowledge of the ’131 patent "from at least the filing date of the lawsuit," which forms the basis for a claim of post-filing willfulness. (Compl. ¶11). Plaintiff also reserves the right to amend the complaint if pre-suit knowledge is discovered. (Compl. ¶11, n.2).

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

• A core issue will be one of definitional scope: can the term "electronic objects," which Claim 1 defines in the context of a computer file system and contact list, be construed broadly enough to cover the product listings and user reviews presented on an e-commerce website?
• A key evidentiary question will be one of factual infringement: does the accused Tecovas website actually possess a mechanism for a user to enter a non-binary "importance value" that "directly" determines the display position of content, as required by the claim, or is there a fundamental mismatch in technical operation between the accused features and the patented method?
• A third question concerns damages and marking: will Plaintiff's arguments regarding prior settlement agreements successfully shield it from a defense that it failed to comply with the patent marking statute, which could limit the recovery of pre-suit damages?