Linfo IP LLC v. BK Beauty Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: BK Beauty, Inc. (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00250, W.D. Tex., 05/28/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant is a Texas corporation with a regular and established place of business in the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce website infringes a patent related to systems and methods for organizing and displaying unstructured data objects based on a calculated "importance value."
• Technical Context: The technology at issue addresses information overload by providing a method to sort and display digital objects (e.g., files, contacts, search results) based on user-defined or system-inferred relevance, rather than conventional alphabetical or chronological sorting.
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity. The complaint notes that Plaintiff and its predecessors have entered into settlement licenses with other entities but argues these do not trigger patent marking requirements 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"

• 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 addresses the problem of "information overload" where users are presented with large amounts of unstructured data (e.g., social media feeds, emails, search results, file lists) and have difficulty discerning valuable information from irrelevant information (’131 Patent, col. 1:20-35). Conventional filtering and sorting methods are described as inadequate for this task (’131 Patent, col. 1:43-48).
• The Patented Solution: The invention proposes a system where electronic objects are assigned a non-binary "importance value" based on various attributes. This value is used to determine the position or visual presentation of the object in a user interface, thereby distinguishing more relevant objects from less relevant ones (’131 Patent, Abstract; col. 2:5-15). For example, objects with a higher importance score can be displayed more prominently, in a larger font, or in a separate, dedicated area of the screen (’131 Patent, col. 8:56-64; Fig. 4).
• Technical Importance: The technical approach provides a more granular and flexible method for relevance ranking than simple binary "important/not important" flags, allowing for more nuanced organization of large digital collections (’131 Patent, col. 14:30-49).

Key Claims at a Glance

• The complaint asserts claims 1-20 of the ’131 Patent (Compl. ¶10). Independent claim 1 is representative.
• Independent Claim 1 Elements:
  • obtaining a plurality of electronic objects (comprising existing files, folders, or contacts);
  • 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 (e.g., as a direct numerical value or transformed from a text or UI selection);
  • determining a position to place the object in the UI directly from the importance value; and
  • placing the object in that determined position.
• The complaint reserves the right to assert dependent claims (Compl. ¶10).

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Defendant BK Beauty, Inc.’s e-commerce website and associated systems (Compl. ¶3, 10).

Functionality and Market Context

• The complaint alleges that the 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. ¶10). The complaint does not provide specific details on how product listings, user reviews, or other content on the BK Beauty website are sorted or displayed. The allegations suggest that the underlying functionality of the website for presenting information to users is what infringes the patent (Compl. ¶10). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a "preliminary exemplary table attached as Exhibit B" to support its infringement allegations, but this exhibit was not included with the filed complaint (Compl. ¶11). The following chart is constructed based on the narrative allegations in the complaint body.

’131 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question will be whether the content on Defendant’s e-commerce website (e.g., product listings, search results, customer reviews) qualifies as "electronic objects" as defined by the claim, which is limited to "currently existing files or file folders or directories... contacts in a contact list or address book."
  • Technical Questions: The complaint provides no specific evidence of how the accused website performs the core steps of the claimed method: receiving a user-entered, non-binary "importance value" and using that value to determine an object's display position. A key question for the court will be whether any sorting or filtering functionality on the website (e.g., "sort by price," "sort by popularity") meets these specific claim limitations.

V. Key Claim Terms for Construction

• The Term: "importance value"

• Context and Importance: This term is the core of the invention. Its definition will determine whether any ranking or sorting mechanism on the accused website infringes. Practitioners may focus on this term because the patent repeatedly emphasizes that it is a "non-binary numerical value" (Claim 8) and can be granularly specified by the user to reflect a degree of relevance, distinguishing it from simple binary flags or conventional sorting criteria (’131 Patent, col. 14:30-49).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests the value can be derived from various user actions, stating it can be "transformed from a text specified by a user, a numerical value transformed from a selection of a user interface object indicated by a user" (’131 Patent, col. 18:43-46). This could be argued to cover a wide range of user inputs beyond just typing a number.
  • Evidence for a Narrower Interpretation: The claims and specification consistently describe the "importance value" as being "entered by a user" (Claim 1) or specified via an explicit UI element, such as a slider or numeric input field (’131 Patent, Figs. 2A-2C, 6A-6B). Embodiments show explicit numerical scores (e.g., 0.95, 0.8) being assigned to criteria, suggesting a requirement for a specific, quantitative input rather than an implicit preference.

• 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 universe of things to which the claimed method applies. The infringement case depends on whether content on an e-commerce website falls within this definition.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party might argue that "comprise" is inclusive, not exhaustive, and that product listings or user reviews on a web server are analogous to "files" in a "computer file system."
  • Evidence for a Narrower Interpretation: The explicit listing of "files," "folders," "directories," and "contacts" suggests the invention was directed at personal information management on a local computer or social network, not general web content. This interpretation may be used to argue that product data in a commercial database is outside the scope of the claims.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement and contributory infringement based on Defendant actively encouraging customers to use its website and providing instructions "through its website and product instruction manuals" to perform the allegedly infringing methods (Compl. ¶12-13). The complaint asserts the accused features have no substantial non-infringing use (Compl. ¶13).
• Willful Infringement: Willfulness allegations are based on knowledge of the patent "from at least the filing date of the lawsuit" (Compl. ¶12-13). The complaint does not allege pre-suit knowledge, which may limit the viability of a claim for pre-suit enhanced damages.

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 the claim language defines by referencing personal data types like files, folders, and contacts, be construed to cover the product listings and user-generated content of a commercial e-commerce website?

2. A second central issue will be one of technical proof: Can Plaintiff produce evidence that the accused website's functionality meets the specific claim requirement of receiving a user-entered, non-binary "importance value" and using it "directly" to determine an object's display position, or will the website's standard e-commerce sorting features be found to operate in a technically distinct manner?

3. Finally, a key question will concern damages limitation: Given Plaintiff’s status as a non-practicing entity and its disclosure of prior settlement licenses, the court may need to resolve disputes over whether the patent marking statute (35 U.S.C. § 287) applies and potentially limits the recovery of pre-suit damages.