Linfo IP LLC v. Mariner Finance LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Mariner Finance, LLC (Maryland)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00262, W.D. Tex., 06/04/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business within the Western District of Texas and has committed the alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s system for discovering, extracting, and presenting information infringes a patent related to organizing unstructured electronic data objects based on user-defined relevance.
• Technical Context: The technology addresses information overload by providing systems and user interfaces that assign "importance" scores to data objects (e.g., files, contacts, messages) and display them in a manner that highlights relevance for the user.
• Key Procedural History: The complaint states that Plaintiff and its predecessors have entered into prior settlement licenses. It also notes that Plaintiff is a non-practicing entity and preemptively addresses the patent marking statute, arguing that its licensees did not produce patented articles and that it may limit its infringement claims to method claims to obviate any marking requirement.

Case Timeline

Date	Event
2013-03-25	’131 Patent Priority Date
2016-08-30	’131 Patent Issue Date
2025-06-04	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 August 30, 2016

The Invention Explained

• Problem Addressed: The patent describes the problem of "information overload" where users of social networks, email, and search engines are confronted with a large volume of unstructured data, making it difficult and time-consuming to find relevant information (’131 Patent, col. 1:19-47).
• The Patented Solution: The invention is a system that allows users to more effectively organize and retrieve data objects like files, folders, or contacts. It achieves this by enabling a user to assign a specific "importance measure" or "relevance score" to individual data objects or to attributes associated with them. The system then uses these scores to organize and display the objects, for example, by sorting them according to their importance value or by displaying high-relevance and low-relevance objects in different, concurrently viewable areas of a user interface (’131 Patent, Abstract; col. 2:6-14; Fig. 3).
• Technical Importance: The described methods provide a more granular way to filter and prioritize information beyond simple binary sorting (e.g., alphabetical) or flagging (e.g., "favorite"), which is valuable in environments with large datasets (’131 Patent, col. 13:30-41).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 (Compl. ¶9). The independent claims are 1, 9, and 18.
• Independent Claim 1 (a method) includes the key elements:
  • obtaining a plurality of electronic objects (e.g., existing files, folders, or contacts);
  • receiving an "importance value" associated with at least one object, where the value is entered by a user (e.g., as a numerical value, text, or via a UI object);
  • determining a position for the object in the user interface "directly from the importance value"; and
  • placing the object in that determined position.
• Independent Claim 9 (a method) includes the key elements:
  • identifying an "attribute or attribute value" associated with an object (e.g., number of times accessed, a specific word in its content);
  • providing a UI option for the object to be associated with an "importance value" based on that attribute; and
  • receiving the importance value specified by the user.
• Independent Claim 18 (a method) includes the key elements:
  • identifying a shared attribute for a subset of objects;
  • grouping or labeling the subset based on the shared attribute;
  • providing a UI option for the group or label to be associated with a user-specified "importance value"; and
  • receiving that importance value.
• The complaint reserves the right to assert any of claims 1-20, which include numerous dependent claims that add further limitations (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentality as a "system with methods and user interface for discovering information in a text content and extracting and presenting the information," which is maintained, operated, and administered by Defendant Mariner Finance, LLC (Compl. ¶9). The complaint also references Defendant's website, in connection with the accused products and services (Compl. ¶3, ¶12).

Functionality and Market Context

• The complaint provides very limited detail on the specific functionality of the accused system. It alleges the system is used for "discovering information in a text content and extracting and presenting the information" and that Defendant provides instructions on its use through its website and "product instruction manuals" (Compl. ¶9, ¶12). No specific features corresponding to the assignment or use of "importance values" are described. 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 does not include the exhibit (Compl. ¶10). In its absence, the infringement theory must be drawn from the complaint's narrative allegations. The complaint alleges that Defendant's system for discovering and presenting information infringes the ’131 Patent (Compl. ¶9). However, the pleading lacks specific factual allegations mapping features of the accused Mariner Finance system to the specific elements of the asserted claims. The analysis below identifies the open questions that arise from this lack of detail.

• Identified Points of Contention:
  • Technical Questions: A central question will be whether the accused Mariner Finance system performs the core functions recited in the claims. What evidence does the complaint provide that the system has a user interface through which a user can assign a non-binary "importance value" to an electronic object, as required by independent claim 1? The complaint does not specify.
  • Scope Questions: The complaint alleges infringement by a system for "discovering information in a text content" (Compl. ¶9). The asserted claims, however, are directed to organizing "currently existing files or file folders or directories... [or] contacts in a contact list or address book" (’131 Patent, claim 1). This raises the question of whether the functionality described in the complaint falls within the scope of the objects recited in the claims.
  • Evidentiary Questions: The complaint does not describe how the accused system determines the position of displayed information "directly from the importance value" as required by claim 1, or how it groups objects based on shared attributes for the assignment of importance values as required by claim 18. Discovery will be required to determine if any such functionality exists.

V. Key Claim Terms for Construction

The complaint does not identify any specific claim terms as being in dispute. However, based on the technology, the following terms may become central to the case.

• The Term: "importance value"

• Context and Importance: This term is the core of the invention, appearing in all independent claims. Its construction will determine what type of user input or system parameter qualifies, which is fundamental to the infringement analysis. Practitioners may focus on this term because the patent's specification seeks to distinguish the invention from prior art binary systems.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Claim 1 defines the term by example, stating it can be "a numerical value directly entered by a user, a numerical value 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. 18:40-47). This could support a reading that covers a wide range of user inputs that result in a ranking value.
  • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes a "non-binary numerical value" and a "finer-granulated difference in importance" to distinguish the invention from conventional binary marking (e.g., important/unimportant) (’131 Patent, claim 8; col. 13:35-41). This could support a narrower construction requiring more than a simple sort or filter selection.

• The Term: "determining a position to place the electronic objects... directly from the importance value"

• Context and Importance: This limitation from claim 1 connects the user's input to the final visual arrangement of data. The meaning of "directly from" will be critical in determining whether an accused system infringes.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue that any system that uses the importance value as a primary factor in a sorting or ranking algorithm determines the position "directly from" that value, even if other factors are considered.
  • Evidence for a Narrower Interpretation: The patent’s figures and description show a direct sorting of objects based on their assigned numerical importance value (e.g., Fig. 9; col. 14:11-15). This may support a construction requiring a more direct mapping, where the importance value is the sole or determinative factor for an object's position in a list.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. It asserts that Defendant instructs customers on how to use the accused system through its website and manuals, causing them to directly infringe (Compl. ¶11-12). The complaint further alleges the accused system is not a staple product and has no substantial non-infringing use (Compl. ¶12).
• Willful Infringement: The complaint alleges knowledge of the ’131 Patent "from at least the filing date of the lawsuit" (Compl. ¶11, ¶12). It includes a conditional prayer for enhanced damages and a willfulness finding if discovery reveals pre-suit knowledge (Compl., Prayer for Relief ¶e).

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

• A central issue will be one of evidentiary proof: Can Plaintiff produce evidence showing that the accused Mariner Finance system performs the specific, granular steps of the asserted claims? The complaint's general allegations of "discovering... and presenting" information lack the factual specificity to demonstrate how the system receives a non-binary "importance value" from a user and uses it to "directly" position electronic objects.
• A second key issue will be one of claim construction: Assuming some relevant functionality exists, can the term "importance value," which the patent repeatedly frames as a granular, non-binary measure, be construed broadly enough to read on conventional sorting or filtering options that might be present on a commercial website?
• Finally, a procedural question will concern pre-suit conduct: As the complaint does not allege pre-suit knowledge of the patent, a key question is whether Plaintiff can develop facts in discovery to support its claims for pre-suit indirect infringement and willfulness, or if damages and culpability will be limited to conduct occurring after the lawsuit was filed.