DCT
7:25-cv-00361
Ve Opening LLC v. Moveworks Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: VE Opening LLC (Texas)
- Defendant: Moveworks, Inc. (Delaware)
- Plaintiff’s Counsel: Direction IP Law
- Case Identification: 7:25-cv-00361, W.D. Tex., 08/22/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a place of business in the district and has allegedly committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Enterprise Search product infringes a patent related to methods for searching across and linking information between distinct software applications on a computing device.
- Technical Context: The technology addresses the challenge of unifying information retrieval across multiple, often siloed, enterprise software applications to improve user efficiency and productivity.
- Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2014-06-05 | U.S. Patent No. 9,916,079 Priority Date |
| 2018-03-13 | U.S. Patent No. 9,916,079 Issues |
| 2024-10-29 | Accused Product (Moveworks Enterprise Search) Launch Date |
| 2025-08-22 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,916,079 - “Method and System for Enabling the Sharing of Information Between Applications on a Computing Device”
- Patent Identification: U.S. Patent No. 9916079 (“Method and System for Enabling the Sharing of Information Between Applications on a Computing Device”), issued March 13, 2018 (the “’079 Patent”).
The Invention Explained
- Problem Addressed: The patent's background section describes the inefficiency and difficulty users face when a task requires using multiple, independent software applications that do not cooperate or share information easily (e.g., using a calendar application and a separate email application to manage a single event) (’079 Patent, col. 1:21-43). Setting up such information sharing manually can be confusing for typical users and tedious even for advanced users (Compl. ¶13; ’079 Patent, col. 1:39-43).
- The Patented Solution: The invention provides a method where a user can initiate a "global search" from within a "first application." This search retrieves information not just from the first application, but also from a "second application." The system then presents "candidate elements" (e.g., search results) from the second application to the user within the first application's environment. The user can then select a candidate element to create a link, effectively connecting information from the second application back into the first, streamlining the user's workflow (’079 Patent, Abstract; col. 2:50-63). For example, a user in a task management application could search for and link to a relevant email from a separate email application directly within a task's notes field (’079 Patent, Fig. 4).
- Technical Importance: The claimed method aims to enable even non-sophisticated users to leverage information sharing across multiple applications, saving time and improving efficiency in completing complex tasks (’079 Patent, col. 6:35-42).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶14).
- The essential elements of Claim 1 include:
- From a first application, initiating a global search that covers both a first application and a second application.
- Prompting for and receiving a search term from a user.
- Based on the term, automatically determining and presenting corresponding "candidate elements" associated with the second application for the user's selection.
- Receiving the user's selection of a candidate element.
- Linking information between the first and second applications by generating a selectable link in the first application that enables access to information related to the second application.
- Receiving selection of the link and presenting the related information through the first application.
- The prayer for relief seeks judgment on "one or more claims," which may suggest Plaintiff contemplates asserting additional claims later in the litigation (Compl. p. 28, ¶a).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant’s “Moveworks Enterprise Search” product (Compl. ¶14).
Functionality and Market Context
- The complaint describes Moveworks Enterprise Search as a generative AI-powered solution that allows employees to find information across hundreds of different enterprise applications, such as Workday, ServiceNow, Slack, and Google Calendar (Compl. ¶15, p. 5).
- The product allegedly uses an "agentic Reasoning Engine" to understand user goals and search across various business systems to provide results (Compl. p. 5). The complaint alleges that the product ingests and indexes data from these various sources into an "Enterprise Graph" to facilitate a unified search experience (Compl. ¶18, p. 12). A screenshot in the complaint depicts a user interacting with a chat interface to check PTO balance, which the system resolves by accessing Workday data (Compl. p. 7).
- The product is marketed as a solution to information fragmentation and is positioned as a productivity driver that reduces the time employees spend searching for information across disparate systems (Compl. pp. 5-6).
IV. Analysis of Infringement Allegations
’079 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| from the first application, initiating a global search covering the first application and the second application by performing steps comprising: receiving a global search request through the first application, wherein the global search request requests information across the first application and the second application; | A user allegedly initiates a search from the Moveworks Enterprise Search window (the "first application"), which searches across Moveworks' internal data sources as well as integrated third-party business applications like Slack, Salesforce, and Google Calendar (the "second application(s)"). | ¶17 | col. 12:40-44 |
| in response to the reception of the global search request, prompting for a search term from a user; receiving the search term; | After opening the search bar, the system allegedly prompts for a search term. A screenshot depicts a search bar with the entered term "Q4 sales deck." | ¶19, p. 13 | col. 8:51-54 |
| based on the received search term, automatically determining one or more corresponding candidate elements associated with the second application and presenting the determined one or more corresponding candidate elements associated with the second application for selection by the user; | The complaint alleges that after a search term is entered, the system presents relevant results from both internal sources and integrated applications as a selectable preview. A screenshot labeled "Detailed search mode" shows results from a PDF file (first application) and a Slack message (second application), which are described as "candidate elements." | ¶20, pp. 13, 17 | col. 10:6-14 |
| receiving the selection of at least one of the candidate elements; | A user may allegedly select one of the presented candidate elements directly by clicking on it. A provided screenshot shows a user filtering the sources of the search results, an action that constitutes a form of selection. | ¶21, p. 20 | col. 11:21-24 |
| and linking information between the first application and the second application by performing steps comprising: responsive to receiving the selection of the candidate element, linking the selected candidate element with the first application such that a user may access the selected candidate element from the first application; generating for the first application a selectable link that, when selected, is operable to enable access to information related to the second application; | The complaint alleges that each returned candidate element has a selectable link that enables access to information from the source application (e.g., Sharepoint, Google Drive, Slack). A screenshot shows search results from Salesforce with selectable links like "1. Acme Account" that surface additional information. | ¶¶21, 23, p. 22 | col. 11:45-53 |
| receiving the selection of the linked selected candidate element through the first application; and responsive to the reception of the selection of the linked selected candidate element, presenting information related to the linked selected candidate element through the first application. | When a user selects a linked candidate element, the complaint alleges that information related to that element is revealed. A screenshot shows that after selecting a link, information from the source (e.g., Salesforce) is displayed within the Moveworks interface. | ¶24, p. 25 | col. 13:16-20 |
Identified Points of Contention
- Scope Questions: The case may turn on whether the accused architecture maps onto the patent's terminology. A central question is whether the Moveworks platform (a unified search interface) and its integrated backend services (like Slack or Workday) constitute a "first application" and a "second application" as understood in the patent. The defense could argue that Moveworks is a single, integrated service, not a combination of distinct applications in the manner described in the patent's examples of separate email and calendar programs on a device (’079 Patent, col. 1:25-28).
- Technical Questions: Another point of contention may be the interpretation of "linking information between" the applications. The complaint shows the accused product presenting hyperlinks to content residing in other systems (Compl. p. 22). The question is whether displaying a list of search results that are hyperlinks satisfies this limitation, or if the claim requires a deeper data integration, such as embedding a representation of the external data into an information field of the first application, as depicted in Figure 4 of the ’079 Patent.
V. Key Claim Terms for Construction
"first application" and "second application"
- Context and Importance: The entire infringement theory depends on mapping the Moveworks platform to the "first application" and its integrated data sources (e.g., Slack, ServiceNow) to the "second application." The construction of these terms will determine whether the accused product's architecture falls within the claim scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves do not restrict the applications to a specific type or architecture, referring generally to "applications on a computing device" (’079 Patent, col. 14:36-37). This could support an interpretation where one "application" is a user-facing interface and the other is a backend service it communicates with.
- Evidence for a Narrower Interpretation: The patent's background and detailed description consistently use examples of distinct, user-facing programs like an email application, a calendar application, and a contacts application, often as part of a "personal information manager (PIM) application" (’079 Patent, col. 1:25-28; col. 10:21-34). This context could support a narrower construction requiring two separate, stand-alone programs.
"linking information between the first application and the second application"
- Context and Importance: The nature of the "link" is critical. If it merely means providing a URL, the infringement case may be simpler for the plaintiff to prove. If it requires a more substantial data embedding or integration, the analysis becomes more complex.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language recites "generating for the first application a selectable link" that enables access to information related to the second application (’079 Patent, col. 14:59-62). This language could be read to cover a standard hyperlink presented in a search result list.
- Evidence for a Narrower Interpretation: Figure 4 and its corresponding description detail generating a link and presenting it within a specific "information field" (the "Notes" field) of the first application (’079 Patent, col. 12:45-50). This embodiment suggests a more integrated action than merely displaying a list of search results, potentially requiring the link to be embedded into a data structure of the first application.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement, stating that Defendant provides the Enterprise Search product to its customers with knowledge of infringement and provides marketing materials, videos, and user guides that instruct and encourage customers to use the product in the claimed infringing manner (Compl. ¶¶26-27).
- Willful Infringement: The complaint does not explicitly plead willful infringement. However, it alleges that Defendant has known of the infringement "since becoming aware of the ‘079 Patent" and "at least as of the date of the service of the original Complaint," which lays the groundwork for a potential claim of post-suit willfulness and enhanced damages (Compl. ¶¶27-28).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural mapping: Can the patent’s framework of a "first application" and a "second application," conceived in the context of discrete programs on a user device, be construed to cover a modern, cloud-native architecture where a central search platform ("first application") queries integrated, third-party enterprise systems ("second applications")?
- A second key question will be one of functional scope: Does the accused product’s functionality of presenting a list of selectable hyperlinks that redirect to source content meet the claim requirement of "linking information between" the applications, or does the patent's specification demand a deeper level of data integration where information from the second application is embedded within a data field of the first?