DCT
7:25-cv-00362
Ve Opening LLC v. Sprinklr Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: VE Opening LLC (Texas)
- Defendant: Sprinklr, Inc. (Delaware)
- Plaintiff’s Counsel: Direction IP Law
- Case Identification: 7:25-cv-00362, W.D. Tex., 08/22/2025
- Venue Allegations: Venue is based on Defendant’s alleged regular and established place of business within the Western District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s Universal Search feature, part of its Unified-CXM platform, infringes a patent related to methods for searching and linking information between distinct software applications on a computing device.
- Technical Context: The technology addresses the challenge of integrating data from multiple, often siloed, software applications, aiming to provide a unified search and access experience for the user.
- 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 |
| 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. 9,916,079, issued March 13, 2018.
The Invention Explained
- Problem Addressed: The patent describes a problem arising from the proliferation of software applications on computing devices, where each application typically operates independently. Performing a task that requires information from multiple applications (e.g., scheduling an event discussed in an email) can be "difficult and confusing for a typical user and may be tedious even for an advanced user." (’971 Patent, col. 1:39-43).
- The Patented Solution: The invention proposes a method to streamline this process by enabling a "global search" initiated from a "first application" that can retrieve information from a "second application." The system presents search results, or "candidate elements," from the second application to the user within the first application's interface. Upon user selection, the system creates a selectable link to the chosen information and presents it within the first application, allowing the user to access data from the second application without manually switching between them. (’971 Patent, Abstract; col. 12:45-53).
- Technical Importance: This approach seeks to improve user efficiency by creating a unified information access layer over otherwise disparate applications. (Compl. ¶13; ’971 Patent, col. 1:43-46).
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 the first and a second application.
- Receiving a search term from a user.
- Based on the term, automatically determining and presenting "candidate elements" associated with the second application for user selection.
- Receiving the user's selection of a candidate element.
- Linking the selected candidate element with the first application by generating a selectable link within the first application.
- Upon selection of the link, presenting information related to the linked element through the first application.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- Sprinklr's Universal Search, a feature of its Unified-CXM platform. (Compl. ¶14).
Functionality and Market Context
- The complaint alleges that Universal Search provides a "single pane of glass" for searching all data that has been "unified, ingested, or processed by the Sprinklr Unified-CXM platform from its wide array of integrations and channels." (Compl. ¶15). This functionality allows users to search for various "entities" managed within the Sprinklr platform as well as content from integrated third-party applications. (Compl. ¶15). A screenshot provided in the complaint from a Sprinklr help article describes Universal Search as a tool to "quickly find and access all the entities of Sprinklr like Assets, Campaigns, Dashboards, Cases, Macros, Rules and Tasks." (Compl. p. 5).
IV. Analysis of Infringement Allegations
U.S. Patent No. 9,916,079 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... | A user initiates a Universal Search from within the Sprinklr platform (the "first application") by clicking an icon or using a keyboard shortcut. | ¶16 | col. 14:37-43 |
| receiving a global search request... prompting for a search term from a user; receiving the search term; | Upon initiation, the Universal Search feature prompts the user for a search request and receives a search term. A screenshot depicts the search input field presented to the user. (Compl. p. 8). | ¶17 | col. 14:44-50 |
| based on the received search term, automatically determining one or more corresponding candidate elements associated with the second application and presenting [them]... for selection... | When a user inputs a search term, Universal Search searches across both Sprinklr's internal data and integrated third-party sources (the "second application(s)"), such as Twitter/X or news feeds, and displays corresponding "candidate elements." A provided visual shows search results from various external sources. (Compl. p. 10). | ¶18 | col. 14:51-57 |
| receiving the selection of at least one of the candidate elements; | The user can select one of the presented candidate elements by clicking on it. The complaint provides an image showing that candidate elements from an outbound message search can be individually selected by clicking on them. (Compl. p. 14). | ¶19 | col. 14:58-59 |
| linking the selected candidate element with the first application such that a user may access the selected candidate element from the first application; | Upon selection, the chosen element is linked with the Sprinklr platform, allowing the user to access it from within that first application. | ¶20 | col. 14:60-63 |
| presenting information related to the linked selected candidate element through the first application. | After a user selects a linked element, information related to that element (e.g., a message from a third-party application) is displayed within a "Third Pane" inside the Universal Search interface (the "first application"). A screenshot illustrates this "Third Pane" displaying information within the Sprinklr UI. (Compl. p. 16). | ¶22 | col. 14:65-col. 15:2 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the Sprinklr Unified-CXM platform and its integrated data sources (e.g., internal modules, external social media feeds) meet the claim definitions of a "first application" and a "second application." The defense may contend that Universal Search operates within a single, integrated platform, not between the distinct, standalone applications described in the patent's examples (e.g., separate email and calendar programs).
- Technical Questions: The analysis may focus on the nature of the "linking" performed by the accused system. A question for the court will be whether displaying selectable search results and their corresponding details within a unified interface constitutes the specific method of "generating for the first application a selectable link" that is then presented within that application, as required by the claim.
V. Key Claim Terms for Construction
The Term: "first application" and "second application"
Context and Importance: The entire infringement theory rests on establishing that Sprinklr's platform functions as the "first application" initiating a search across one or more distinct "second applications." The construction of these terms will determine whether the patent's scope can extend from the context of separate consumer device applications to an integrated enterprise software platform.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines an "application" broadly as a "program or programs that perform one or more particular tasks on a computing device." (’971 Patent, col. 4:51-53). Plaintiff may argue this general definition encompasses software modules or integrated data sources within a larger platform.
- Evidence for a Narrower Interpretation: The patent's background consistently uses examples of discrete, standalone applications like a "calendar application" and an "email application" that "operate independently of each other." (’971 Patent, col. 1:25-33). The figures likewise depict separate icons for Email, Calendar, and Contacts, suggesting the invention was contemplated for bridging functionally distinct programs. (’971 Patent, Fig. 3).
The Term: "linking the selected candidate element with the first application"
Context and Importance: The definition of "linking" is critical to determining whether the accused functionality—displaying search results from one data source within the interface of another—infringes. The dispute may turn on whether this requires creating a persistent, embedded object or if a more transient display of information suffices.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language requires "generating for the first application a selectable link" that enables access to information. (’971 Patent, col. 14:63-65). This could be interpreted to cover any selectable UI element that, when clicked, presents information from the external source.
- Evidence for a Narrower Interpretation: An embodiment in the specification shows a specific implementation where a link to an email is generated and embedded within the "notes" information field of a separate task-management application. (’971 Patent, Fig. 4; col. 12:45-53). This could support a narrower construction requiring the creation and storage of a data object (the link) within the data structure of the first application.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, asserting that Sprinklr provides marketing materials, videos, and user guides that instruct and encourage customers to use the Universal Search feature in an infringing manner. (Compl. ¶¶24-25). Contributory infringement is also alleged. (Compl. ¶26).
- Willful Infringement: The complaint does not use the term "willful," but it alleges that Defendant had knowledge of its infringement at least as of the date of service of the complaint and continued to infringe thereafter. (Compl. ¶¶25-26). This pleading structure may form the basis for a claim of post-filing willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the patent's framework of a "first application" and a "second application," exemplified by distinct consumer programs like email and calendar, be construed to cover the functionally integrated modules and third-party data sources within Sprinklr's unified enterprise platform?
- A key technical question will be one of operational mechanics: does the accused Universal Search's method of displaying selectable search results and presenting related information within its own interface constitute the specific, multi-step process of "linking" claimed by the patent, which is described as generating and embedding a selectable link from one application into an information field of another?