DCT
7:25-cv-00450
Ve Opening LLC v. Bloomfire Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: VE Opening LLC (Texas)
- Defendant: Bloomfire, Inc. (Delaware)
- Plaintiff’s Counsel: DIRECTION IP LAW
- Case Identification: 7:25-cv-00450, W.D. Tex., 10/06/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a place of business in Austin, Texas, and has committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s AI Enterprise Search platform infringes a patent related to enabling the sharing of information between different applications on a computing device.
- Technical Context: The technology concerns methods for unifying search and data access across disparate software applications, a key function in modern enterprise knowledge management systems.
- Key Procedural History: The complaint does not mention 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 Issue Date |
| 2025-10-06 | Complaint Filing Date |
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
The Invention Explained
- Problem Addressed: The patent’s background section describes the problem of users needing to utilize multiple, independent software applications (e.g., a calendar and an email client) to perform a single task, which can be a difficult, confusing, and tedious process of information sharing for a typical user ('079 Patent, col. 1:21-46; Compl. ¶12).
- The Patented Solution: The invention provides a method where a user initiates a "global search" from within a "first application." This search is configured to retrieve information from both the first application and a separate "second application." The system then presents "candidate elements" (e.g., contacts, files, calendar events) from the second application to the user, who can select an element to create a link to it within the first application. This allows information from one application to be accessed directly from the other, streamlining the user's workflow ('079 Patent, Abstract; col. 2:50-63).
- Technical Importance: This approach aimed to provide a more efficient and user-friendly method for performing tasks that span multiple software contexts by reducing the need for users to manually switch between applications ('079 Patent, col. 1:43-46).
Key Claims at a Glance
- The complaint asserts independent claim 1 ('079 Patent, col. 14:36-15:2).
- The essential elements of Claim 1 include:
- From a first application, initiating a global search covering the first application and a second application by receiving a global search request.
- In response, prompting for and receiving a search term from a user.
- Based on the search term, automatically determining and presenting one or more "candidate elements" associated with the second application for the user's selection.
- Receiving the user's selection of at least one candidate element.
- Linking information between the first and second applications, which comprises linking the selected candidate element with the first application, generating a selectable link for the first application, and, upon selection of that link, presenting information related to the linked element through the first application.
III. The Accused Instrumentality
Product Identification
- Defendant’s AI Enterprise Search product (the “Accused Instrumentality”) (Compl. ¶14).
Functionality and Market Context
- The complaint describes the Accused Instrumentality as a knowledge management platform that enables unified searching across a company's internal data sources and external, third-party applications (Compl. ¶15). It allegedly integrates with "knowledge connectors" like Bloomfire databases and SharePoint, as well as "App Integration" sources such as Slack, Google Drive, and Microsoft Teams (Compl. ¶15). A screenshot of Defendant’s marketing material highlights available integrations. (Compl. p. 8). The complaint alleges the product’s goal is to minimize "context switching across applications" by providing a "unified search experience" (Compl. ¶15).
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 by performing steps comprising: receiving a global search request through the first application... | The complaint alleges a user initiates a search from within the Bloomfire platform (the "first application") that covers both internal Bloomfire data and integrated third-party sources like Microsoft Teams (the "second application"). A screenshot shows a user initiating a search via an "Ask AI" button. | ¶16-17 | col. 14:37-44 |
| in response to the reception of the global search request, prompting for a search term from a user; receiving the search term; | After the search is initiated, the system allegedly prompts the user for a search term via a search bar or a dialog box. A screenshot provided in the complaint depicts this prompt. | ¶17 | col. 14:45-48 |
| 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...for selection by the user; | The system allegedly returns search results ("candidate elements") from integrated sources. A screenshot shows search results sourced from both SharePoint ("first application") and MS Teams ("second application"). | ¶18 | col. 14:49-54 |
| receiving the selection of at least one of the candidate elements; and | The user selects one of the presented candidate elements from the search results list (Compl. ¶19). | ¶19 | col. 14:55-56 |
| linking information between the first application and the second application...such that a user may access the selected candidate element from the first application; | The complaint alleges that upon selection, information from the candidate element (e.g., a document from SharePoint) is linked and presented to the user within the Bloomfire interface. A screenshot shows information from a selected document displayed within the accused product. | ¶20, 22 | col. 14:57-62 |
Identified Points of Contention
- Scope Questions: A potential dispute may arise over whether the accused architecture maps onto the claimed "first application" and "second application" structure. A question for the court could be whether a centralized, cloud-based search platform that uses APIs to query various data sources constitutes initiating a search from a first application covering a distinct second application, as opposed to being a single, unified search application.
- Technical Questions: The complaint's evidence for the "linking" limitation raises a technical question. Does displaying content from an external source within the Bloomfire UI meet the claim requirement of "linking the selected candidate element with the first application such that a user may access the selected candidate element from the first application"? The analysis may focus on whether this action is functionally equivalent to the patent's description of generating a "selectable link" and embedding it within an information field of the first application ('079 Patent, col. 12:45-53).
V. Key Claim Terms for Construction
The Term: "first application" and "second application"
- Context and Importance: The entire infringement theory rests on mapping the Bloomfire platform to the "first application" and its integrated data sources (e.g., Microsoft Teams, Slack) to the "second application." The construction of these terms will determine if the accused product's architecture falls within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides examples of these as common, distinct programs like a calendar application and an email application that "operate independently of each other" but can be made to cooperate ('079 Patent, col. 1:25-35). This language may support a construction where any two functionally distinct software services qualify, regardless of their integration architecture.
- Evidence for a Narrower Interpretation: The patent’s figures and detailed descriptions often depict these applications as residing on a single user device, such as a smartphone ('079 Patent, Fig. 3-4). The specification also refers to them as part of a "personal information manager (PIM) application" ('079 Patent, col. 9:35-38), which could suggest a more limited, client-side context than the accused enterprise cloud service.
The Term: "linking the selected candidate element with the first application"
- Context and Importance: This term defines the required functional relationship between a search result from the second application and the first application where the search originated. Its construction will be critical to determining if simply displaying external content within the accused product's UI meets the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent claims the step of "generating for the first application a selectable link that, when selected, is operable to enable access to information related to the second application" ('079 Patent, col. 14:63-15:2). This could be interpreted broadly to encompass any user-selectable element in the first application's UI that brings up data from the second.
- Evidence for a Narrower Interpretation: An embodiment described in the specification shows the generated link being presented within a specific "information field" of the first application, such as embedding a link to an email within the "notes" field of a task-management application ('079 Patent, col. 12:45-53). This may support an argument that the "linking" requires a more persistent integration into the data structure of the first application, not just a transient display in a search results view.
VI. Other Allegations
Indirect Infringement
- The complaint alleges both induced and contributory infringement (Compl. ¶¶24-26). The inducement allegation is based on Defendant allegedly providing the Accused Instrumentality to customers and advertising its infringing functionality through marketing materials and videos (Compl. ¶25). The contributory infringement allegation asserts that the Accused Instrumentality is a material part of the invention and not a staple article of commerce suitable for substantially non-infringing use (Compl. ¶26).
Willful Infringement
- The complaint does not use the term "willful." It alleges knowledge of infringement "at least as of the date of the service of the original Complaint," which frames the dispute around potential post-suit, rather than pre-suit, knowledge and intent (Compl. ¶24).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of architectural scope: whether the patent's model of a "first application" searching a separate "second application," often depicted in the context of a personal computing device, can be construed to cover the accused cloud-based, unified search platform that aggregates data from multiple, API-connected enterprise sources.
- A key question of functional interpretation will be whether displaying search results from an external data source within the accused product's interface constitutes "linking the selected candidate element with the first application" in the specific manner required by the patent, which describes generating and embedding a selectable link into an information field of the first application.