DCT
7:25-cv-00538
Ve Opening LLC v. Dropbox Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: VE Opening LLC (Texas)
- Defendant: Dropbox, Inc. (Nevada)
- Plaintiff’s Counsel: Direction IP Law
- Case Identification: 7:25-cv-00538, W.D. Tex., 11/19/2025
- Venue Allegations: Venue is based on Defendant having a regular and established place of business in the district, specifically an office in Austin, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s Dropbox Dash universal search product infringes a patent related to methods for enabling the sharing and linking of information between different software applications on a computing device.
- Technical Context: The technology addresses the challenge of integrating disparate software applications by providing a unified interface to search for and link information across them, aiming to reduce the inefficiency of switching between multiple programs to complete a task.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or specific 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 Issued |
| 2023-06-21 | Dropbox Dash Announced (Accused Instrumentality) |
| 2025-11-19 | 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, “Method and System for Enabling the Sharing of Information Between Applications on a Computing Device,” issued March 13, 2018 (’079 Patent).
The Invention Explained
- Problem Addressed: The patent’s background section describes the difficulty and confusion users face when needing to use several independent applications to perform a single task, noting that setting up information sharing between them can be tedious even for advanced users (’079 Patent, col. 1:36-43).
- The Patented Solution: The invention proposes a method where a user can initiate a "global search" from within a first application. This search queries not only the first application but also a second (and potentially other) application. The system then displays "candidate elements" (e.g., files, contacts, emails) from the second application within the first application's interface. A user can then select one of these elements to create a link, enabling access to information from the second application without having to manually switch between programs (’079 Patent, Abstract; col. 2:50-64).
- Technical Importance: The method aims to create a more integrated and efficient user experience by centralizing access to siloed information, a persistent challenge in software design as the number of specialized applications grows (’079 Patent, col. 1:43-46).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 4, 5, and 6 (’079 Patent, col. 14:36-15:24; Compl. ¶14).
- Independent Claim 1 recites a multi-step method comprising:
- From a first application, initiating a global search covering the first and a second application.
- Receiving a global search request through the first application.
- Prompting for and receiving a search term from a user.
- Automatically determining and presenting "candidate elements" from the second application for user selection.
- Receiving the user's selection of a candidate element.
- Linking information between the applications by: linking the selected element, generating a selectable link within the first application, receiving a user's selection of that link, and presenting information related to the element from the second application through the first application.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant’s Dropbox Dash product (Compl. ¶14).
Functionality and Market Context
- The complaint describes Dropbox Dash as an "AI-powered universal search" tool designed to solve the problem of work being spread across "hundreds of tabs and apps" (Compl. ¶15). It functions as a single search bar that connects to and searches across a user's content in Dropbox as well as other connected third-party applications like Google Drive, Notion, and Slack (Compl. ¶¶15, 18). A screenshot provided in the complaint shows a grid of "Top Apps" that can be integrated with Dash, including both productivity and communication tools (Compl. p. 8). The complaint alleges this functionality directly addresses the problem of finding information located in multiple, separate applications (Compl. ¶15).
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 | A user initiates a search in the Dropbox Dash interface (the first application) which is configured to search both Dropbox content and content in connected apps (the second application). | ¶1e | col. 14:37-40 |
| receiving a global search request through the first application... prompting for a search term from a user; | The complaint alleges that clicking in the Dash search bar constitutes receiving a global search request, which then prompts the user to enter search terms. A provided screenshot illustrates the search bar before a user types. | ¶16 | col. 14:37-40 |
| receiving a global search request through the first application... prompting for a search term from a user; | The complaint alleges that clicking in the Dash search bar constitutes receiving a global search request, which then prompts the user to enter search terms. A provided screenshot illustrates the search bar before a user types. | ¶1D | col. 14:41-44 |
| 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 | After a user enters a search term like "company objectives," Dash searches connected apps and returns relevant results, or "candidate elements," from both Dropbox and other applications like Notion. The complaint provides a screenshot showing results from both Dropbox Paper and Notion. | ¶19 | col. 14:48-54 |
| receiving the selection of at least one of the candidate elements | The user can select one of the displayed search results, such as a document from Notion. The complaint includes a screenshot showing two search results, one from Dropbox and one from Notion, and alleges a user can select them. | ¶19 | col. 14:-55-56 |
| responsive to receiving the selection... linking the selected candidate element with the first application such that a user may access the selected candidate element from the first application | The complaint alleges that when a user clicks on a search result, information from the second application (e.g., Notion) is linked and made accessible from the first application (Dash). A screenshot video allegedly shows this process. | ¶20 | col. 14:58-62 |
| 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 search result displayed in Dash functions as a selectable link that enables access to information from the underlying application. A screenshot shows search results from various apps presented as clickable items. | ¶21 | col. 14:63--66 |
| receiving the selection of the linked selected candidate element through the first application... presenting information related to the linked selected candidate element through the first application | When a user selects a search result, Dash allegedly presents information related to that element (e.g., file name, app source, author) within the Dash interface. The complaint offers a screenshot depicting search results from integrated apps after a search for "cobalt-circle." | ¶22 | col. 15:1-5 |
Identified Points of- Contention
- Scope Questions: The case may raise questions about whether the sequence of user interactions with a universal search bar constitutes the specific, in-order method steps recited in Claim 1. A central question may be whether displaying a standard hyperlink to a file in another application satisfies the multi-part "linking information" limitation, which requires distinct steps of "linking," "generating a selectable link," and "presenting information" in response to selecting that link.
- Technical Questions: A factual dispute may arise over the technical mechanism of Dropbox Dash. The court may need to determine if Dash merely performs a federated search and displays links, or if it performs a deeper "linking" of information between applications as the claim requires. The complaint asserts that information is displayed "through the first application," which could be a point of contention if Dash simply opens the content in the native second application. The screenshot on page 20, showing content from a Google Drive document summarized within a "Dash Chat" box, may be used to support the argument that information is presented through Dash.
V. Key Claim Terms for Construction
The Term: "global search"
- Context and Importance: This term defines the core action that initiates the patented method. The scope of what qualifies as a "global search" will be critical to determining if the accused product's functionality falls within the claims. Practitioners may focus on whether this term requires a specific type of search architecture or if it can broadly cover any user-initiated query across multiple data sources.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines the term as "a request for information across a number of applications stored on or accessible by a computing device," which does not impose specific technical limitations on how the search is performed (’079 Patent, col. 6:36-39).
- Evidence for a Narrower Interpretation: The patent's figures and description consistently depict the search being initiated from within a specific application environment (e.g., a Personal Information Manager), which could suggest the search is contextually rooted in that first application, rather than being a system-level desktop search (’079 Patent, Fig. 3; col. 10:19-24).
The Term: "linking information"
- Context and Importance: This is a complex limitation with several sub-steps. The definition of "linking" will determine whether simply presenting a search result that acts as a hyperlink infringes, or if a more integrated data connection is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the link enables "access to information related to the second application," a functional outcome that could be achieved by a hyperlink (’079 Patent, col. 14:65-66). The complaint's allegation that clicking a result shows a "short preview" could support this broader view (Compl. ¶19).
- Evidence for a Narrower Interpretation: The claim recites "linking the selected candidate element with the first application" as a separate step before "generating for the first application a selectable link." This structure suggests "linking" is a prerequisite action distinct from merely creating a clickable URL. A defendant may argue this requires a persistent data association between the applications, not just a transient display of search results.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant advertises Dropbox Dash and provides "marketing material and videos" that instruct customers on how to use the product in a manner that allegedly performs the claimed method (Compl. ¶27).
- Willful Infringement: The complaint alleges willfulness based on Defendant's knowledge of the ’079 Patent "at least as early as the filing and service of the Original Complaint" (Compl. ¶28). This frames the willfulness contention as being based on post-suit conduct.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of method versus functionality: does the user-driven operation of Dropbox Dash’s universal search feature, which is designed for flexible information retrieval, inherently perform the specific, ordered sequence of steps required by the patented method claim, or is there a fundamental mismatch between a product's general capability and a claimed procedural sequence?
- A key question of claim scope will be the interpretation of "linking information": does presenting a hyperlink to a document in a second application satisfy the claim's multi-part requirement to first "link" an element and then "generate a selectable link," or does the claim language necessitate a more technically integrated connection between the two applications?
- An evidentiary question will center on technical operation: what factual evidence will demonstrate how information from a second application is "presented... through the first application"? The outcome may depend on whether Dropbox Dash displays content within its own interface, as some screenshots suggest, versus simply launching the second application to display the content.