DCT
7:25-cv-00539
Ve Opening LLC v. Salesforce Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: VE Opening LLC (Texas)
- Defendant: Salesforce, Inc. (Delaware)
- Plaintiff’s Counsel: Direction IP Law
- Case Identification: 7:25-cv-00539, W.D. Tex., 11/19/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Salesforce maintains a place of business in Austin, Texas, and has allegedly committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Slack Enterprise Search product infringes a patent related to methods for enabling the sharing of information between different applications on a computing device.
- Technical Context: The technology concerns federated search systems that allow a user within one software application to search for and link to information residing in other, separate applications, thereby breaking down information silos.
- 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 Issues |
| 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.
The Invention Explained
- Problem Addressed: The patent addresses the inefficiency and difficulty users face when a task requires information from multiple, independent software applications (e.g., a calendar and an email client) that do not cooperate or share data (Compl. ¶12; ’079 Patent, col. 1:21-35). Setting up information sharing between applications can be confusing for typical users and tedious for advanced users (’079 Patent, col. 1:39-43).
- The Patented Solution: The invention proposes a method where a user, from within a "first application," can initiate a "global search" that queries for information across a "second application" (and potentially others). The system then presents "candidate elements" (e.g., search results) from the second application and allows the user to select one, creating a link to that element within the first application. This allows the user to access information from the second application without manually navigating to it (’079 Patent, Abstract; col. 2:50-63).
- Technical Importance: This approach aimed to provide a more integrated and user-friendly way to perform tasks by unifying access to disparate data sources directly within the context of a primary application (’079 Patent, col. 1:43-46).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶14).
- The essential elements of independent claim 1 are:
- Receiving a global search request through a first application, where the request seeks information across the first 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 user selection.
- Receiving the user's selection of a candidate element.
- Linking information between the applications by:
- Linking the selected candidate element with the first application for user access.
- Generating a selectable link in the first application that enables access to information from the second application.
- Receiving selection of the link and presenting the related information through the first application.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- Slack’s Enterprise Search product (“Accused Instrumentality”) (Compl. ¶14).
Functionality and Market Context
- The complaint alleges that Slack Enterprise Search is an AI-powered feature within the Slack application that allows users to search for information across all connected tools and systems without leaving Slack (Compl. ¶15). It connects to various third-party applications (e.g., Asana, Salesforce, Google Drive) and indexes their content, allowing a user to initiate a single search from the Slack interface and receive results from both Slack messages ("first application") and the connected third-party tools ("second application") (Compl. ¶¶15, 18). A promotional screenshot describes the feature as a way to "Search everything. Find anything." from a single search bar (Compl. p. 6). The complaint alleges this functionality directly maps to the method claimed in the patent (Compl. ¶¶15-22).
IV. Analysis of Infringement Allegations
’079 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| 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 initiates a search from the Slack Enterprise Search bar, which is part of the Slack application (the "first application"). The search covers both Slack and connected third-party apps (the "second application") (Compl. p. 7). | ¶16 | 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 initiating a search, the user is prompted to enter a search term, such as "What's the status of the Hawksdale Group deal?", into the search bar (Compl. p. 8). | ¶17 | 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... candidate elements... for selection by the user | The system processes and indexes content from connected applications and, based on the search term, automatically determines and presents candidate elements from both the first (Slack) and second (e.g., Asana) applications. A screenshot shows results from Slack, Google Drive, and Salesforce (Compl. p. 11). | ¶18 | col. 10:1-4, 55-62 |
| receiving the selection of at least one of the candidate elements | A user may select one of the presented candidate elements, such as a Google document titled "Hawksdale Group Proposal" (Compl. p. 12). | ¶19 | col. 11:20-24 |
| linking the selected candidate element with the first application such that a user may access the selected candidate element from the first application | Responsive to the selection, the system links the element (e.g., a document from Google Drive) to the first application (Slack), allowing the user to access it from within the Slack interface. | ¶20 | col. 11:46-53 |
| generating for the first application a selectable link that, when selected, is operable to enable access to information related to the second application | The search results are presented as selectable links within Slack. When selected, these links provide access to information from the second application (e.g., Asana, Confluence Cloud) (Compl. p. 14). | ¶21 | col. 11:46-53 |
| presenting information related to the linked selected candidate element through the first application | The system displays information from the second application ("information from different sources") within a "single pane of glass" in the Slack user interface (Compl. p. 18). | ¶22 | col. 13:27-33 |
Identified Points of Contention
- Scope Questions: A central question may be the interpretation of "first application" and "second application." The patent's specification often describes two distinct applications, such as a PIM and an email client (’079 Patent, col. 9:20-30). The defense may argue that the Accused Instrumentality is a single, integrated feature within Slack, not a method connecting two separate, pre-existing applications in the manner contemplated by the patent.
- Technical Questions: The complaint alleges that presenting a hyperlink to a document in a second application constitutes "linking the selected candidate element with the first application" and "presenting information... through the first application." A point of contention could be whether displaying a link or a summary snippet meets the technical requirements of these claim limitations, or if a deeper form of data integration is required by the patent's disclosure.
V. Key Claim Terms for Construction
"global search request"
- Context and Importance: This term defines the trigger for the entire claimed method. Its construction will be critical to determining what user action constitutes the initiation of an infringing act. Practitioners may focus on whether simply typing into a unified search bar that queries multiple sources meets the definition, as opposed to a more explicit user action to launch a "global" search as distinct from a local one.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent defines it as a "request for information across a number of applications" (’079 Patent, col. 6:35-38), suggesting any search that queries more than one application could qualify.
- Evidence for a Narrower Interpretation: The specification provides examples like a specific "user gesture" such as a downward swipe to initiate the search (’079 Patent, col. 8:1-12), which could suggest the "request" is a discrete step separate from entering the search term itself.
"linking the selected candidate element with the first application"
- Context and Importance: This term is central to how the two applications are connected. The infringement allegation hinges on whether displaying a selectable search result (a hyperlink) in the Slack UI constitutes "linking" in the claimed sense.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes generating a "selectable link" that, when selected, enables access to information, which aligns with how a hyperlink functions (’079 Patent, col. 12:51-53).
- Evidence for a Narrower Interpretation: The patent also discusses integrating the link into an "information field of the first application," such as adding a linked contact into the "notes" field of a task manager application (’079 Patent, col. 12:45-50). This may suggest a more persistent data integration than merely displaying a temporary search result.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Salesforce provides marketing materials, videos, instructions, and user guides that encourage and instruct customers to use the Slack Enterprise Search feature in an infringing manner (Compl. ¶¶24, 25).
- Willful Infringement: The complaint does not contain allegations of pre-suit knowledge or willfulness. It alleges knowledge of the ’079 Patent and its infringement beginning "at least as of the filing and service of the Original Complaint" (Compl. ¶25).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural scope: does the claimed method, which describes receiving a search request "through a first application" to find data in a "second application," read on an integrated search feature that is part of the first application (Slack) and searches both itself and external sources? The case may turn on whether the accused product's unified search architecture is fundamentally different from the patent's model of connecting two distinct applications.
- A key question of claim construction will be the definition of "linking." The dispute will likely focus on whether presenting a hyperlink in a list of search results within the Slack UI satisfies the claim limitation of "linking the selected candidate element with the first application," or if the patent requires a more durable integration of data from the second application into a specific data field of the first.