DCT
7:25-cv-00539
Ve Opening LLC v. Salesforce Inc
Key Events
Amended Complaint
Table of Contents
amended 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., 02/05/2026
- Venue Allegations: Venue is alleged to be proper based on Defendant maintaining a place of business in Austin, Texas, within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Slack Enterprise Search product infringes a patent related to methods for searching and sharing information between different software applications on a computing device.
- Technical Context: The dispute is situated in the enterprise software and collaboration market, where tools that aggregate information from multiple, often siloed, applications are of significant commercial importance.
- Key Procedural History: The operative complaint is a First Amended Complaint. The complaint does not reference any prior litigation, licensing history, or administrative proceedings involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2014-06-05 | ’079 Patent Priority Date |
| 2018-03-13 | ’079 Patent Issue Date |
| 2026-02-05 | 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
- 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 technical problem of software applications operating independently, making it "difficult and confusing for a typical user" to perform tasks that require information from multiple applications Compl. ¶14 ’079 Patent, col. 1:39-46 This creates inefficiency and a poor user experience, particularly as the number of applications grows Compl. ¶14 ’079 Patent, col. 1:39-43
- The Patented Solution: The invention provides a method where a user, from within a "first application," can initiate a "global search" that covers a separate "second application" Compl. ¶14 ’079 Patent, abstract The system automatically identifies and presents relevant items ("candidate elements") from the second application. The user can then select one of these elements to generate a selectable link within the first application, allowing the user to access information from the second application directly through the interface of the first Compl. ¶14 ’079 Patent, col. 2:50-64
- Technical Importance: This approach addresses the problem of application siloing by creating a centralized search and access portal within a primary application, aiming to improve user efficiency and streamline workflows Compl. ¶14 ’079 Patent, col. 1:43-46
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 4, 5, and 6 Compl. ¶21
- Independent Claim 1 recites a multi-step method, the essential elements of which include:
- From a first application, initiating a global search covering the first and a second application.
- Receiving a search term from a user.
- Automatically determining and presenting corresponding "candidate elements" from the second application for user selection.
- Receiving the user's selection of a candidate element.
- Linking the selected candidate element with the first application.
- Generating a "selectable link" for the first application that is operable to enable access to information from the second application.
- Receiving a selection of the link and, in response, presenting the information from the second application through the first application.
- The complaint reserves the right to assert additional claims Compl. ¶21
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Salesforce's "Slack's Enterprise Search" product Compl. ¶22
Functionality and Market Context
- The complaint alleges that Slack Enterprise Search is an "AI-powered feature within Slack that allows users to search for information across all connected tools and systems, without leaving Slack" Compl. ¶22
- The system is described as connecting to and searching across various third-party applications (e.g., Asana, Salesforce, Google Drive) from within the primary Slack application interface Compl. ¶22 The complaint includes a screenshot from a Slack marketing page showing a user initiating a search for a "Hawksdale Group deal," which returns results from Slack, Google Drive, and Salesforce in a single interface Compl. ¶11
- The product is positioned as a solution to "break down information silos and streamline productivity" by creating a "single pane of glass" to find information from different sources Compl. ¶21
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 global search from within the Slack application using the Enterprise Search bar, which covers both Slack ("first application") and connected apps like Asana ("second application"). | ¶23 | col. 2:50-54 |
| in response to the reception of the global search request, prompting for a search term from a user; receiving the search term; | In response to initiating a search, the user is prompted to enter a search term, such as "What's the status of the Hawksdale Group deal?". | ¶24 | col. 2:54-56 |
| 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... | Slack Enterprise Search allegedly indexes content from connected second applications and, based on the search term, automatically determines and presents candidate elements from those applications. A screenshot from a product demonstration video depicts various search results, including a "Google document" and a "Slack AI result," which are presented as selectable candidate elements Compl. ¶14 | ¶25 | col. 2:56-61 |
| receiving the selection of at least one of the candidate elements; | The user can select one of the presented candidate elements, such as the "Hawksdale Group Proposal" from Google Drive. | ¶26 | col. 2:61-62 |
| 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; | The complaint alleges that upon selection, the candidate element is linked with the first application (Slack), enabling user access to that element from within Slack. | ¶27 | col. 12:49-58 |
| generating for the first application a selectable link that, when selected, is operable to enable access to information related to the second application; | The system generates selectable links within the search results that enable access to information from the second application. The complaint provides a screenshot showing linked search results, such as "Hawksdale Executive Briefing," presented within the Slack interface Compl. ¶22 | ¶28 | col. 14:5-9 |
| 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. | Upon selecting a linked result, information from the second application is presented through the first application (Slack), creating a "single pane of glass" experience. | ¶29 | col. 14:62-67 |
Identified Points of Contention
- Scope Questions: A central question may be whether an integrated collaboration platform like Slack, which is designed to incorporate other applications via APIs, constitutes a "first application" that is meaningfully distinct from the "second applications" it searches. A defense could argue the accused product creates a single, unified environment rather than linking two separate applications as contemplated by the patent.
- Technical Questions: The complaint relies on marketing materials to describe the accused functionality. A key factual dispute may concern the underlying technical mechanism. For example, does Slack Enterprise Search merely display hyperlinks to external content, or does it perform the claimed steps of "linking the selected candidate element with the first application" and "presenting information... through the first application" in a manner that aligns with the patent's teachings?
V. Key Claim Terms for Construction
The Term: "global search request"
- Context and Importance: This term defines the trigger for the entire claimed method. Its construction will determine what user actions constitute the first step of infringement. Practitioners may focus on this term because the complaint alleges a user typing into a search bar initiates the request, and the scope could be broader or narrower than that specific action.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the request can be initiated by various user inputs, including "detecting a swiping in a first predetermined direction or first predetermined swiping pattern on a touch screen" ’079 Patent, col. 2:20-24
- Evidence for a Narrower Interpretation: The primary embodiment shown in Figure 3 depicts the search being initiated via a distinct search dialog box (element 310), which could suggest a more formal and deliberate user action is required than any general query within an application.
The Term: "candidate elements"
- Context and Importance: This term defines the output of the search step. Its meaning is critical to determining whether the results presented by Slack Enterprise Search meet the claim limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a broad definition, stating an "element" is "data that can be stored on or accessed by components of a computing device" ’079 Patent, col. 6:28-30 This could encompass simple file names or links.
- Evidence for a Narrower Interpretation: The patent's examples and figures consistently show candidate elements being organized into "one or more categories based on an association between the corresponding candidate elements... and the type of element or an application" (e.g., Contacts, Email, Calendar) ’079 Patent, col. 10:40-45 ’079 Patent, Fig. 3 This may support an argument that "candidate elements" are structured data objects, not merely a list of undifferentiated keyword matches.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Salesforce provides "marketing material and videos" and user guides that instruct and encourage customers to use the Accused Instrumentality in a manner that performs the claimed method Compl. ¶¶34-35
- Willful Infringement: The basis for willfulness is alleged post-suit knowledge. The complaint asserts that Salesforce became aware of the ’079 Patent and its infringement "at least as early as the filing and service of the Original Complaint" and continued its allegedly infringing conduct despite this knowledge Compl. ¶35
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 distinct "first application" and "second application" be construed to cover a modern, highly integrated platform like Slack and its connected services, or does the accused product function as a single, unified system that falls outside the patent's claimed architecture?
- A key evidentiary question will be one of technical implementation: what evidence will emerge in discovery to show how Slack Enterprise Search technically operates? The case will likely turn on whether its function of presenting search results from connected apps constitutes the specific, multi-step process of "linking" and "presenting information... through the first application" as required by the claim language.
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