Linfo IP LLC v. Hydrojug Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: HydroJug, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 1:25-cv-00107, D. Utah, 07/25/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Utah because Defendant has a regular and established place of business in the district, has committed alleged acts of infringement there, and resides in Utah.
• Core Dispute: Plaintiff alleges that Defendant’s system for discovering, extracting, and presenting information infringes a patent related to organizing and displaying unstructured data objects based on user-defined importance.
• Technical Context: The technology addresses the problem of information overload by enabling users to filter and sort digital content (such as files, contacts, or message feeds) based on assigned relevance scores, rather than relying on simple chronological or alphabetical sorting.
• Key Procedural History: The complaint notes that Plaintiff and its predecessors have entered into settlement licenses with other entities in prior litigation. Plaintiff asserts these confidential settlements did not involve admissions of infringement or licenses to produce a patented article, and therefore do not trigger patent marking requirements under 35 U.S.C. § 287. Plaintiff is identified as a non-practicing entity.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,430,131 - "System, Methods, And User Interface for Organizing Unstructured Data Objects", Issued August 30, 2016

The Invention Explained

• Problem Addressed: The patent describes the problem of "information overload" where users are faced with an overwhelming amount of data from sources like social network feeds, emails, search results, and large collections of personal files or contacts (’131 Patent, col. 1:18-42). Conventional methods for organizing this data, such as chronological or alphabetical sorting, are described as insufficient for efficiently finding relevant information (’131 Patent, col. 1:43-47).
• The Patented Solution: The invention proposes a system where electronic objects (e.g., files, contacts, messages) are assigned an "importance measure" to quantify their relevance to a user (’131 Patent, Abstract). This measure can be based on user input, content analysis, or metadata. The system then displays these objects in different formats or in separate, concurrently viewable areas based on their importance score, allowing a user to distinguish high-relevance items from low-relevance items (’131 Patent, col. 2:7-15; Fig. 3). For example, high-relevance items might be displayed in a larger area (410) or with a larger font size (510) than low-relevance items (420, 520) (’131 Patent, Figs. 4-5).
• Technical Importance: The claimed approach provides a more granular, user-driven method for managing large datasets by moving beyond binary filtering (e.g., relevant/irrelevant) to a system of weighted importance that influences the visual presentation of information (’131 Patent, col. 13:35-49).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 (Compl. ¶9). Independent claim 1 is a method claim.
• The essential elements of independent claim 1 include:
  • Obtaining a plurality of electronic objects, comprising currently existing files, folders, or contacts.
  • Displaying the electronic objects or their names/icons in a user interface.
  • Receiving an "importance value" associated with at least one object, where the value is entered by a user (e.g., as a direct numerical value or transformed from a text or UI selection).
  • Determining a position for the object in the user interface directly from the importance value.
  • Placing the object at that determined position.
• The complaint does not explicitly reserve the right to assert dependent claims, but the assertion of claims 1-20 covers them.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentality as Defendant's "system with methods and user interface for discovering information in a text content and extracting and presenting the information" (Compl. ¶9). It also references Defendant's website, "https://www.thehydrojug.com/", and associated "review platforms" (Compl. ¶12).

Functionality and Market Context

The complaint provides very little specific detail on the technical operation of the accused system. It alleges the system is used for "discovering information in a text content and extracting and presenting the information" (Compl. ¶9, ¶11). The functionality is broadly framed in the context of electronic commerce conducted through Defendant's website (Compl. ¶8, ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a "preliminary exemplary table attached as Exhibit B" to support its infringement allegations (Compl. ¶10). However, Exhibit B was not attached to the publicly filed complaint. Therefore, a detailed claim chart analysis is not possible based on the provided documents.

The complaint’s narrative theory of infringement alleges that Defendant "maintains, operates, and administers a system" that directly infringes one or more claims of the ’131 Patent (Compl. ¶9). This system is alleged to involve "discovering information in a text content and extracting and presenting the information" (Compl. ¶9). The allegations lack specific factual detail linking features of the accused HydroJug website or review platform to the discrete elements of the asserted claims.

Identified Points of Contention

• Scope Questions: A central dispute may arise over the definition of "electronic objects" in claim 1, which the claim explicitly limits to "currently existing files or file folders or directories in a computer file system, contacts in a contact list or address book" (’131 Patent, col. 18:33-36). The complaint accuses a system for presenting "information in a text content" on a review platform (Compl. ¶9, ¶12). This raises the question of whether a product review on an e-commerce website can be considered a "file," "folder," or "contact" as those terms are used in the claim.
• Technical Questions: The infringement allegation hinges on whether the accused HydroJug system performs the core functional steps of claim 1. Specifically, what evidence does the complaint provide that the system allows a user to enter an "importance value" for an object (such as a product review) and then determines a new display "position" for that object "directly from the importance value"? The complaint does not contain facts or screenshots demonstrating such functionality.

V. Key Claim Terms for Construction

• The Term: "importance value"
• Context and Importance: This term is the central mechanism of the asserted independent claim. Its construction will determine what type of user input qualifies as infringement. A broad construction may cover a wide range of user interface interactions, while a narrow one could significantly limit the scope of the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes multiple ways a user can indicate importance, including selecting buttons for "high normal low" relevance (Fig. 2B), using a slider (Fig. 2C), or entering text (’131 Patent, col. 8:15-41). This may support an argument that "importance value" encompasses any user action that assigns a relative weight, not just a typed number.
  • Evidence for a Narrower Interpretation: Claim 1 requires that the value be "entered by a user" and can be a "numerical value" that is either "directly entered" or "transformed from a text" or UI selection (’131 Patent, col. 18:40-45). This language, combined with specification examples that show explicit numerical scores (e.g., Fig. 9, value "5"), may support a narrower construction requiring a quantitative, user-specified score, as distinct from a system-generated relevance ranking.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant "actively encouraged or instructed" its customers on how to use its services in a way that causes infringement (Compl. ¶11). For contributory infringement, it alleges that the accused product is not a staple commercial product and that Defendant had reason to know its customers' use would be infringing (Compl. ¶12).
• Willful Infringement: Plaintiff alleges that Defendant has known of the ’131 patent "from at least the filing date of the lawsuit" and that its continued infringement is willful (Compl. ¶11-12). The prayer for relief also asks the court to declare the infringement willful if discovery reveals pre-suit knowledge (Compl. p. 7, ¶e).

VII. Analyst’s Conclusion: Key Questions for the Case

1. A core issue will be one of definitional scope: Can the term "electronic objects," which is narrowly defined in Claim 1 of the ’131 Patent to mean files, folders, and contacts, be construed to cover the "information in a text content" (e.g., product reviews) on Defendant's e-commerce website as alleged in the complaint?
2. A key evidentiary question will be one of factual support: Can Plaintiff produce evidence that Defendant's system possesses the core functionality required by the asserted claims—specifically, a mechanism for a user to enter a specific "importance value" that directly dictates the display position of an object—a factual allegation for which the complaint currently provides no specific support?
3. A third question relates to damages and marking: Given that Plaintiff is a non-practicing entity with a history of licensing, the parties may dispute whether Plaintiff's prior licensing activities trigger the marking requirements of 35 U.S.C. § 287, potentially limiting the period for which pre-suit damages could be recovered.