2:25-cv-00714
Linfo IP LLC v. Luxy Hair Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Linfo IP, LLC (Texas)
- Defendant: Luxy Hair, Inc. (Canada)
- Plaintiff’s Counsel: Ramey LLP
- Case Identification: 2:25-cv-00714, D. Utah, 08/25/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district, has committed acts of infringement in the district, and conducts substantial business in the forum.
- Core Dispute: Plaintiff alleges that Defendant’s website and associated systems, which present information to users, infringe a patent related to organizing unstructured data objects based on user-defined relevance.
- Technical Context: The technology addresses the problem of information overload by providing systems and user interfaces for sorting and displaying electronic data (such as files, contacts, or message feeds) based on assigned importance values rather than purely chronological or alphabetical order.
- Key Procedural History: The complaint notes that Plaintiff and its predecessors-in-interest have entered into prior "settlement licenses" with other entities, but asserts these licenses were not for producing a patented article and thus do not trigger marking requirements under 35 U.S.C. § 287(a).
Case Timeline
| Date | Event |
|---|---|
| 2013-03-25 | ’131 Patent Priority Date |
| 2016-08-30 | ’131 Patent Issue Date |
| 2025-08-25 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 9,430,131, “System, Methods, And User Interface for Organizing Unstructured Data Objects,” issued August 30, 2016 (’131 Patent).
The Invention Explained
- Problem Addressed: In an era of increasing information, users face "information overload" from sources like social networks, email, and search engine results, making it difficult to discern valuable information from irrelevant data ( Compl. ¶71; ’131 Patent, col. 1:19-38). Conventional methods for organizing data, such as alphabetical or chronological sorting, are often insufficient for managing large collections of electronic objects like files, folders, or contacts (’131 Patent, col. 1:40-47).
- The Patented Solution: The invention provides a system for organizing unstructured collections of "electronic objects" by assigning "importance measures" to them based on various attributes (’131 Patent, Abstract). As depicted in Figure 1, the system can identify a user's topic of relevance, analyze content in data feeds, calculate a relevance score, and then display objects differently based on that score, for instance by separating them into high and low relevance groups (’131 Patent, Fig. 1; col. 4:1-10). This allows users to more effectively locate and retrieve needed items from a large number of candidates (’131 Patent, col. 2:6-9).
- Technical Importance: The technology provides a method to move beyond simple filtering or chronological feeds by enabling a more granular, user-influenced system for prioritizing and displaying information based on calculated relevance (’131 Patent, col. 1:48-52).
Key Claims at a Glance
- The complaint asserts infringement of one or more of claims 1-20 (Compl. ¶72).
- Independent Claim 1 recites a method with the essential elements of:
- Obtaining a plurality of electronic objects (e.g., files, folders, contacts).
- Displaying the electronic objects in a user interface.
- Receiving an "importance value" associated with at least one object, where the value is entered by a user.
- Determining a position to place the object in the user interface directly from the importance value.
- Placing the object at that determined position.
- Independent Claim 9 recites a method with the essential elements of:
- Obtaining an electronic object.
- Identifying an attribute or attribute value associated with the object (e.g., metadata like access frequency, or a specific word in the content).
- Displaying a name or description of the attribute in a user interface.
- Providing an option in the user interface for the object to be associated with an importance value based on the attribute.
- Receiving the importance value specified by a user.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is a "system with methods and user interface" that Defendant "maintains, operates, and administers" for "discovering information in a text content and extracting and presenting the information" (Compl. ¶72). The complaint specifically identifies Defendant's website, https://www.luxyhair.com/, and associated "review platforms" (Compl. ¶75).
Functionality and Market Context
The complaint does not describe the specific functionality of the accused website in detail. It alleges broadly that the Defendant's products and services involve processes for presenting information (Compl. ¶72, ¶74). The Defendant is alleged to sell products and services throughout the United States via its website (Compl. ¶65).
IV. Analysis of Infringement Allegations
The complaint references a "preliminary exemplary table attached as Exhibit B" to support its infringement allegations, but this exhibit was not included with the filed complaint (Compl. ¶73). The complaint’s narrative theory alleges that Defendant’s systems and user interfaces, such as its website and review platforms, perform infringing methods related to discovering, extracting, and presenting information (Compl. ¶72, ¶75). No probative visual evidence provided in complaint.
The complaint does not provide a detailed mapping of specific features of the accused instrumentality to the limitations of the asserted claims.
Identified Points of Contention
- Scope Questions: The infringement analysis may raise the question of whether standard e-commerce website functionalities (e.g., "sort by relevance," product filtering, or user review ratings) meet the specific claim limitation of receiving a user-entered "importance value" for the purpose of determining the display "position" of an "electronic object."
- Technical Questions: A central factual question is what evidence the complaint provides that Defendant's website performs the specific steps of Claim 1 or Claim 9. For instance, what feature of the accused system allows a user to enter an "importance value" that is then used to directly determine and place an object in a specific position in the user interface? The complaint does not specify the mechanism by which this allegedly occurs.
V. Key Claim Terms for Construction
- The Term: "importance value" (appears in independent claims 1 and 9)
- Context and Importance: This term is the central mechanism of the asserted claims. The outcome of the case may depend on whether functionality on the Defendant's e-commerce website can be construed as receiving a user-specified "importance value." Practitioners may focus on this term because its definition will determine whether the patent reads on common web features or is limited to more explicit, granular user-input systems.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: Claim 1 describes the value as "an element selected from the group consisting at least of a numerical value directly entered by a user, a numerical value transformed from a text specified by a user, a numerical value transformed from a selection of a user interface object indicated by a user" (’131 Patent, col. 18:18-26). This language could support an argument that actions other than direct numerical entry, such as clicking a button or selecting from a menu, can generate an "importance value."
- Evidence for a Narrower Interpretation: The patent’s figures repeatedly illustrate the "importance value" as an explicit, often numerical, score that a user consciously assigns to an item to signify its relevance. For example, Figure 2A shows numerical importance scores (e.g., 0.95, 0.8), and Figure 9 shows contacts sorted by a discrete "importance value" from 2 to 5 (’131 Patent, Fig. 2A, Fig. 9). This may support a narrower construction requiring a more deliberate and granular user input than a generic "sort by" or "like" function.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is alleged based on Defendant actively encouraging or instructing customers on how to use its services to discover and present information (Compl. ¶74). Contributory infringement is alleged based on instructions for using "review platforms" and "product instruction manuals," with the assertion that the accused service is not a staple commercial product and has no substantial non-infringing use (Compl. ¶75).
- Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’131 Patent from "at least the filing date of the lawsuit" (Compl. ¶74, ¶75). The complaint reserves the right to amend if pre-suit knowledge is discovered (Compl. ¶74, n.2).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "importance value," which the patent illustrates as a specific, user-assigned relevance score, be construed broadly enough to cover the functions of a conventional e-commerce website, such as sorting products or displaying customer reviews?
- A key evidentiary question will be one of technical mapping: what specific feature of the Defendant’s website allows a user to enter or generate an "importance value," and does that value directly determine the display "position" of an electronic object as required by the claims? The plaintiff will need to provide technical evidence beyond the high-level allegations in the complaint to connect the accused system’s actual operation to the patent’s specific requirements.