1:24-cv-01811
Gamehancement LLC v. Electronic Team Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Gamehancement LLC (Delaware)
- Defendant: Electronic Team, Inc. (Virginia)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 1:24-cv-01811, E.D. Va., 10/14/2024
- Venue Allegations: Venue is alleged to be proper in the Eastern District of Virginia because Defendant is a Virginia corporation with an established place of business in the district and has allegedly committed acts of infringement there.
- Core Dispute: Plaintiff alleges that certain unnamed software products of the Defendant infringe a patent related to a method for resizing and scaling user interface windows that display logically grouped data.
- Technical Context: The technology at issue addresses user interface design for visualizing complex systems, such as industrial control layouts, where information is organized into discrete groups and must remain legible when the viewing window is resized.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2000-09-29 | U.S. Patent No. 6,825,860 Priority Date |
| 2004-11-30 | U.S. Patent No. 6,825,860 Issue Date |
| 2024-10-14 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,825,860 - Autoscaling/autosizing user interface window
The Invention Explained
- Problem Addressed: The patent’s background section describes the challenge of viewing representations of complex systems, such as industrial equipment layouts, on a computer monitor. When a viewing window is resized, conventional scaling can render small details unreadable, while conventional zooming can cause the user to lose the overall context of how different logical groups of components relate to one another (ʼ860 Patent, col. 1:35-44).
- The Patented Solution: The invention proposes a method where resizing the display window has different effects depending on the direction of the resize. As described in the summary and detailed description, adjusting the window in a first dimension (e.g., vertically) rescales the graphical elements to maintain their aspect ratio, making them larger or smaller while preserving their shape. In contrast, adjusting the window in a second, orthogonal dimension (e.g., horizontally) changes the number of "logical groups" of elements shown, rather than rescaling them, allowing a user to see more or fewer groups side-by-side without loss of detail (ʼ860 Patent, col. 2:24-44).
- Technical Importance: This two-mode resizing technique was designed to improve the usability of software for viewing dense, grouped information, such as CAD drawings or diagrams of motor control centers, by allowing users to control both detail level and contextual scope independently (ʼ860 Patent, col. 1:45-58).
Key Claims at a Glance
- The complaint does not specify which claims it asserts, referring only to "Exemplary '860 Patent Claims" (Compl. ¶11). The first independent claim is Claim 1.
- The essential elements of independent Claim 1 include:
- displaying an image on a computer monitor in a display area, the image being displayed in logical groupings of elements;
- adjusting the first dimension only of the display area; and
- rescaling the image's third and fourth dimensions based upon the adjustment to the first dimension to maintain an aspect ratio between the third and fourth dimensions.
- The complaint alleges infringement of "one or more claims," reserving the right to assert other independent claims (e.g., 10, 19, 26) and their dependents (Compl. ¶11).
III. The Accused Instrumentality
Product Identification
The complaint does not identify any specific accused products by name, referring to them generally as the "Exemplary Defendant Products" (Compl. ¶11).
Functionality and Market Context
The complaint alleges that the accused products "practice the technology claimed by the '860 Patent" but provides no specific factual allegations about how they operate or their function (Compl. ¶13). It further makes no allegations regarding the products' commercial importance or market position.
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges direct infringement but does so by incorporating by reference an "Exhibit 2" that purportedly contains claim charts comparing the patent claims to the accused products (Compl. ¶13-14). As this exhibit was not filed with the complaint and the complaint itself contains no factual allegations describing the operation of the accused products, a detailed infringement analysis or claim chart summary is not possible based on the provided documents. The complaint's infringement theory rests entirely on the contents of the unsubmitted exhibit.
- Identified Points of Contention: Based on the technology and the language of the asserted patent, the dispute, once developed, may center on the following questions:
- Scope Questions: The complaint's lack of specificity raises the question of what constitutes a "logical grouping of elements" (Claim 1) within the accused products' user interfaces. The infringement analysis will depend on whether the data displayed by the accused products is organized into structures that meet this claim limitation.
- Technical Questions: A central technical question will be whether the accused products actually implement the two-mode resizing behavior required by the patent. Specifically, what evidence demonstrates that adjusting a window's first dimension causes a scaling of the image's components while adjusting a second, orthogonal dimension changes the number of "logical groupings" displayed, as distinct from a conventional proportional scaling in all directions?
V. Key Claim Terms for Construction
The Term: "logical groupings of elements" (Claim 1)
- Context and Importance: This term is foundational to the patent's novelty. The definition will be critical for determining whether the accused products, which are not described, fall within the scope of the claims. Practitioners may focus on this term because its interpretation will likely determine whether the patent applies narrowly to representations of physical layouts or broadly to any user interface that organizes data into visual clusters.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers generally to "components or features... associated into groups" and states the groups can be based on "any other logical association of the elements" beyond physical layout (ʼ860 Patent, col. 2:17-18, col. 2:33-34).
- Evidence for a Narrower Interpretation: The patent’s primary embodiment and figures describe a specific context: displaying vertical sections of an industrial motor control center, where the "logical groupings" are columns of physical components (ʼ860 Patent, Fig. 2; col. 4:10-12).
The Term: "rescaling... based upon the adjustment to the first dimension" (Claim 1)
- Context and Importance: This term defines the specific functional behavior of the invention. The infringement question will turn on whether the accused products' resizing algorithm performs this precise function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify the precise mathematical nature of the rescaling, only that it is based on the change in the first dimension and maintains an aspect ratio.
- Evidence for a Narrower Interpretation: The patent describes a specific two-part process: resizing in one direction scales the components, while resizing in the other changes the number of groups displayed (ʼ860 Patent, col. 2:24-39; Fig. 6a-6c). An accused product that uses a single, uniform scaling algorithm for both dimensions may not meet this limitation.
VI. Other Allegations
- Indirect Infringement: The complaint does not allege indirect or induced infringement; it alleges only direct infringement (Compl. ¶11-12).
- Willful Infringement: The complaint does not use the term "willful." However, the prayer for relief requests a judgment that the case be "declared exceptional within the meaning of 35 U.S.C. § 285," which is the statutory basis for awarding attorneys' fees (Compl., Prayer for Relief ¶E.i). The complaint provides no factual allegations, such as pre-suit knowledge of the patent, to support a claim for enhanced damages or exceptionality.
VII. Analyst’s Conclusion: Key Questions for the Case
Evidentiary Sufficiency: The primary threshold issue is evidentiary. Given that the complaint names no products and provides no factual description of infringement, a key question is what evidence Plaintiff will produce to substantiate its claims that Defendant’s products practice the specific two-mode resizing method taught by the ’860 patent.
Claim Scope and Construction: The case will likely turn on a question of definitional scope: can the term "logical groupings of elements," which is demonstrated in the patent with visualizations of physical industrial hardware, be construed to cover the way data is presented in the accused software? The breadth of this construction will be a central point of contention.
Operational Mismatch: A critical infringement question will be one of functional operation: does the accused software’s resizing feature perform the specific, two-part logical function required by Claim 1—where resizing in one axis scales content size and resizing in the other axis alters the quantity of content groups displayed—or is there a fundamental mismatch in its technical operation compared to the patented method?