HyperQuery LLC v. Appian Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HyperQuery LLC (Delaware)
  • Defendant: Appian Corporation (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-01884, E.D. Va., 10/28/2025
• Venue Allegations: Venue is based on Defendant maintaining an established place of business in the Eastern District of Virginia.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for searching and downloading mobile applications based on user search intent.
• Technical Context: The technology addresses the challenge of application discovery in crowded digital marketplaces by attempting to infer a user's underlying intent rather than relying solely on keyword matching.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

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

U.S. Patent No. 9,529,918 - "System and methods thereof for downloading applications via a communication network"

• Patent Identification: U.S. Patent No. 9,529,918, issued December 27, 2016.

The Invention Explained

• Problem Addressed: The patent’s background section describes conventional application search processes as "very time consuming," requiring users to navigate through extensive lists of applications. It notes that results are often promoted by the repository owner and may not meet the user's exact needs or intent (’918 Patent, col. 2:4-11).
• The Patented Solution: The invention proposes a method where a server receives a search query, determines the user’s underlying "search intent," and then selects a relevant application from a repository based on that intent. An icon for the selected application is then displayed in a "display segment" on the user's device, and a user interaction with the icon initiates a direct download of the application (’918 Patent, Abstract; col. 2:21-33). The overall process is illustrated in the flowchart of Figure 2 (’918 Patent, Fig. 2).
• Technical Importance: The described solution sought to improve the relevance of application search results and streamline the discovery-to-download process for mobile device users (’918 Patent, col. 2:12-16).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specification, instead referring to "Exemplary '918 Patent Claims" in a non-proffered exhibit (Compl. ¶11, ¶16). Independent claim 1 is representative of the patented method.
• Essential Elements of Independent Claim 1:
  • Receiving an input search query from a user device.
  • Determining the search intent based on the input search query.
  • Selecting, based on the search intent, at least one application from a central repository.
  • Causing an icon for the selected application to be displayed on the user's device.
  • Receiving an input from the user device indicating a particular one of the selected applications.
  • Causing the establishment of a direct communication link to a location hosting the application.
  • Causing the initiation of a download of the application to the user device.
• The complaint’s general allegation of infringing "one or more claims" suggests Plaintiff reserves the right to assert additional claims, including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" (Compl. ¶11, ¶16).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' functionality. It makes the conclusory allegation that the products "practice the technology claimed by the '918 Patent" and incorporates by reference the allegations in "the claim charts of Exhibit 2," which was not filed with the complaint (Compl. ¶16, ¶17).

IV. Analysis of Infringement Allegations

The complaint provides no narrative infringement theory or specific factual allegations mapping accused product features to the elements of any asserted claim. Instead, it states that infringement is demonstrated in claim charts attached as Exhibit 2, which was not provided with the publicly filed complaint (Compl. ¶16, ¶17). As such, a claim chart summary cannot be constructed from the provided documents.

• Identified Points of Contention: Lacking specific infringement allegations, the central points of contention can be anticipated based on the claim language and the nature of the technology.
  • Scope Questions: A likely dispute will concern the scope of "determining the search intent." The question for the court may be whether this requires the complex, multi-engine probabilistic analysis described in the specification or if it can be read more broadly to cover simpler forms of topic or category-based search filtering.
  • Technical Questions: A key evidentiary question will be whether the accused products perform the distinct steps of "selecting... at least one application" based on intent and then "causing an icon... to be displayed" in a manner that is technically distinguishable from a conventional, ranked list of search results. The complaint provides no facts to address this.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

"search intent"

• Context and Importance: This term is central to the patent's novelty. Its construction will likely determine the boundary between the patented invention and conventional keyword-based search technologies.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification defines "search intent" as indicating a "topic of interest of a user" (’918 Patent, col. 2:24-25). This language could support a broad construction covering any search that identifies a general subject matter.
  • Evidence for a Narrower Interpretation: The detailed description outlines a specific process for determining intent that involves tokenizing a query and processing it through a "plurality of engines" that compute "certainty scores" for various entities, followed by statistical and semantic analysis (’918 Patent, col. 7:55-col. 8:16; Claim 5). This detailed embodiment may be used to argue for a narrower construction requiring a similarly complex, multi-factor analysis.

"display segment"

• Context and Importance: The nature of how the application icon is presented is a required step of the claimed method. Whether this term covers a standard search results interface or requires a distinct user interface element, such as an overlay, will be a key issue.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The abstract describes "creating a display segment over a display of the user device," which could be argued to encompass any designated area on a screen where a result is shown (’918 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The patent also refers to a "dynamic display segment" (’918 Patent, col. 5:41), and system claim 11 requires a processor to be configured to "instigate a display segment to be created" (’918 Patent, col. 12:40-42). This language suggests an affirmative act of creating a special or temporary UI element, potentially distinguishable from a standard, persistent search results list.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to use its products in a manner that infringes the ’918 Patent (Compl. ¶14).
• Willful Infringement: The basis for willfulness is alleged post-suit knowledge. The complaint asserts that service of the complaint itself provides "actual knowledge of infringement" and that Defendant's continued infringement thereafter is willful (Compl. ¶13, ¶14).

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

• A threshold procedural question will be one of pleading sufficiency: Does a complaint that contains no factual infringement allegations in its body and instead relies entirely on an unattached exhibit meet the plausibility standard required to state a claim for patent infringement?
• A central substantive issue will be one of claim scope: Will the term "search intent" be construed broadly to cover any search result filtering based on a topic, or will it be limited to the specific multi-engine, probability-based analytical process detailed in the patent’s preferred embodiments?
• A key evidentiary question will be one of technical implementation: Assuming the case proceeds, what evidence will show that the accused products "cause an icon... to be displayed" in a distinct "display segment" as required by the claims, rather than simply presenting it within a conventional list of search results?