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CXT Systems Inc. v. CC Filson Co. et al

COMPLAINT FOR PATENT INFRINGEMENT

E-commerce websites and computer systems supporting those websites (collectively, the

“Accused Infrastructures”) employ methods covered by the ’703 Patent, ’234 Patent and ’661 Patent (collectively, the “Knight Patents”) in order to improve the shopping experience of their buyers. The Knight Patents generally cover systems and methods relating to optimizing the usability of online message boards such as those found at e-commerce websites. In one embodiment, a user may search for specific customer reviews for a product and then perform an action such as indicating that a review was “helpful.” Systems implementing the inventions covered by the Knight Patents achieve significant benefits and improvements in their operation and performance. As one example, users of the system can more easily navigate a website to find the most meaningful information, such as helpful negative reviews. By finding the most relevant information in a speedy manner, efficient usage of the

seller’s system, including from the perspective of both processing and communication resources, is achieved. Additionally, when a buyer focuses his review of a message board on the most targeted information, more efficient usage of the buyer’s computer system is achieved. This includes efficiencies in terms of processing, communication, power and display resources. Further, in the case where the buyer’s computer is a handheld device, which typically has limited resources, the improvements in performance due to the inventions covered by the Knight Patents are determinative as to whether many buyers will use the system.


The ’875 Patent, ’581 Patent and ’806 Patent (collectively, the “Steele Patents”) generally cover systems and methods relating to optimizing the online shopping experience. For example, in one embodiment, an authenticated user may access and control relevant account information such as shipping address or credit card information. In another embodiment, a user need only authenticate himself once in order to repeatedly access consumer information associated with different websites. In a third embodiment, an application is executed at the client side which manages the request/response process for the client side. Systems implementing the inventions covered by the Steele Patents achieve significant benefits and improvements in their operation and performance. By allowing a user to store and repeatedly access relevant account information, more efficient usage of the

buyer’s system is achieved. This includes efficiencies from the perspective of processing

resources as the buyer does not need not to repeatedly spend time entering in information such as a shipping address. Additionally, by allowing the buyer’s system to manage the request/response process through an application the request/response process can be more properly geared to the buyer’s system including its processing load and network latency. Further, in the case where the buyer’s computer is a handheld device, which typically has limited resources, the improvements in performance due to the inventions covered by the Steele Patents are determinative as to whether many buyers will use the system.


The Accused Infrastructures employ methods covered by the Knight Patents in

order to improve the shopping experience of their buyers. For example, the Accused Infrastructures processes a user command associated with one or more electronic message items taken from a set of electronic message items, where the user command is used to locate an author of a message item originating from a particular author.


The Accused Infrastructures employ methods covered by the Steele Patents in order to improve the shopping experience of their buyers. The Accused Infrastructures practice a method comprising retrieving selected consumer information elements from the information

stored within an online account by filtering data from the online account with a database management system, and transmitting the selected consumer information elements, over a

distributed electronic network, to the network device.



The Patents-in-Suit are presumed to be valid under 35 U.S.C. § 282 and while

many have tried to invalidate them, none have succeeded. In a recent action styled CXT Systems, Inc. v. Academy, Ltd., d/b/a Academy Sports + Outdoors, Case No. 2:18-cv-00171-RWS-RSP (Lead Case) (“Academy Litigation”), eight different sets of defendants filed or joined in 12(b)(6) motions alleging lack of eligible subject matter under 35 U.S.C. §101. A Report and Recommendation stated “The Court concludes that the claimed invention [of the ’703, ’234 and ’661 Patents] is not directed to an abstract idea under step 1 as it is directed to a specific improvement in the capabilities of computing devices.” Academy Litigation, Dkt. No. 128 at *5. It further stated that “Claim 1 [of the ’875 Patent] provides an inventive concept that transforms the nature of the claim into a patent-eligible application.” Id. at *13. Ultimately, the Court adopted the Report and Recommendation and denied all the 12(b)(6) motions. Academy Litigation, Dkt. No. 137. Recognizing the validity of these patents, Industry leaders have instead chosen to license them.


Case No. 2:19-cv-00170

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