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CXT Systems Inc. v. Harbor Freight Tools USA, Inc.

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 Patents-in-Suit are presumed to be valid under 35 U.S.C. § 282 and while many have tried to invalidate them, none has 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), 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." Ultimately, the Court adopted the Report and Recommendation and denied all the 12(b)(6) motions. Recognizing the validity of these patents, industry leaders have instead chosen to license them.


Case No. 2:19-cv-00167

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