Case 3:22-cv-02868-K Document 1 Filed 12/21/22 Page 1 of 30 PageID 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
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`R2 Solutions LLC,
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` Plaintiff,
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`v.
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`7-Eleven, Inc.,
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` Defendant.
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`
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`Civil Action No. 3:22-cv-02868
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`Jury Trial Demanded
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff R2 Solutions LLC files this Complaint against 7-Eleven, Inc. for infringement of
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`
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`U.S. Patent Nos. 8,341,157 (“the ’157 patent”), 7,698,329 (“the ’329 patent”), 8,209,317 (“the
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`’317 patent”), 9,805,097 (“the ’097 patent”), and 10,176,272 (“the ’272 patent”). The ’157
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`patent, ’329 patent, ’317 patent, ’097 patent, and ’272 patent are referred to collectively as the
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`“patents-in-suit.”
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`THE PARTIES
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`1.
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`Plaintiff R2 Solutions LLC (“R2”) is a Texas limited liability company located in
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`Frisco, Texas.
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`2.
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`Defendant 7-Eleven, Inc. (“7-Eleven”) is a corporation with headquarters at 3200
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`Hackberry Road, Irving, Texas 75063. 7-Eleven may be served with process through its
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`registered agent, Corporate Creations Network Inc. at 5444 Westheimer #1000, Houston, TX
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`77056.
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`JURISDICTION AND VENUE
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`3.
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`This action arises under the patent laws of the United States, 35 U.S.C. § 101, et
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`seq. This Court’s jurisdiction over this action is proper under the above statutes, including 35
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`U.S.C. § 271, et seq., 28 U.S.C. § 1331 (federal question jurisdiction), and 28 U.S.C. § 1338
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`(jurisdiction over patent actions).
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`4.
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`This Court has personal jurisdiction over 7-Eleven in accordance with due process
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`and/or the Texas Long Arm Statute because, among other things, 7-Eleven is a resident of Texas.
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`7-Eleven also does business in this State by, among other things, “recruit[ing] Texas residents,
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`directly or through an intermediary located in this state, for employment inside or outside this
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`state.” TEX. CIV. PRAC. & REM. CODE § 17.042(3). For instance, 7-Eleven has 590 job
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`openings listed near Irving, Texas as of December 14, 2022.1
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`5.
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`Relative to patent infringement, 7-Eleven has committed and continues to commit
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`acts in violation of 35 U.S.C. § 271, and has made, used, marketed, distributed, offered for sale,
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`and/or sold infringing products and services in this State, including in this District, and otherwise
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`engaged in infringing conduct within and directed at, or from, this District. Such infringing
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`products, systems, and/or services (collectively, the “Accused Instrumentalities”) include
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`systems, services, processes, methods, acts, components (hardware and/or software), and/or other
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`instrumentalities associated with web-page widgets and/or searches or queries performed in
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`connection with 7-Eleven’s web platform(s) and mobile application(s), including the products,
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`systems, and/or services identified in Exhibits 6-10. The “Accused Instrumentalities” include,
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`without limitation, all systems, processes, and instrumentalities associated with receiving,
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`
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`1 https://careers.7-
`eleven.com/jobs?location=Irving,%20TX&woe=7&stretchUnit=MILES&stretch=10&page=1.
`2
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`handling, processing, responding to, or otherwise interacting with queries (including user queries
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`and back-end queries); all systems, processes, and instrumentalities related to the location,
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`identification, delivery, display, rendering, ranking, and communication of information relating
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`to such queries; and all systems, processes, and instrumentalities associated with the delivery,
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`display, rendering, and communication of information via 7-Eleven’s web platform(s) and
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`mobile application(s), including those accessible at and/or through 7-Eleven.com, 7now.com,
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`and 7-elevenshop.com. The “Accused Instrumentalities” include, without limitation, the front-
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`end(s) and back-end(s) of 7-Eleven’s online store for groceries, apparel, and other items, such as
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`can be found at 7-eleven.com, 7now.com, 7-elevenshop.com, and/or the 7-Eleven mobile
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`application.
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`6.
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`Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b) because 7-
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`Eleven has regular and established places of business in the District, at least at its headquarters in
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`Irving. Venue is further proper in this District because 7-Eleven has infringed and/or induced the
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`infringement of others, including its customers, in this District.
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`BACKGROUND
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`7.
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`The patents-in-suit were filed by Yahoo! Inc. (“Yahoo!”) between 2006 and 2009.
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`At the time, Yahoo! was a leading Internet communications, commerce, and media company.
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`Yahoo! invested billions of dollars in research and development over this period, filing hundreds
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`of patent applications each year to cover the innovative computing technologies emerging from
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`its expansive research and development efforts.
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`8.
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`Yahoo! began as a directory of websites that two Stanford graduate students
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`developed as a hobby. The name “Yahoo” stands for “Yet Another Hierarchical Officious
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`Oracle,” a nod to how the original Yahoo! database was arranged hierarchically in layers of
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`subcategories. From this initial database, Yahoo! would develop and promulgate numerous
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`advancements in the field of data storage and recall.
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`9.
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`For example, in 1995, Yahoo! introduced Yahoo! Search. This software allowed
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`users to search the Yahoo! directory, making it the first popular online directory search engine.
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`This positioned Yahoo! as the launching point for most users of the World Wide Web. By 1998,
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`Yahoo! had the largest audience of any website or online service.
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`10.
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`However, the early iterations of Yahoo! Search did not operate like a modern
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`search engine because Yahoo! Search was only a directory. Yahoo! Search first integrated a
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`Web crawling engine in 2000. Yahoo! Search used Google’s Web crawling engine from 2000–
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`2004. During this time, Yahoo! was developing its own Web search technologies. Yahoo!
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`deployed its own Web crawler in early 2004. The engine, known as Slurp, allowed Yahoo! to
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`collect documents from the Web and build a searchable index. The patents-in-suit relate to
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`innovations associated with Yahoo! Search that were developed and implemented during this
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`period, which enabled Yahoo! to become Google’s biggest competitor in the search engine
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`space.
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`THE PATENTS-IN-SUIT
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`11.
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`The ’157 patent is entitled, “System and Method for Intent-Driven Search Result
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`Presentation.” The ’157 patent lawfully issued on December 25, 2012, and stems from U.S.
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`Patent Application No. 12/533,299, which was filed on July 31, 2009. A copy of the ’157 patent
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`is attached hereto as Ex. 1.
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`12.
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`The ’329 patent is entitled, “Method for Improving Quality of Search Results by
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`Avoiding Indexing Sections of Pages.” The ’329 patent lawfully issued on April 13, 2010, and
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`stems from U.S. Patent Application No. 11/652,356, which was filed on January 10, 2007. A
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`copy of the ’329 patent is attached hereto as Ex. 2.
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`13.
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`The ’317 patent is entitled, “Method and Apparatus for Reconstructing a Search
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`Query.” The ’317 patent lawfully issued on June 26, 2012, and stems from U.S. Patent
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`Application No. 13/270,933 filed on October 11, 2011. The ’317 patent is a continuation of U.S.
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`Patent Application No. 12/765,676 filed on April 22, 2010, which is a continuation of U.S.
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`Patent Application No. 11/502,202 filed on August 10, 2006. A copy of the ’317 patent is
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`attached hereto as Ex. 3.
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`14.
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`The ’097 patent is entitled, “Method and System for Providing a Search Result.”
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`The ’097 patent lawfully issued on October 31, 2017, and stems from PCT Application No.
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`PCT/CN2014/094122, which was filed on December 17, 2014. A copy of the ’097 patent is
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`attached hereto as Ex. 4.
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`15.
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`The ’272 patent is entitled, “System and Method of Automatically Sizing and
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`Adapting a Widget to Available Space.” The ’272 patent lawfully issued on January 8, 2019,
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`and stems from U.S. Patent Application No. 11/864,589, which was filed on September 28,
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`2007. A copy of the ’272 patent is attached hereto as Ex. 5.
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`16.
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`R2 Solutions is the owner of the patents-in-suit with all substantial rights,
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`including the exclusive right to enforce, sue, and recover damages for past and future
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`infringements.
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`17.
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`The claims of the patents-in-suit are directed to patent eligible subject matter
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`under 35 U.S.C. § 101. They are not directed to abstract ideas, and the technologies covered by
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`the claims consist of ordered combinations of features and functions that, at the time of
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`invention, were not, alone or in combination, well-understood, routine, or conventional.
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`18.
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`Indeed, the specifications of the patents-in-suit disclose shortcomings in the prior
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`art and then explain, in detail, the technical way the claimed inventions resolve or overcome
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`those shortcomings. For example, relative to the ’157 patent, the specification explains that if, as
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`in the case of traditional search engines, the “engine simply regards a web query as, for example,
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`a ‘bag of words’, the search engine will search for web pages and other data objects (e.g.,
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`images, audio files, text files) that contain, or are otherwise associated with, the individual words
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`within the query.” ’157 patent at 4:1-5. However, simply treating a user query as a “bag of
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`words” may yield results that do not align with the purpose of the user’s search. Additionally, it
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`can be onerous to scrutinize generated results for a desired returned object, as the objects can be
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`unremarkable as to each other. Id. at 4:10-15. Thus, the specification teaches:
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`Search results could be significantly enhanced if the likely intent of the query is
`known. For example, search results may be ranked such that results that are more
`relevant to the user’s intent appear at or near the top of the search results. Perhaps
`more significantly, however, the user’s intent can be used to customize the display
`and behavior of a search result to be narrowly targeted to a user’s intent. An
`illustrative list of such customizations could include a customized title or abstract
`for the result or specialized parameters of a displayed clickable URL to provide
`the landing page with information regarding the user’s intent or triggered by the
`user’s intent.
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`Id. at 4:16-26.
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`19.
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`This “intents”-driven search engine process offers significant technical features
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`that constitute enhancements over then-existing search engine technology. For example, the
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`’157 patent discusses how pre-programmed “intents” can be mapped to from query keywords,
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`and how “intents” determination can be fine-tuned via particular parameters:
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`The query is then classified into one or more likely intents, which can include an
`unclassified intent when no defined intents match the query 2300. An intent is a
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`mapping from many combinations of keywords to a relatively small set of
`common goals that users pursue in a search query or session of multiple queries.
`Often, the intent of the query is not explicitly stated in the keywords. While the
`space of possible queries, is very large, the set of intents is much smaller.
`Examples of intents relating to product queries can be, for example: official-site,
`research, purchase, dealer, support, or reviews. Examples of intents relating to
`local/map queries: directions, reviews, phone, hours-of-operation. In one
`embodiment, query intent may be determined by linguistic analysis of query
`keywords. In one embodiment, previous queries in the user session, user profile
`information such as preferences, the set of all queries from all users or any subset
`of all users (e.g. a subset of users having specific demographics or usage
`patterns), and click data from previous sessions for the current user as well as the
`set of all users or any subset of all users are used to determine query intent.
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`’157 patent at 9:42-61.
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`20.
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`The “intents”-driven search engine process of the ’157 patent ensures that query
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`keywords, via the “intents,” can even ultimately impact how particular data objects are
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`constructed within a result. This provides an added benefit of enabling keywords to be utilized
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`for more than just relevancy analysis. Also, while other search engines existing at the time could
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`tailor search results by ranking the results and displaying each result with a title and brief
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`abstract taken from the document, the ’157 patent explains how “results could be significantly
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`enhanced if the likely intent of the query is known.” ’157 patent at 4:16-17. Rather than return
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`all documents having a matching keyword—i.e., by using traditional indexing methods—a
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`narrower set of results can be returned if the search results are “ranked such that results that are
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`more relevant to the user’s intent appear at or near the top of the search results.” Id. at 4:17-19.
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`21.
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`Indeed, the claims of the ’157 patent provide just such a solution to the problem
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`of generating robust yet usable search results in response to a user query. For example, Claim 1
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`of the ’157 patent discloses a method comprising:
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`receiving, over a network, a query from a user, the query comprising at least one
`query token;
`analyzing the query, using at least one computing device, to identify at least one
`query keyword;
`determining, at least the one computing device, a plurality of intents from the at least
`one keyword, each of the plurality of intents indicates a type of information
`regarding the query keyword that is likely to be desired by a user submitting the
`query;
`classifying the query, using the at least one computing device, into at least one of the
`plurality of intents;
`identifying, using the at least one computing device, a plurality of data objects
`available over the network that match the at least one query keyword;
`assigning, using the at least one computing device, at least one of the plurality of
`intents to at least some of the plurality of data objects;
`ranking, using the at least one computing device, the plurality of data objects;
`building a result, using the at least one computing device, using the ranked plurality
`of data objects, the result comprises a plurality of display entries, at least one
`display entry customized to a respective assigned intent is constructed for each
`of the ranked plurality of data objects; and
`transmitting the result, over the network, to the user.
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`(emphasis added).
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`22.
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`These technical features highlight that Claim 1 itself outlines a novel process
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`executed by a specialized programming architecture that constitutes a significant improvement in
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`computer functionality. Each of the technical features emphasized above operates cooperatively
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`to enhance the technological process of search engine application, and these advances define a
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`novel improvement in computer capabilities.
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`23.
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`Thus, the inventions claimed in the ’157 patent improve the speed, efficiency,
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`effectiveness, and functionality of computer systems rather than improve upon some other task
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`for which a computer is used in its ordinary capacity. For example, the ’157 patent focuses on
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`circumventing the “bag of words” approach in result generation, and ultimately achieves better,
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`more-usable computer-generated results as compared to technologies that existed in 2009. As
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`another example, the ’157 patent can rank documents based on intent rather than using “a
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`traditional {query,document} score,” increasing the probability that a relevant result will be in
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`the final result set presented to the user. ’157 patent at 12:7-22. This reduces the number of
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`queries that must be processed in order to return relevant results to the user. As a result, the
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`processor is free to allocate more resources to other tasks.
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`24. With respect to the ’329 patent, the specification explains that nefarious parties
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`can trick traditional search engines “into recalling documents and inflating their ranking” using
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`techniques known as “search engine spamming.” ’329 patent at 2:6-8. For example, spamming
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`may be used to “trick search engine ranking algorithms into recalling and highly ranking
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`documents that contain . . . sponsored links to a web merchant.” Id. at 2:8-11. The result is that
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`search results for many queries include irrelevant content that the querier did not desire. Id. at
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`2:14-17. The specification gives a specific example of an online shopper:
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`A typical example of search engine spam is when a user tries to search for the
`terms “digital camera reviews” and expects to find pages which review various
`models of digital cameras, detailing performance specifications, sample images
`and reviewer pros and cons list. Having this expectation when the user clicks on a
`link for one of the results, the user is instead led to a page that contains nothing
`but a plethora of keywords and links to other stores where he can buy the camera.
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`Id. at 2:18-27. Thus, the specification recognizes that “there is need for mechanisms that prevent
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`hiding of search engine spam but yet allow webmasters to designate page content that should not
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`be indexed.” Id. at 2:34-37.
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`25.
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`The specification describes a novel approach to achieve this goal:
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`As a crawler examines an individual document, one of the attributes that can be
`considered is section structure. In examining the various sections, the crawler
`identifies sections to ignore, that is, to not index in search engine indexes and or
`otherwise use for recalling the document. Such sections are referred to herein as
`“no-recall sections.” Those portions that are indexed for recalling are referred to
`as recall sections. In an embodiment, a crawler ignores no-recall sections
`demarcated by, for example, a tag. In another embodiment a no-recall section may
`be identified by analyzing section content rather than examining only delimiters.
`The terms inside no-recall sections do not contribute to the document term
`frequency counts and are not used for recalling the documents in response to
`search engine queries. However the no-recall sections are included as input to
`forms of analysis of the document that affect, for example, the document’s
`ranking. Links inside the no-recall sections as well as the rest of the document
`may be followed in order to discover new content. The document may be
`analyzed for the amount of advertisements or other features in its entirety.
`Therefore, terms inside the no-recall sections can affect document ranking.
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`Id. at 3:7-27. This approach solves the problem described in the specification by simultaneously
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`enabling ranking that is not dictated by relevance scores and preventing nefarious parties from
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`hiding search engine spam, e.g., because pages with “copious amounts of advertisements, or low
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`quality links, will be readily identified and ranked accordingly.” Id. at 3:28-31.
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`26.
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`Claim 1 of the ’329 patent embodies this solution:
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`A method, comprising:
`ranking a plurality of documents recalled by a search engine for a query;
`wherein the plurality of documents contain certain documents, each document of said
`certain documents containing at least one section that is not used by said search
`engine for recall and one or more sections that are used by said search engine for
`recall;
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`wherein ranking a plurality of documents includes ranking said plurality of
`documents based, at least in part, on the at least one section of said certain
`documents not used by said search engine to recall documents; and;
`wherein the method is performed by one or more computing devices.
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`(emphasis added).
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`27.
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`Claim 1 communicates two overarching technological improvements: 1) an
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`improved data structure that is capable of facilitating both search engine recall and improved
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`ranking via the attributes of recall and no-recall sections; and 2) an improved ranking process
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`rooted in a specialized computing device and/or software capable of delineating between and
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`selectively employing recall and no-recall sections found in a plurality of the aforementioned
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`improved data structures. These two technological advancements, working in tandem, realize a
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`discrete process and/or system that greatly improves upon search engine technology that existed
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`in 2007.
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`28.
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`The claimed method of search engine architecture improves navigation of the
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`World Wide Web by increasing the relevance of search results and thwarting nefarious Web
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`users seeking to game Web query rankings. See, e.g., ’329 patent at 1:67 - 2:17. By improving
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`the functionality of navigating the Web, the claimed invention is necessarily rooted in the
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`improvement of computer functionality, as opposed to, e.g., enhancing the economy of a task
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`usually performed by hand. For example, by not ignoring no-recall sections when ranking the
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`documents, the claimed invention prevents a document from being “designed so that content that
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`increases recall and/or ranking potential is placed in the recall section and content that
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`diminishes high ranking potential is hidden in a no-recall section.” ’329 patent at 4:1-9. This
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`allows “[a]ll the attributes in all of the sections of a document such as ‘links’, frequency of
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`terms, coloring, font, etc.” to be considered in the spam and relevancy analyses. Id. at 4:13-16.
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`The result is that a search engine can “affect the recall and ranking of documents to more
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`accurately reflect relevance of the documents to search engine queries.” Id. at 3:1-3. This
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`technological solution is the precise reason that the ’329 patent was allowed, as is apparent from
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`the prosecution history.
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`29.
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`Relative to the ’317 patent, the specification explains that existing search engine
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`interfaces “may be rigid and require users to submit full queries to perform searche[s].” ’317
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`patent at Abstract. Traditional search engines were built with desktop computer users in mind.
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`Thus, they were designed with the assumption that a user had access to a full keyboard for
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`composing a complete, properly structured search query. However, as noted in the specification
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`of the ’317 patent, users at the time could increasingly access the internet from a variety of
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`devices, including “cell phones, personal digital assistants, and the like.” Id. at 1:44-47.
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`Portability started to become “an increasingly important concern for users.” Id. at 1:50-52. The
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`increasing portability of these devices came with a tradeoff in input capabilities. See id. at 1:50-
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`52. For example, most phones at the time the ’317 patent was filed did not have a full keyboard.
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`The simpler input mechanisms available on mobile devices presented a barrier to entering
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`properly structured queries, thus limiting users’ ability to fully explore the Internet. See id. at
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`1:52-53.
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`30.
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`To solve these problems, the ’317 patent discloses “a flexible and intuitive system
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`for reconstructing a search query based on a received partial query.” Id. at 1:16-18. This
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`solution is embodied in Claim 1 of the ’317 patent:
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`A computer database system for providing search results to a user in response to user
`submissions over a data network, the computer database system comprising:
`a database configured to store information about events in the computer database
`system; and
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`a query reconstruction server in data communication with the database and operative
`to receive a partial query submitted at a remote user client system by a user
`seeking search results matching the submitted partial query and, in response to
`the received partial query, determine a full query based on
`the received partial query, and
`(i)
`(ii)
`information stored in the database about queries previously-submitted by
`users,
`wherein the submitted partial query comprises an abbreviated or incomplete search
`query which is not fully representative of an entire search query desired by the
`user and the full query is better representative of the entire search query desired
`by the user.
`
`(emphasis added).
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`31.
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`The specification explains that partial queries are “shorthand ways of expressing
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`typical search queries.” Id. at 3:15-17. For example, “auto ins” may be a partial query for the
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`full search query “auto insurance.” Id. at 3:20-23. While “auto ins” may be an intentional
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`abbreviation, it might also be a typographical error resulting from the restrictive input options of
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`a mobile device. Because the claimed invention will nevertheless be able to take the incomplete
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`query “auto ins” and return search results for “auto insurance,” a broader array of mobile devices
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`and input mechanisms may be used to search the Internet. See id. at 1:43-56.
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`32. With respect to the ’097 patent, the specification addresses disadvantages in prior
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`art approaches to searching algorithms and renderings. For example, the ’097 patent explains
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`that “[c]onventional approaches for providing a search result focus on presenting the items in the
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`search result as a list. For example, a conventional search result includes items listed from top to
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`bottom on a screen. This can limit user engagement on the search result as the user may lose
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`interest after viewing the top two items.” ’097 patent at 1:30-35. “It is [also] time consuming
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`for the user to scroll up and down to find an interesting item with a listed presentation….” Id. at
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`1:35-40.
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`33.
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`As a solution to this drawback, the ’097 patent enables, in response to a search
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`query, the displaying of content items in a framed structure (e.g., displaying thumbnails of the
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`video content in some framed structure), as opposed to a list of search results going from top to
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`bottom, where there is a correspondence between one or more content items and at least one sub-
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`component. The solution is embodied in Claim 1 of the ’097 patent:
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`A method, implemented on at least one computing device each of which has at
`least one processor, storage, and a communication platform connected to a
`network for providing a search result, the method comprising:
`receiving a search request from a user;
`determining a plurality of content items based on the search request;
`selecting one or more content items from the plurality of content items;
`generating a framed structure having at least one sub-component;
`determining a correspondence between the one or more content items and the at
`least one sub-component;
`arranging each of the one or more content items with respect to a
`corresponding sub-component;
`generating a search result based on the one or more content items and the framed
`structure; and
`providing the search result.
`(emphasis added).
`The inventions described and claimed in the ’097 patent improve the speed,
`34.
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`efficiency, effectiveness, and functionality of computer systems. Moreover, the inventions
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`provide an improvement in computer functionality beyond rote tasks for which a computer is
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`used in its ordinary capacity. For example, the ’097 patent enhances “search result generation
`
`and presentation, realized as a specialized and networked system by utilizing one or more
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`computing devices (e.g., mobile phone, personal computer, etc.) and network communications
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`(wired or wireless).” Id. at 4:29-33. The ’097 patent provides significant advantages over prior
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`art by “providing a search result to a user to improve the user engagement and/or increase
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`revenue for a search engine. After submitting a query to a search engine, a user may receive a
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`search result including one or more content items. The user’s interest on the items may be
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`stimulated not only by their content but also by a manner of providing or presenting them.” Id.
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`at 4:33-40.
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`35.
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`Relative to the ’272 patent, the specification explains that with respect to web-
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`page widgets, “[e]ven though multiple sizes are offered, their limited number cannot account for
`
`all web-page sizing variations; not only do web pages come in a wide number of styles and
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`designs, but an end user ultimately has control, to a greater or lesser relative extent, over the
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`monitor size and the web browser dimensions; if the web page is designed using mostly relative
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`constraints, then the size of the web page can vary widely depending on monitor size, browser-
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`window size, etc.” ’272 patent at 1:40-48. The specification further explains that “changing the
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`size of a widget is often a frustrating experience,” especially with respect to incorporating the
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`widget into a webpage, which can require a user to “repeat the entire settings-choosing process,
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`including placing the widget code on the web page.” Id. at 48-51. Thus, “[i]n light of the
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`immutable nature of current widgets, it is often the case that they do not or cannot fit into an
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`already-established web page layout,” meaning that a widget will often “overflow[] out of its
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`section,” “not appear[] at all,” or cause other errors, such as pushing other sections “down and
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`out of view” or causing other sections to be “resized to fit [the] widget.” Id. at 2:38-52.
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`36.
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`To address these failings in the art, the ’272 patent discloses an enhanced widget
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`technology that realizes the “general object of…automatically siz[ing] a web-based widget
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`Case 3:22-cv-02868-K Document 1 Filed 12/21/22 Page 16 of 30 PageID 16
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`relative to its real-time constraints to make optimal and efficient use of available space.” Id. at
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`1:57-60. This solution is embodied in, e.g., claim 1 of the ’272 patent:
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`A method comprising:
`
`receiving structural data associated with a web page, the web page including a widget,
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`the widget including a plurality of widget elements, wherein the structural data
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`includes a size of a browser window used to display the web page;
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`accessing a constraint regarding a pre-determined number of the widget elements to
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`display within the widget;
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`triggering during a display of the browser window and the plurality of widget elements
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`a reduction in a size of the widget and a reduction in a plurality of sizes of the
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`widget elements to display within the widget when the size of the browser window
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`reduces;
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`removing one or more of the widget elements from being displayed within the widget
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`after reducing the sizes of the widget elements, wherein said removing the one or
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`more of the widget elements is performed until the constraint is achieved;
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`increasing a size of remaining one of the widget elements of the reduced size to fit
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`within the widget of the reduced size upon achieving the constraint; and
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`sending data for displaying the widget.
`
`(emphasis added).
`
`37.
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`The claimed inventions of the ’272 patent detail an enhanced widget technology
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`that implements technological features like those emphasized above to improve upon computer
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`functionality—indeed, the patent focuses on technology that can only exist in the realm of
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`computers, e.g., widgets. Moreover, the inventions provide an improvement in computer
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`Case 3:22-cv-02868-K Document 1 Filed 12/21/22 Page 17 of 30 PageID 17
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`functionality beyond rote tasks for which a computer is used in its ordinary capacity, and the
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`inventions described and claimed in the ’272 patent improve the speed, efficiency, effectiveness,
`
`and functionality of computer systems. For example, the ’2