Mountech IP filed a patent infringement complaint on Friday in the Southern District of Florida against TracFone Wireless, a mobile telecommunication company, for use of automated word completion for predictive texting on its devices.
The patents-in-suit are U.S. Patent No. 7,991,784 (the ‘784 patent) and U.S. Patent No. 8,311,805 (the ‘805 patent), both entitled “Automatic Dynamic Contextual Data Entry Completion System.”
TracFone allegedly infringed at least Claim 1 of the ’784 patent, which “recites a method – performed in a character entry system, so that incomplete character strings input by a user interacting with the character entry system, that are part of a series of input character strings which establish a context for the incomplete input character string, can be completed by the selection of a presented character string using an input device connected to the character entry system…” This provides for automated word completion within an incomplete character string on a user’s device. Mountech asserted that TracFone used and performed all of the steps in the patented method, thus infringing on the ’784 patent.
TracFone also purportedly infringed at least Claims 1 and 2 of the ’805 patent, which describe a “method, performed in a character entry system, for interrelating character strings so that an incomplete input character string can be completed by selection of a presented character string, the method comprising: computing relationship scores for individual character strings in the system from documents stored in memory of the character entry system, the relationship scores consisting of a function consisting of co-occurrence scores between pairs of distinct character strings stored in a single matrix created from the character strings in the stored documents.” Claim 2 describes the method in claim 1, “wherein each relationship score represents the contextual association between an individual character string and another character string based upon co-occurrence of character strings relative to each other.” The plaintiff proffered that TracFone infringed both of these claims.
TracFone’s allegedly infringing products, such as the TCL A1 (A501DL) allegedly utilize both of the methods described in the patents for automated text completion. For example, the predictive text system is performed when a user inputs incomplete character strings into the character entry system, which are part of a larger context of character strings, which the system uses to complete the selection of presented character strings on the device. This is used to predict and complete the selected input words for the system because the system has created a relationship between words and specific character strings. The example in the suit discusses a hypothetical user with notes about a specific person, James Maxwell, so when the user types in the name James, the device suggests Maxwell as the next word. Moreover, when the user’s “combined essay” contains the phrases “James Maxwell,” “James Maxima,” and “James Michener,” the predictive system suggests “Maxwell” “Maxima” and “Michener” after the phrase “James M” based on the frequency of those phrases. As a result, this product purportedly infringed the claims of the patents-in-suit.
TracFone is accused of patent infringement for the aforementioned conduct. Mountech has sought for the defendant to be adjudged, an accounting of all sales and damages, an injunction, an award for damages, pre- and post-judgment interest, and other relief.
Mountech is represented by Sand, Sebolt & Wernow Co., LPA