Hitel Technologies LLC v. Guess?, Inc.

On January 31, 2022, Hitel Technologies LLC (“Hitel” or “Plaintiff”), represented by Raymond W Mort, III of The Mort Law Firm, PLLC, filed an intellectual property lawsuit against GUESS?, Inc. (“Defendant”), seeking declaratory relief, damages and costs along with interest for the alleged infringement of United States Patent owned by the plaintiff. This case was filed in the U.S. District Court in the Western District of Texas with Judge Alan D. Albright presiding.

The plaintiff filed this complaint for the alleged infringement of U.S. Patent No. 7,689,617 (“the ’617 Patent”), entitled “DYNAMIC LEARNING NAVIGATION SYSTEMS” owned by the plaintiff.

In the complaint the plaintiff alleged the “defendant provides for its customers use the GUESS? Website (https://www.guess.com/us/en/home) (the ‘Accused Website’). On information and belief, Defendant provides the Accused Website that provides the user the ability to search and navigate among various categories of items. For these categories the user is able to search for items using keywords using a search box. On information and belief, when searching for an item category the user may enter a keyword that does not directly match an existing category. The Accused Website then determines the requested search term is unknown.  On information and belief, the Accused Website then receives additional input from the user to select the desired category and presents a response to the user based on the items in the selected category. On information and belief, the Accused Website learns the association between the unknown word and the keywords associated with the item category for which a direct relationship is formed.”

The plaintiff further alleged, “Defendant has been and is now infringing one or more claims of the ’617 Patent under 35 U.S.C. § 271 by making and using the Accused Website in the United States without authority. Defendant has also infringed the ’617 Patent by encouraging customers (and potential customers) to use the Accused Website to practice the claims of the ’617 Patent. On information and belief, Defendant makes and uses the Accused Website, which comprises navigable nodes, documents attached to the user navigable nodes, keywords associated with the user navigable nodes. On information and belief, the Accused Website has search and navigation capability that allows users of the website to move from node to node via links between the nodes and make selections when at individual nodes.”

The plaintiff also alleged, “Defendant receives an input from a user. . . .determines that the input contains an unknown word. . . .subsequently, Defendant navigates through the system to a current node from the user navigable node based upon at least one additional input from the user that was provided while at the user navigable node. . . .Defendant learns one or more associations between the unknown word and one or more keywords from the documents attached to the current node, such that a direct relationship is formed between the unknown word and the one or more keywords. Hitel has been damaged by Defendant’s infringing activities.”

The claim for relief brought by the plaintiff was for the alleged infringement of U.S. Patent No. 7,689,617 owned by the plaintiff.

In its prayer for relief, the plaintiff requested a declaration that the defendant infringed upon the ’617 Patent, damages, costs, attorneys’ fees, expenses, interest, and further relief as the court finds appropriate.

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