R2 Solutions LLC v. iHeartMedia, INC.

On June 1, 2021, R2 Solutions LLC (“Plaintiff” or “R2 Solutions”), represented by Brent N. Bumgardner, Christopher Granaghan and Edward Nelson, III of Nelson Bumgardner Casto, PC, filed an intellectual property lawsuit against iHeartMedia, Inc. (“iHeartMedia” or “Defendant”), seeking declaratory and compensatory relief, along with reasonable ongoing royalties for the alleged patent infringement of innovations associated with Yahoo! Search, owned by the Plaintiff. This case was filed in U.S. District Court in the Western District of Texas with Judge Alan D. Albright presiding. 

The Plaintiff filed this complaint for the Defendant’s infringement of U.S. Patent Nos. 7,698,329 (“the ’329 patent”) entitled, “Method for Improving Quality of Search Results by Avoiding Indexing Sections of Pages.”, 8,341,157 (“the ’157 patent”) entitled, “System and Method for Intent-Driven Search Result Presentation.” and 8,190,610 (“the ’610 patent”) entitled, “MapReduce for Distributed Database Processing” (Collectively as the “patents-in-suit”).

In its complaint, the Plaintiff alleged that “iHeartMedia has directly infringed and continues to directly infringe one or more claims of the patents-in-suit in this District and elsewhere in Texas and the United States. To this end, iHeartMedia has infringed and continues to infringe, either by itself or via an agent, at least claims 1 and 4–5 of the ’329 patent, claims 1–5 and 11 of the ’157 patent and claims 1–5, 17–21, 33–34, and 40–41 of the ’610 patent by, among other things, making, offering to sell, selling, testing and/or using the iHeartRadio application and iHeartMedia data analytics system built on Apache Hadoop.”

The Plaintiff further alleged that “Despite having knowledge of the ’157 patent, iHeartMedia has specifically intended, and continues to specifically intend, for persons (including customers and end users) who subscribe to/acquire and/or use the iHeartRadio platform to use the iHeartRadio platform (which is stored on one or more computer readable media) such that those persons (including customers and end users) infringe claim 2 of the ’157 patent. This is evident when iHeartMedia encourages and instructs persons (including customers and end users) in the use and operation of the iHeartRadio platform, including the use of the search feature.”

The Plaintiff lists out three claims for relief. The claims are for the alleged infringement of ’329 Patent, ’157 Patent and ’610 patent, respectively, wherein the Plaintiff claimed that, iHeartMedia is liable for its alleged infringements of the patents-in-suit pursuant to 35 U.S.C. § 271. 

In its prayer for relief, the Plaintiff requested the Court to adjudicate that iHeartMedia has directly infringed one or more claims of each of the patents-in-suit, order iHeartMedia to pay R2 Solutions past and future damages, including supplemental damages arising from any continuing, post-verdict infringement for the time between trial and entry of the final judgment, together with an accounting, as needed, as provided under 35 U.S.C. § 284; reasonable ongoing royalties on a go-forward basis after Final Judgment and prejudgment and post-judgment interest on the damages awarded and award costs of litigation to Plaintiff.

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