Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 1 of 45
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`GREATGIGZ SOLUTIONS, LLC,
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`Plaintiff
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` v.
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`LINKEDIN CORPORATION,
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`Defendant
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`Case No. 6:20-cv-_________
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`JURY TRIAL DEMANDED
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`GreatGigz Solutions, LLC (“Plaintiff”) hereby files this Original Complaint for Patent
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`Infringement against LinkedIn Corporation (“Defendant”), and alleges, upon information and belief, as
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`follows:
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`THE PARTIES
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`1.
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`GreatGigz Solutions, LLC is a limited liability company organized and existing under the laws
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`of the State of Florida with its principal place of business at 600 S. Dixie Highway, Suite 605,
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`West Palm Beach, Florida 33401.
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`2.
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`Upon information and belief, LinkedIn Corporation (“LinkedIn”) is a domestic corporation
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`organized and existing under the laws of Delaware, with a principal place of business located in
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`Sunnyvale, California. LinkedIn may be served through its registered agent in the State of Texas
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`at Corporation Service Company, 211 East 7th Street, Suite 620, Austin, Texas 78701. On
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`information and belief, LinkedIn sells and offers to sell products and services throughout the
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`State of Texas, including in this judicial District, and introduces services via its infringing
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 2 of 45
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`systems into the stream of commerce knowing and intending that they would be extensively used
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`in the State of Texas and in this judicial District. On information and belief, LinkedIn
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`specifically targets customers in the State of Texas and in this judicial District.
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`JURISDICTION AND VENUE
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`3.
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`4.
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`This Court has subject matter jurisdiction over this case under 28 U.S.C. §§ 1331 and 1338.
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`This Court has personal jurisdiction over Defendant. Defendant has continuous and systematic
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`business contacts with the State of Texas. Defendant directly conducts business extensively
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`throughout the State of Texas, by distributing, making, using, offering for sale, selling, and
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`advertising (including the provision of interactive web pages and apps) its services in the State of
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`Texas and in this District. Defendant has purposefully and voluntarily made its infringing
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`systems available to residents of this District and into the stream of commerce with the intention
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`and expectation that they will be purchased and used by consumers in this District.
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`5.
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`On information and belief, Defendant maintains an ongoing and continuous business presence in
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`the State of Texas and specifically within this District, which is illustrated by the fact that
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`LinkedIn has 82 employees residing in Texas, with half of those residing and working in this
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`District. See, e.g., LinkedIn corporate profile page on LinkedIn.com, which lists the location of
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`453 LinkedIn employees worldwide (including 23 in Austin; 5 in San Antonio; 3 in El Paso; and
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`1 in Killeen/Temple; plus 30 in Dallas/Ft. Worth; 18 in Houston; 2 in Bryan/College Station; and
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`1 in Longview). Indeed, nearly 20% of all LinkedIn employees listed reside in the State of
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`Texas, and nearly 10% reside in this District alone. Further, on information and belief, LinkedIn
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`maintains substantial long-term data centers in the State of Texas. On information and belief,
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`such data centers are under the direct control of LinkedIn and are fundamental elements of the
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`infringing system operated by LinkedIn to directly infringe the asserted claims. See, e.g.,
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 3 of 45
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`Business Article “LinkedIn Expands With Texas Data Center,” excerpted below, available at:
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`https://www.datacenterknowledge.com/archives/2013/11/06/linkedin-expands-with-dallas-data-
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`center.1
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`6.
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`The data center location in Texas is strategic and represents an important business advantage to
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`LinkedIn’s business model. See, e.g., LinkedIn Engineering Blog, excerpted below, and
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`available at: https://engineering.linkedin.com/blog/2015/11/introducing-linkedins-west-coast-
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`data-center.
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`
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`1 All references to Internet content, unless noted otherwise, are cited as of June 10, 2020, and as accessed
`from a location in the State of Texas.
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`7.
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`The location of the LinkedIn data center in Texas is important to the business of LinkedIn, as
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`explained in the LinkedIn Engineering Article entitled: “A Brief History of Scaling LinkedIn,”
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`at:
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`https://engineering.linkedin.com/architecture/brief-history-scaling-linkedin
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`(excerpted
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`below). The LinkedIn article explains how the use of “geographically close data centers”
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 5 of 45
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`facilitates and enhances the effectiveness of LinkedIn’s business model for the benefit of its
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`customers.
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`8.
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`Venue is proper in the Western District of Texas as to Defendant pursuant to at least 28 U.S.C.
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`§§ 1391(c)(2) and 1400(b). As noted above, Defendant maintains a regular and established
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`
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`business presence in this District.
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`PATENTS-IN-SUIT
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`9.
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`GreatGigz Solutions, LLC is the owner, by assignment, of U.S. Patent Nos. 6.662,194 (“the ’194
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`Patent”); 7,490,086 (“the ’086 Patent”); 9,760,864 (“the ’864 Patent”); and 10,096,000 (“the
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`’000 Patent”) (hereinafter collectively referred to as “the GGS Patents”).
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`10.
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`The GGS Patents are valid, enforceable, and were duly issued in full compliance with Title 35 of
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`the United States Code.
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`11.
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`The inventions described and claimed in the GGS Patents were invented by Raymond Anthony
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`Joao.
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`12.
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`The priority date of each of the GGS Patents is at least as early as July 31, 1999.
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 6 of 45
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`13.
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`14.
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`The GGS Patents each include numerous claims defining distinct inventions.
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`During prosecution of the ’864 Patent, the patent examiner considered whether the claims of the
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`’864 Patent were eligible under 35 USC §101 in view of the United States Supreme Court’s
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`decision in Alice. The patent examiner found that the claims are in fact patent eligible under 35
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`USC §101 because all pending claims are directed to patent-eligible subject matter, none of the
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`pending claims are directed to an abstract idea and there would be no preemption of the abstract
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`idea or the field of the abstract idea.
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`15.
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`GreatGigz Solutions, LLC alleges infringement on the part of Defendant of the ’194 Patent and
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`the ’086 Patent (the “Asserted Patents”).
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`16.
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`The ’194 Patent relates generally to an apparatus and method for providing recruitment
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`information, including a memory device for Storing information regarding at least one of a job
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`opening, a position, an assignment, a contract, and a project, and information regarding a job
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`Search request, a processing device for processing information regarding the job Search request
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`upon a detection of an occurrence of a Searching event, wherein the processing device utilizes
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`information regarding the at least one of a job opening, a position, an assignment, a contract, and
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`a project, Stored in the memory device, and further wherein the processing device generates a
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`message containing information regarding at least one of a job opening, a position, an
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`assignment, a contract, and a project, wherein the message is responsive to the job Search
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`request, and a transmitter for transmitting the message to a communication device associated
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`with an individual in real-time. See Abstract, ’194 Patent.
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`17.
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`The ’086 Patent relates generally to an apparatus, including a memory device which stores
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`information regarding a job opening, position, assignment, contract, or project, and information
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`regarding a job search request or inquiry, a processing device which processing the information
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 7 of 45
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`regarding a job search request or inquiry upon an automatic detection of an occurrence of a
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`searching event which is an occurrence of a job posting, a posting of new or revised data or
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`information, a news release of a business event, an employment-related event, an economic
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`report, industry-specific news, an event which creates an to fill a position, or an event which
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`creates an interest to seek a position, and generates a message, containing the information
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`regarding a job opening, position, assignment, contract, or project, responsive to the job search
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`request or inquiry, and a transmitter which transmits the message to a communication device
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`associated with an individual. See Abstract, ’086 Patent.
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`18.
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`As noted, the claims of the Asserted Patents claim priority to at least July 31, 1999. At that time,
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`the idea of launching LinkedIn.com was still several years away.
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`19.
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`The claims of the Asserted Patents are not drawn to laws of nature, natural phenomena, or
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`abstract ideas. Although the systems and methods claimed in the Asserted Patents are ubiquitous
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`now (and, as a result, are widely infringed), the specific combinations of elements, as recited in
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`the claims, was not conventional or routine at the time of the invention.
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`20.
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`Further, the claims of the Asserted Patents contain inventive concepts which transform the
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`underlying non-abstract aspects of the claims into patent-eligible subject matter.
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`21.
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`Consequently, the claims of the Asserted Patents recite systems and methods resulting in
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`improved functionality of the claimed systems and represent technological improvements to the
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`operation of computers.
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`22.
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`The ’194 Patent was examined by Primary United States Patent Examiner Franz Colby. During
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`the examination of the ’194 Patent, the United States Patent Examiner searched for prior art in
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`the following US Classifications: 705/1, 10, 11, 705/26, 707/104.1, 10, 3, and 103R.
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`23.
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`After conducting a search for prior art during the examination of the ’194 Patent, the United
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`States Patent Examiner identified and cited the following as the most relevant prior art references
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`found during the search: (i) 5,164,897, 11/1992, Clark et al.; (ii) 5,832,497, 11/1998, Taylor;
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`(iii) 5,884.270, 3/1999, Walker et al.; (iv) 5,884.272, 3/1999, Walker et al.; (v) 5,978,768,
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`11/1999, McGovern et al.; (vi) 6,324,538, 11/2001, Wesinger, Jr. et al.; (vii) 6,332,125, 12/2001,
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`Callen et al.; (viii) 6,363,376, 3/2002, Wiens et al.; (ix) 6,370,510, 4/2002, McGovern et al.; (x)
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`6,381,592, 4/2002, Reuning; and (xi) 6,385,620, 5/2002, Kurzius et al.
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`24.
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`After giving full proper credit to the prior art and having conducted a thorough search for all
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`relevant art and having fully considered the most relevant art known at the time, the United
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`States Patent Examiner allowed all of the claims of the ’194 Patent to issue. In so doing, it is
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`presumed that Examiner Colby used his or her knowledge of the art when examining the claims.
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`K/S Himpp v. Hear-Wear Techs., LLC, 751 F.3d 1362, 1369 (Fed. Cir. 2014). It is further
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`presumed that Examiner Colby has experience in the field of the invention, and that the
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`Examiner properly acted in accordance with a person of ordinary skill. In re Sang Su Lee, 277
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`F.3d 1338, 1345 (Fed. Cir. 2002).
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`25.
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`The ’086 Patent was examined by Primary United States Patent Examiner Jean M. Corrielus.
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`During the examination of the ’086 Patent, the United States Patent Examiner searched for prior
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`art in the following US Classifications: 707/104.1, 707/3, 10, 103R, 1, 2, 4, 5, 705/1, 10, 11, and
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`705/26.
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`26.
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`After conducting a search for prior art during the examination of the ’086 Patent, the United
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`States Patent Examiner identified and cited the following as the most relevant prior art references
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`found during the search: (i) 4,625,081, 11/1986, Lotito et al.; (ii) 5,164,897, 11/1992, Clark et
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`al.; (iii) 5,978,768, 11/1999, McGovern et al.; (iv) 6,370,510, 4/2002, McGovern et al.; (v)
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 9 of 45
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`6,381,592, 4/2002, Reuning; (vi) 6,385,620, 5/2002, Kurzius et al.; (vii) 6,567,784, 5/2003,
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`Bukow; (viii) 6,662,194, 12/2003, Joao; (ix) 6,873,964, 3/2005, Williams et al.; (x) 7,148,991,
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`12/2006, Suzuki et al.; and (xi) 2003/020531, 6/2003, Parker.
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`27.
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`After giving full proper credit to the prior art and having conducted a thorough search for all
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`relevant art and having fully considered the most relevant art known at the time, the United
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`States Patent Examiner allowed all of the claims of the ’086 Patent to issue. In so doing, it is
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`presumed that Examiner Corrielus used his or her knowledge of the art when examining the
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`claims. K/S Himpp v. Hear-Wear Techs., LLC, 751 F.3d 1362, 1369 (Fed. Cir. 2014). It is
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`further presumed that Examiner Corrielus has experience in the field of the invention, and that
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`the Examiner properly acted in accordance with a person of ordinary skill. In re Sang Su Lee,
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`277 F.3d 1338, 1345 (Fed. Cir. 2002).
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`28.
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`The claims of the Asserted Patents are properly issued, valid, and enforceable.
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`THE ACCUSED INSTRUMENTALITIES
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`Upon information and belief, Defendant makes, sells, advertises, offers for sale, uses, or
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`29.
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`otherwise provides the LinkedIn website and its ancillary sites in the United States. The
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`LinkedIn apparatus comprises servers, hardware, software, and a collection of related and/or
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`linked web pages for providing job search services to individuals (including job seekers,
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`recruiters, and employers) in the United States. The LinkedIn system comprises an apparatus
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`with multiple interconnected infrastructures that infringe the Asserted Patents. The public-facing
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`aspect of
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`the LinkedIn apparatus
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`is
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`the LinkedIn website, which
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`is available at
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`www.linkedin.com. Ancillary sites include the LinkedIn Talent Site (www.linkedin.com/talent),
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`the LinkedIn ProFinder Site (www.linkedin.com/profinder), and the LinkedIn Talent Solutions
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 10 of 45
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`Site (www.business.linkedin.com). Collectively, all of the foregoing comprises the “Accused
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`Instrumentalities.”
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`COUNT I
`Infringement of U.S. Patent No. 6,662,194
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`Plaintiff incorporates the above paragraphs by reference.
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`Defendant has been on actual notice of the ’194 Patent at least as early as the date it received
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`service of this Original Complaint.
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`30.
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`31.
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`32.
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`Upon information and belief, Defendant owns and controls the operation of the Accused
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`Instrumentalities and generates substantial financial revenues therefrom.
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`33.
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`Upon information and belief, Defendant has directly infringed and continues to directly infringe
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`at least Claim 1 of the ’194 Patent by making, using, importing, selling, and/or, offering for sale
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`the Accused Instrumentalities.
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`34.
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`The Accused Instrumentalities comprise an apparatus for providing recruitment information.
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`The infringing apparatus comprises servers, hardware, software, and a collection of related
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`and/or linked web pages for providing job search services to individuals (including job seekers,
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`recruiters, and employers) in the United States. The Accused Instrumentalities comprise an
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`apparatus with multiple interconnected infrastructures, including but not limited to what
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`LinkedIn refers to as Streams, Search, Data Storage, Feed, and Machine Learning.
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 11 of 45
`Case 6:20-cv-00545—ADA Document 1 Filed 06/17/20 Page 11 of 45
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`
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`Job alerts
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`Saved job alerts
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`X
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`Saved job alerts
`You can turn onjob alerts from any of your
`recent job searches
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`Job recommendations from Linkedln
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`Get job recommendations
`Get job recommendations based on your profile, interests and activity
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`Cir C
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`® Job address or city
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`Start job post
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`See, e.g., LinkedIn web pages at www.linkedin.com
`See, e.g., Linkedln web pages at www.1inkedin.com
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`System Design and Architecture
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`Linkedln has built a search stack on top of Lucene called Galene, and contributed to
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`various plug-ins, including capability to live—update search index. The search index
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`consists of two types of fields:
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`. The inverted field: a mapping from search terms to the list of entities (members)
`that contain them.
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`. The fonuard field: a mapping from entities (members) to metadata about them.
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`These search index fields contribute to the evaluation of machine learning feature
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`values in search ranking. The freshness of data in the search index fields is also of
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`high importance for machine learning features.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 12 of 45
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`See also, e.g., The AI Behind LinkedIn Recruiter Search and Recommendation Systems, available at
`https://engineering.linkedin.com/blog/2019/04/ai-behind-linkedin-recruiter-search-and-
`recommendation-systems
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 13 of 45
`Case 6:20-cv-00545—ADA Document 1 Filed 06/17/20 Page 13 of 45
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`
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`Feed Infrastructure
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`Feed Infrastructure owns multiple large scale distributed
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`systems that power the feeds and many of the search
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`experiences core to our Linkedln members’ experiences. Our
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`technology domain includes information retrieval, machine
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`learning, and distributed datastore.
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`
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`See, e.g., LinkedIn Engineering Infrastructure Page, available at
`See, e.g., Linkedln Engineering Infrastructure Page, available at
`https://engineering.linkedin.com/teams/data/data-infrastructure
`https://engineering.1inkedin.com/teams/data/data-infrastructure
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`
`§€ kafkoi
`
`Apache Kafka is a core part ofour is a core part of our
`infrastructure at Linkedln. It was originally developed in—house
`as a stream processing platform and was subsequently open
`sourced. Today, it’s widely used by the industry, has an active
`community, and few companies — if any — do so at Linkedln’s
`scale.
`
`@|samza
`
`Kafka
`
`
`Samza
`
`Apache Samza enables data processing in near real-time. At
`Linkedln, Samza operates at a massive scale, enabling
`thousands of applications, tens of thousands of containers to
`process trillions of messages each day.
`
`Learn more
`
`
`
`
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 14 of 45
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`See also, e.g. LinkedIn Engineering Information at https://engineering.linkedin.com/teams/data/data-
`infrastructure/streams
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`35.
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`Upon information and belief, the servers for the LinkedIn Accused Instrumentalities and are in
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`Newark, New Jersey and in Des Moines, Iowa.
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`
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`See, e.g., Data Obtained from https://check-host.net/ip-info?host=www.linkedin.com
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 15 of 45
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`36.
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`Upon information and belief, the LinkedIn Accused Instrumentalities comprises data centers
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`housing memory devices, processing devices, and transmitters. Such data centers are in Oregon,
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`Virginia, and Texas. See, e.g., Business Article “LinkedIn Expands With Texas Data Center,”
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`excerpted below,
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`at: https://www.datacenterknowledge.com/archives/2013/11/06/linkedin-
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`expands-with-dallas-data-center. The data center location in Texas is strategic and represents an
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`important business advantage to LinkedIn’s business model. See, e.g., LinkedIn Engineering
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`Blog,
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`excerpted
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`below,
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`and
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`available
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`at:
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`https://engineering.linkedin.com/blog/2015/11/introducing-linkedins-west-coast-data-center.
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`
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`
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`37.
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` The LinkedIn Accused Instrumentalities comprises a sophisticated architecture, working
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`together as an apparatus to provide employment and recruiting services to users throughout the
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`United States. See, e.g., LinkedIn Engineering Article entitled: “A Brief History of Scaling
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`LinkedIn,” available at: https://engineering.linkedin.com/architecture/brief-history-scaling-
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`linkedin. The infringing LinkedIn “geographically close data centers” facilitate and enhance the
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`effectiveness of LinkedIn’s business model for the benefit of its customers.
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 16 of 45
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`38.
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` The LinkedIn Accused Instrumentalities comprises a memory device, which stores information
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`regarding at least job openings, positions, assignments, contracts, and/or projects.
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`39.
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`As noted above, the LinkedIn infrastructure comprises a “Storage Infrastructure,” which
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`efficiently stores large volumes of data. The “Storage Infrastructure” comprises, inter alia, data
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`centers with servers which serve as memory devices for the system. Upon information and
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`belief, the LinkedIn database is maintained in the Espresso datastore.
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 17 of 45
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`
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`See, e.g., LinkedIn Engineering Information at: https://engineering.linkedin.com/teams/data/data-
`infrastructure/storage-infra
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`40.
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`Upon information and belief, the LinkedIn Accused Instrumentalities comprises multiple data
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`centers in the United States, and each LinkedIn member is assigned a primary data center, as
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`well as a secondary data center, depending on geographical distance from the member to the data
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`centers.
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 18 of 45
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`
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`See, e.g., LinkedIn Engineering Blog at https://engineering.linkedin.com/blog/2019/eliminating-toil-
`with-fully-automated-load-testing
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`41.
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`The LinkedIn infrastructure further comprises a “Search Infrastructure,” which provides a means
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`for searching for posted Jobs. Data relating to each such “Job” is stored in memory devices (e.g.,
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`servers) under the direction and control of LinkedIn, and responsive data is returned to a user of
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`the LinkedIn system when queried. Upon information and belief, the “Job” information stored
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`by the LinkedIn system includes all the following: job openings, positions, assignments,
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`contracts, and projects.
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`42.
`
`The below example, which was conducted in Allen, Texas on June 9, 2020, illustrates the range
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`of “Job” data stored by LinkedIn relating to a search for an “Intellectual Property Specialist” in
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`the United States.
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 19 of 45
`Case 6:20-cv-00545—ADA Document 1 Filed 06/17/20 Page 19 of 45
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`
`IP Docket Specialist Promoted
`MARcw
`““5“ Marcum Search LLC
`Orange County, California United States
`@ Actively recrumng
`
`4 weeks ago a 19 applicants - m Easy Apply
`Intellectual Property Docket Specialist Promoted
`Marcum Search LLC
`Costa Mesa. California United States
`
`@ Actively recruiting
`1 week ago m Easy Apply
`
`Intellectual Property Paralegal
`Adams 8t Maitin Group
`Sacramento, California. United States
`
`Promoted
`
`@ Actively recrumng
`4 weeks age ' fl E85" Apply
`lP/Trademark Docketing Specialist
`Munck Wilson Mandala LLP
`DallaerOl‘I WOIth Metroplex
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`64>
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`lP Docket Specialist
`Marcum Search LLC - Oran 6 Count ,
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`California, Ulilted States
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`Posted 4 weeks ago- 107 VIEWS
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`AVAirNVSquN’V‘Co‘ANNV
`MARCUM
`8 E A R C H
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`Job
`. 5],? skills match
`- 19 applicants
`
`Posted by
`
`P n E M i u M
`Sharon Sognalian
`Send lnMail
`Director, Marcum Search LLC
`Lane international law firm has an immediate oooenin for an Intellectual Pro- ,
`
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`
`
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`
`Experience Level V
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`All filters
`
`3 Internship (4)
`
`3 Entry level (45)
`
`MARCUN 3 Associate (27)
`§.E5§J§sg$ :] Mid—Senior level (13)
`
`3 Director (1)
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`
`
`3 Executive (0)
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`1!, ' Iytonult' I vwv CV!
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`I I"V‘I\l'
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`19
`19
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`

`

`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 20 of 45
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`
`
`
`
`See, e.g., LinkedIn.com search results at:
`https://www.linkedin.com/jobs/search/?currentJobId=1860548095&keywords=intellectual%20property
`%20specialist
`
`43.
`
`As illustrated, the LinkedIn Accused Instrumentalities stores information regarding at least “job
`
`openings,” and such information includes at least the date posted, employer name, required
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`20
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`

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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 21 of 45
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`experience level, number of applicants, job requirements, benefits, job description, name of
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`person posting the information, industry, employment type, and an assessment of how the person
`
`performing the search satisfies the job criteria as posted.
`
`44.
`
`The memory device of the LinkedIn Accused Instrumentalities further stores information
`
`regarding a job search request or inquiry. Upon information and belief, each individual search
`
`performed by users of the LinkedIn Accused Instrumentalities are stored in memory by LinkedIn
`
`to generate responsive search results to the user (as illustrated above).
`
`45.
`
`Further upon information and belief, information regarding each job search performed by users is
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`stored by LinkedIn for improving and informing its internal algorithms and its Search
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`Infrastructure. As advertised by LinkedIn, information regarding job search requests are
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`incorporated into the “Search Infrastructure,” which is powered by bringing together
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`“information retrieval, machine learning, distributed systems, big data, and other fundamental
`
`areas of computer science.”
`
`
`
`See, e.g., LinkedIn Engineering Infrastructure Page at https://engineering.linkedin.com/teams/data/data-
`infrastructure
`
`46.
`
`Upon information and belief, the LinkedIn Accused Instrumentalities stores information
`
`regarding each job search performed, which is evidenced by the fact that individual job postings
`
`reflect the total number of times it has been viewed, as well as the total number of applicants for
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`21
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`

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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 22 of 45
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`the position. By way of example, the illustrative job opening cited above (and copied again
`
`below) indicates it has been “viewed” 107 times and has received 19 applicants.
`
`
`
`See, e.g., LinkedIn.com search results at:
`https://www.linkedin.com/jobs/search/?currentJobId=1860548095&keywords=intellectual%20property
`%20specialist
`
`47.
`
`Upon information and belief, the LinkedIn Accused Instrumentalities stores information
`
`regarding job search requests and/or inquiries, which is evidenced by the fact that users of the
`
`LinkedIn system can set “Job Search Alerts.” Upon information and belief, a LinkedIn “Job
`
`Search Alert” relies upon stored information regarding the user’s job search request or inquiry,
`
`which is used to generate responsive emails and/or notifications to the user. By way of example,
`
`the above-referenced job search for an “Intellectual Property Specialist in the United States” can
`
`be used as the basis for a daily or weekly “Job Search Alert.”
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`22
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`
`
`

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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 23 of 45
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`48.
`
`In addition, upon information and belief, the LinkedIn Accused Instrumentalities stores
`
`information regarding job search requests and/or inquiries, which is evidenced by the fact that
`
`users of the LinkedIn system can “Save” a job in a “Jobs Tracker.” For example:
`
`
`
`49.
`
`The LinkedIn Accused Instrumentalities comprises a processing device. As noted above, the
`
`LinkedIn Accused Instrumentalities comprises servers, hardware, software, and a collection of
`
`related and/or linked web pages for providing job search services to individuals (including job
`
`seekers and employers) in the United States. The LinkedIn Accused Instrumentalities comprises
`
`an apparatus with multiple interconnected infrastructures, including but not limited to what
`
`LinkedIn refers to as Streams, Search, Data Storage, Feed, and Machine Learning.
`
`50.
`
`The LinkedIn “Search Infrastructure” comprises a processing device, which allows users of the
`
`LinkedIn system so search for people, jobs, companies, groups, and other professional content.
`
`To power these solutions, the LinkedIn Search Infrastructure brings together information
`
`retrieval, machine learning, distributed systems, big data, and other fundamental areas of
`
`computer science.
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`23
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`

`

`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 24 of 45
`
`See, e.g., LinkedIn Engineering Infrastructure Page at https://engineering.linkedin.com/teams/data/data-
`infrastructure
`
`51.
`
`As explained by LinkedIn, the processing device of the Accused Instrumentalities comprises at
`
`least a “Federation Layer,” a “Serving Platform,” and a “Search Engine.” For example:
`
`
`
`See, e.g., LinkedIn Engineering Infrastructure Page at https://engineering.linkedin.com/teams/data/data-
`infrastructure/search-and-discovery
`
`52.
`
`The LinkedIn processing device of the Accused Instrumentalities processes the information
`
`regarding a job search request or inquiry upon a detection of an occurrence of a searching event,
`
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`24
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`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 25 of 45
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`wherein the searching event is an occurrence of, for example, a job posting by an employer or a
`
`hiring entity.
`
`53.
`
`As noted above, the LinkedIn Accused Instrumentalities allows users to set “Job Search Alerts.”
`
`Upon information and belief, a LinkedIn “Job Search Alert” relies upon stored information
`
`regarding the user’s job search request or inquiry, which is used to generate responsive emails
`
`and/or notifications to the user. By way of example, the above-referenced job search for an
`
`“Intellectual Property Specialist in the United States” can be used as the basis for a daily or
`
`weekly “Job Search Alert.”
`
`
`
`54.
`
`Upon information and belief, the LinkedIn processing device of the Accused Instrumentalities
`
`causes an Email or Notification to be delivered to the creator of the Job Search Alert upon a
`
`detection on the part of LinkedIn of, for example, a job posting by an employer or hiring entity.
`
`More specifically, when an employer creates a job posting which matches the “Job Search Alert”
`
`criteria, the user is notified.
`
`55.
`
`Likewise, the LinkedIn Accused Instrumentalities allows employers and/or job recruiters to
`
`search for potential qualified employees. As part of this service, LinkedIn allows users to inform
`
`recruiters of their individual interest in seeking employment opportunities. Upon information
`
`and belief, the LinkedIn processing device of the Accused Instrumentalities processes
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`25
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`

`

`Case 6:20-cv-00545-ADA Document 1 Filed 06/17/20 Page 26 of 45
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`information regarding a job search request or inquiry (e.g., the notice of a user’s interest in
`
`seeking employment opportunities) upon a detection of an occurrence of a searching event,
`
`wherein such event is, for example, a posting of new information from an individual, or an event
`
`which creates an interest by an employer. Fo