Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 1 of 30
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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` Case No. 6:21-cv-00532-ADA
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`
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`MEDALLIA INC.,
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`Plaintiff,
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`v.
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`CONTENT SQUARE SAS,
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`Defendant.
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`
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`AMENDED COMPLAINT FOR PATENT INFRINGEMENT AND
`DEMAND FOR JURY TRIAL
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 2 of 30
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`Plaintiff Medallia Inc. (“Plaintiff” or “Medallia”), by and through its counsel, files its
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`First Amended Complaint against Defendant Content Square SAS (“Defendant” or “Content
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`Square”) and alleges as follows:
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`NATURE OF THE ACTION
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`1.
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`This is a civil action for infringement of Plaintiff’s United States Patent No.
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`8,886,552 (“the ‘552 Patent”) by Defendant under the patent laws of the United States, 35 U.S.C.
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`§ 1 et seq.
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`2.
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`PARTIES
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`Plaintiff Medallia is a publicly traded corporation organized and existing under
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`the laws of the State of Delaware. Medallia maintains an office within this Judicial District at
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`211 East 7th St., Floor 11, Austin, TX 78701.
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`3.
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`Upon information and belief, Defendant Content Square SAS is a company
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`organized and existing under the laws of France, having its principal place of business at 5
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`Boulevard de la Madeleine, 75001 Paris, France.
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`4.
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`Upon information and belief, Content Square has over 700 employees located in
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`France, Israel, the United States, Japan, the United Kingdom, and Germany, including in Austin,
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`Texas.
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`JURISDICTION AND VENUE
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`5.
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`This action arises under the patent laws of the United States, 35 U.S.C. § 1 et seq.,
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`including 35 U.S.C. § 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§
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`1331 and 1338(a).
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`6.
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`This Court has personal jurisdiction over Content Square at least because Content
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`Square has committed one or more of the infringing acts complained of herein in Texas and in
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`this Judicial District. On information and belief, Content Square places infringing products into
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`the stream of commerce, and/or causes such products to be placed into the stream of commerce,
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`with the knowledge, understanding, and expectation that such products will be sold and/or used
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`in Texas and in this Judicial District. Additionally, upon information and belief, Content Square
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 3 of 30
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`maintains an office in this Judicial District, has multiple employees in this Judicial District, and
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`is currently advertising multiple open sales, marketing, and engineering positions in this Judicial
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`District. Plaintiff is informed and believes, and on that basis alleges, that Content Square derives
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`substantial revenue from the sale of infringing products in this Judicial District, expects its
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`actions to have consequences in this Judicial District, and derives substantial revenue from its
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`acts in this Judicial District. Thus, a substantial part of the events giving rise to Medallia’s claims
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`occurred and continues to occur in this Judicial District. On information and belief, Content
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`Square has purposefully availed itself of the privilege of conducting activities within the State of
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`Texas and within this Judicial District. Content Square’s activities in the State of Texas and
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`within this Judicial District are continuous and systematic and give rise to the liabilities that are
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`the subject of this Complaint. More specifically, on information and belief, Content Square’s
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`activities include, inter alia, developing, promoting, and supporting infringing products that it
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`offers for sale, sells, markets, advertises, and supports at least in part through personnel in Texas
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`and in this Judicial District. See, e.g., https://contentsquare.com/blog/the-digital-happiness-
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`summer-roadshow-2019/ (“We’re hosting our Austin roadshow at Maggie Mae’s, an iconic ‘bar’
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`that screams Austin.”) (visited on 5-23-21).
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`7.
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`Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b). On
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`information and belief, Content Square resides, and/or is deemed to reside, in this Judicial
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`District and has substantial, systematic, and continuous contacts with this Judicial District. On
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`information and belief, Content Square has committed acts of infringement in this Judicial
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`District and/or has purposefully transacted business involving the accused products in this
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`District including by, among other things, making, using, selling, offering to sell, and/or
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`importing products in this Judicial District by itself or in conjunction with others, either directly
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`or through intermediaries.
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`FACTUAL BACKGROUND
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`8.
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`Medallia is a leader in customer, employee, citizen, and patient experience
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`analytics. Medallia’s award-winning SaaS platform, the Medallia Experience Cloud, captures
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 4 of 30
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`billions of experience signals across voice, video, digital, IoT, social media, and corporate
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`messaging channels. Medallia has invested substantial time and money in developing its
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`proprietary artificial intelligence and machine learning technology to automatically uncover
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`predictive insights that drive powerful business actions and outcomes.
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`9.
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`The ‘552 Patent addresses a real need to evaluate user reaction and user
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`experience when navigating through websites over a network. The ‘552 Patent is an
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`improvement over pre-existing computer technology that enables more accurate and interactive
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`analysis of user interaction and feedback collected on the websites over the network in real time.
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`By improving the underlining computer technology for user feedback analysis, the ‘552 Patent
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`has achieved commercial success as exemplified by Medallia’s award-winning SaaS platform,
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`the Medallia Experience Cloud, which leads the market in understanding and management of
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`experience for customers, employees, patients and citizens. The ‘552 Patent invention can reduce
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`churn, turn detractors into promoters and buyers, create in-the-moment cross-sell and up-sell
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`opportunities and drive revenue-impacting business decisions.
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`10.
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`Content Square was founded in 2012 by Jonathan Cherki, who serves as CEO of
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`Content Square SAS.
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`FIRST CAUSE OF ACTION
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`(Infringement of Patent No. 8,886,552)
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`11. Medallia hereby re-alleges and incorporates by reference the foregoing
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`paragraphs of the Complaint as if fully set forth herein.
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`12.
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`The ‘552 Patent, entitled “METHOD AND SYSTEM FOR ONLINE USER
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`FEEDBACK ON WEBSITES AND SOFTWARE,” was duly and legally issued on November
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`11, 2014.
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`13. Medallia owns all right, title, and interest in the ‘552 Patent as well as the right to
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`sue for, collect, and receive damages for past, present, and future infringements of the ‘552
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`Patent. A true and correct copy of the ‘552 Patent is attached hereto as Exhibit A.
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`14.
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` The ‘552 Patent is valid and enforceable.
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 5 of 30
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`15.
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`Content Square has infringed and continues to infringe, literally and/or by the
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`doctrine of equivalents, one or more claims of the ‘552 Patent by making, using, selling, and/or
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`offering to sell its web analytics platform(s) and relatedservices (the “Accused Product” and/or
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`“Accused Service”), alone or in coordination with one or more Technology Partners
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`(https://partners.contentsquare.com/technology-partners) other than Medallia, including but not
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`limited to Momentive Global Inc. (formerly known as SurveyMonkey) and Qualtrics
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`International Inc., in violation of at least one claim of the ‘552 Patent in the United States and/or
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`importing the Accused Product into the United States. On information and belief, the Accused
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`Product and/or Accused Service infringes at least claims 1 and 9 of the ‘552 Patent because it
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`“helps companies understand hidden customer behaviors, and use those insights to drive more
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`successful experiences” (https://ContentSquare.com/).
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`16.
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`For example, the Accused Product and/or Accused Service involve(s) computer
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`systems that collect and analyze structured user feedback on websites, at least as shown by the
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`examples of the screenshots below:1
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` Highlighting, red text and text boxes have been added for emphasis to screenshots throughout
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` 1
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`the First Amended Complaint.
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 6 of 30
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`https://Content Square.com/why-Content Square/design-ux-teams/
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`https://Content Square.com/partners/ -- Video Clip “The Power of Customer Insights
`Everywhere The Content Square Experience Partner Ecosystem & Open APIs”
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`17. Moreover, at least as shown by the examples of the screenshots below, the
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`Accused Product and/or Accused Service generate(s) and provide(s) structured feedback forms
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`for providing website user feedback on website user interaction that includes user-selectable
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 7 of 30
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`feedback messages provided in a categorized and nested structure.
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`https://Content Square.com/partners/ -- Video Clip “The Power of Customer Insights
`Everywhere The Content Square Experience Partner Ecosystem & Open APIs
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`18.
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`At least as shown by the examples of the screenshots below taken from a Content
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`Square video, the Accused Product and/or Accused Service further predict that a given user
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`intends to cancel a transaction or abandon a website based on one or more website action(s) of a
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`given user, and upon making such determination, automatically present a feedback form or an
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`invitation to a feedback form to the user in order to collect and analyze feedback data. For
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`example, and without limitation, the Accused Product and/or Accused Service use a prior
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`action/behavior of a user on a website, such as a “friction signal” or “frustration signal,” to
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`identify frustrations that may result in website abandonment (bounce rate) or loss conversion (i.e.
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`transaction cancelation) in order to identify the best timing and placement to solicit feedback. At
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`the moment that a customer is experiencing frustration, the Accused Product/Service generates a
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`“live friction signal” that triggers/directs at least integrated Technology Partner Qualtrics to
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`immediately intercept and present a feedback form to the frustrated customer.
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 8 of 30
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`https://contentsquare.com/qualtrics/ -- Video Clip “Qualtrics + Contentsquare = Better Customer
`Experiences” at 1:29
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`Id. at 1:30
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 9 of 30
`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 9 of 30
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 10 of 30
`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 10 of 30
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 11 of 30
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`Id. at 1:45
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`Id. at 1:47
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`See also https://contentsquare.com/partners/, video at 0:41-1:07 (“Content Square provides
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`signals when a website or app user engages with content, struggles, hesitates, or achieves a
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`goal. Allowing you to enhance the value of these [technology partners’] technologies. …
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`[D]igging deeper into struggles you find in voice of customer tools to troubleshoot the cause of
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`complaints quickly.”).
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 12 of 30
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`As shown by at least the screen shots below, the Accused Product and/or Accused Service also
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`provide analytics of website user journeys.
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`https://Content Square.com/platform/
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`https://Content Square.com/platform/customer-journey-analytics
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 13 of 30
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`19.
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`As shown at least by the examples of the screenshots below, the Accused Product
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`and/or Accused Service also automatically collect(s) and analyze(s) website user feedback and
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`include(s) functionality to provide at least one analysis report based on multiple website users,
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`including a structured analysis report.
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`https://contentsquare.com/qualtrics/ -- Video Clip “Qualtrics + Contentsquare = Better
`Customer Experiences” at 1:19.
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 14 of 30
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`https://contentsquare.com/qualtrics/ -- Video Clip “Qualtrics + Contentsquare = Better
`Customer Experiences” at 1:21.
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`https://contentsquare.com/qualtrics/ -- Video Clip “Qualtrics + Contentsquare = Better
`Customer Experiences” at 1:24.
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 15 of 30
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`https://Content Square.com/platform/customer-journey-analytics
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`20.
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`As illustrated on Content Square’s website at least by the examples of the
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`screenshots below, the Accused Product and/or Accused Service further provide(s) a web
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`analytics interfacing functionality to receive web behavior analysis of the user, wherein the
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`analysis identifies the user behavior and produces an analysis report.
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 16 of 30
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`https://contentsquare.com/why-contentsquare/design-ux-teams/
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 17 of 30
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`https://contentsquare.com/why-contentsquare/design-ux-teams/
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 18 of 30
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`https://Content Square.com/why-Content Square/design-ux-teams/
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`https://Content Square.com/platform/customer-journey-analytics/
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 19 of 30
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`https://contentsquare.com/platform/customer-journey-analytics/
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 20 of 30
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`https://Content Square.com/why-Content Square/design-ux-teams/
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`https://Content Square.com/platform/
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`21.
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`Likewise, at least as shown by the examples of the screenshots below, the
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`automatic analysis of website user feedback produced by the Accused Product and/or Accused
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`Service include(s) factoring the received web behavior analysis in the automatic analysis and
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`producing at least one analysis report that includes an integration of the received web behavior
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`analysis.
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 21 of 30
`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 21 of 30
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`Use Contentsquares journey analysisito see
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`the mosticommon paths leading ur
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`ei
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 22 of 30
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`https://contentsquare.com/qualtrics/ -- Video Clip “Qualtrics + Contentsquare = Better Customer
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`Experiences”.
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 23 of 30
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`https://Content Square.com/platform/struggle-analysis/
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`https://Content Square.com/platform/
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`https://Content Square.com/platform/customer-journey-analytics/
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 24 of 30
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`https://Content Square.com/platform/ai-insights/
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`https://contentsquare.com/platform/struggle-analysis/
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 25 of 30
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`22.
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`Also shown at least in the screenshots from Content Square’s website provided in
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`connection with the above paragraph, the Accused Product and/or Accused Service analyze
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`feedback for each path in relation to each of two or more stages in the website-based process
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`separately leading up to the specific types of feedback and it factors in behavioral analysis for
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`each path relating to each of the two or more stages. The journey analysis of the Accused
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`Product/Service provide(s) different paths leading to different types of feedback, resulting in
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`analysis of the user feedback in relation to two or more different stages. Each path of the
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`Accused Product/Service is analyzed based on its specific type of feedback and corresponds to
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`analyzing user feedback in relation to each of two or more stages in the website-based process.
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`23.
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`Upon information and belief, Content Square has been and is also responsible for
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`direct infringement of one or more method claims of the ’552 Patent, including at least claim 9,
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`on a joint or divided infringement theory because Content Square performs one or more claimed
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`steps, and has conditioned the benefit of a financial relationship with itself on a Technology
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`Partner’s (e.g., Momentive Global’s and/or Qualtrics’) performance of at least one other method
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`step, and Content Square controls the manner or timing of that performance through contractual
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`and/or technological means.
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`24.
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`Upon information and belief, and as evidenced by the integration of their
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`respective software and/or hardware, Content Square is also liable on a joint or divided
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`infringement theory of claim 9 because it has formed a joint enterprise with its Technology
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`Partners by agreeing to each perform certain steps of claim 9 for the common purpose of
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`profiting from the marketing of products and/or services related to the Accused Product/Service,
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`with Content Square and the partner(s) having equal voices and rights of control in the joint
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`enterprise.
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`25.
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`Upon information and belief, Content Square has been and is also responsible for
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`direct infringement of one or more system claims of the ’552 Patent, including at least claim 1,
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`on a joint or divided infringement theory because at least Content Square makes and uses a
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`system that infringes through integrations that use another company’s (e.g., at least Momentive
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 26 of 30
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`Global Inc. and Qualtrics International Inc.) software and/or hardware that comprise elements of
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`the infringing system. Content Square places this system as whole into service, and thereby
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`controls it, through its operation of the Accused Product/Service. Content Square benefits from
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`this use, at least through its ability to offer the Accused Product/Service for sale to, and/or use
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`by, others. Upon information and belief, Content Square’s users also directly infringe the ’552
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`Patent in a similar manner by using the Accused Product to monitor one or more websites, which
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`places the system as whole into service, and thereby users of the Accused Product/Service
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`control the infringing system. Content Square’s users benefit from this use, at least through their
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`ability to obtain information provided by the operation of the Accused Product/Service.
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`26. Medallia is informed and believes, and on that basis alleges, that Content Square’s
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`infringement of the ‘552 Patent has been and continues to be intentional, willful, and without
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`regard to Medallia’s rights at least because it had knowledge of the ‘552 Patent (1) through
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`Content Square’s relationship with Medallia as a technology partner and in the course of
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`becoming a technology partner, Content Square performed due diligence on Medallia’s
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`offerings; (2) through interactions and/or due diligence involving ClickTale, Ltd. and Kampyle,
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`Ltd. that preceded Content Square’s acquisition of ClickTale; (3) through Content Square’s
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`attorneys at Cooley LLP who represented Medallia during the acquisition of the ‘552 Patent; (4)
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`through Content Square’s attorneys at Cooley LLP who have represented Content Square
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`adverse to Medallia subsidiaries and other parties in district court patent litigations and patent
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`proceedings before the Patent Trial & Appeal Board since at least 2020; (5) through Content
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`Square’s attendance at trade shows and conferences where Medallia’s offerings were discussed;
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`and/or (6) by service of the original Complaint. Alternatively, Content Square was at least
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`willfully blind to the existence of the ‘552 Patent.
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`27.
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`Upon information and belief, Content Square has been and is inducing
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`infringement of the ‘552 Patent through the dissemination of the products and services described
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`above and/or the creation and dissemination of promotional materials, marketing materials,
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`instructions, product manuals, professional services, and/or technical information that instruct
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 27 of 30
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`users such as its customers to use those products and services in a manner that infringes one or
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`more claims of the ‘552 Patent, including but not limited to the Content Square web pages
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`described above. Upon information and belief, Content Square has been and is engaging in such
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`acts of inducement with knowledge of the ‘552 Patent and knowledge that the induced acts
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`constitute patent infringement, or willful blindness to that fact, in violation of 35 U.S.C. §
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`271(b).
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`28.
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`Upon information and belief, Content Square has been and is contributing to the
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`infringement of the ‘552 Patent by selling or offering to sell the Accused Product, knowing it to
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`be especially made or especially adapted for practicing the invention of the ‘552 Patent and not a
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`staple article or commodity of commerce suitable for substantial non-infringing use, in violation
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`of 25 U.S.C. § 271(c).
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`29.
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` Medallia is informed and believes, and on that basis alleges, that Content Square
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`has profited from its infringement of the ‘552 Patent.
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`30.
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` Medallia has sustained damages as a direct and proximate result of Content
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`Square’s infringement of the ‘552 Patent.
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`31. Medallia will suffer and is suffering irreparable harm from Content Square’s
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`infringement of the ‘552 Patent. Medallia has no adequate remedy at law and is entitled to an
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`injunction against Content Square’s continuing infringement of the ‘552 Patent. Unless enjoined,
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`Content Square will continue its infringing conduct.
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`PRAYER FOR RELIEF
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`WHEREFORE, Medallia prays for the following relief:
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`32.
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`A judgment that Content Square has directly infringed, contributorily infringed,
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`and/or induced infringement of one or more claims of the ‘552 Patent;
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`33.
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`An order and judgment preliminarily and permanently enjoining Content Square
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`and its officers, directors, agents, servants, employees, affiliates, attorneys, and all others acting
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`in privity or in concert with them, and their parents, subsidiaries, divisions, successors, and
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`assigns from further acts of infringement of the ‘552 Patent;
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 28 of 30
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`34.
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`A judgment awarding Medallia all damages adequate to compensate for Content
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`Square’s infringement of the ‘552 Patent, including its lost profits but in no event less than a
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`reasonable royalty, along with prejudgment and post-judgment interest at the maximum rate
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`permitted by law;
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`35.
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`A judgment awarding Medallia all damages, including treble damages, based on
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`any infringement found to be willful, pursuant to 35 U.S.C. § 284, together with prejudgment
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`interest;
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`36.
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`Actual damages suffered by Medallia as a result of Content Square’s unlawful
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`conduct, in an amount to be proven at trial, as well as prejudgment interest as authorized by law;
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`37.
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`A judgment that this is an exceptional case and an award to Medallia of its costs
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`and reasonable attorneys’ fees incurred in this action as provided by 35 U.S.C. § 285; and
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`38.
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`Such other relief as this Court deems just and proper.
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`27
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`

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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 29 of 30
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`Dated: September 14, 2021
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`RIMON, P.C.
`
`By: /s/ Melissa R. Smith
`RIMON, P.C.
`Karineh Khachatourian (CA SBN 202634) Pro
`Hac Vice)
`karinehk@rimonlaw.com
`Amir A. Tabarrok (CA SBN 238781) (Pro Hac
`Vice)
`amir.tabarrok@rimonlaw.com
`David T. Xue (CA SBN 256668) (Pro Hac Vice)
`david.xue@rimonlaw.com
`Nikolaus A. Woloszczuk (CA SBN 286633) (Pro
`Hac Vice)
`nikolaus.woloszczuk@rimonlaw.com
`Oren J. Torten (CA SBN 332720) (Pro Hac Vice)
`oren.torten@rimonlaw.com
`2445 Faber Place, Suite 250
`Palo Alto, California 94303
`Telephone: 650.461.4433
`Facsimile: 650.461.4433
`
`MELISSA R. SMITH (TX SBN 24001351)
`melissa@gillamsmithlaw.com
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, TX 75670
`Telephone:
`903-934-8450
`Facsimile:
`903-934-9257
`
`Attorneys for Plaintiff MEDALLIA INC.
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`28
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`Case 6:21-cv-00532-ADA Document 26 Filed 09/14/21 Page 30 of 30
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above and foregoing
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`document has been served on this the 14th day of September, 2021 to all counsel of record who are
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`deemed to have consented to electronic service via the Court’s CM/ECF system per Local Rule
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`CV-5(b).
`
`
`
`/s/ Melissa R. Smith
`Melissa R. Smith
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`29
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