Numberai Inc v. Dream Lab Ai Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: NumberAI, Inc. d/b/a Numa (Delaware)
  • Defendant: Dream Lab AI, Inc. d/b/a Pam (Delaware)
  • Plaintiff's Counsel: Morris, Nichols, Arsht & Tunnell LLP
• Case Identification: 1:26-cv-00713, D. Del., 06/17/2026
• Venue Allegations: Venue is asserted as proper in the District of Delaware because the Defendant, Dream Lab AI, Inc., is a Delaware corporation and therefore resides in the district.
• Core Dispute: Plaintiff alleges that Defendant's AI-powered customer communication platform for automotive dealerships infringes patents related to automated, machine-learning-based communication processing, analysis, and routing.
• Technical Context: The technology at issue involves using artificial intelligence and machine learning models to automate and improve the efficiency of business-to-customer communications, a field of increasing importance for managing high-volume customer interactions across multiple channels.
• Key Procedural History: The complaint notes that U.S. Patent No. 11,553,055 is a divisional of U.S. Patent No. 10,917,483, meaning both patents share the same specification and priority date, which may streamline claim construction arguments concerning common terms.

Case Timeline

Date	Event
2017-06-22	'483 & '055 Patents Priority Date
2021-02-09	U.S. Patent No. 10,917,483 Issued
2023-01-10	U.S. Patent No. 11,553,055 Issued
2026-06-17	Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,917,483 - Automated Communication-based Intelligence Engine

• Patent Identification: U.S. Patent No. 10,917,483, issued February 9, 2021.

The Invention Explained

• Problem Addressed: The patent describes the inefficiency and error-prone nature of conventional business communication systems, which required manual effort to route communications, answer common questions, and keep business information up-to-date, leading to missed opportunities and customer frustration '483 Patent, col. 1:36-44 '483 Patent, col. 2:13-28
• The Patented Solution: The invention is a system that automates the routing of online conversations. It receives historical communications, including those that resulted in a "conversion" (e.g., a sale), and uses this data to train a "likelihood-of-conversion model" '483 Patent, col. 21:11-14 When a new communication session begins, the system uses an artificial response system (like a bot) to handle it, analyzes the communication against the trained model to determine the probability of a conversion, and then intelligently decides whether to hand the session off to a human agent, for instance, if the likelihood of a valuable interaction is high '483 Patent, abstract '483 Patent, col. 21:1-8
• Technical Importance: This technology replaces static, rule-based routing with a dynamic, predictive model, aiming to conserve human resources and network bandwidth by focusing human attention on communications with the highest potential for conversion '483 Patent, col. 16:41-44

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 Compl. ¶47
• The essential elements of independent claim 1 include:
  • receiving a plurality of communications from a plurality of secondary entities... wherein the plurality of communications include a plurality of conversions, the plurality of conversions comprising a plurality of sale transactions;
  • training a likelihood of conversion model based on the plurality of communications and... conversions;
  • receiving via a network particular communications from a particular secondary entity during a particular communication session;
  • using an artificial response system to respond to the particular communications;
  • analyzing the particular communications to determine a particular likelihood of conversion based on the likelihood of conversion model; and
  • handing off the particular communication session to a particular user from the artificial response system based on the particular likelihood of conversion.
• The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims," leaving this possibility open Compl. ¶47

U.S. Patent No. 11,553,055 - Automated Communication-based Intelligence Engine

• Patent Identification: U.S. Patent No. 11,553,055, issued January 10, 2023.

The Invention Explained

• Problem Addressed: The patent addresses the difficulty businesses face in maintaining accurate and synchronized information-such as business hours, services, or FAQs-across the many different online platforms where customers might access that information '055 Patent, col. 2:13-28
• The Patented Solution: The invention proposes a system that monitors an entity's communications (e.g., calls, texts, chats) to "build an entity model" containing business-specific data '055 Patent, col. 3:62-65 When a new, particular communication like an online chat occurs, the system applies the entity model to generate an "update" to the entity's data. This update is then applied "to a particular platform via a network," such as changing an event listing in a scheduler or updating an FAQ page, often through an Application Program Interface (API) '055 Patent, abstract '055 Patent, col. 4:5-9 '055 Patent, FIG. 8
• Technical Importance: This technology creates a specific, automated workflow to synchronize information derived from real-time communications with a business's published information on disparate platforms, improving data accuracy and reducing manual upkeep Compl. ¶14

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 Compl. ¶54
• The essential elements of independent claim 1 include:
  • monitoring a plurality of communications of a particular entity;
  • building an entity model of the particular entity based on the plurality of communications, the entity model comprising entity data;
  • monitoring at least one particular communication of the particular entity;
  • applying the entity model to the... communication to generate an update to the entity data;
  • applying the update to a particular platform via a network;
  • wherein the at least one particular communication comprises an online chat message; and
  • wherein applying the update to the particular platform comprises changing at least one of electronically published FAQs, an hours of operation listing, or an event listing via an application program interface enabled by the particular platform.
• The complaint alleges infringement of "one or more claims," which may include dependent claims Compl. ¶54

III. The Accused Instrumentality

Product Identification

The accused instrumentality is "Pam," an AI-powered customer communications and customer experience platform designed for automotive dealerships Compl. ¶34

Functionality and Market Context

The complaint alleges that the Accused Pam Product is a comprehensive communication tool that processes customer interactions across various channels, including voice, text, messages, and online inquiries Compl. ¶35 Its functionality is alleged to include an "AI receptionist" that answers common questions, routes callers to the correct department based on intent, books appointments, and captures lead details Compl. ¶36 The platform also allegedly includes sales-focused AI to convert inquiries into sales opportunities Compl. ¶36 A key alleged feature is its integration with third-party dealership systems like Dealer-FX and Tekion for managing service scheduling and other operational data in real-time Compl. ¶¶37-38 Dealerships can allegedly monitor these workflows through a "Pam Console" dashboard Compl. ¶39

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

'483 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
receiving a plurality of communications from a plurality of secondary entities during a plurality of electronic communication sessions, wherein the plurality of communications include a plurality of conversions...	The Pam product allegedly receives multiple communications from dealership customers that result in conversions such as lead captures, test-drive bookings, and vehicle purchases Compl. ¶48(a)	¶48(a)	col. 20:50-54
training a likelihood of conversion model based on the plurality of communications and on the plurality of conversions;	The Pam product is alleged to train and/or update a "likelihood-of-conversion model" based on received communications and conversion-related outcomes like lead qualification and sales opportunities Compl. ¶48(b)	¶48(b)	col. 21:11-14
receiving via a network particular communications from a particular secondary entity during a particular communication session;	The Pam product allegedly receives communications from particular dealership customers or leads during specific communication sessions Compl. ¶48(c)	¶48(c)	col. 21:15-18
using an artificial response system to respond to the particular communications;	The Pam product allegedly uses its AI receptionist and sales AI functionality to respond to communications by answering questions, collecting lead details, and routing based on intent Compl. ¶48(d)	¶48(d)	col. 21:23-25
analyzing the particular communications to determine a particular likelihood of conversion based on the likelihood of conversion model...;	The Pam product is alleged to analyze communications to determine a likelihood that a customer will engage in a sales-related transaction, based on its conversion model Compl. ¶48(e)	¶48(e)	col. 21:26-30
and handing off the particular communication session to a particular user from the artificial response system based on the particular likelihood of conversion.	The Pam product is alleged to hand off communication sessions from its AI system to a human dealership user (e.g., sales representative) based on the determined likelihood of conversion, buyer intent, or need for human support Compl. ¶48(f)	¶48(f)	col. 21:4-8

• Identified Points of Contention:
  • Scope Question: A central question may be whether the accused product's alleged function of "rout[ing] callers to the correct department based on intent" Compl. ¶36 satisfies the claim's specific, multi-step requirement of "training a likelihood-of-conversion model" and then "analyzing" new communications with that model to determine a "particular likelihood of conversion."
  • Technical Question: The complaint alleges the training of a conversion model based on outcomes like "sales opportunities" Compl. ¶48(b) A key issue for the court will be what evidence demonstrates that the accused system's AI is a predictive model trained on past "sale transactions," as the claim requires, rather than a system that operates on different principles, such as keyword-based intent recognition.

'055 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
monitoring a plurality of communications of a particular entity;	The Pam product is alleged to monitor multiple communications of a dealership, including calls, texts, messages, and chats Compl. ¶55(a)	¶55(a)	col. 3:62-63
building an entity model of the particular entity based on the plurality of communications, the entity model comprising entity data of the particular entity;	The Pam product is alleged to build an "entity model" for a dealership based on monitored communications, with the model comprising data such as workflows, customer information, and call logs Compl. ¶55(b)	¶55(b)	col. 3:63-65
monitoring at least one particular communication of the particular entity;	The Pam product is alleged to monitor specific communications such as a sales inquiry or service request Compl. ¶55(c)	¶55(c)	col. 3:66-67
applying the entity model to the at least one particular communication to generate an update to the entity data of the entity model;	The Pam product is alleged to apply its entity model to a communication to generate an update, such as updated lead details or appointment information Compl. ¶55(d)	¶55(d)	col. 4:5-7
applying the update to a particular platform via a network, wherein... the at least one particular communication comprises an online chat message... and wherein applying the update... comprises changing at least one of electronically published FAQs, an hours of operation listing, or an event listing...	The Pam product is alleged to apply updates (such as appointment or scheduling information) to dealership platforms like a scheduler (e.g., Dealer-FX, Tekion) or the Pam Console, allegedly changing an "event listing" like a service appointment via its networked integrations Compl. ¶55(e) Compl. ¶55(h) This is alleged to occur after processing an online message Compl. ¶55(f) Compl. ¶55(g)	¶55(e), (h)	col. 4:21-27

• Identified Points of Contention:
  • Scope Question: The claim requires applying an update to a platform to change an "event listing." A potential issue is whether confirming an appointment in a third-party scheduler like Dealer-FX Compl. ¶37, as the accused product allegedly does, qualifies as "changing" an "event listing" on a "particular platform" within the meaning of the claim.
  • Technical Question: The complaint alleges on "information and belief" that the product "builds... an entity model" Compl. ¶55(b) The infringement theory depends on proving that the accused system follows the specific ordered steps of the claim: first building a discrete "entity model" from a plurality of communications, and then applying that same model to a subsequent communication to generate an update. The case may turn on whether discovery reveals this specific operational architecture or an alternative one.

V. Key Claim Terms for Construction

For the '483 Patent

• The Term: "likelihood of conversion model"
• Context and Importance: This term is the technological core of claim 1. The infringement case hinges on whether the accused product's AI functionality can be characterized as this specific type of predictive model. Its construction will determine the level of technical sophistication required to infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the model in functional terms as a system that "performs a test to score a particular message or conversation" where the "score represents the probability that the message or conversation will lead to a conversion" '483 Patent, col. 16:15-19 This could support an argument that any predictive scoring mechanism for communications falls within the term's scope.
  • Evidence for a Narrower Interpretation: The claim explicitly requires the model to be trained on data from a "plurality of conversions," which are themselves defined as a "plurality of sale transactions" '483 Patent, col. 20:53-54 '483 Patent, col. 21:11-14 This language could support a narrower construction requiring the model to be trained specifically on historical sales data, not just general user interactions or intents.

For the '055 Patent

• The Term: "entity model"
• Context and Importance: The entire process in claim 1 revolves around "building" and "applying" the "entity model." The definition of this term is critical, as it will dictate whether the accused system's data architecture and processing methods fall within the claim's scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification gives a broad definition, stating an entity model "encompasses facts about the entity such as who its customers and partners are, what matters to the entity, and the tone, personality, and style that the entity wishes to convey" '055 Patent, col. 3:38-42 This could support a reading that covers any structured collection of a business's operational data.
  • Evidence for a Narrower Interpretation: The claim requires "building an entity model... based on the plurality of communications" and then "applying the entity model... to generate an update" '055 Patent, claim 1 This suggests the "entity model" is not just any database, but a specific, dynamic construct that is both created from and then used to process communications in a defined workflow, potentially limiting the term's scope to such architectures.

VI. Analyst's Conclusion: Key Questions for the Case

The resolution of this dispute will likely depend on the court's determination of several key issues:

1. A core question will be one of definitional scope and technical proof: Can Plaintiff demonstrate that the accused "Pam" platform's AI-driven routing is not merely a sophisticated rules-based engine but in fact constitutes "training" and "applying" a "likelihood of conversion model" based on actual "sale transactions," as specifically required by the claims of the '483 patent?

2. A second key issue will be one of operational architecture: Will evidence show that the accused system operates according to the precise, ordered steps of the '055 patent-namely, first "building" a discrete "entity model" from monitored communications and then using that model to generate and apply updates to external platforms-or does it utilize a fundamentally different data processing architecture to achieve a similar commercial result?