Adaptive Avenue Associates Inc v. Motorola Mobility LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Adaptive Avenue Associates, Inc. (Minnesota)
  • Defendant: Motorola Mobility LLC (Delaware)
  • Plaintiff's Counsel: Direction IP Law
• Case Identification: 1:26-cv-09049, N.D. Ill., 07/30/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because the Defendant's principal place of business is located in Chicago, Illinois, and infringing acts are alleged to have occurred within the district.
• Core Dispute: Plaintiff alleges that Defendant's corporate website, www.motorola.com, infringes two patents related to systems and methods for creating and displaying automated slideshows of web content.
• Technical Context: The technology concerns server-side systems for assembling lists of URLs and presenting them in a timed, sequential "slideshow" format to website visitors, aiming to automate content delivery and improve user engagement.
• Key Procedural History: The complaint notes that U.S. Patent No. 7,428,707 is a continuation-in-part of the application that issued as U.S. Patent No. 7,171,629, and that the two patents share an identical specification. The complaint also references the prosecution history of the '707 patent to distinguish the invention from prior art.

Case Timeline

Date	Event
2000-10-20	Priority Date for '629 and '707 Patents
2007-01-30	'629 Patent Issued
2008-09-23	'707 Patent Issued
2026-07-30	Complaint Filed

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

U.S. Patent No. 7,171,629 - Customizable Web Site Access System And Method Therefore

• Patent Identification: U.S. Patent No. 7,171,629, "Customizable Web Site Access System And Method Therefore," issued January 30, 2007 Compl. ¶9

The Invention Explained

• Problem Addressed: The patent's background describes the challenges of web navigation at the time, noting that viewing content was often "tedious and labor-intensive" and that existing presentation technologies required costly reprogramming of a website Compl. ¶16 Compl. ¶17 '629 Patent, col. 7:60-67 The inventor sought to provide a more dynamic way to present sequences of web pages without requiring client-side software installation Compl. ¶14 Compl. ¶18
• The Patented Solution: The patent describes a server-side system comprised of a "composer" and a "performer" Compl. ¶20 '629 Patent, FIG. 1 A developer or an automated system uses the composer to create a "presentation," which consists of a list of URLs, a display sequence, and display durations '629 Patent, abstract The performer then automatically displays this presentation to a web user as a "slide show," with controls to pause, navigate, or modify the presentation '629 Patent, col. 10:1-24
• Technical Importance: This technology aimed to improve user engagement by replacing "passive" site browsing with an "active," guided tour model, thereby helping to retain visitor attention and more effectively deliver content Compl. ¶19 '629 Patent, col. 13:30-50

Key Claims at a Glance

• The complaint asserts independent claim 11 Compl. ¶27
• The essential elements of claim 11 include:
  • Remotely invoking a "composer" operating on a host server.
  • Creating a "presentation" in the composer by establishing a list of URLs (via manual entry or a query-based system), determining a display sequence, and determining a display duration.
  • Remotely invoking a "performer" on the host server to present the created presentation.
  • Automatically locally displaying the presentation in a slide show format, where each URL is a slide.
  • Each slide is automatically displayed to a user for a pre-determined duration as a portion of a web page.

U.S. Patent No. 7,428,707 - Customizable Web Site Access System And Method Therefore

• Patent Identification: U.S. Patent No. 7,428,707, "Customizable Web Site Access System And Method Therefore," issued September 23, 2008 Compl. ¶41

The Invention Explained

• Problem Addressed: The '707 Patent shares its specification with the '629 Patent and addresses the same general problems Compl. ¶45 The complaint emphasizes that, according to the prosecution history, the invention was unconventional because prior art slideshows were composed manually and stored as static files, a cumbersome process Compl. ¶46
• The Patented Solution: This patent focuses on an "auto-composing" system Compl. ¶45 The system composes a slideshow by automatically "extracting" "web page details" from a desired web page to create a list of URLs '707 Patent, abstract These details can be a plurality of hyperlinks, a presentation text file, or a meta tag found within the page Compl. ¶50 '707 Patent, cl. 7
• Technical Importance: The invention provided a method to automatically generate a web slideshow from the content of an existing webpage, streamlining the creation process that was previously manual and static Compl. ¶46

Key Claims at a Glance

• The complaint asserts independent claim 7 Compl. ¶47
• The essential elements of claim 7 include:
  • Composing a presentation for a desired web page by creating a list of URLs.
  • This composing step comprises one or more of: automatically "extracting" a plurality of hyperlinks from the page, "extracting" a presentation/rendition text file from the page, or "extracting" a meta tag from the page.
  • Automatically displaying the presentation in the order of the created list of URLs.

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is the website www.motorola.com, and specifically the web slideshow or "carousel presentation" feature on its homepage Compl. ¶27 Compl. ¶47 Compl. ¶28

Functionality and Market Context

• The complaint alleges that the homepage of www.motorola.com features an automated slideshow that presents a series of promotional content or images in sequence Compl. ¶28 Compl. ¶35 Exhibit E provided in the complaint shows a screen capture of the Motorola homepage with a large "web slideshow seen in the upper portion" Compl. ¶28 The complaint alleges this slideshow is generated and controlled by server-side resources (HTML, JavaScript, CSS) that create a presentation from a list of URLs and display it to the user Compl. ¶29 This feature is presented as a method for viewing "featured promotional offerings" Compl. ¶34

IV. Analysis of Infringement Allegations

'629 Patent Infringement Allegations

Claim Element (from Independent Claim 11)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
remotely invoking a composer operating on a host server;	A web browser or other remote application invokes a composer on Defendant's host server that accepts a list of URLs for the slideshow presentation Compl. ¶29	¶29	col. 9:1-15
creating a presentation in said composer, wherein said step of creating comprises the steps of: establishing a list of URLs in said composer by one of a plurality of list establishment methodologies... comprising manual entry via a user interface portion of the composer and automatic entry by a query-based system;	The system establishes a list of URLs for the carousel, which comprises two slides as shown in Exhibit C Compl. ¶31 This list is allegedly established through manual entry via a user interface or automatic entry by querying a database Compl. ¶31	¶31	col. 14:1-3
determining a display sequence of said list of URLs in said composer;	The resulting display sequence is allegedly evident in the source code and the slide sequence shown in the complaint's exhibits Compl. ¶32	¶32	col. 9:44-51
determining a duration of display for said list of URLs in said composer;	The composer accepts a pre-set display duration for each URL in the slideshow, which advance automatically based on this duration Compl. ¶33	¶33	col. 9:44-51
remotely invoking a performer operating on said host server to present said created presentation;	A user's navigation to www.motorola.com remotely invokes the performer, which is required to view the automated slideshow Compl. ¶34	¶34	col. 9:1-15
and automatically locally displaying the created presentation...in a slide show format...wherein each of said plurality of URLs comprises a slide...and wherein each slide is automatically displayed...for the pre-determined display duration as at least a portion of a web page.	The performer, including code and resources on the host server, provides for the automated slideshow on the website Compl. ¶35 Each slide advances automatically based on a pre-set duration, with the "transform: translate3d" variable progressively rotating through values Compl. ¶37	¶35; ¶37	col. 10:1-10

'707 Patent Infringement Allegations

Claim Element (from Independent Claim 7)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
composing a presentation for a desired web page by creating a list of URLs, wherein said step of composing comprises... automatically extracting a plurality of hyperlinks from the desired web page, wherein the plurality of hyperlinks provides the URLs...	The system composes a presentation by creating a list of URLs Compl. ¶49 The complaint alleges the system automatically extracts "web page details," and identifies the image URLs used in the slideshow (shown in Exhibit C) as the extracted hyperlinks Compl. ¶50	¶49; ¶50	col. 8:19-23
and automatically displaying said presentation, wherein said presentation is presented in order of the created list of URLs.	The presentation is automatically displayed when a user enters the website, with software components loading and advancing the URLs in order Compl. ¶51 The complaint notes this is a condition of accessing the site, with no user ability to opt out Compl. ¶52	¶51; ¶52	col. 8:42-45

Identified Points of Contention

• Scope Questions: A likely point of contention for the '629 patent will be whether the general-purpose, server-side scripts of a modern website architecture constitute the distinct "composer" and "performer" components as described and depicted in the patent Compl. ¶20 '629 Patent, FIG. 1
• Technical Questions: A key technical question for the '707 patent is the meaning of "automatically extracting." The complaint alleges that the use of image URLs in the slideshow means those URLs were "automatically extracted" Compl. ¶50 The case may turn on whether the accused system actively parses the webpage to find and collect hyperlinks, as the patent language suggests, or if it simply renders a pre-configured list of URLs provided by a backend content management system. The complaint's visual evidence, such as the HTML screenshot in Exhibit A, shows the structure of the final slideshow but may not, by itself, resolve how that structure was generated Compl. ¶28

V. Key Claim Terms for Construction

• The Term: "composer" and "performer" '629 Patent, cl. 11

  • Context and Importance: These terms define the core functional modules of the claimed system. Infringement of claim 11 depends on whether the functionality of the Accused Instrumentality can be mapped onto these specific components. Practitioners may focus on these terms because the patent depicts them as discrete blocks, which may not align with how modern, integrated web applications are architected.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The abstract describes the invention as a "software program incorporating both a composing portion and a performing portion," suggesting they are functional aspects of a single program rather than necessarily separate applications '629 Patent, abstract
    • Evidence for a Narrower Interpretation: Figure 1 explicitly shows "Composer 12" and "Performer 14" as distinct boxes interacting with each other and external users/systems on a "Host Server" '629 Patent, FIG. 1 This could support an argument that they must be structurally separate and identifiable modules.

• The Term: "automatically extracting" '707 Patent, cl. 7

  • Context and Importance: This term is central to the "auto-composing" concept of the '707 patent. The infringement allegation hinges on whether the accused system's method of generating its URL list qualifies as "extracting" them from the webpage itself.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A broad, functional reading might suggest that any process where the final displayed page contains both the slideshow and the URLs that feed it could be considered "extraction," as the URLs are conceptually taken from the page's data set.
    • Evidence for a Narrower Interpretation: The specification describes this as one of three specific methods for auto-composition, distinct from manual creation, and refers to reviewing a page and "extracting all hyperlinks, i.e., href's" '707 Patent, col. 8:20-23 The complaint itself notes that the prosecution history distinguished this automatic process from the prior art Compl. ¶46, which may support a narrower definition requiring an active parsing or discovery of URLs from the webpage's content, rather than simply using a pre-configured list to generate the page.

VI. Other Allegations

• Indirect Infringement: The complaint alleges direct infringement by the Defendant. However, for steps that involve a web user (e.g., navigating to the website to invoke the "performer"), the complaint argues that this performance is "attributable to Defendant" because Defendant "directed or controlled performance" by conditioning access to the website and its content on the performance of the claimed steps Compl. ¶34 Compl. ¶52 This theory of liability for the actions of a third party is central to the direct infringement claim.

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

This case presents two central questions for the court that are common in software patent litigation: one of architectural mapping and one of technical operation.

• A core issue will be one of architectural equivalence: can the functional descriptions of a "composer" and "performer" from the '629 patent, which are depicted as discrete modules, be mapped onto the integrated, script-based architecture of a modern commercial website, or is there a fundamental mismatch?
• A key evidentiary question will be one of technical process: for the '707 patent, does the accused website perform the specific act of "automatically extracting" hyperlinks from a webpage to create a slideshow, or does it simply render a pre-configured list of content from a database? The answer will determine if the accused functionality aligns with the claimed invention or represents a different, non-infringing technical approach.