Content Aware LLC v. Reliance Retail Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Content Aware, LLC (Virginia)
  • Defendant: Reliance Retail Limited (India)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:26-cv-00068, E.D. Tex., 01/23/2026
• Venue Allegations: Venue is alleged to be proper in the district on the basis that the defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s products and services infringe a patent related to systems for recognizing and categorizing objects within digital content to determine brand correlations and marketing insights.
• Technical Context: The technology at issue involves automated, AI-driven analysis of user-generated digital media (e.g., photos, videos) to identify brands, products, and demographic information from both foreground and background elements for marketing intelligence purposes.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 11,107,098 - System and method for content recognition and data categorization

• Patent Identification: U.S. Patent No. 11,107,098, System and method for content recognition and data categorization, issued August 31, 2021.

The Invention Explained

• Problem Addressed: The patent's background section describes a market need for more sophisticated analysis of digital content beyond what was currently available '098 Patent, col. 2:5-10 It notes that while massive amounts of data are collected, existing systems were "barely scratching the surface of what can be mined and cataloged per piece of content," failing to capture valuable information about demographics, goods, and brands present in the background of images and videos col. 2:8-15
• The Patented Solution: The invention is a system that captures digital content from various providers, uses machine learning and AI to identify objects in both the foreground and background, and catalogs these objects in a structured database '098 Patent, Abstract; Fig. 3 This system is designed to determine relationships between different brands and products appearing in content, allowing users (e.g., businesses) to gain a "deeper understanding" of consumer behavior, brand associations, and market competition col. 6:54-59
• Technical Importance: The technology purports to enable more granular and context-aware marketing intelligence by analyzing the entirety of a digital asset, not just its primary subject matter or associated text '098 Patent, col. 1:16-20

Key Claims at a Glance

• The complaint asserts infringement of one or more claims of the ’098 Patent, referring to them as the "Exemplary '098 Patent Claims" without specifying them Compl. ¶11 Independent Claim 1 is representative and includes the following essential elements:
  • A system with a server maintaining a database that communicates with third-party content providers and user devices.
  • Storing unique user profiles, each associated with at least one "brand identifier."
  • Collecting captured content (e.g., images) in various formats.
  • Identifying objects within the content using Optical Character Recognition (OCR).
  • Transforming extracted data into a standardized format by cataloging items in "foregrounds and backgrounds" using machine learning and AI.
  • Searching the database to identify "potential associated brand identifiers" based on user profiles and the object data.
  • Determining a "brand correlation" between a user's primary brand identifier and the potential associated brand identifiers to identify "consumer overlap."
  • Presenting data representing the identified potential associated brand identifiers to the user.
• The complaint does not explicitly reserve the right to assert dependent claims, but alleges infringement of "one or more claims" Compl. ¶11

III. The Accused Instrumentality

Product Identification

• The complaint accuses unspecified "Exemplary Defendant Products" Compl. ¶11

Functionality and Market Context

• The complaint does not name or describe the accused products in the main body of the pleading. It states that charts identifying the products and comparing them to the patent claims are included in an "Exhibit 2" Compl. ¶¶14, 16 As this exhibit was not filed with the complaint, the public record does not currently specify which of Defendant's products are accused or describe their specific functionality. The complaint alleges that the accused products have been made, used, sold, and imported in the United States by Defendant and its customers Compl. ¶11

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from an unprovided "Exhibit 2," alleging these charts demonstrate how the "Exemplary Defendant Products" practice the technology claimed by the ’098 Patent Compl. ¶¶16-17 In the absence of these charts, the complaint's narrative theory is that the accused products "satisfy all elements of the Exemplary '098 Patent Claims" Compl. ¶16 No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the language of Claim 1 of the ’098 Patent and the general nature of the dispute, several points of contention may arise:
  • Scope Questions: A central dispute may concern the scope of "brand correlation" col. 23:1-4 The infringement analysis will turn on whether the accused products perform a function that meets this claimed step of determining "additional brands that have a consumer overlap."
  • Technical Questions: A key factual question will be what, if any, "Optical Character Recognition technology" the accused products employ to identify objects, as required by Claim 1 col. 22:46-48 The complaint does not provide evidence on this point. Further, it raises the question of whether the accused system specifically distinguishes between and catalogs items from the "foregrounds and backgrounds" of content, another required element col. 22:55-59

V. Key Claim Terms for Construction

• The Term: "brand identifier"

  • Context and Importance: This term appears in Claim 1 and is fundamental to the patent's purpose of linking users, content, and brands. Its construction will define what types of user-associated information can serve as the baseline for the system's "brand correlation" analysis. Practitioners may focus on this term because its potential breadth could significantly impact the scope of infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a non-limiting list that includes not only a "trademark" but also "animation, text, movies...musical bands or genres, celebrities, historical or religious figures, geographic locations, colors, patterns, occupations, hobbies or any other thing that can be associated with some demographic information" '098 Patent, col. 6:14-21
    • Evidence for a Narrower Interpretation: The core of the claim relates to associating user profiles with brands for market analysis. A defendant may argue that, in the context of the claim as a whole, "brand identifier" should be limited to commercial indicators like trademarks and logos, rather than general hobbies or colors.

• The Term: "brand correlation"

  • Context and Importance: This is the core analytical step recited in Claim 1. The infringement case hinges on whether the accused system performs an analysis that constitutes a "brand correlation." The definition of this term will dictate the specific type of data processing and output required to infringe.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not define the term with a specific algorithm, which may suggest that any process that identifies relationships or overlaps between brands based on content analysis could meet the limitation.
    • Evidence for a Narrower Interpretation: Claim 1 explicitly links this term to the function of "assist[ing] the first unique user in determining additional brands that have a consumer overlap" '098 Patent, col. 23:1-4 This language could support an interpretation requiring a specific output that quantifies or identifies consumer overlap, not merely a generic association between two brands found in the same piece of content.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that allegedly infringes the ’098 Patent Compl. ¶14
• Willful Infringement: The complaint does not use the term "willful." However, it alleges that the service of the complaint provides Defendant with "Actual Knowledge of Infringement" Compl. ¶13 This allegation lays the groundwork for a potential claim of post-suit willful infringement if Defendant's allegedly infringing conduct continues.

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

1. A core issue will be one of definitional scope: How broadly will the court construe key claim terms like "brand identifier" and "brand correlation"? The outcome may depend on whether these terms are interpreted to cover a wide range of demographic associations and data analytics, or if they are limited to more specific commercial and algorithmic functions described in the patent's embodiments.
2. A primary challenge for the plaintiff will be one of evidentiary proof: Given the complaint's lack of specific factual allegations regarding the accused products' operation, the case will likely turn on whether discovery reveals evidence that the accused systems perform each discrete step of the asserted claims, particularly the use of OCR and the specific process for determining "brand correlation."