UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

BROWSE3D LLC, 

Plaintiff 

 v. 

ASICS AMERICA CORPORATION, 

Defendant 

Case No. 6:20-cv-00135 

JURY TRIAL DEMANDED 

COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Brwose3D LLC (“Browse3D” or “Plaintiff”) files this Complaint for patent 

infringement against Defendant Asics America Corporation. (“Asics” or “Defendant”), 

and alleges as follows: 

NATURE OF THE ACTION 

1. This is an action for patent infringement arising under 35 U.S.C. § 1 et seq.

PARTIES 

2. Browse3D is a limited liability company organized and existing under the

laws of the State of Texas with its principal place of business 108 Wild Basin Rd South, 

Suite 250, Austin, Texas 78746. 

3. Defendant is a corporation organized and existing under the laws of

California with corporate address of 80 Technology Drive, Irvine, California 92618. 

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JURISDICTION AND VENUE 

4. This Court has original jurisdiction over the subject matter of this action 

pursuant to 28 U.S.C. §§ 1331 and 1400. 

5. Upon information and belief, Defendant is subject to personal jurisdiction 

of this Court based upon it having regularly conducted business, including the acts 

complained of herein, within the State of Texas and this judicial district and/or deriving 

substantial revenue from goods and services provided to individuals in Texas and in this 

District. 

6. Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400 because 

Defendants have committed acts of infringement and have regular and established places 

of business in this judicial district. 

COUNT I 

(Infringement of U.S. Patent No. 10,031,897) 

7. Browse3D incorporates paragraphs 1 through 6 as though fully set forth 

herein. 

8. Plaintiff is the owner, by assignment, of U.S. Patent No. 10,031,897 (the 

“’897 Patent”), entitled SYSTEM AND METHOD FOR WEB BROWSING, which issued 

on July 24, 2018. A copy of the ’897 Patent is attached as Exhibit A. 

9. The ’897 Patent is valid, enforceable, and was duly issued in full compliance 

with Title 35 of the United States Code. 

10. Defendant hosts and provides an interactive website at 

https://www.asics.com for advertising and promoting the sale of items to users of the 

website (the “Accused Product”). In use, Defendant tracts user behavior when interacting 

with the website, including selection of individual hyperlinks. Defendant uses the user 

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behavior information to customize the rendering of webpages to present information to 

the user. The Defendant’s system for hosting and operating the website is the Accused 

Product that infringes the ’897 Patent. 

11. At least by hosting, promoting, and publishing the website, Defendant 

encourages its customers, potential customers, and users of the website to use the website 

and practice the claimed methods, which Defendant controls the use of and derives a 

direct benefit and profit from. 

12. Upon information and belief, Defendant has infringed and continues to 

infringe one or more claims, including Claim 10, of the ’897 Patent by making and using 

Defendant’s interactive website in the United States without authority. Defendant has 

infringed and continues to infringe the ’897 Patent either directly or through the acts of 

inducement in violation of 35 U.S.C. § 271. Defendant has been on notice of the ’897 

Patent at least as early as the date it received service of this complaint. 

13. Claim 10: A method for web browsing comprising: 

over a plurality of browsing sessions, monitoring browsing activity of a 

user at a particular web page that comprises a plurality of 

hyperlinks for hyperlinking from the particular web page; 

determining a pattern of hyperlink usage of the user based on the 

monitored browsing activity; 

determining a prioritized list of hyperlinks based on the determined 

pattern of hyperlink usage, wherein the prioritized list of 

hyperlinks comprises a subset of said plurality of hyperlinks, and 

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wherein each hyperlink on the prioritized list links to a respective 

web page; 

in an other browsing session, presenting a window that comprises a first 

area and a second area; 

in the other browsing session, presenting the particular web page in the 

first area of the window; 

in the other browsing session, automatically requesting web page data for 

the respective web pages; and 

in the other browsing session, presenting in the second area each 

hyperlink in the prioritized list of hyperlinks, wherein the 

presented hyperlinks are positioned according to prioritization of 

the prioritized list, and wherein the presented hyperlinks are 

presented as reduced size images rendered using said requested 

web page data. 

14. The Accused Products practices a method for web browsing: 

https://www.asics.com/us/en-us/

15. The Accused Product determines a pattern of hyperlink usage of the user 

based on the monitored browsing activity (e.g. “We Recommend” is a list of items related 

matching and prioritizing the recently viewed items) 

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16. https://www.asics.com/us/en-us/cookie-policy.html

17. The Accused Product determines a prioritized list of hyperlinks based on 

the determined pattered of hyperlink usage (e.g. “Recently Viewed”). 

18. The prioritized list of hyperlinks comprises a subset of the plurality of 

hyperlinks (e.g. constitutes four items on screen, and a scroll arrow to access items 

beyond four. The hyperlink on the prioritized list links to a respective webpage (e.g. the 

image contains an embedded link to the respective webpage). 

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19. When a user closes the original browsing session and opens a new one, the 

Accused Product produces another browsing session presenting a window that comprises 

a first area and a second area. 

New Browsing Session: 

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20. The other browsing session displays the particular web page in the first 

area of the window: 

 

21. The web page data for the respective web pages is automatically populated 

in the other browsing session. 

22. In the other browsing session, the Accused Product presents in a second 

area each hyperlink in a prioritized list of hyperlinks (e.g. Recently Viewed). The 

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presented hyperlinks are positioned according to prioritization of the prioritized list (e.g. 

most recent to earliest in a scroll bar displaying four items). 

23. The presented hyperlinks are presented as reduced size images rendered 

using said requested webpage data. 

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24. Browse3D has been damaged by Defendant’s infringing activities. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff respectfully requests the Court enter judgment against 

Defendant: 

1. declaring that the Defendant has infringed the ’897 Patent; 

2. awarding Plaintiff its damages suffered as a result of Defendant’s 

infringement of the ’897 Patent; 

3. awarding Plaintiff its costs, attorneys’ fees, expenses, and interest; and 

4. granting Plaintiff such further relief as the Court finds appropriate. 

JURY DEMAND 

Plaintiff demands trial by jury, Under Fed. R. Civ. P. 38. 

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Dated: February 20, 2020 Respectfully submitted, 

/s/ Raymond W. Mort, III 

Raymond W. Mort, III 

Texas State Bar No. 00791308 

raymort@austinlaw.com 

THE MORT LAW FIRM, PLLC 

106 E. Sixth Street, Suite 900 

Austin, Texas 78701 

Tel/Fax: (512) 865-7950 

ATTORNEYS FOR PLAINTIFF 

 BROWSE3D LLC 

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