UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

BROWSE3D LLC, 

 Plaintiff 

 v. 

BOOKING HOLDINGS INC., 

 Defendant 

Case No. 6:20-cv-00547 

JURY TRIAL DEMANDED 

CHECK FOR HIGHLIGHTS 

COMPLAINT FOR PATENT INFRINGEMENT 

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

infringement against Defendant Booking Holdings Inc. (“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 Delaware corporation with a principal place of business at 28 Liberty 

Street, Floor 29, New York, NY 10005. Defendant may be served via its registered agent: 

CSC-Lawyers Incorporating Service Company, 211 E. 7th Street, Suite 620, Austin, Texas 

78701. 

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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. §§ 1391 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. On information and belief Defendant maintains a regular place business in 

this District. In particular, from statements from Defendant’s employees, Defendant has 

an office in Austin, Texas. 

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https://www.linkedin.com/in/christianlopez1/ 

7. More specifically, on information and belief, Defendant maintains a regular 

place of business at 327 Congress Ave, Suite 300, Austin, Texas 78701. 

8. 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. 

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COUNT I 

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

9. Browse3D incorporates paragraphs 1 through 8 as though fully set forth 

herein. 

10. 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. 

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

with Title 35 of the United States Code. 

12. Defendant hosts and provides an interactive website at 

https://www.booking.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 

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 

Instrumentality that infringes the ’897 Patent. 

13. 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. 

14. 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. 

15. 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; 

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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 

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. 

16. Booking.com’s website monitors the browsing activity of a user at a particular 

webpage. As shown below the Austin Properties page constitutes a particular webpage. The page 

comprises a plurality of hyperlinks for hyperlinking from the particular page. 

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17. The Booking.com website determines a pattern of hyperlink usage based on monitored browsing activity (e.g. 

Your viewed properties comprises hyperlinks user has recently viewed): 

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18. The hyperlinks, displayed in the “Your viewed properties” section, are prioritized 

by when the user visited the page:

19. Each hyperlink from the prioritized list link to a respective webpage: 

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20. After the user closed the first browsing session and returned to the computer an hour later the Austin Properties 

page displayed the following

New browsing session: 

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21. In the other browsing session, the website presents a particular page in the 

first area of the window. 

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22. The page automatically request the browsing activity which was captured and 

stored by Booking.com’s Website: 

23. The hyperlinks, displayed in the “Your viewed properties” section, are prioritized 

by when the user visited the page:

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24. The images presented are reduced sized images rendered using the 

webpage data. 

25. 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: June 17, 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 

100 Congress Ave, Suite 2000 

Austin, Texas 78701 

Tel/Fax: (512) 865-7950 

ATTORNEYS FOR PLAINTIFF 

 BROWSE3D LLC 

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