DCT
2:19-cv-01002
Data Scape Ltd v. Teradata Operations Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Data Scape Limited (Ireland)
- Defendant: Teradata Operations, Inc. (Delaware)
- Plaintiff’s Counsel: Russ, August & Kabat
- Case Identification: 2:19-cv-01002, C.D. Cal., 02/11/2019
- Venue Allegations: Venue is alleged to be proper as Defendant has transacted business, committed acts of infringement, and maintains a regular and established place of business within the Central District of California.
- Core Dispute: Plaintiff alleges that Defendant’s Teradata Unity suite of data synchronization and management products infringes two patents related to systems for managing and transferring data between a primary apparatus and an external apparatus.
- Technical Context: The technology at issue involves methods for managing data synchronization between distinct computer systems, a critical function in enterprise database management for ensuring data consistency, availability, and disaster recovery.
- Key Procedural History: U.S. Patent 7,720,929 is subject to a disclaimer filed on July 13, 2020, which disclaimed the entirety of claims 1, 2, 8-12, and 17. As the complaint asserts infringement of Claim 1 of the ’929 Patent, the post-filing disclaimer renders this asserted claim unenforceable and may be dispositive of the second count of the complaint. U.S. Patent 8,386,581 is subject to a terminal disclaimer.
Case Timeline
| Date | Event |
|---|---|
| 1999-09-21 | Earliest Priority Date for '581 and '929 Patents |
| 2010-05-18 | U.S. Patent 7,720,929 Issued |
| 2013-02-26 | U.S. Patent 8,386,581 Issued |
| 2019-02-11 | Complaint Filed |
| 2020-07-13 | Disclaimer of claims in U.S. Patent 7,720,929 filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,386,581 - "Communication System And Its Method and Communication Apparatus And Its Method"
- Patent Identification: U.S. Patent No. 8,386,581, "Communication System And Its Method and Communication Apparatus And Its Method," issued February 26, 2013.
The Invention Explained
- Problem Addressed: The patent describes the process of transferring data between a main device (like a music server with a large library) and an external device (like a portable player with limited storage) as potentially cumbersome. Specifically, it notes that creating a list of data to be transferred can be confusing if the purpose of the list—whether for simple organization or for batch transfer—is unclear (’929 Patent, col. 1:31-40).
- The Patented Solution: The invention proposes a communication apparatus (the "server") that allows a user to create and edit a specific "list" of content data intended for transfer. The system uniquely identifies the external apparatus and its associated list. When the external apparatus connects to the server, the server extracts the correct list from potentially many lists and controls the transfer of the content on that list to the connected device (’581 Patent, Abstract; ’929 Patent, Fig. 13). This architecture decouples list management from the physical act of data transfer.
- Technical Importance: This approach provides a structured and simplified workflow for users to manage and synchronize content between a large, centralized data repository and multiple, distinct external devices.
Key Claims at a Glance
- The complaint asserts independent Claim 1.
- The essential elements of Claim 1 are:
- A communication apparatus comprising a storage unit and a communication unit.
- A controller configured to:
- edit a list to register content data;
- uniquely associate the list with an external apparatus using a unique identifier;
- extract the associated list from a plurality of lists when the external apparatus is connected;
- control the transfer of content data from the extracted list to the external apparatus.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,720,929 - "Communication System And Its Method and Communication Apparatus And Its Method"
- Patent Identification: U.S. Patent No. 7,720,929, "Communication System And Its Method and Communication Apparatus And Its Method," issued May 18, 2010.
The Invention Explained
- Problem Addressed: The patent addresses the same problem as the ’581 Patent, as they share a common specification: the tedious nature of piece-by-piece data transfers and the potential for user confusion when creating transfer lists (’929 Patent, col. 1:25-40).
- The Patented Solution: The invention is a two-part communication system. The second apparatus (e.g., a server) includes an editor that allows a user to select data for transfer and edit the corresponding "management information" (the transfer list). Crucially, this editing can be performed "without regard to the connection of said first apparatus" (’929 Patent, Abstract). The system also includes a detector to determine when the two apparatuses are connected and a controller that then initiates the transfer based on the pre-edited list (’929 Patent, col. 2:50-60).
- Technical Importance: This system architecture decouples the user's task of selecting content for synchronization from the physical state of the devices, allowing users to prepare for a transfer at any time.
Key Claims at a Glance
- The complaint asserts independent Claim 1.
- The essential elements of Claim 1 are:
- A communication system with a first apparatus (with a storage medium) and a second apparatus.
- The second apparatus comprises:
- a second storage medium for management information;
- a communicator to connect to the first apparatus;
- a detector to determine if the apparatuses are connected;
- an editor to select data and edit management information "without regard to the connection";
- a controller to transfer the selected data based on the edited information when a connection is detected.
- As noted in Section I, Claim 1 was disclaimed in its entirety on July 13, 2020, rendering it unenforceable (’929 Patent, Disclaimer). The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused products are the Teradata Unity, Unity Director, Unity Loader, Data Mover, and related server models and software, referred to collectively as the "Accused Instrumentalities" or the "Teradata Unity suite" (Compl. ¶¶ 6, 21).
Functionality and Market Context
- The Teradata Unity suite is an enterprise software solution designed to manage and synchronize data across multiple, independent Teradata database systems (Compl. ¶¶ 9, 24). A block diagram titled 'Unity-Query Routing and Data Synchronization' illustrates the flow of data and commands between 'System A' and 'System B' managed by the "Unity" software (Compl. p. 7, Fig. 1). The products deliver SQL commands to all participating systems, queuing and dispatching them in order to maintain data consistency and integrity (Compl. ¶9). The suite also provides tools for defining data dictionaries and managed routing rules that govern how data is synchronized and where it resides (Compl. ¶¶ 12, 28). This functionality is marketed for providing data backup, high availability, and disaster recovery in large-scale data ecosystems (Compl. ¶¶ 10, 17). A screenshot of the "Unity Director" dashboard shows the management of multiple database systems, labeled "einstein" and "innovation" (Compl. p. 4).
IV. Analysis of Infringement Allegations
’581 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| [a] communication apparatus comprising a storage unit configured to store content data to a storage medium, and a communication unit configured to communicate with an external apparatus. | The Accused Instrumentalities include hardware with disk drives to store content data (e.g., SQL commands) and communicate with external Teradata database servers. | ¶9-11 | col. 10:1-10 |
| a controller configured to edit a list so that content data is registered in the list | The Accused Instrumentalities use a "Recovery Log" to register database writes and employ managed routing rules to define a list of writes to be sent to specific database systems. | ¶12 | col. 24:1-6 |
| [a controller configured] to uniquely associate the list with the external apparatus using a unique identification of the external apparatus | The Accused Instrumentalities use a unique identifier called a "TDPID" to identify and associate a list of data with a specific external Teradata Database system. | ¶13 | col. 24:7-14 |
| [a controller configured] to extract the list associated with the external apparatus from a plurality of lists in the communication apparatus when the external apparatus is connected to the communication apparatus | The Accused Instrumentalities use the unique TDPID to identify the correct list of SQL statements to be transferred to the associated external database server when it is connected. | ¶14 | col. 25:51-67 |
| and to control transferring of content data registered in the extracted list to the external apparatus. | The Accused Instrumentalities transfer data only when the external database is in an "Active" or "Read-Only" state (i.e., connected), not when it is disconnected. A table titled 'Read and Write Requests for Managed Sessions' shows that data transfers are predicated on the connection state (Compl. p. 13). | ¶14 | col. 25:51-67 |
’929 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| [a] communication system including a first apparatus having a first storage medium, and a second apparatus. | The system comprises the Accused Instrumentalities (e.g., a device running Unity Director) as the second apparatus communicating with an external Teradata Database system as the first apparatus. | ¶24 | col. 1:50-54 |
| a second apparatus comprising a second storage medium configured to store management information of data to be transferred to said first storage medium | The Accused Instrumentalities include disk drives to store management information, such as data dictionaries and routing rules for the data to be transferred. | ¶25 | col. 2:56-58 |
| [a second apparatus comprising] a communicator configured to communicate with said first apparatus | The Accused Instrumentalities communicate with external Teradata database servers to synchronize data and deliver SQL commands. | ¶26 | col. 2:59-60 |
| [a second apparatus comprising] a detector configured to detect whether said first apparatus and a second apparatus are connected | The Accused Instrumentalities detect the connection state of the external database and will only transfer data when the database is in an "Active" or "Read-Only" state, not a "Disconnected" state. | ¶27 | col. 29:9-12 |
| [a second apparatus comprising] an editor configured to select certain data to be transferred and to edit said management information based on said selection without regard to the connection of said first apparatus | The Accused Instrumentalities provide an editor to select data for transfer using managed routing rules and data dictionaries. A screenshot from the 'Unity Configuration' interface displays a 'Data Dictionary' for selecting specific databases and objects for management (Compl. p. 18). This editing is alleged to be done without regard to the target system's connection. | ¶28 | col. 29:13-19 |
| [a second apparatus comprising] a controller configured to control transfer of the selected data... to said first apparatus... based on said management information... when said detector detects that said first apparatus and said second apparatus are connected | The Accused Instrumentalities control the transfer of data to the external database system based on the managed routing rules when the system is connected and identified by its unique TDPID. | ¶29 | col. 29:20-28 |
Identified Points of Contention
- Scope Questions: A primary issue for both patents is whether the claims, which are described in the specification in the context of transferring "musical data" between a "music server" and a "portable... playback apparatus," can be construed to read on Defendant's enterprise-level system for synchronizing SQL commands between database servers. The interpretation of terms like "communication apparatus", "content data", and "list" will be central.
- Technical Questions: A key technical question for the ’581 Patent is whether Teradata's "Recovery Log" or "managed routing rules" function as the claimed "list" that is "extract[ed]... from a plurality of lists." For the ’929 Patent, a question is what evidence exists that the "editor" for creating routing rules and data dictionaries operates "without regard to the connection" of the target database systems, as required by the claim.
V. Key Claim Terms for Construction
’581 Patent
- The Term: "list"
- Context and Importance: This term is the central data structure in Claim 1. Plaintiff’s infringement theory relies on construing this term to cover structures like a "Recovery Log" or a set of "managed routing rules" (Compl. ¶12). The viability of the infringement claim depends on whether these accused features fall within the scope of the term "list" as used in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself uses the general term "list" without modifiers. The patent abstract refers to editing a "list" so that "content data" is registered, suggesting a generic structure for holding references to data.
- Evidence for a Narrower Interpretation: The specification repeatedly describes the list in the context of a "program list" for musical data, analogous to a playlist (’929 Patent, Fig. 10; col. 22:15-18). The detailed description of the editing process in Figure 13 is titled "START EDITING A TRANSFER LIST," which may be argued to tie the term to this specific embodiment.
’929 Patent
- The Term: "editor configured to... edit said management information... without regard to the connection of said first apparatus"
- Context and Importance: This limitation captures the core inventive concept of decoupling the preparation for a data transfer from the physical connection of the devices. Plaintiff must prove that the Teradata Unity suite's configuration tools, such as the data dictionary editor shown in the complaint (Compl. p. 18), can be used to define data transfer rules irrespective of the target database's connection status.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a flowchart where the work to edit a transfer list is started, and only later does the system check if the portable apparatus is connected (’929 Patent, Fig. 13, steps S50-S57). This supports the idea that editing is independent of connection.
- Evidence for a Narrower Interpretation: The term "editor" could be interpreted narrowly to mean a tool for editing a specific "transfer list" of data files, as shown in the "Music A, Music B, Music C" example (’929 Patent, Fig. 10), rather than a general-purpose rules engine for database routing. An opponent could argue that configuring system-wide routing rules is technically different from editing a discrete list of content.
VI. Other Allegations
- Indirect Infringement: For both patents, the complaint alleges induced infringement, stating that Defendant’s user manuals, marketing materials, and product support instruct and encourage customers to use the Accused Instrumentalities in an infringing manner (Compl. ¶¶ 17, 33). It also pleads contributory infringement, alleging the products are especially made for infringing use and are not staple articles of commerce (Compl. ¶¶ 18, 34).
- Willful Infringement: The complaint alleges that Defendant has had knowledge of the patents and their infringement "since at least the filing of the original Complaint" (Compl. ¶¶ 15, 31). This allegation supports a claim for post-filing willfulness only and does not allege pre-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
- The Dispositive Effect of the Disclaimer: The primary question for this case is the legal effect of the post-filing disclaimer of Claim 1 of the ’929 Patent. As this is the only claim asserted under Count II of the complaint, a central issue is whether this count is now moot and subject to dismissal, substantially narrowing the scope of the litigation.
- Claim Scope and Technical Context: A core issue for the remaining ’581 Patent will be one of definitional scope: can claim terms rooted in the specification’s context of consumer-level music synchronization (e.g., "list", "content data", "apparatus") be construed broadly enough to encompass the accused enterprise database synchronization technology?
- Evidentiary Sufficiency of Infringement: A key evidentiary question will be one of functional mapping: does Plaintiff's evidence, which relies heavily on marketing materials and user-interface screenshots, sufficiently demonstrate that the accused Teradata Unity suite's "Recovery Log" and "managed routing rules" perform the specific functions of "extract[ing] the list... from a plurality of lists" and "uniquely associat[ing]" it with an external apparatus, as required by the elements of Claim 1 of the ’581 Patent?