2:22-cv-04111
Zodex Data Systems LLC v. Siemens
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Zodex Data Systems LLC (Delaware)
- Defendant: Siemens Medical Solutions USA, Inc. (Delaware)
- Plaintiff’s Counsel: DEVLIN LAW FIRM LLC
- Case Identification: 2:22-cv-04111, U.S. District Court for the Central District of California (C.D. Cal.), 06/15/2022
- Venue Allegations: Venue is alleged to be proper as Defendant is a California corporation, transacts business in the district, and maintains a regular and established place of business in the Central District of California, including an office employing sales and user operations teams.
- Core Dispute: Plaintiff alleges that Defendant’s medical imaging software infringes a patent related to efficiently viewing selected portions of large images stored on a remote server.
- Technical Context: The technology addresses latency in client-server systems by proposing a method where, upon a user's request to zoom, the server extracts and sends only the data for the selected image portion, rather than the entire image file.
- Key Procedural History: The patent’s original assignee is listed as Nippon Steel Corporation, while the complaint asserts that Plaintiff Zodex Data Systems LLC is the current assignee and exclusive owner of all rights. The complaint does not mention any prior litigation or administrative proceedings involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 1996-09-13 | ’507 Patent Priority Date |
| 2002-05-28 | U.S. Patent No. 6,396,507 Issues |
| 2022-06-15 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,396,507 - "Data Storage/Access Network System for Zooming Image and Method of the Storage/Access," Issued May 28, 2002
The Invention Explained
- Problem Addressed: The patent describes the problem of long delays when viewing a detailed part of a large image stored on a server, particularly over low-speed networks. Transferring the entire large image file is time-consuming, and the client device then requires significant memory and processing power to isolate and display the zoomed-in portion. (’507 Patent, col. 1:58 - col. 2:7).
- The Patented Solution: The invention proposes a method to improve efficiency in a client-server network. When a user on a client device designates a portion of a displayed image to enlarge, a request is sent to the server. The server then extracts only the image data corresponding to that specific portion from the main image file and transmits this much smaller dataset to the client for display. (’507 Patent, Abstract; col. 3:20-33). This reduces network traffic and the computational load on the client device.
- Technical Importance: This server-side data extraction approach was designed to significantly improve the responsiveness of remote image viewing systems by addressing the critical bottleneck of data transfer volume over the networks of the era. (’507 Patent, col. 2:2-7).
Key Claims at a Glance
- The complaint asserts direct infringement of at least independent claim 1. (Compl. ¶23).
- The essential elements of independent claim 1 are:
- A data reading method in a client-server network.
- Transmitting image data in a file from a storage device (server) to an access device (client).
- Designating an arbitrary portion of the displayed image on the access device.
- Reading out only the desired ("wanting") image data for that arbitrary portion from the same file on the storage device.
- Transferring that "wanting" image data to the access device through the network.
- The complaint expressly reserves the right to assert additional claims during litigation. (Compl. ¶23, n.1).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are Defendant's "software products for viewing medical images," with the "syngo webspace system" being specifically named. This includes associated server software and client-side software such as Mobile Applications, Web browser interfaces, and/or Desktop Applications. (Compl. ¶¶16, 19).
Functionality and Market Context
The complaint alleges that the accused products provide a system for viewing medical images stored on Defendant's servers from remote client devices. (Compl. ¶19). Users can interact with the software to designate portions of images for more detailed viewing. (Compl. ¶¶28-29). A system diagram provided in the complaint illustrates the client-server architecture, showing a "syngo WebSpace" server connecting to a "PACS Archive" and communicating with "Workplaces" such as an "Office/Home PC." (Compl. p. 7). This diagram depicts the client-server environment in which the allegedly infringing method operates.
IV. Analysis of Infringement Allegations
'507 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A data reading method applied to a network system in which an image data storage device and an access device are connected. | The accused syngo webspace system operates in a network connecting servers (storage device) and client workstations (access device). | ¶26 | col. 3:20-24 |
| transmitting image data in a file from said storage device to said access device; | The system transmits image data from a server archive to a client device, such as an Office/Home PC. A provided diagram shows data transfer between a server and workplaces. (Compl. p. 7). | ¶27 | col. 33:1-3 |
| designating an arbitrary portion of said image data transmitted and displayed on said access device; | The software's viewer provides scaling tools, such as a "magnifier or zoom," that allow a user to select a portion of an image for enlargement. | ¶28 | col. 33:4-6 |
| reading out only wanting image data in said arbitrary portion ... from the same file ... transmitted; | The magnifier function "enlarges a portion of an image," which is alleged to constitute reading out the wanting image data. | ¶29 | col. 33:7-10 |
| transferring said wanting image data to said access device through a network. | The system includes a "Fetch function" that allows sending studies and series from a DICOM archive to a client destination over the network via a C-MOVE operation. | ¶30 | col. 33:11-12 |
Identified Points of Contention
- Technical Question: The complaint's allegations for the "reading out only wanting image data" element describe the client-side result of a zoom or magnification. (Compl. ¶29). A central technical question will be what evidence demonstrates that the accused system’s server performs the specific function of extracting only the data for the selected portion from the larger source file, as required by the claim. The complaint does not provide direct evidence of this specific server-side mechanism.
- Scope Questions: Claim 1 recites a sequence of (1) "transmitting image data in a file" and then (3) "reading out only wanting image data ... from the same file." This language raises the question of whether the claim requires two distinct operations against the same server-side file. The infringement allegations cite different functionalities (general image display, magnification, a "Fetch function") for different claim elements, and it will be a point of contention whether these functionalities, as they operate in the accused system, collectively map to the specific sequence required by the claim. A screenshot of the 'Physician Access' interface displays a medical image in the main 'Image area' alongside various toolbars and patient information panels. (Compl. p. 8).
V. Key Claim Terms for Construction
The Term: "reading out only wanting image data"
Context and Importance
This term appears to be the central technical limitation of the claim, defining the core of the patented efficiency gain. The case's outcome may depend on whether this requires proof of a specific server-side partial extraction mechanism, or if it can be satisfied by the end result of a user viewing a zoomed image.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent's abstract states that as a result of the invention, "the amount of data to be transferred from the server to the client can be decreased," which could be argued to focus on the overall goal rather than a specific mechanism. (’507 Patent, Abstract).
- Evidence for a Narrower Interpretation: The specification repeatedly describes the specific action of the server extracting a subset of data. For instance, it describes "image read means for reading out only an arbitrary portion of image data stored in the storage device." (’507 Patent, col. 3:37-40). This language may support a narrower construction requiring a specific server-side action.
The Term: "from the same file as said file of said image data transmitted"
Context and Importance
This phrase connects the initial data transmission step to the subsequent partial read-out step. Its construction is critical for determining the required relationship and sequence between the acts of the claimed method.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: A party could argue that "from the same file" simply means the data for both steps originates from the same master data object on the server, without imposing a strict procedural order of a full file transmission followed by a separate partial read.
- Evidence for a Narrower Interpretation: The plain language suggests a sequence: a file is transmitted (or made accessible) in the first step, and the subsequent "reading out" step operates on that identical server-side source file. The patent's description of operations may support this sequential view. (’507 Patent, col. 12:20-29).
VI. Other Allegations
Indirect Infringement
The complaint alleges inducement to infringe under 35 U.S.C. § 271(b). It asserts that Defendant provides users with instructions, promotional materials, and user manuals that guide them to operate the accused software in a way that practices the claimed method. The complaint alleges Defendant possessed the specific intent to encourage this use. (Compl. ¶¶32, 34). An excerpt from a user manual describes a 'Fetch function' used to send studies and series from a DICOM archive to a client destination via a C-MOVE operation, which is offered as evidence of these instructions. (Compl. p. 9).
Willful Infringement
The complaint does not contain an explicit allegation of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute may turn on the following key questions:
A central evidentiary issue will be one of technical mechanism: Can Plaintiff produce evidence that the accused syngo webspace system’s server, when a user zooms, performs the specific act of "reading out only wanting image data" from the source file? Or does the system achieve the zoom effect through an alternative method, such as re-transmitting a larger block of data that the client-side software then crops?
A key legal issue will be one of claim scope: Does the phrase "from the same file as said file of said image data transmitted" require a specific two-act sequence where a file is first transmitted and then separately read from? The court's construction of this term will determine whether the various discrete functions of the accused system can be mapped onto the limitations of Claim 1.