DCT
2:23-cv-02246
Web 20 Tech LLC v. Freedcamp Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Web 2.0 Technologies, LLC (Texas)
- Defendant: Freedcamp, Inc. (California)
- Plaintiff’s Counsel: Devlin Law Firm LLC
- Case Identification: 2:23-cv-02246, C.D. Cal., 03/27/2023
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant is a California corporation with its principal place of business in the district, has purposefully availed itself of the privileges of conducting business in the state, and has committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Freedcamp online project management and collaboration platform infringes two patents related to securely managing and sharing personal information and collaborating on documents online.
- Technical Context: The technology concerns foundational methods for creating centralized, permission-based online repositories for user data and documents, a core component of modern cloud-based software-as-a-service (SaaS) platforms.
- Key Procedural History: The complaint alleges that Defendant has had actual knowledge of the patents-in-suit and their infringement since at least June 15, 2021, the date it received notice from the Plaintiff. This notice date is asserted as the basis for willful infringement allegations.
Case Timeline
| Date | Event |
|---|---|
| 2000-01-07 | Priority Date for U.S. Patent No. 6,845,448 |
| 2000-01-07 | Priority Date for U.S. Patent No. 8,117,644 |
| 2005-01-18 | U.S. Patent No. 6,845,448 Issues |
| 2012-02-14 | U.S. Patent No. 8,117,644 Issues |
| 2021-06-15 | Defendant allegedly receives notice of infringement |
| 2023-03-27 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,845,448 - “Online Repository for Personal Information” (Issued Jan. 18, 2005)
The Invention Explained
- Problem Addressed: The patent describes the inefficiency and annoyance for users who must repeatedly fill out forms with personal and demographic information for various websites, such as news sites, software downloads, and e-commerce platforms (’448 Patent, col. 1:12-32). Existing methods lacked a central, user-controlled system for managing and selectively distributing this information.
- The Patented Solution: The invention proposes a method where a user stores their personal information in a centralized repository on a server. The user can assign different security levels to various "information objects" (e.g., name, address, preferences) and then authorize specific requesters (e.g., websites, service providers) to access only the information they are permitted to see (’448 Patent, Abstract; col. 2:22-42). The system handles receiving requests, verifying authorization, and securely transmitting the approved data.
- Technical Importance: This technology provided an early framework for user-centric data management, addressing privacy and convenience issues that arose with the growth of the interactive web by giving users granular control over their digital identity (’448 Patent, col. 1:50-59).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1, as corrected by the Certificate of Correction dated December 31, 2013 (Compl. ¶21, ¶34).
- Essential Elements of Corrected Claim 1 (Method performed by a server computer):
- Establishing an account for a first party (user).
- Assigning an identifier to the first party.
- Entering the first party's personal information, comprising a plurality of information objects.
- Receiving, from the first party, an assignment of security levels to each information object.
- Storing the first party's identifier, information objects, and their assigned security levels in a database.
- Receiving a request from a second party (requester) that includes the first party's identifier.
- In response to the request, selecting and retrieving a portion of the first party's personal information.
- Securely transmitting the retrieved information to the second party.
- Obtaining a second party identifier, recording it if unauthorized, and rejecting the request for information.
- The complaint reserves the right to assert other claims (Compl. ¶38).
U.S. Patent No. 8,117,644 - “Method and System for Online Document Collaboration” (Issued Feb. 14, 2012)
The Invention Explained
- Problem Addressed: The patent identifies challenges in online collaboration, including the unmanageability of saving numerous web pages, bookmarks becoming "stale" when content moves, and the lack of a secure, controlled way to share and edit documents with others (’644 Patent, col. 1:20-65).
- The Patented Solution: The invention discloses a system where a user can establish an online personal library. A first user can store a document, associate specific access restrictions with it, and grant access to other users for modification. The system manages receiving modification requests from a second user, verifying their identity, permitting changes based on their access rights, and receiving and storing approvals or disapprovals for those changes (’644 Patent, Abstract; col. 12:47-65). This is illustrated by system architecture in Figure 1.
- Technical Importance: The technology outlines a system for permission-based, asynchronous document collaboration, a foundational concept for modern project management, cloud storage, and online productivity software (’644 Patent, col. 2:1-6).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (Compl. ¶42, ¶53).
- Essential Elements of Claim 1 (Method performed by a server computer):
- Establishing an account for each of a plurality of users.
- Storing a document created by a first user.
- Associating a set of access restrictions with the document for a first group of users.
- Receiving a request to modify the document from a second user, which includes the second user's identification.
- Verifying the identity of the second user.
- Permitting the second user to modify the document based on their granted access rights.
- Receiving approval or disapproval for the modifications from one or more users.
- Storing identifying information of the user(s) who approved or disapproved the modifications.
- The complaint reserves the right to assert other claims (Compl. ¶57).
III. The Accused Instrumentality
- Product Identification: The accused instrumentality is the "Freedcamp" online platform, marketed as "All Your Favorite Business Collab Tools In One Place," and its constituent features, including "Tasks," "Time," "Project Overview," "Discussions," "Files," "Issue Tracker," "Milestones," "Calendar," and "Wiki" (Compl. ¶21, ¶42).
- Functionality and Market Context: The complaint describes Freedcamp as a web-based project management and collaboration service. Its alleged functionality includes allowing users to create accounts, establish user profiles with personal information (name, email, etc.), create and store documents and files, and collaborate with other users on projects (Compl. ¶22-24, ¶43-44). The system is alleged to have a permission-based architecture where administrators can control what individual users can see and do within a project (Compl. ¶25, ¶45). The complaint also highlights specific features like "FileEdit" for editing documents and version control for tracking changes (Compl. ¶44, ¶50).
IV. Analysis of Infringement Allegations
'448 Patent Infringement Allegations
| Claim Element (from Corrected Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| establishing an account for the first party with the server computer; | The Freedcamp platform allows users to establish an account on its server. The complaint provides a screenshot of the Freedcamp "Login" page where a user enters an email address to create or access an account. (Compl. p. 6). | ¶22 | col. 8:16-24 |
| assigning an identifier to the first party; | Freedcamp allegedly assigns a unique "user_id" to every user participating in a project. The complaint includes a JSON data snippet showing the "user_id" field. (Compl. p. 7). | ¶23 | col. 8:26-33 |
| entering the first party's personal information, said first party's personal information comprising at least one of a plurality of information objects; | Users can enter personal information such as name, email address, role, and job title into their user profile. The complaint provides a screenshot of the "User Profile & Settings" page to support this. (Compl. p. 8). | ¶24 | col. 8:41-50 |
| receiving, from the first party, assignment of at least one of a plurality of security levels to each information object... | The Freedcamp platform allegedly allows administrators to set access permissions for users and apps, which controls "who can do or see what within Freedcamp." The complaint presents a screenshot titled "Management Tools And Permissions For Administrators." (Compl. p. 8). | ¶25 | col. 14:40-49 |
| storing in the database the first party identifier, the information object and the security level assigned to the information object; | The complaint alleges that Freedcamp's database stores the user identifier ("user_id") and associated permissions (security level). | ¶26 | col. 14:50-54 |
| receiving a request, said request comprising at least the first party identifier; | The '448 Accused Instrumentalities allegedly "receive a request to view a specific user based on the first party identifier." | ¶27 | col. 8:36-39 |
| securely transmitting the retrieved first portion of personal information objects to the second party; | The system allegedly selects, transmits, and displays the first party's personal information to an authorized second party. It is also alleged to encrypt all traffic in transit and at rest. | ¶29-30 | col. 9:8-10 |
| ...if the second party is not authorized to receive the information, ...rejecting the second party's request for information. | The complaint alleges the system rejects requests from unauthorized parties, citing a developer document stating the system returns an empty "users" array if the current user lacks permissions. The complaint includes a screenshot of this documentation. (Compl. p. 12). | ¶33 | col. 14:61-64 |
- Identified Points of Contention:
- Scope Question: A primary issue may be whether Freedcamp’s project-level and role-based permissions system meets the claim limitation of "assigning...a plurality of security levels to each information object at any granularity." The defense could argue that assigning a general role (e.g., "User" or "Administrator") to a person within a project is different from assigning a specific security level to each discrete piece of that person's profile data, as contemplated by the patent.
- Technical Question: The complaint alleges that when an unauthorized user requests information, the system returns an "Empty 'users' array" (Compl. ¶33). The court will have to determine if returning an empty data array constitutes "rejecting the second party's request for information" as required by the claim, or if it is merely a null response that functions differently than an explicit rejection.
'644 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| storing, on the server computer, a document created by a first user; | The complaint alleges that Freedcamp’s "FileEdit" and "Wiki" features allow a user to create and store documents on Freedcamp’s servers. The complaint shows a marketing image for the "FileEdit" feature which automates file downloads and uploads. (Compl. p. 15). | ¶44 | col. 12:51-52 |
| associating a set of access restrictions with the document...; | The platform allegedly allows users to set access permissions that control who can access a project and what they can do with information objects, such as documents. | ¶45 | col. 12:53-56 |
| receiving a request to modify the document from a second user...; | A second user who has been granted access can allegedly request to modify documents by using features like "FileEdit." | ¶46 | col. 12:59-62 |
| verifying the identity of the second user; | The system allegedly verifies a user's identity through a unique user name and form-based authentication (username and password). The complaint points to its login form screenshot. (Compl. p. 17). | ¶48 | col. 12:63-64 |
| permitting the second user to modify the document based on a set of access rights...; | The platform is alleged to have "highly customizable permissions" that permit a second user to modify a document based on their individual access rights. | ¶49 | col. 12:65-67 |
| receiving approval or disapproval for the modifications from one or more users; | The complaint alleges Freedcamp implements version control, which permits the "approving or disapproving [of] modifications from one or more users." The complaint includes a screenshot for the "Version control" feature. (Compl. p. 18). | ¶50 | col. 13:1-4 |
| storing identifying information of the one or more users who approved or disapproved the modifications. | It is alleged that Freedcamp "logs the identifying information of users who edited or revised the document, including approving or disapproving of any such modifications." | ¶52 | col. 13:5-8 |
- Identified Points of Contention:
- Technical Question: The claim requires "storing identifying information of the one or more users who approved or disapproved the modifications." The complaint cites a general logging feature that records "metrics about the Freedcamp services" (Compl. ¶52). A key question will be whether a general activity log that shows a user edited a document is sufficient to prove that the system stores information about who explicitly approved or disapproved a modification, which is a more specific action.
- Scope Question: The claim requires receiving "approval or disapproval." The complaint points to a "Version control" feature (Compl. ¶50). The infringement analysis will depend on whether this feature is merely for tracking different versions of a file or if it includes a specific workflow for users to formally approve or reject changes made by others.
V. Key Claim Terms for Construction
For the '448 Patent
- The Term: "information object"
- Context and Importance: This term defines the fundamental unit of data being managed. Its construction is critical because it determines whether the patent applies only to discrete, user-defined personal data fields (e.g., name, address) or more broadly to any data associated with a user in a modern, complex application. Practitioners may focus on this term to argue about the patent's applicability to data types not explicitly envisioned in 2000.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states, "In this application, any piece of information, however small in granularity or however agglomerated, is referred to as an 'information object'" (’448 Patent, col. 5:57-60).
- Evidence for a Narrower Interpretation: The detailed examples provided in the specification are all traditional categories of personal data, such as employment history, demographics, health information, and personal preferences (’448 Patent, col. 7:1-35).
For the '644 Patent
- The Term: "receiving approval or disapproval for the modifications"
- Context and Importance: This term is central to the collaborative workflow claimed by the patent. The definition will determine whether a simple versioning system that tracks edits infringes, or if the claim requires a more formal, explicit approval/rejection mechanism (e.g., a manager reviewing and clicking "approve" on a subordinate's changes).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The abstract broadly mentions the step, and one could argue that a system allowing a user to revert a change is an implicit form of "disapproval." The patent does not explicitly limit the mechanism in the claims.
- Evidence for a Narrower Interpretation: The claim language "receiving approval or disapproval" suggests an affirmative act or communication from a user that is then received by the system, rather than the mere existence of different document versions. The final element, "storing identifying information of the one or more users who approved or disapproved," further supports the idea that this is a discrete, recordable event.
VI. Other Allegations
- Indirect Infringement: The complaint alleges "direct and jointly" infringement but does not plead separate counts for indirect infringement (Compl. ¶21, ¶36, ¶42, ¶55). The factual allegations regarding Freedcamp providing a platform and instructions for users to perform the claimed steps could potentially support a later theory of induced infringement.
- Willful Infringement: The complaint alleges that Defendant had "actual knowledge" of both patents and their infringement since at least June 15, 2021, due to a notice provided by Plaintiff (Compl. ¶20, ¶41). This forms the basis for a claim of willful infringement for all post-notice conduct. The prayer for relief seeks a finding of an exceptional case and enhanced damages under 35 U.S.C. § 285 (Compl. p. 20, ¶C).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical translation: can the specific, granular data management steps claimed in patents from the dot-com era be read onto the integrated, role-based functionalities of a modern SaaS collaboration platform? The outcome may depend on whether Freedcamp's project-level permissions are legally equivalent to the '448 Patent's "per-object" security levels.
- A key evidentiary question will be one of functional specificity: does Freedcamp’s general-purpose versioning and logging system perform the specific, claimed functions of "receiving approval or disapproval" and "storing identifying information of the...users who approved or disapproved" ('644 Patent)? The case may turn on whether a log of who edited a document is sufficient to meet the claim's requirement of logging an explicit approval action.
- The dispute will likely involve a significant claim construction battle over foundational terms like "information object" and "receiving approval." The breadth of these definitions will be critical in determining whether the accused platform, which evolved in a different technological environment, infringes claims drafted to solve earlier internet problems.