DCT
8:19-cv-01150
Uniloc 2017 LLC v. Infor Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Uniloc 2017 LLC (Delaware)
- Defendant: Infor, Inc. (Delaware)
- Plaintiff’s Counsel: Prince Lobel Tye LLP
- Case Identification: 8:19-cv-01150, C.D. Cal., 06/10/2019
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant maintains a regular and established place of business within the district.
- Core Dispute: Plaintiff alleges that Defendant’s enterprise software, particularly its Workforce Management solutions, infringes patents related to the network-based management and distribution of configurable software applications.
- Technical Context: The patents address methods for centrally managing and deploying software in a client-server environment, including user- and administrator-specific preferences, a foundational technology for enterprise and Software-as-a-Service (SaaS) platforms.
- Key Procedural History: The complaint alleges that Defendant was put on notice of the patents-in-suit no later than May 12, 2017, via service of a complaint in a prior litigation between the parties in the Eastern District of Texas. This prior notice forms the basis for the willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 1998-12-14 | ’578 and ’293 Patents Priority Date |
| 2001-11-27 | ’578 Patent Issue Date |
| 2006-06-27 | ’293 Patent Issue Date |
| 2017-05-12 | Alleged notice of patents to Defendant via prior litigation |
| 2019-06-10 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,324,578
- Patent Identification: U.S. Patent No. 6,324,578, titled “METHODS, SYSTEMS AND COMPUTER PROGRAM PRODUCTS FOR MANAGEMENT OF CONFIGURABLE APPLICATION PROGRAMS ON A NETWORK,” issued on November 27, 2001.
- The Invention Explained:
- Problem Addressed: The patent’s background section describes the difficulty of managing software applications and user preferences across large, geographically dispersed, and heterogeneous computer networks, a challenge compounded by users who access the network from multiple different client stations (’578 Patent, col. 1:44-57).
- The Patented Solution: The invention proposes a client-server system to centralize application management. A server hosts the application and manages two key components: a "configuration manager program" for an administrator to set system-wide preferences, and an "application launcher program" distributed to clients. When a user on a client station requests to run an application, the server combines the administrator-defined settings with the specific user’s own preferences to execute the program, thereby providing a consistent, personalized experience regardless of the access point (’578 Patent, Abstract; col. 3:50-col. 4:9).
- Technical Importance: This architecture aimed to simplify enterprise software administration and improve the user experience for an increasingly mobile workforce by separating user-specific settings from administrator-controlled policies.
- Key Claims at a Glance:
- The complaint asserts at least independent claim 1 (Compl. ¶15).
- Claim 1 requires:
- Installing an application program on a server.
- Distributing an associated "application launcher program" to a client.
- Obtaining a "user set" of configurable preferences from a user executing the launcher.
- Obtaining an "administrator set" of configurable preferences from an administrator.
- Executing the application program using both the user and administrator sets of preferences in response to a user request.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,069,293
- Patent Identification: U.S. Patent No. 7,069,293, titled “METHODS, SYSTEMS AND COMPUTER PROGRAM PRODUCTS FOR DISTRIBUTION OF APPLICATION PROGRAMS TO A TARGET STATION ON A NETWORK,” issued on June 27, 2006.
- The Invention Explained:
- Problem Addressed: The patent addresses the operational challenges of deploying and updating software across a network. Traditional approaches required manual or customized installation processes for each client or server, which was inefficient and difficult to manage at scale (’293 Patent, col. 1:46-col. 2:14).
- The Patented Solution: The invention describes a centralized distribution method where a network management server prepares a "file packet" for an application. This packet includes a segment designed to automatically initiate registration of the application on a target on-demand server. The central server then distributes this packet to the target, making the application available for use by clients without requiring manual installation or configuration on the target machine (’293 Patent, Abstract; col. 21:25-41). The process is illustrated in the flowchart of Figure 8, which shows software being distributed from a central server to specified on-demand servers.
- Technical Importance: This method provided a framework for automated, on-demand software deployment to servers within a large network, a critical capability for scaling enterprise software services.
- Key Claims at a Glance:
- The complaint asserts at least independent claim 1 (Compl. ¶26).
- Claim 1 requires a method of distributing application programs executed on a centralized network management server, comprising:
- Providing an application program to be distributed.
- Specifying a source directory and a target directory for distribution.
- Preparing a "file packet" associated with the program, which includes a segment configured to initiate registration operations at the target.
- Distributing the file packet to the target on-demand server to make the program available for use by a client user.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
- Product Identification: The complaint names the "Infor software licensing and management system" and associated applications, such as "Infor Workforce Management," which includes a "Workforce Mobility module" (Compl. ¶9, ¶15, ¶7).
- Functionality and Market Context: The accused instrumentality is described as an enterprise-level Software-as-a-Service (SaaS) platform that provides workforce management solutions over the internet to desktops, smartphones, and tablets (Compl. ¶6-8). The complaint alleges the system operates on a client-server model, utilizing Apache servers and data centers in multiple countries (Compl. ¶23, ¶24). An image included in the complaint describes a "fully configurable rules engine" allowing administrators to define business and compliance rules (Compl. ¶11). Another image describes how employees can use a "web or mobile-based interface" to define personal work preferences, such as preferred shift times, which are then "automatically included and considered in the schedule creation and optimization process" (Compl. ¶10). The complaint includes a screenshot of the "Infor Workforce Management" login screen, suggesting user-specific access (Compl. ¶9).
IV. Analysis of Infringement Allegations
’578 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| installing an application program having a plurality of configurable preferences and a plurality of authorized users on a server coupled to the network; | The Infor system involves installing applications like Workforce Management on a backend server architecture coupled to a network. | ¶15 | col. 3:25-28 |
| distributing an application launcher program associated with the application program to a client coupled to the network; | The system allegedly distributes an application launcher program to a client, which allows users to access the Workforce Management software. | ¶15 | col. 3:28-30 |
| obtaining a user set of the plurality of configurable preferences associated with one of the plurality of authorized users executing the application launcher program; | The system allows employees to "define their own work preferences such as when they are available for work, their preferred shift times, [or] preferred days." An image shows these preferences are used in scheduling. | ¶10, ¶15 | col. 3:30-33 |
| obtaining an administrator set of the plurality of configurable preferences from an administrator; and | The system provides a "fully configurable rules engine" for administrators to define "any number of business, work or compliance rules which can be enforced, or validated, as data is entered into the system." | ¶11, ¶15 | col. 3:33-35 |
| executing the application program using the obtained user set and the obtained administrator set of the plurality of configurable preferences responsive to a request from the one of the plurality of authorized users. | The system allegedly executes the application (e.g., creates schedules) using the combination of user-defined preferences and administrator-defined rules in response to user requests. | ¶10, ¶15 | col. 3:35-40 |
’293 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing an application program to be distributed to the network management server; | The system provides an application program such as Workforce Management for licensing and distribution. | ¶26 | col. 21:25-27 |
| specifying a source directory and a target directory for distribution of the application program; | The system is alleged to specify source and target directories for distributing the program. An image shows software being delivered from a source to a target at a user's device. | ¶25, ¶26 | col. 21:28-30 |
| preparing a file packet associated with the application program and including a segment configured to initiate registration operations for the application program at the target on-demand server; | The system allegedly prepares a file packet that includes a segment to initiate registration operations for the application at a target server. | ¶26 | col. 21:31-35 |
| distributing the file packet to the target on-demand server to make the program available for use by a client user. | The system allegedly distributes the file packet to a target server to make the program available to a client user. The complaint provides an image showing Infor uses Apache servers for storing and distributing software. | ¶23, ¶26 | col. 21:36-39 |
- Identified Points of Contention:
- Architectural Mapping ('578 Patent): A central question may be whether the architecture of the accused modern SaaS product maps onto the distinct components of the patent. For example, the court may need to determine if a single, role-based web interface constitutes both an "application launcher program" and a "configuration manager program" as understood in the patent, or if the patent requires physically separate programs.
- Scope of "File Packet" ('293 Patent): The infringement analysis for the ’293 patent raises the question of whether serving dynamic web assets (e.g., HTML, JavaScript) from a server to a browser constitutes distributing a "file packet" as that term is used in the patent. The patent's description, which includes pre- and post-distribution programs, may suggest a more structured, installable package rather than a stream of web content.
V. Key Claim Terms for Construction
'578 Patent
- The Term: "application launcher program"
- Context and Importance: The existence of a distinct "application launcher program" is a core requirement of claim 1. The outcome of the infringement analysis may depend on whether the user-facing portion of the accused Infor web application qualifies as this "program," particularly in relation to the administrator functions, which are allegedly part of a separate "configuration manager program." Practitioners may focus on this term because the defense may argue that Infor provides a single, unified web application with different views based on user roles, not the two separate programs recited in the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states the program "not only provides for a user interface to execute the application program itself but also allows a user to specify one or more of the configurable parameters" (’578 Patent, col. 3:65-col. 4:2). This functional description could be argued to cover any user-facing interface that initiates the application's core logic.
- Evidence for a Narrower Interpretation: The patent repeatedly describes this as a program that is "distributed to a client" and is distinct from the "configuration manager program" (’578 Patent, col. 3:28-30, col. 3:50-55). This could support a narrower construction requiring a separate, distributed software component rather than merely a user-facing view of an integrated web application.
'293 Patent
- The Term: "file packet"
- Context and Importance: This term is central to claim 1 of the ’293 patent. The infringement question will likely turn on whether the bundle of digital assets (e.g., scripts, stylesheets, HTML) delivered from Infor's servers to a user's browser constitutes a "file packet." Practitioners may focus on this term because the patent’s specification heavily references a more formal software distribution environment (Tivoli), which may imply a discrete, packaged installer rather than the dynamic delivery of web content.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent itself uses the term generally, stating that a distribution feature may be used to "transmit a file package to client and server stations" (’293 Patent, col. 2:11-13). This general language could support a broad definition covering any collection of files transmitted together.
- Evidence for a Narrower Interpretation: The detailed description of the distribution process involves specifying "source & target" directories, executing "before/after" programs, and using "command script[s]" (’293 Patent, Fig. 9A). This context suggests a structured, self-contained package more akin to a traditional software installer, which could support a narrower definition that excludes dynamically-served web assets.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement by asserting that "Infor intentionally instructed its customers to infringe through instructions on using the Workforce Management software and Infor system" (Compl. ¶16). It also alleges contributory infringement, claiming that Infor's software was "especially written solely for use to implement" the infringing functionality and constituted a "material part of the invention" with no substantial non-infringing uses (Compl. ¶17).
- Willful Infringement: The complaint alleges that Infor has been on notice of both the ’578 and ’293 patents "since, at the latest, the service on Infor on May 12, 2017 of the complaint filed in the previous action between Uniloc and Infor in the Eastern District of Texas" (Compl. ¶18, ¶27). The allegation of continued infringement after this date forms the basis of the claim for willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technological translation: can the architectural elements described in the 1998-era patents—such as a distinct "application launcher program" and a distributable "file packet"—be construed to cover their alleged equivalents in a modern, integrated SaaS web application? The case may depend on whether the functional descriptions in the patents are broad enough to overcome the significant differences in technical implementation between the two eras.
- A key evidentiary question will be one of factual plausibility: does the complaint provide sufficient factual detail to plausibly show that the accused Infor system operates in the specific manner claimed by the patents? While the complaint identifies accused features, it offers limited insight into the underlying software architecture, raising the question of whether its conclusory allegations will satisfy the pleading standards required by the court.