DCT
8:22-cv-01167
Zodex Data Systems LLC v. Ge Healthcare General Electric Co
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Zodex Data Systems LLC (Delaware)
- Defendant: GE Healthcare, General Electric Company (Delaware)
- Plaintiff’s Counsel: Devlin Law Firm LLC
- Case Identification: 8:22-cv-01167, C.D. Cal., 06/15/2022
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a corporation with multiple offices in California, including a regular and established place of business in Irvine within the Central District, where it transacts business and offers the accused products for sale.
- Core Dispute: Plaintiff alleges that Defendant’s medical imaging software infringes a patent related to a client-server network system that efficiently processes requests to zoom in on portions of large image files.
- Technical Context: The technology addresses the challenge of quickly viewing high-resolution images over a network by transmitting only the user-selected portion of an image for zooming, rather than the entire, much larger, image file.
- Key Procedural History: The complaint identifies Plaintiff as a "small technology and licensing company" but does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 1996-09-13 | U.S. Patent No. 6,396,507 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"
- Patent Identification: 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 technical problem of network latency and processing delays when a user on a client computer wants to view a detailed portion of a very large image file stored on a remote server. Transmitting the entire large file over a network with a low transfer rate can be time-consuming and frustrating for the user (’507 Patent, col. 1:59-2:8).
- The Patented Solution: The invention proposes a client-server method where, after an initial image is displayed, the client can designate an "arbitrary partial region" to enlarge. In response, the server "dynamically extracts" and transfers only the image data corresponding to that requested portion, rather than resending the entire file. This significantly reduces the amount of data transferred over the network, decreasing wait times ('507 Patent, Abstract; col. 12:20-28).
- Technical Importance: This method of selective, on-demand data extraction was designed to improve performance for applications handling large graphical data, such as remote medical imaging or computer-aided design, where efficient network data transfer is critical (Compl. ¶13, ¶15).
Key Claims at a Glance
- The complaint asserts direct infringement of at least independent claim 1 (Compl. ¶23).
- Claim 1 (Method):
- transmitting image data in a file from said storage device to said access device;
- designating an arbitrary portion of said image data transmitted and displayed on said access device;
- reading out only wanting image data in said arbitrary portion designated on said access device from the same file as said file of said image data transmitted; and
- transferring said wanting image data to said access device through a network.
- The complaint reserves the right to assert additional claims during litigation (Compl. ¶23, fn. 1).
III. The Accused Instrumentality
Product Identification
- The complaint names "Centricity Enterprise Web and Universal Viewer" as the accused products and/or services (Compl. ¶19).
Functionality and Market Context
- The accused products are described as "imaging software products for viewing medical images" that operate in a client-server environment (Compl. ¶13, ¶19). A "Centricity Web Server" retrieves images from archives and provides them to a web-based client over a network like the internet or an intranet (Compl. ¶26).
- The complaint alleges the products include a feature where users can select thumbnails to view specific images, which "can significantly reduce download times if you are using a relatively low bandwidth connection" (Compl. ¶27).
- A "magnifying glass" feature is identified as allowing a user to "look at small details in your images," which the plaintiff alleges is the mechanism for designating and viewing a portion of an image (Compl. ¶29). A screenshot from a user guide depicts a medical image with a rectangular 'magnifying glass' tool overlaid, showing a magnified view of a specific portion of the image (Compl. p. 8).
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 products operate as a web-based system where a "Centricity Web Server retrieves images from archives and other sources and provides them to the Centricity Web client." | ¶26 | col. 2:21-28 |
| ...transmitting image data in a file from said storage device to said access device; | A user selects a study to display thumbnails, and the "Centricity Web Server" retrieves and sends image data to the client. | ¶27 | col. 2:32-35 |
| ...designating an arbitrary portion of said image data transmitted and displayed on said access device; | A user can employ a "magnifying glass" tool to "look at small details in your images," which the complaint alleges constitutes the designation of an arbitrary portion. | ¶28, ¶29 | col. 11:7-14 |
| ...reading out only wanting image data in said arbitrary portion...from the same file as said file of said image data transmitted; | The complaint alleges that the "magnifying glass" feature performs this function, but provides evidence from a user guide that describes the user-facing action rather than the underlying server-side data process. | ¶29 | col. 12:4-9 |
| ...transferring said wanting image data to said access device through a network. | The accused products are described as a "web-based system for examining medical images over an intranet or the Internet," which inherently involves transferring data from a server to a client through a network. | ¶30 | col. 12:10-13 |
- Identified Points of Contention:
- Technical Questions: A primary question for the court will be how the accused "magnifying glass" feature is technically implemented. The complaint's evidence is based on a user guide, which describes the user experience but does not detail the underlying server-side operations (Compl. ¶29). The key factual dispute may be whether using the tool triggers a new request to the server to extract and send a portion of the original high-resolution file, or if it performs a client-side digital magnification of image data already transferred to the client.
- Scope Questions: The infringement analysis may turn on the interpretation of "reading out only wanting image data... from the same file." The question is whether the accused product's functionality, whatever it may be, meets this specific limitation, which appears to require a targeted data extraction operation on the server in response to the user's designation on the client.
V. Key Claim Terms for Construction
- The Term: "reading out only wanting image data in said arbitrary portion... from the same file"
- Context and Importance: This limitation is central to the patent's claimed technical improvement of reducing network traffic. The case's outcome may depend on whether the accused "magnifying glass" feature is found to perform this specific server-side action. Practitioners may focus on this term because the plaintiff's infringement theory hinges on the server performing a new, partial data extraction from the original source file, a fact not explicitly detailed in the user-facing evidence provided.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent’s "Summary of the Invention" broadly discusses solving the problem of long transfer times by dynamically extracting and transferring only the requested portion, which could be argued to cover any server-side process that achieves this result without being limited to a specific implementation ('507 Patent, col. 3:58-64).
- Evidence for a Narrower Interpretation: The Abstract and the detailed description of the first embodiment provide strong support for a narrower reading, stating that "only image data in the requested partial region is dynamically extracted on the server and transferred instead of transferring the entire file" ('507 Patent, Abstract). This language suggests a specific sequence of operations initiated by the client and executed by the server on the original file, not a client-side function.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides users with instructions and promotional materials that instruct and encourage them to use the accused products in a manner that allegedly practices the claimed method (Compl. ¶32, ¶34).
- Willful Infringement: The complaint does not contain a formal count for willful infringement. However, the prayer for relief seeks attorneys' fees under 35 U.S.C. § 285 (Compl., Prayer for Relief, ¶(c)). The allegations assert that Defendant intended to "encourage its customers to use the Accused Instrumentalities in an infringing manner," which could form the basis for a future willfulness claim, though no specific facts alleging pre-suit knowledge of the patent are pleaded (Compl. ¶34).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core technical and evidentiary question will be one of operational mechanism: Does the accused "magnifying glass" feature function by triggering a new data request to the server for a high-resolution partial image from the original file, as required by the patent, or does it operate as a purely client-side digital zoom on data already delivered to the user's device?
- A central issue of claim scope will be whether the phrase "reading out only wanting image data... from the same file" requires a new, discrete server-side file access and extraction operation for the designated portion, or if it can be construed more broadly. The resolution of this question will likely depend on evidence concerning the specific software architecture of the accused products.