DCT

8:26-cv-00194

Corent Technology Inc v. Aws Amazon Web Services

Key Events
Complaint
complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:26-cv-00194, C.D. Cal., 01/27/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant AWS maintains regular and established places of business in the Central District of California, including multiple offices in Irvine, employs thousands of tech workers in the district, and has committed the alleged acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s cloud computing services—specifically its tools for migrating applications to the cloud, orchestrating containerized workloads, enabling multi-tenant software-as-a-service (SaaS) functionality, and metering cloud usage—infringe four of its patents.
  • Technical Context: The technology relates to foundational processes in cloud computing that enable businesses to move legacy software applications from on-premises servers to cloud infrastructure and operate them efficiently in a multi-tenant, usage-based model.
  • Key Procedural History: The complaint alleges that Plaintiff Corent had multiple meetings with AWS’s product team beginning in 2019, during which it demonstrated its patented technologies and identified its issued and pending patents. It further alleges providing AWS with written notice of infringement in December 2025, approximately one month prior to filing the complaint. These allegations form the basis of the willfulness claim.

Case Timeline

Date Event
2011-09-23 U.S. Patent No. 9,495,372 Priority Date
2014-07-31 U.S. Patent Nos. 11,019,136; 10,320,893; and 10,305,761 Priority Date
2016-11-15 U.S. Patent No. 9,495,372 Issues
2017 AWS Migration Hub is launched
2018 AWS Managed Kubernetes Service (EKS) is released
2019-05-28 U.S. Patent No. 10,305,761 Issues
2019-06-11 U.S. Patent No. 10,320,893 Issues
2019 Plaintiff and Defendant begin meetings regarding the technology
2021-05-25 U.S. Patent No. 11,019,136 Issues
2025 AWS Transform is launched
2025-12-22 Plaintiff sends notice letter to Defendant
2026-01-27 Complaint is filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 11,019,136 - "PARTITIONING AND MAPPING WORKLOADS FOR SCALABLE SAAS APPLICATIONS ON CLOUD"

The Invention Explained

  • Problem Addressed: The patent's background section, as summarized in the complaint, identifies the problem that many legacy software applications are "not well suited to a particular cloud environment" due to a "wide variety of configurations" and the inability of legacy systems to take full advantage of cloud resources, causing them to "run inefficiently in a cloud" Compl. ¶65 ’136 Patent, col. 1:43-51
  • The Patented Solution: The invention claims a method to automate and optimize the migration of these "non-tenant-aware" applications. The method involves computationally identifying an application's constituent "workloads," partitioning them based on their characteristics, grouping them into sub-partitions, and then systematically constructing and ranking a plurality of "workload assignment maps." These maps assign the workloads to specific cloud resources, and the ranking is based on user-defined rules such as cost, efficiency, or scalability Compl. ¶¶64, 66 ’136 Patent, col. 2:67-3:2
  • Technical Importance: This technology aims to replace a manual, complex, and error-prone cloud migration process with an automated, rule-based system for optimizing application architecture Compl. ¶¶46-47

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶140
  • Essential elements of claim 1 include:
    • identifying workloads of a non-tenant-aware application and a set of application characteristics for each of the identified workloads;
    • creating a partition of the workloads in reference to a partition application characteristic;
    • grouping the created partition of the workloads into a plurality of workload sub-partitions as a function of a common workload characteristic;
    • assigning each partition of the workloads to a set of cloud resources as a function of the partition application characteristic and a characteristic of the set of cloud resources;
    • constructing a plurality of workload assignment maps to assign to each of the workloads in accordance with the created partition; and
    • ranking each one of plurality of workload assignment maps based on a set of rules.
  • The complaint notes that infringement of other claims may be alleged later.

U.S. Patent No. 10,320,893 - "PARTITIONING AND MAPPING WORKLOADS FOR SCALABLE SAAS APPLICATIONS ON CLOUD"

The Invention Explained

  • Problem Addressed: The patent addresses the same technical problem as the '136 Patent: the challenge of effectively migrating and orchestrating non-tenant aware applications in a cloud environment where they may run inefficiently Compl. ¶72 ’893 Patent, col. 1:38-44
  • The Patented Solution: While the '136 Patent claims a method, the ’893 Patent claims a system for performing the automated workload configuration. The system is comprised of distinct software components: a "scanning engine" to identify workloads and their characteristics, a "partitioning engine" to group the workloads into partitions based on rules, a "mapping engine" to assign those partitions to cloud resources, and a "rendering engine" to construct a final migration plan Compl. ¶¶71, 74 ’893 Patent, col. 2:5-24 The patent describes a concrete architecture for implementing the migration and orchestration method.
  • Technical Importance: This patent provides the system-level blueprint for the automated cloud migration technology described in the '136 Patent, defining the specific functional engines required to carry out the process Compl. ¶47

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶147
  • Essential elements of claim 1 include:
    • a scanning engine configured to identify workloads of a non-tenant-aware application using workload rules;
    • a partitioning engine configured to group the workloads to a smaller set of partitions using partition rules;
    • a mapping engine configured to assign each partition to a set of cloud resources using partition rules;
    • a rendering engine that constructs a migration plan to migrate the workloads; and
    • wherein the engines comprise stored program instructions embedded in a non-transitory computer readable storage medium.
  • The complaint notes that infringement of other claims may be alleged later.

Multi-Patent Capsule: U.S. Patent No. 9,495,372 - "MULTI-TENANT AGILE DATABASE CONNECTOR"

  • Technology Synopsis: The patent addresses the problem of enabling a single-tenant application to work with a multi-tenant database system without requiring significant reprogramming of the original application Compl. ¶79 The solution is an "agile database connector" that acts as an intermediary, intercepting standard database commands, inferring the correct tenant identifier from an external source, and transparently translating the command into a tenant-specific one before it reaches the database Compl. ¶¶78, 80
  • Asserted Claims: Independent claim 1 is asserted Compl. ¶153
  • Accused Features: AWS Serverless SaaS Platform and related services (e.g., API Gateway, Lambda, DynamoDB, Relational Database Service), which are alleged to provide functionality for adapting single-tenant applications for multi-tenant use Compl. ¶¶118-119, 155

Multi-Patent Capsule: U.S. Patent No. 10,305,761 - "MULTI-APPLICATION SAAS METERING ENGINE"

  • Technology Synopsis: The patent addresses the need for granular, usage-based monitoring and billing in multi-tenant SaaS environments, as opposed to less precise "block billing" Compl. ¶86 The claimed system includes a "metering engine" to monitor data streams, an "identity engine" to identify the user associated with an event, a "bucket aggregator" to aggregate that user's activity, and a "subscription engine" to generate a summary of usage, enabling accurate, per-user billing (Compl. ¶¶85, 87; ’761 Patent, col. 13:28-14:21).
  • Asserted Claims: Independent claim 1 is asserted Compl. ¶160
  • Accused Features: AWS Marketplace, AWS Billing and Cost Management, and AWS Billing View, which are alleged to provide metered billing services that measure customer usage of cloud resources and enable charging based on that consumption Compl. ¶¶89, 108, 162

III. The Accused Instrumentality

Product Identification

  • The complaint collectively refers to a broad suite of Amazon Web Services products as the "Accused Products" Compl. ¶89 These can be categorized as:
    • Migration and Orchestration Services: AWS Migration Hub, AWS Transform, and Amazon EKS Managed Kubernetes Service (EKS).
    • SaaS Enablement Services: AWS Serverless SaaS Platform, AWS Serverless Application Model (SAM), Amazon API Gateway, AWS Lambda, Amazon DynamoDB, and Amazon Relational Database Service.
    • Metering and Billing Services: AWS Marketplace, AWS Billing and Cost Management, and AWS Billing View.

Functionality and Market Context

  • The complaint alleges that AWS Migration Hub and AWS Transform provide tools for discovering on-premises applications, analyzing their workloads and dependencies, and migrating them to the AWS cloud Compl. ¶¶93, 96 A diagram in the complaint illustrates a workflow where a "Server Migration Connector" analyzes an on-premise data center and feeds information into the AWS Migration Hub, which then utilizes other AWS services to create a cloud-based version Compl. p. 7 EKS is described as a container orchestration service that uses a "Kube Scheduler" to automatically assign containerized workloads to cloud resources through a process of filtering and scoring Compl. ¶¶103-104
  • The AWS Serverless SaaS offerings are alleged to provide architectures, such as "database-per-tenant" and "sharded multi-tenant" models, that allow developers to run applications with multi-tenant capabilities Compl. ¶¶114-116 The complaint includes diagrams illustrating these two distinct database architectures Compl. p. 32
  • AWS Marketplace is alleged to provide a platform for metering and billing based on customer consumption of cloud resources, which can include monitoring container usage and producing subscriber-specific IDs for billing Compl. ¶¶108, 110
  • The complaint positions these services as central to AWS's business model, alleging that migration services are offered for free for 90 days to "lure customers" into the AWS ecosystem, where they then pay for other services like EKS and Marketplace Compl. ¶¶14, 101

IV. Analysis of Infringement Allegations

'136 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
identifying workloads of a non-tenant-aware application and a set of application characteristics for each of the identified workloads AWS Migration Hub's "discover phase," where it identifies and inventories the on-premises architecture and applications. ¶¶93, 95 col. 1:33-42
creating a partition of the workloads in reference to a partition application characteristic During the "migrate phase," workloads of the application are identified and grouped into partitions based on their dependencies and other characteristics. ¶96 col. 2:37-41
grouping the created partition of the workloads into a plurality of workload sub-partitions as a function of a common workload characteristic The process of grouping servers and workloads as applications based on their characteristics and dependencies. ¶96 col. 7:1-13
assigning each partition of the workloads to a set of cloud resources... AWS Migration creates "targeted mappings to cloud resources" after analyzing the partitioned workloads. EKS uses a scheduler to assign workloads to cloud resources. ¶¶97, 104 col. 2:42-49
constructing a plurality of workload assignment maps... The AWS Migration process creates "a series of targeted mappings" to cloud resources that are analyzed to determine a final migration plan. ¶97 col. 8:34-45
ranking each one of plurality of workload assignment maps based on a set of rules The system determines a "most favorable mapping" before executing the migration. The EKS scheduler uses a "scoring" functionality to select resources. ¶¶97, 104 col. 2:67-3:2
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether AWS's process of creating a "most favorable mapping" meets the claim limitation of "constructing a plurality of workload assignment maps" and then "ranking" them. The analysis may explore whether AWS generates and compares multiple complete migration plans or uses a more direct optimization algorithm that does not create discrete, comparable "maps."
    • Technical Questions: For infringement by EKS, a key question will be whether the standard Kubernetes scheduling process (filtering and scoring nodes) constitutes the specific "ranking" of "workload assignment maps" as required by the claim. The complaint's visual of the Kubernetes architecture shows a multi-step scheduling pipeline, including "Filter" and "Score" stages, which will be a focus of technical analysis Compl. p. 29

'893 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a scanning engine configured to identify workloads of a non-tenant-aware application... using workload rules... AWS Migration's discovery tools, such as the Application Discovery Service, which assess on-premises virtual machines and map dependencies. ¶¶89, 93 col. 2:5-15
a partitioning engine configured to group the workloads to a smaller set of partitions... using partition rules... The functionality within AWS Migration and EKS that groups identified workloads into partitions or containers based on dependencies and compute requirements. ¶¶96, 103 col. 2:16-24
a mapping engine configured to assign each partition of the workloads to a set of cloud resources... using partition rules... The component of AWS Migration that creates targeted mappings to cloud resources and the Kube Scheduler in EKS that assigns partitions to resources. ¶¶97, 104 col. 2:25-35
a rendering engine that constructs a migration plan to migrate each of the workloads... The functionality that finalizes and executes the migration based on the "most favorable mapping" determined by the system. ¶97 col. 2:36-42
  • Identified Points of Contention:
    • Scope Questions: The dispute may focus on whether the collection of tools within the AWS Migration suite constitutes the specific, claimed set of "scanning", "partitioning", "mapping", and "rendering" engines. Defendant may argue that its architecture does not map cleanly onto the patent's four-engine structure.
    • Technical Questions: What specific "workload rules" and "partition rules" does AWS Migration employ? The infringement analysis will depend on whether AWS's automated, and allegedly AI-driven, processes can be shown to operate according to the type of user-defined rules databases described in the patent Compl. ¶¶74, 98

V. Key Claim Terms for Construction

  • The Term: "ranking each one of plurality of workload assignment maps based on a set of rules"
  • Context and Importance: This limitation appears to be the core inventive step, describing the optimization process. The outcome of the case for the migration/orchestration patents may depend heavily on whether AWS's accused systems perform this specific type of comparative analysis or a different kind of optimization. Practitioners may focus on this term because it requires both the creation of multiple distinct "maps" and a subsequent "ranking" step, which may not be present in a system that uses a heuristic to find a single optimal solution directly.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the rules can be as simple as "cost, efficiency, and/or scalability," which could be read broadly to cover the scoring functions used in modern schedulers '893 Patent, col. 2:60-63 The term "ranking" could be interpreted to mean any system that evaluates and prioritizes different workload placement options.
    • Evidence for a Narrower Interpretation: The claim language "constructing a plurality of workload assignment maps" and then "ranking each one" suggests a two-step process. This could be interpreted to require the full generation of multiple, discrete migration plans, followed by a separate comparison. A system that iteratively builds a single optimal plan without creating other complete plans to compare against might be argued to fall outside this scope.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that AWS induces infringement by providing customers with extensive documentation, technical support, websites, and promotional materials that instruct them on how to use the Accused Products (e.g., Migration Hub, EKS, Serverless SaaS tools) in a manner that directly infringes the asserted claims Compl. ¶¶142, 148, 155, 162
  • Willful Infringement: Willfulness is alleged for all four patents. The complaint bases this on alleged pre-suit knowledge, asserting that Corent demonstrated its patented technology and identified its patents to the AWS product team in meetings starting in 2019 Compl. ¶99 The claim is further supported by allegations that Corent sent a specific notice letter to AWS in December 2025 and that AWS continued its allegedly infringing conduct thereafter Compl. ¶¶100, 137

VII. Analyst’s Conclusion: Key Questions for the Case

  1. A central issue will be one of operational equivalence: Do the automated processes within AWS Migration Hub and the Kubernetes scheduler in EKS perform the specific sequence of steps claimed in the '136 and '893 patents? The case will likely require a deep technical dive into whether AWS's systems "construct a plurality of workload assignment maps" and then "rank" them, or if they achieve a similar outcome through a technically distinct optimization method.
  2. A key question regarding damages will be willfulness and pre-suit knowledge: Can Corent produce evidence to substantiate its claim that it disclosed its patents and demonstrated the patented technology to AWS product teams as early as 2019? The answer will be critical to determining whether AWS's conduct, if found to be infringing, was egregious enough to warrant enhanced damages.
  3. For the SaaS-enablement and metering patents, a primary question will be one of architectural scope: Can the collection of discrete AWS services (e.g., API Gateway, Lambda, DynamoDB) be considered an infringing "agile database connector" ('372 Patent), and do the functions within AWS Marketplace constitute the claimed "metering", "identity", and "aggregator" engines ('761 Patent)? The dispute may focus on whether AWS provides an integrated infringing system or merely a set of non-infringing tools that customers can assemble.