DCT

1:17-cv-00933

E Numerate Solutions Inc v. Mattress Firm Holding Corp

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:17-cv-00933, D. Del., 07/11/2017
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation and, on information and belief, operates multiple retail outlets within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s use of the eXtensible Business Reporting Language (XBRL) standard for its public financial filings infringes four patents related to reusable markup languages for processing and displaying numerical data.
  • Technical Context: The technology concerns structured data formats that embed descriptive metadata within numerical documents, aiming to make financial and business data machine-readable and computationally reusable across different systems.
  • Key Procedural History: The complaint alleges that Defendant was made aware of the asserted patents via a letter sent to its General Counsel on August 18, 2016, nearly a year before the suit was filed, which forms the basis for the willfulness allegations.

Case Timeline

Date Event
1999-05-21 Earliest Priority Date for Asserted Patents ('355, '816, '383, '748 Patents)
2010-01-19 U.S. Patent No. 7,650,355 Issues
2012-05-22 U.S. Patent No. 8,185,816 Issues
2016-02-16 U.S. Patent No. 9,262,383 Issues
2016-02-23 U.S. Patent No. 9,268,748 Issues
2016-08-18 Plaintiffs allegedly notify Defendant of infringement via letter
2017-07-11 Complaint Filed

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

U.S. Patent No. 7,650,355 - "Reusable Macro Markup Language"

The Invention Explained

  • Problem Addressed: The patent’s background section describes the inefficiency of conventional data processing where numerical data and its descriptive documentation are separate (Compl., Ex. A, ’355 Patent, col. 2:11-25). It notes that spreadsheet macros are not typically reusable because they are tied to specific cell locations and lack standardized semantic designators, making it difficult to automate the analysis and combination of numerical data from different sources (Compl., Ex. A, ’355 Patent, col. 3:1-15).
  • The Patented Solution: The invention proposes a markup language, "Reusable Macro Markup Language" (RMML), which works in conjunction with a "Reusable Data Markup Language" (RDML). This system allows numerical analysis routines (macros) to be written in a standardized, reusable format by embedding metadata tags directly with the numerical values (Compl., Ex. A, ’355 Patent, col. 8:15-24). These tags describe characteristics like units, magnitude, and scale, enabling a data viewer to automatically interpret, transform, and display numerical data from disparate documents on a single interface (Compl., Ex. A, ’355 Patent, col. 1:57-68, Fig. 1).
  • Technical Importance: This approach aimed to create a standardized, web-friendly method for exchanging and manipulating numerical data, analogous to how HTML standardized the display of text and images.

Key Claims at a Glance

  • The complaint asserts independent claims 1, 27, 28, and 54. Claim 1, a method claim, is representative.
  • Claim 1 Elements:
    • A method in a data processing system that receives a markup document having a set of numerical values and tags indicating their characteristics.
    • Determining a transformation for the set of numerical values to reflect new characteristics.
    • Accessing a plurality of the tags, which indicate magnitude, scale, modifier, units, measure, adjustment, and aggregation.
    • Determining conversion factors for these tags to accomplish the transformation.
    • Multiplying the set of numerical values by the determined conversion factors to transform them to reflect the new characteristics.

U.S. Patent No. 8,185,816 - "Combining Reusable Data Markup Language Documents"

The Invention Explained

  • Problem Addressed: The patent addresses the difficulty of combining numerical data from multiple online sources, especially when the data is in different formats (e.g., one in thousands of U.S. dollars, another in hundreds of French francs) (Compl., Ex. C, ’816 Patent, col. 7:31-38). Conventional methods require manual intervention to reconcile these differences before the data can be coherently displayed or analyzed together.
  • The Patented Solution: The invention provides a method where a data viewer automatically combines a first and second markup document, each containing numerical data with descriptive tags, into a single data set for display (Compl., Ex. C, ’816 Patent, col. 4:1-4). By reading the embedded metadata tags (e.g., for currency, magnitude), the system can automatically perform the necessary transformations to present the combined data on a single, coherent graphical display without manual adjustments by the user (Compl., Ex. C, ’816 Patent, col. 7:38-46).
  • Technical Importance: This technology sought to automate the collation and normalization of structured numerical data from disparate sources, a key step in enabling large-scale, machine-driven data analysis.

Key Claims at a Glance

  • The complaint asserts independent claims 1, 10, 17, 26, and 27. Claim 1, a method claim, is representative.
  • Claim 1 Elements:
    • A method in a data processing system that receives a first markup document and a second markup document, both containing numerical values and tags.
    • The characteristics of the numerical values in the first document differ in format from those in the second.
    • Automatically transforming the numerical values of at least one of the documents so they have a common format.
    • Combining the first and second markup documents into a single data set.
    • Displaying the single data set.

U.S. Patent No. 9,262,383 - "System, Method, And Computer Program Product For Processing A Markup Document"

  • Technology Synopsis: This patent describes a system for processing markup documents by identifying numerical values and first tags, which define characteristics like a unit of measure. The system can then transform the data based on these tags when combining it with a second document that has different characteristics, creating a unified data set for display.
  • Asserted Claims: Independent claims 1, 17, and 18 are asserted (Compl. ¶26).
  • Accused Features: The accused features are Defendant’s alleged acts of preparing and filing multiple XBRL-compliant filings (Compl. ¶26).

U.S. Patent No. 9,268,748 - "System, Method, And Computer Program Product For Outputting Markup Language Documents"

  • Technology Synopsis: This patent focuses on an apparatus that processes an extensible markup language (XML) compliant data document. The system is configured to handle multiple hierarchical relationships between line items and includes a browser component for allowing review of the XML-compliant data.
  • Asserted Claims: Independent claims 1, 11, and 19 are asserted (Compl. ¶32).
  • Accused Features: The accused features are Defendant’s alleged acts of preparing and filing multiple XBRL-compliant filings (Compl. ¶32).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is not a specific product but rather Defendant Mattress Firm’s alleged practice of “prepar[ing] and fil[ing] multiple XBRL-compliant filings” with the Securities and Exchange Commission (“SEC”) (Compl. ¶14, 20, 26, 32).

Functionality and Market Context

  • The complaint alleges that Defendant uses the eXtensible Business Reporting Language (XBRL) standard for its routine financial disclosures to the SEC (Compl. ¶11). XBRL is an open technology standard for tagging financial data, which allows the data to be processed and analyzed automatically by software. The complaint provides a hyperlink to a specific Mattress Firm SEC filing as an example of the accused activity (Compl. ¶11). The use of XBRL for public company financial reporting is mandated by the SEC, making it a standard business practice for publicly traded companies. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references infringement chart exhibits for each asserted patent (e.g., Ex. B, D, F, H), but these exhibits were not filed with the complaint. Therefore, the infringement theory is summarized below in prose based on the complaint's narrative allegations.

Narrative Infringement Summary

  • The central infringement theory is that Defendant’s use of the XBRL standard to create and file financial documents with the SEC directly infringes the asserted patents (Compl. ¶14, 20). The complaint alleges that this process of preparing and filing XBRL documents constitutes practicing the methods and using the systems claimed in the patents. For the ’355 Patent, this activity allegedly includes the claimed steps of receiving numerical values with associated characteristics, adding tags to the document, and performing transformations (Compl. ¶14). For the ’816 Patent, the preparation and filing of "multiple" XBRL documents is alleged to meet the claim limitations of receiving first and second markup documents, automatically transforming them to a common format, and combining them into a single data set (Compl. ¶20). The allegations for the ’383 and ’748 patents follow a similar theory (Compl. ¶26, 32).

Identified Points of Contention

  • Scope Questions: A primary question may be whether the patents’ claims, which describe a proprietary "Reusable Data Markup Language" (RDML) and associated macros (RMML), can be construed to cover the use of XBRL, a publicly developed and federally mandated open standard. The court may need to determine if practicing an industry standard constitutes infringement of patents that describe a specific, albeit conceptually similar, language and system.
  • Technical Questions: The complaint makes high-level allegations without providing specific evidence of how Mattress Firm's actions meet each element of the asserted claims. For instance, for claim 1 of the ’355 Patent, a key question will be what evidence exists that Defendant's process involves "determining conversion factors" and "multiplying" numerical values by those factors as part of its standard XBRL filing preparation. Similarly, for claim 1 of the ’816 Patent, it raises the question of whether filing multiple, separate reports over time constitutes "combining" two documents into a "single data set" for "displaying," as the claim requires.

V. Key Claim Terms for Construction

Term: "markup document" (e.g., ’355 Patent, Claim 1)

  • Context and Importance: This term's construction is fundamental to the scope of all asserted patents. A broad definition could read on any document using a markup language like XBRL, while a narrow definition might limit the claims to the specific RDML/RMML languages and systems described in the patent specifications.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "markup document" is a generic term of art. The claims themselves do not explicitly limit the term to the RDML embodiment.
    • Evidence for a Narrower Interpretation: The specifications heavily feature the terms "Reusable Data Markup Language" (RDML) and "Reusable Macro Markup Language" (RMML) as the invention (Compl., Ex. A, ’355 Patent, Abstract, col. 1:57-60). The title of the ’355 Patent is "Reusable Macro Markup Language", suggesting the invention is not just any markup language, but a specific one with reusable macro capabilities as described.

Term: "combining the first markup document and the second markup document into a single data set" (e.g., ’816 Patent, Claim 1)

  • Context and Importance: This term is critical to the infringement analysis for the ’816 Patent. The infringement allegation rests on the defendant preparing and filing "multiple" XBRL documents. Whether this serial activity constitutes "combining" documents into a single set as claimed will likely be a central dispute.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term could be interpreted broadly to mean any logical association of data from two documents for a common purpose, even if not simultaneous.
    • Evidence for a Narrower Interpretation: The specification describes a data viewer that "automatically combine[s] and manipulate[s] multiple documents on a single display" (Compl., Ex. C, ’816 Patent, col. 4:59-62). This suggests a contemporaneous act of merging data from distinct files for unified presentation, which may differ from the defendant's alleged serial filing of separate reports.

VI. Other Allegations

Willful Infringement

  • The complaint alleges that Defendant's infringement has been willful because it had pre-suit knowledge of all four asserted patents. This knowledge is based on a letter allegedly sent by Plaintiff to Defendant's General Counsel on August 18, 2016 (Compl. ¶15, 21, 27, 33).

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

  • A core issue will be one of definitional scope and public standards: can claims rooted in the disclosure of a proprietary "Reusable Data Markup Language" be construed broadly enough to cover a defendant's use of XBRL, an open, consensus-based, and government-mandated standard for financial reporting? The case may test the boundary between patenting a specific technological system and attempting to cover a general concept that is later adopted as a public standard.
  • A key evidentiary question will be one of factual mapping: beyond the general allegation that using XBRL infringes, what specific evidence will show that Defendant's routine business filings perform the detailed, multi-step data transformation and combination processes required by the independent claims of the asserted patents? The absence of claim charts in the public filing suggests this detailed mapping will be a primary focus of discovery and subsequent litigation.