DCT
1:18-cv-01104
Riggs Technology Holdings LLC v. McGraw Hill Education Inc
I. Executive Summary and Procedural Information
Riggs Technology Holdings, LLC v. McGraw-Hill Education, Inc.
- Parties & Counsel:
- Plaintiff: Riggs Technology Holdings, LLC (New Mexico)
- Defendant: McGraw-Hill Education, Inc. (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt; Rabicoff Law LLC
- Case Identification: 1:18-cv-01104, D. Del., 07/26/2018
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is incorporated in Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s online educational platforms, which provide training to users on mobile devices, infringe a patent related to methods for managing remotely completed training.
- Technical Context: The technology relates to the field of remote e-learning, specifically the management and certification of training conducted on portable electronic devices.
- Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2001-10-12 | ’067 Patent Priority Date |
| 2007-11-20 | U.S. Patent No. 7,299,067 Issues |
| 2018-07-26 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,299,067 - "Methods and Systems for Managing the Provision of Training Provided Remotely through Electronic Data Networks to User of Remote Electronic Devices"
The patent-in-suit is U.S. Patent No. 7,299,067, issued November 20, 2007 (the "’067 Patent").
The Invention Explained
- Problem Addressed: The patent describes the inefficiencies of traditional training methods, such as travel to off-site locations, scheduling difficulties, and high costs (’067 Patent, col. 2:1-15). It notes that even early remote training via satellite or videotape was often tied to specifically equipped rooms and lacked effective mechanisms for trainee evaluation and feedback (’067 Patent, col. 2:32-44).
- The Patented Solution: The invention proposes a method and system where a central training server manages the entire lifecycle of a remote training course delivered to a user's handheld device, such as a PDA (’067 Patent, Abstract; col. 4:5-14). This includes receiving identifying information from the user, authenticating them, recording the completed training data, comparing that data against a master template to determine completion status (e.g., passed, failed), and recording that final status (’067 Patent, col. 18:9-24).
- Technical Importance: The technology aimed to make professional development and other training more flexible and efficient by untethering it from fixed locations and integrating user authentication and certification into a single, server-managed process for the emerging class of wireless handheld devices (’067 Patent, col. 2:16-29).
Key Claims at a Glance
- The complaint asserts independent claim 1 of the ’067 Patent (Compl. ¶13).
- The essential elements of method claim 1 include:
- Receiving, at a training server, training data transmitted from a user's handheld device representing training taken by the user.
- Receiving identifying information for the user concurrently with the training data file.
- Identifying the user of the handheld device.
- Authenticating the user's identity by comparing user-provided authentication data with a master user identification template stored on the server.
- Recording the training data in the server's memory.
- Locating at least one training file within the received training data.
- Determining the status of the training file (e.g., pending, incomplete, failed, passed) by comparing it with a master training template.
- Recording the determined training status in memory.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is "McGraw's Architectural Record Continuing Education" platform and its associated mobile applications (collectively, the "McGraw product") (Compl. ¶13).
Functionality and Market Context
The complaint alleges the McGraw product provides interactive online education and training to users on mobile devices like smartphones and tablets (Compl. ¶13). The system involves application servers that send training materials (e.g., videos, assignments) to users and track their progress toward certification or course credit (Compl. ¶13, ¶14). Users log into the application to access courses and view their progress (Compl. ¶13). The complaint includes a screenshot from a mobile application showing a list of downloadable course chapters, illustrating the delivery of educational content to a handheld device (Compl. Fig. 1).
IV. Analysis of Infringement Allegations
’067 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving at a training server through a data network from a user of a hand held device, the training data representing training taken by the user at hand held device | McGraw's application servers track user progress towards earning course credit, which involves receiving data from the user's mobile device representing their activity. | ¶14 | col. 18:10-15 |
| receiving identifying information for the user of a hand held device concurrently with the training data file | Users enter a username and password to access the application, and the server receives this login information to identify them and access their training data. | ¶15 | col. 16:40-49 |
| identifying the user of the hand held device | Users enter a username and password, which the system uses to identify them. The complaint provides a screenshot of the "Sign In" screen to support this allegation (Compl. Fig. 2). | ¶16 | col. 16:40-49 |
| authenticating the identity of the user of hand held device by requesting authentication data from the user and comparing the authentication data with a master identification template containing authentication data associated with the user and accessible by the training server | McGraw's server receives the user's login information and compares it against stored login credentials for the user's account to authenticate them. | ¶17 | col. 16:40-49 |
| recording the training data in memory associated with the training server | McGraw's application and server track and record users' progress towards earned credits and certificates. A screenshot shows a "Student performance" report (Compl. Fig. 3). | ¶18 | col. 18:16-24 |
| locating at least one training file contained within the training data | Once logged in, users can choose from multiple training courses and videos. The complaint includes a screenshot showing "Focused Learning" materials available to students (Compl. Fig. 4). | ¶19 | col. 29:20-22 |
| determining the status of the training file by comparing the training file with an associated master training template... the status including a determination if training... meets a set criterion including at least one of: pending, incomplete, failed, passed | The application server tracks user activities, credits, and certificates, and automatically grades online quizzes to give the user a score, thereby determining a status. | ¶20, ¶21 | col. 30:10-21 |
| recording training status in memory | The application maintains a record of information from the server, including the user's completion status of a program, which can be viewed on the user's device. | ¶21 | col. 30:22-23 |
Identified Points of Contention
- Scope Questions: Claim 1(b) requires "receiving identifying information... concurrently with the training data file." The complaint alleges the server receives login information to access the application (Compl. ¶15), while the "training data file" appears to represent the results of a completed course. This raises the question of whether an initial login authentication is "concurrent" with the later submission of completed training data.
- Technical Questions: Claim 1(g) requires determining training status by "comparing the training file with an associated master training template." The complaint alleges the server "tracks users' activities" and "grades all online quizzes" (Compl. ¶20, ¶21). A central question will be whether this functionality constitutes a comparison with a "master training template" as required by the claim, or if it is a different technical process. The complaint does not specify what component of the accused system constitutes the claimed "master training template."
V. Key Claim Terms for Construction
The Term: "hand held device"
Context and Importance
This term is foundational to the patent, which was filed in 2002 when PDAs were common. The accused products are modern smartphones and tablets. The construction of this term will be critical to determining whether the patent's scope covers current technology.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification provides a list of examples, including "PDAs, pagers, and wireless phones" (’067 Patent, Abstract) and more generally refers to "portable, wireless handheld computer systems" (’067 Patent, col. 4:8-9), which may support a construction covering a wide range of portable electronic devices.
- Evidence for a Narrower Interpretation: The specification repeatedly uses PDAs as the primary example (e.g., ’067 Patent, col. 3:32-34, col. 9:18-24). A party could argue the term should be limited to devices with the specific characteristics and capabilities of handhelds from the 2001-2002 era.
The Term: "master training template"
Context and Importance
This term appears in claim 1(g) and is central to the step of determining a user's completion status. Infringement of this element depends entirely on identifying a corresponding structure in the accused system, and its definition is therefore critical.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition. A party may argue the term should be broadly construed to mean any reference data structure against which a user's work is measured, such as a course syllabus, answer key, or set of passing criteria stored on the server.
- Evidence for a Narrower Interpretation: A party may argue that the use of the specific term "template" implies a particular, predefined data structure, rather than a general process of grading or progress tracking. The claims state it is "accessible from memory by the training server" (’067 Patent, col. 30:13-15), but provide little additional detail, making its precise meaning a likely point of dispute.
VI. Other Allegations
Indirect Infringement
The complaint alleges that McGraw induces infringement by "providing access to, support for, training and instructions for its website to its customers" to enable them to use the product in an infringing manner (Compl. ¶22). It also posits a theory of joint infringement between McGraw and its customers (Compl. ¶22).
Willful Infringement
The complaint does not contain an explicit allegation of willful infringement in its factual counts. However, the prayer for relief requests an award of "trebling of all damages" and a declaration that the case is "exceptional," remedies often associated with findings of willful or egregious infringement (Compl. p. 10, ¶D-E).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and technological evolution: Can terms like "hand held device" and "master training template", which were defined in the context of early 2000s PDA technology, be construed to read on the functionality of modern learning management systems operating on smartphones and tablets?
- A key evidentiary question will be one of functional mapping: Does the accused product’s method of authenticating users at login and later tracking their quiz scores and progress perform the specific, sequential steps of the claimed method? In particular, does the general act of grading or progress tracking meet the specific limitation of "comparing the training file with an associated master training template"?
- A third question concerns timing and concurrency: Does the process of authenticating a user upon logging into an application, potentially long before training is completed and submitted, satisfy the claim 1(b) requirement that identifying information be received "concurrently with the training data file"?