Kaleasy Tech LLC v. PanTerra Networks Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Kaleasy Tech LLC (Texas)
  • Defendant: Panterra Networks, Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Sand, Sebolt & Wernow Co., LPA
• Case Identification: 1:19-cv-01298, D. Del., 07/11/2019
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in Delaware, which constitutes residence for venue purposes under TC Heartland.
• Core Dispute: Plaintiff alleges that Defendant’s unified communication system infringes a patent related to methods for efficiently sharing user presence information within a group.
• Technical Context: The technology concerns aggregating and distributing user status information (e.g., "available," "busy," "offline") in group-based communication platforms, a foundational feature for modern collaboration and messaging services.
• Key Procedural History: The complaint is the initial pleading in this litigation and does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Patent No. 7,899,479, METHOD, SYSTEM AND APPARATUSES FOR SHARING PRESENCE INFORMATION, issued March 1, 2011. (Compl. ¶10).
• The Invention Explained:
  • Problem Addressed: The patent's background section describes a problem where group communication services and presence information services were separate and independent. For a user in a group to see the status of all other members, the user would have to make individual requests for each member, a process described as "lengthy and inconvenient" (’479 Patent, col. 2:1-3).
  • The Patented Solution: The invention proposes to solve this by creating a method to consolidate this information. A central system element (such as a group server) acquires both "basic group information" (e.g., the member list) and the individual "presence information" (e.g., online/offline status) of the members. It then combines this data into "group presence information" and sends it to group members, streamlining the sharing process (’479 Patent, Abstract; col. 4:46-51). Figure 1 illustrates this core two-step process of acquiring and then sending the consolidated information.
  • Technical Importance: This approach allows group members to "conveniently share the presence information of each other," which in turn "enriches the functions of the group service" by integrating previously separate functionalities (’479 Patent, col. 2:62-65).
• Key Claims at a Glance:
  • The complaint asserts independent claim 1 and dependent claim 3 (Compl. ¶¶13, 15).
  • Independent Claim 1 requires:
    • Acquiring, by one of a group server, presence server, or management apparatus, "group presence information" that includes both "basic group information" and "presence information" of at least one group member.
    • The "basic group information" (containing a group attribute, member list, and member attribute) comes from the group server.
    • The "presence information" of the group member comes from the presence server.
    • Sending the combined "group presence information" to a group member.
  • The complaint reserves the right to assert other claims and modify its infringement theories as the case progresses (Compl. ¶35).

III. The Accused Instrumentality

Product Identification

• The "Panterra Unified Communication" system (the "Accused Instrumentality") (Compl. ¶17).

Functionality and Market Context

• The complaint alleges the Accused Instrumentality is a system that enables a method for sharing presence information for individual team members across various platforms like desktop and mobile devices (Compl. ¶¶17-18). It allegedly stores group information (e.g., group name, membership) and gathers individual status information (Compl. ¶20). The complaint characterizes the system as having a "module for storing the presence information of the group members as a group" which it equates to a "group server," and an "identity module" for individual presence which it equates to a "presence server" (Compl. ¶21). This system allegedly combines the group member list with presence information to display the status of group members (Compl. ¶21).

IV. Analysis of Infringement Allegations

• Claim Chart Summary: The complaint references an exemplary claim chart in "Exhibit B," which is not attached to the publicly filed document. The following table is constructed from the narrative allegations in the complaint body (Compl. ¶¶18-24).

• Identified Points of Contention:
  • Scope Questions: The patent’s figures depict the "group server" and "presence server" as distinct architectural blocks (’479 Patent, Figs. 3, 4). The complaint alleges that software "modules" within the single Panterra system correspond to these servers (Compl. ¶21). This raises the question of whether the term "server," as used in the patent, can be construed to read on a software module, or if it requires a physically or logically distinct machine or process.
  • Technical Questions: Claim 1 recites acquiring and sending information "by one of" a group server, presence server, or management apparatus. The complaint alleges the accused system contains equivalents of both a group server and a presence server (Compl. ¶21). The infringement analysis may require identifying which specific component of the accused system performs the "acquiring" and "sending" steps and whether that mapping is consistent with the claim language.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "group server"

  • Context and Importance: This term's construction is central to whether the architecture of the Accused Instrumentality infringes. The complaint maps this term to a software "module" (Compl. ¶21). Practitioners may focus on this term because its definition will determine if a single, integrated system can contain a "group server" as claimed, or if a distinct entity is required.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "server." Its functionality is described as establishing groups and subscribing to presence information (e.g., ’479 Patent, col. 9:4-6, 9:26-28). A party may argue that any component, including a software module, that performs these functions meets the claim limitation.
    • Evidence for a Narrower Interpretation: The patent’s background describes the group service and presence service as historically "independent of each other" (’479 Patent, col. 1:50-51). Further, Figures 3 and 4 depict the "group server" (301, 401) and "presence server" (302, 402) as separate boxes, which may imply they are structurally distinct entities.

• The Term: "presence server"

  • Context and Importance: Similar to "group server," the complaint maps this term to an "identity module" or the "server that houses the individual identity information database" (Compl. ¶¶20-21). The viability of the infringement case depends on whether this software-based characterization falls within the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the function of a presence service as "collecting and publishing presence information" (’479 Patent, col. 1:26-27). A party could argue that any component performing this function, regardless of its integration with other components, constitutes a "presence server."
    • Evidence for a Narrower Interpretation: The same evidence for a narrow construction of "group server" applies here: the background distinction between services and the separate blocks in Figures 3 and 4 suggest the "presence server" is a discrete component, not merely a feature set within a monolithic software application (’479 Patent, col. 1:50-51; Figs. 3, 4).

VI. Other Allegations

• Willful Infringement: The complaint alleges that the Defendant has had "knowledge of infringement of the ’479 Patent at least as of the service of the present Complaint" (Compl. ¶30). This allegation, coupled with the prayer for "enhanced damages" (Compl., Prayer for Relief ¶f), forms the basis for a claim of post-filing willful infringement, but does not allege pre-suit knowledge or willfulness.

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

• A core issue will be one of architectural scope: can the terms "group server" and "presence server", which are depicted as distinct entities in the patent and described in the background as relating to historically separate services, be construed to read on software "modules" that allegedly operate within a single, integrated "Unified Communication" system?
• A key evidentiary question will be one of functional mapping: does the complaint’s theory, which maps the claimed server functions to software "modules," provide a sufficiently detailed and accurate technical correspondence to prove that the accused system performs the specific steps of acquiring and distributing information as required by the claims?