Kaleasy Tech LLC v. Quip LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Kaleasy Tech LLC (Texas)
  • Defendant: Quip LLC (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
• Case Identification: 1:19-cv-02328, D. Del., 12/22/2019
• Venue Allegations: Venue is asserted in the District of Delaware based on Defendant's incorporation in that state.
• Core Dispute: Plaintiff alleges that Defendant’s "Quip Software" infringes a patent related to methods for consolidating and sharing user presence information within a group.
• Technical Context: The technology concerns the integration of user status information (e.g., online, away, busy) with group-based communication systems, a foundational feature in modern collaborative software and messaging platforms.
• Key Procedural History: The complaint notes that the patent-in-suit was assigned to the Plaintiff from its original assignee. No other significant procedural events, such as prior litigation or administrative proceedings, are mentioned.

Case Timeline

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

U.S. Patent No. 7,899,479 - “METHOD, SYSTEM AND APPARATUSES FOR SHARING PRESENCE INFORMATION”

• Patent Identification: U.S. Patent No. 7,899,479, “METHOD, SYSTEM AND APPARATUSES FOR SHARING PRESENCE INFORMATION,” issued March 1, 2011. (Compl. ¶1, ¶9).

The Invention Explained

• Problem Addressed: The patent describes a problem in prior art systems where group services and presence services were independent. To find out the status of all members in a group, a user had to submit individual requests to a presence server for each member, a process described as "lengthy and inconvenient." (’479 Patent, col. 1:50-65).
• The Patented Solution: The invention proposes a method and system to streamline this process by more closely integrating the group and presence functions. A central system entity—such as a "group server," a "presence server," or a dedicated "management apparatus"—is tasked with automatically acquiring both basic group information (like member lists) and individual presence information (like user status). It then combines these into a single "group presence information" package and sends it to group members, eliminating the need for individual queries. (’479 Patent, Abstract; col. 2:11-23).
• Technical Importance: This approach enabled more efficient and automated sharing of user status within a defined group, integrating two previously distinct services to enhance collaborative communication. (’479 Patent, col. 2:59-65).

Key Claims at a Glance

• The complaint asserts independent Claim 1. (Compl. ¶13-14).
• The essential elements of Claim 1 are:
  • Acquiring, by one of a group server, a presence server, or a management apparatus, "group presence information" that comprises "basic group information" and "presence information" of at least one group member.
  • The "basic group information" is from the group server and comprises a group attribute, a group member list, and a group member attribute.
  • The "presence information" is from the presence server.
  • Sending the "group presence information" to a group member.
• The complaint also asserts dependent Claim 3 and states that Plaintiff reserves the right to assert additional claims. (Compl. ¶15-16, ¶35).

III. The Accused Instrumentality

Product Identification

The "Quip Software." (Compl. ¶17).

Functionality and Market Context

The complaint alleges the Quip Software is a solution that "enables a method for sharing presence information." (Compl. ¶17). According to the allegations, the software stores "channel information," including channel name and user membership, on a server or module. (Compl. ¶20). This system then gathers "individual status information," such as a user's presence on desktop or mobile, or a "busy" status. (Compl. ¶19). The complaint further alleges that the software's "channel module" combines the group member list with the presence information from the presence server to display the presence of channel members. (Compl. ¶21).

IV. Analysis of Infringement Allegations

The complaint references an Exhibit B claim chart that was not attached to the publicly filed document. The following analysis is based on the narrative allegations in the body of the complaint.

No probative visual evidence provided in complaint.

'479 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central issue may be how the claim terms "group server" and "presence server" are construed and mapped onto the architecture of the Quip Software. The complaint alleges that a single "channel module" in the accused system functions as both a group server and a presence server. (Compl. ¶21). The case may raise the question of whether Quip's potentially integrated architecture satisfies the claim limitations, which, in some patent figures, are depicted as distinct components (’479 Patent, Fig. 3), or whether the claim's "one of" phrasing allows a single apparatus to perform all recited functions.
• Technical Questions: What evidence will be presented to demonstrate that the accused software's data aggregation and transmission meet the specific requirements of the claims? For example, the complaint alleges the transmission of "presence information for members of a particular channel" (Compl. ¶24), but the claim requires sending "group presence information," a term defined as a combination of specific "basic group information" and "presence information." The degree of correspondence between the data packet sent by Quip and the specific components required by the claim will be a focal point.

V. Key Claim Terms for Construction

• The Term: "group server", "presence server"

  • Context and Importance: Claim 1 recites actions performed by "one of a group server, a presence server and a presence information management apparatus." The Plaintiff's theory collapses the "group server" and "presence server" functions into Defendant's single "channel module." (Compl. ¶21). Practitioners may focus on this term because the validity of this mapping is fundamental to the infringement allegation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim preamble uses the disjunctive "one of," which could suggest that a single apparatus may perform the functions attributed to any of the listed entities. The specification also describes multiple "manners" in which the method can be performed, which may support architectural flexibility. (’479 Patent, col. 3:51-4:44).
    • Evidence for a Narrower Interpretation: The patent’s figures, such as Figure 3, depict the "group server" (301) and "presence server" (302) as separate schematic blocks. This could support an argument that they are structurally distinct entities, not merely abstract sets of functions that can be co-located in a single software module. (’479 Patent, Fig. 3).

• The Term: "group presence information"

  • Context and Importance: This term defines the object that is "acquired" and "sent." It is defined within Claim 1 as "comprising basic group information and presence information," where "basic group information" is further defined to comprise three specific sub-elements. The infringement analysis will depend on whether the data packet sent by the Quip Software contains all the constituent parts of the claimed "group presence information".
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The word "comprising" is a term of art in patent law that is generally interpreted as open-ended, meaning the information packet must include the recited elements but is not limited to them.
    • Evidence for a Narrower Interpretation: The claim explicitly defines "basic group information" as comprising "a group attribute, a group member list and a group member attribute." (’479 Patent, col. 16:8-10). A party could argue that for infringement to be found, the accused "group presence information" must contain data corresponding to all three of these specific sub-elements, and the absence of any one would be non-infringing.

VI. Other Allegations

• Indirect Infringement: The complaint does not include a specific count for indirect infringement.
• Willful Infringement: The complaint alleges that Defendant had knowledge of infringement "at least as of the service of the present Complaint" (Compl. ¶30) and includes a prayer for enhanced damages (Compl. p. 8, ¶f). This appears to lay the groundwork for a claim of post-suit willfulness, but the complaint does not allege any facts supporting pre-suit knowledge.

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

• A core issue will be one of architectural mapping: can the functions of the "group server" and "presence server", which are depicted as distinct entities in the patent's figures, be read onto a single "channel module" within the accused Quip Software, or does the claim language require distinct components that are absent in the accused system's architecture?
• A key evidentiary question will be one of definitional precision: does the information that Quip aggregates and sends to users contain all the specific constituent parts—a "group attribute", a "group member list", and a "group member attribute"—required to meet the claim's definition of "group presence information," or is there a technical mismatch in the data itself?