DCT
1:19-cv-02329
Kaleasy Tech LLC v. RingCentral Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Kaleasy Tech LLC (Texas)
- Defendant: RingCentral, Inc. (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; SAND, SEBOLT & WERNOW CO., LPA
- Case Identification: 1:19-cv-02329, D. Del., 03/23/2020
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation.
- Core Dispute: Plaintiff alleges that Defendant’s RingCentral Glip Software infringes a patent related to methods for efficiently sharing user presence information within communication groups.
- Technical Context: The technology concerns the integration of group-based communication services with presence services (e.g., user status like "online" or "busy") in telecommunications and unified collaboration platforms.
- Key Procedural History: The filing is a First Amended Complaint. The complaint does not mention any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2005-12-30 | U.S. Patent No. 7,899,479 Priority Date |
| 2011-03-01 | U.S. Patent No. 7,899,479 Issue Date |
| 2020-03-23 | First Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,899,479 - "METHOD, SYSTEM AND APPARATUSES FOR SHARING PRESENCE INFORMATION," issued March 1, 2011
The Invention Explained
- Problem Addressed: The patent describes prior art systems where "group service" (for batch communications) and "presence service" (for individual user status) were independent of each other (Compl. ¶13; ’479 Patent, col. 1:50-52). To find the presence information of other group members, a user had to submit repeated, individual requests to a presence server, a process described as "lengthy and inconvenient" (Compl. ¶15-16; ’479 Patent, col. 1:55 - col. 2:3).
- The Patented Solution: The invention proposes a method to integrate these two services. A central system acquires both "basic group information" (e.g., a member list) from a group server and the "presence information" (e.g., online status) of those members from a presence server (’479 Patent, col. 4:46-59). This combined "group presence information" is then sent to group members, streamlining the process and reducing the need for repeated, individual authorization checks (Compl. ¶20; ’479 Patent, col. 2:60-64). This approach is intended to "enrich the functions of the group service" (’479 Patent, col. 2:66-67).
- Technical Importance: The claimed method reflects a move toward unifying communication services, making presence status a native, efficiently distributed feature within a group context rather than a separately queried data point.
Key Claims at a Glance
- Independent Claim 1 is asserted (Compl. ¶18). Its essential elements include:
- Acquiring, by one of a group server, a presence server, or a presence information management apparatus, "group presence information."
- The group presence information comprises "basic group information" (which includes a group attribute, member list, and member attribute) from a group server and "presence information" of at least one group member from a presence server.
- Sending, by one of the same three apparatus types, the combined group presence information to a group member.
- The complaint also asserts dependent Claim 3 and reserves the right to assert additional claims (Compl. ¶19, ¶23, ¶42).
III. The Accused Instrumentality
Product Identification
The "RingCentral Glip Software" (the "Accused Instrumentality") (Compl. ¶24).
Functionality and Market Context
- The complaint alleges the Accused Instrumentality is a communication solution that provides a method for sharing presence information (Compl. ¶24).
- The software allegedly uses "channels" that function as groups, with channel information including a name and member list stored on a "channel module" which the complaint equates to a "group server" (Compl. ¶28-29).
- It gathers and displays individual user presence status, such as "on mobile/on desktop/on the phone/busy" or "available/away/do not disturb," from a server the complaint considers to be a "presence server" (Compl. ¶26-27, ¶30). The system then allegedly combines this information to show the presence of channel members (Compl. ¶28).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in an "Exhibit B" to support its infringement allegations; however, this exhibit was not attached to the filed document (Compl. ¶24). The infringement theory is therefore summarized from the complaint’s narrative allegations. No probative visual evidence provided in complaint.
’479 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method for sharing presence information, comprising: acquiring, by one of a group server, a presence server and a presence information management apparatus connected to the group server and the presence server, | The Accused Instrumentality practices a method of acquiring group presence information through the interaction of its "channel module" (group server) and a server housing individual identity information (presence server) (Compl. ¶26-28). | ¶26 | col. 16:1-4 |
| group presence information comprising basic group information and presence information of at least one group member in a group provided by the group server; | The acquired information allegedly comprises basic group information (e.g., group name, team members) and presence information (e.g., status like "busy") of a group member (Compl. ¶26). | ¶26 | col. 16:1-4 |
| wherein the basic group information is from the group server and comprises a group attribute, a group member list and a group member attribute, | The "channel module" (alleged group server) provides basic group information, including a channel name (group attribute) and a list of team members (group member list) (Compl. ¶29). | ¶29 | col. 16:4-7 |
| the presence information of at least one group member is from the presence server; | The Accused Instrumentality utilizes presence information, such as "available/away/do not disturb," which is from the alleged presence server (Compl. ¶30). | ¶30 | col. 16:7-8 |
| and sending, by the one of the group server, the presence server and the presence information management apparatus, the group presence information to a group member. | The Accused Instrumentality allegedly sends the combined group presence information (e.g., presence for members of a channel) to a group member (Compl. ¶31). | ¶31 | col. 16:9-12 |
Identified Points of Contention
- Scope Questions: A primary question will be whether RingCentral’s software architecture maps onto the patent’s claimed structure. The complaint asserts that a "channel module" is a "group server" and that a "server that houses the individual identity information database can be considered as the presence server" (Compl. ¶27, ¶29). This raises the question of whether these allegedly separate functions in the Accused Instrumentality meet the definitions of the distinct "group server" and "presence server" components as recited in the patent.
- Technical Questions: Claim 1 recites that the "acquiring" and "sending" steps are performed by "one of a group server, a presence server and a presence information management apparatus." The complaint makes a general allegation that the Accused Instrumentality practices this step (Compl. ¶26, ¶31). A key factual question for the court will be to identify which specific component in the RingCentral system performs these functions and whether it corresponds to one of the three entities permitted by the claim language.
V. Key Claim Terms for Construction
- The Term: "group server" and "presence server"
- Context and Importance: The infringement case appears to depend heavily on mapping these two terms onto components of the RingCentral Glip Software. The patent describes a system where these two servers provide distinct types of information ("basic group information" and "presence information," respectively) that are then combined. Practitioners may focus on these terms because the defense will likely argue that RingCentral’s architecture is not the one claimed, perhaps by asserting it uses a single, integrated system rather than the distinct server components contemplated by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent claims a method where the "acquiring" and "sending" can be done by a group server, a presence server, or a "presence information management apparatus" (’479 Patent, col. 16:1-12). This third option, depicted in Figure 4 as a separate apparatus (403) that communicates with both servers, suggests the invention is not strictly limited to an architecture where only the group or presence server itself performs the combination and sending, potentially allowing for more flexible system designs.
- Evidence for a Narrower Interpretation: Figures 3 and 4, along with the detailed description, consistently depict the "group server" (301, 401) and "presence server" (302, 402) as distinct structural blocks that communicate with each other (’479 Patent, Figs. 3-4; col. 6:57-60). A party could argue that these terms require two functionally and perhaps architecturally separate components, and that a single, monolithic software system that performs both roles would not meet these limitations.
VI. Other Allegations
Willful Infringement
The complaint does not explicitly allege willfulness. However, it does request enhanced damages and attorneys' fees pursuant to 35 U.S.C. §§ 284 and 285 (Compl. Prayer for Relief ¶d, ¶f). The basis for knowledge of infringement is asserted to be "at least as of the service of the present Complaint," which would only support a claim for post-suit willful infringement (Compl. ¶37).
VII. Analyst’s Conclusion: Key Questions for the Case
The dispute appears to center on fundamental questions of claim scope and factual correspondence between the patent's described architecture and the accused software.
- A core issue will be one of architectural mapping: Can the complaint successfully demonstrate that the "channel module" and "identity information database" within RingCentral's software function as the distinct "group server" and "presence server" required by the claims, or will the court find a structural mismatch between the accused system and the patented invention?
- A key evidentiary question will be one of functional allocation: Which specific entity within the RingCentral system performs the claimed steps of "acquiring" and "sending" the combined "group presence information," and does that entity fall within the three options recited in Claim 1 (group server, presence server, or management apparatus)?