DCT

1:22-cv-00900

InQuisient Inc v. ServiceNow Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-00900, D. Del., 07/05/2022
  • Venue Allegations: Venue is alleged in the District of Delaware based on Defendant being a Delaware corporation, conducting business in the district, and offering services to customers located in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s "Now Platform" for enterprise workflow automation infringes three patents related to a flexible, metadata-driven database architecture.
  • Technical Context: The technology concerns enterprise data management systems that allow for dynamic definition of data structures and workflows, a key feature in modern platform-as-a-service (PaaS) offerings.
  • Key Procedural History: The complaint states that Plaintiff sent notice letters to Defendant on June 1, 2022, and June 21, 2022, regarding its infringement concerns, to which Defendant allegedly did not respond. Plaintiff also notes that it has marked its own software with the patent numbers for at least six years prior to filing suit.

Case Timeline

Date Event
2005-06-14 Priority Date ('468, '585, '855 Patents)
2011-07-12 Issue Date (U.S. Patent No. 7,979,468)
2012-07-10 Issue Date (U.S. Patent No. 8,219,585)
2012-07-17 Issue Date (U.S. Patent No. 8,224,855)
2022-06-01 First pre-suit notice letter sent to Defendant
2022-06-21 Second pre-suit notice letter sent to Defendant
2022-07-05 Complaint Filing Date

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

U.S. Patent No. 7,979,468 - "Database Data Dictionary"

Issued July 12, 2011

The Invention Explained

  • Problem Addressed: The patent describes conventional data storage systems as being inflexible because their structure is tied to a specific, pre-defined data model, which makes it difficult to modify the system or manage dynamic data sets through processes and state machines (’468 Patent, col. 1:19-52).
  • The Patented Solution: The invention proposes an "elements metadata repository" (EMR) that decouples data storage from a rigid data model. It achieves this by creating a highly normalized structure where all data objects are treated as abstract "elements" in a central table (’468 Patent, col. 6:1-9). A collection of distinct modules—for classes, attributes, relations, and types—then defines the properties and behavior of these elements on the fly. This architecture is described as enabling features like inheritance and, critically for this patent, the enforcement of process workflows through a state machine module (’468 Patent, col. 3:1-12, col. 8:19-24).
  • Technical Importance: This approach aimed to provide the flexibility of object-oriented concepts and process management directly within the database architecture itself, reducing the need for hard-coded application logic to manage complex business rules and workflows (’468 Patent, col. 8:19-40).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶29).
  • Essential elements of claim 1 include:
    • A processor and a data repository adapted to store data and metadata.
    • An "element module" to store and uniquely identify elements.
    • An "element relation module" to store relationships between elements.
    • A "class module" to define and store classes of elements.
    • An "attribute module" to define and store attributes.
    • A "class attribute module" to associate attributes with classes.
    • A "type definition module" to define types for classes, attributes, and relationships.
    • A "state machine module" to store state machine types associated with elements.
    • A "status module" to store the statuses of each state machine.
  • The complaint does not explicitly reserve the right to assert dependent claims but makes a general allegation against one or more claims (Compl. ¶29).

U.S. Patent No. 8,219,585 - "Database Data Dictionary"

Issued July 10, 2012

The Invention Explained

  • Problem Addressed: As with its parent, the ’468 patent, this patent addresses the inflexibility of traditional database systems that are bound to a fixed data model (’585 Patent, col. 1:21-54).
  • The Patented Solution: The invention utilizes the same core EMR architecture but focuses on a different functional aspect: data organization and presentation. Instead of the state machine and status modules found in the ’468 Patent, the claims here recite a "named text module" and a "tuple module" (’585 Patent, col. 10:5-54). The "named text module" stores textual representations of mechanisms like SQL queries, and the "tuple module" links these named texts (which can act as folders or filters) to create a navigable, hierarchical view of data entries for the user (’585 Patent, col. 10:22-54).
  • Technical Importance: This system provides a way to create dynamic, query-based "folders" and data hierarchies within the database itself, approximating the user experience of a file system explorer but with the power of a relational database backend (’585 Patent, col. 11:1-19).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶53).
  • Essential elements of claim 1 are largely similar to the ’468 Patent's claim 1 for the first eight elements, but the final two are distinct:
    • A "named text module" configured to store textual representations of query, control, and display mechanisms, wherein the module defines folders and filters.
    • A "tuple module" configured to link the folders and filters to generate a hierarchy of data entries.
  • The complaint does not explicitly reserve the right to assert dependent claims but makes a general allegation against one or more claims (Compl. ¶53).

U.S. Patent No. 8,224,855 - "Database Data Dictionary"

Issued July 17, 2012

Technology Synopsis

This patent, part of the same family, describes the same underlying metadata-driven database architecture where data is abstracted into "elements." The claims focus specifically on a set of modules for dynamically managing the attributes of these elements. This includes an "element attribute module" to define and transmit attributes, a corresponding "element module" to receive them, an "element history module" to track modifications, and an "element document module" to handle formatting and grouping (’855 Patent, Abstract; col. 16:1-51).

Asserted Claims

The complaint asserts at least independent claim 1 (Compl. ¶74).

Accused Features

The complaint alleges infringement by the Now Platform's functionalities for defining table structures ("sys_db_object", "sys_dictionary"), adding and transmitting data to tables, tracking record changes ("sys_history_set"), and grouping data for display using features like dashboard tabs (Compl. ¶¶79-89). A screenshot in the complaint shows how dashboard tabs are used to organize widgets into logical groupings (Compl. ¶89).

III. The Accused Instrumentality

Product Identification

  • The ServiceNow "Now Platform" (Compl. ¶27).

Functionality and Market Context

The Now Platform is described as an application platform-as-a-service (PaaS) used by enterprises to automate business processes and digitize workflows (Compl. ¶¶22, 25). The complaint alleges that a core feature of the platform is its use of a "single data model" to eliminate data silos, supported by a flexible table schema and reusable components (Compl. ¶26). A diagram from ServiceNow's materials illustrates this "Single data model" concept, showing a central database and intelligent engine serving various business functions like IT, HR, and Sales (Compl. ¶36). The platform is alleged to be built on a relational database and to use features like a data dictionary, state management for workflows, and extensible tables to deliver its functionality (Compl. ¶¶27, 38, 43).

IV. Analysis of Infringement Allegations

'468 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a data repository... adapted to process, retrieve, and store data... and one or more layers of metadata The Accused Product is built upon a relational database that organizes data items into tables and stores metadata, such as in a dictionary name associated with a field. A screenshot from a ServiceNow tutorial video shows the "ServiceNow Platform relational database" (Compl. ¶38). ¶¶38-40 col. 3:62-65
an element module configured to store and uniquely identify a plurality of elements, wherein each of the elements is identified by a unique element identification The Accused Product provides elements (records) that are each associated with a unique 32-character GUID called a Sys ID. ¶41 col. 6:1-9
an element relation module configured to store one or more relationships between the elements The Accused Product allows records to be related to one another through features like its "sys_relationship" table and by allowing fields to hold references to records in other tables. ¶42 col. 6:31-40
a class module configured to define at least one class of the elements and store the class The Accused Product supports "classes" in the form of extensible tables, such as parent and child classes, and provides a "sys_db_object" table that contains a record for each table. ¶43 col. 3:10-12
an attribute module configured to define one or more attributes and store the attributes The Accused Product provides "sys_dictionary" tables that contain the definition for every column (attribute) on each table. ¶44 col. 5:1-4
a class attribute module configured to... store one or more class-attribute associations between... attributes and the class The "sys_dictionary" table allegedly maps classes to corresponding attributes and defines information like data type, character limit, and default value for each field. ¶45 col. 5:5-9
a type definition module configured to define and store one or more types of the class, the attributes... and the relationships The Accused Product supports various "types" of attributes, which are allegedly defined and stored in a "sys_glide_object" table. ¶46 col. 3:26-31
a state machine module configured to store one or more state machine types associated with at least one of the elements The Accused Product provides a "sys_state_model" table to define state models, and "wf_workflow_version", "wf_activity", and "wf_transition" tables to provide a state machine module. ¶¶47-48 col. 8:58-62
a status module configured to store one or more statuses of each state machine The Accused Product allows a user to "define a state model for a new custom application," with multiple states and transitions, and stores statuses in tables like "wf_activity". ¶¶49-50 col. 8:63-65

'585 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
[Elements 1a-1h are substantially similar to those in the '468 Patent and are alleged to be met by the same or similar features of the Now Platform] [The allegations map the Now Platform's processor, relational database, Sys ID, sys_relationship table, extensible classes, and dictionary tables to these claim elements] ¶¶56-63 col. 5:1-9
a named text module configured to store textual representations of query, control, and display mechanisms... wherein the named text module defines one or more folders and one or more filters The Accused Product provides a "database view" that stores textual representations of queries. This view, along with the "field navigator," allegedly provides one or more folders and filters. ¶¶64-65 col. 10:5-21
a tuple module configured to... link the one or more folders and the one or more filters to generate a hierarchy of one or more data entries The Accused Product is alleged to provide this functionality by extending tables (e.g., a "child class" extending a "parent class") and using form pane tabs to generate a hierarchy. A screenshot from a tutorial shows the parent/child class relationship (Compl. ¶70). ¶¶68-71 col. 10:22-54

Identified Points of Contention

  • Scope Questions: A central question for all asserted patents will be whether the specific tables in the Now Platform (e.g., "sys_db_object", "sys_dictionary", "wf_workflow_version") can be properly characterized as the abstract "class module", "attribute module", and "state machine module" recited in the claims. The defense may argue that these are simply standard components of a modern relational database system, not the specific, interconnected modular architecture described in the patents.
  • Technical Questions: For the '468 Patent, it is an open question whether the Accused Product’s "state management" features perform the specific functions of storing "state machine types" and "statuses of each state machine" as required by the claims, or if there is a technical mismatch. For the ’585 Patent, the analysis will question whether creating a "database view" or extending tables in ServiceNow constitutes "linking folders and filters to generate a hierarchy" in the specific manner claimed.

V. Key Claim Terms for Construction

  • The Term: "module" (e.g., "element module," "class module")

    • Context and Importance: This non-standard term appears in every asserted independent claim and is foundational to the patented architecture. Its construction will be critical, as it defines the basic building blocks of the claimed system. Practitioners may focus on this term because its interpretation will determine whether the claims require a specific, novel software architecture or can read on a more conventional arrangement of database tables and functions.
    • Intrinsic Evidence for a Broader Interpretation: The claims define the modules functionally (e.g., "a class module configured to define at least one class..."), which may support an interpretation where any software component that performs the recited function meets the limitation (’468 Patent, col. 15:29-31).
    • Intrinsic Evidence for a Narrower Interpretation: The specification's figures depict these modules as specific, interconnected database tables (e.g., CLASS table 150, ATTRIBUTE table 110). This could support an interpretation that a "module" requires a structure corresponding to these specific disclosed embodiments (’468 Patent, Fig. 1A-1C).

  • The Term: "state machine module"

    • Context and Importance: This term is central to the workflow infringement theory of the '468 Patent. The outcome of the case may depend on whether ServiceNow's workflow engine is found to be a "state machine module."
    • Intrinsic Evidence for a Broader Interpretation: The patent describes the module's purpose broadly as enforcing data behavior and constraining user actions based on a declared process, which could encompass a wide range of workflow systems (’468 Patent, col. 8:19-24).
    • Intrinsic Evidence for a Narrower Interpretation: The detailed description shows a specific implementation comprising a STATE_MACHINE table, a STATE_MACHINE_TRANSITION table, and a STATUS table. This may support a narrower construction requiring this particular multi-table structure (’468 Patent, Fig. 5).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that ServiceNow induces infringement by providing "educational and promotional materials, support activities, as well as its service and consulting activities" that instruct customers on how to use the Now Platform in ways that directly infringe the patents-in-suit (Compl. ¶32).
  • Willful Infringement: The willfulness claim is based on alleged pre-suit knowledge. The complaint alleges that ServiceNow was notified of the patents-in-suit and its alleged infringement via letters sent on June 1, 2022, and June 21, 2022, prior to the lawsuit's filing (Compl. ¶¶5-6).

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

  • A core issue will be one of architectural equivalence: Can the abstract, modular system described in the patents—using terms like "element module", "class module", and "tuple module"—be construed to read on the concrete, table-based implementation of the ServiceNow Now Platform? The case may turn on whether the court finds that ServiceNow's use of conventional-sounding database objects (e.g., tables, views, relationships) constitutes the specific, interconnected modular invention claimed in the patents.
  • A key evidentiary question will be one of functional mapping: Does the evidence provided, which relies heavily on high-level documentation and marketing diagrams, sufficiently demonstrate that the accused ServiceNow features perform the specific, and sometimes multi-part, functions required by the claims? For instance, does ServiceNow’s use of extensible tables functionally equate to the ’585 patent’s "tuple module", which must "link... folders and... filters to generate a hierarchy"?