Web 20 Tech LLC v. Formagrid Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Web 2.0 Technologies LLC (Texas)
  • Defendant: Formagrid Inc., d/b/a Airtable (Delaware)
  • Plaintiff’s Counsel: Devlin Law Firm LLC
• Case Identification: 1:23-cv-00047, D. Del., 01/13/2023
• Venue Allegations: Venue is asserted based on Defendant's incorporation in Delaware and alleged acts of infringement occurring within the district.
• Core Dispute: Plaintiff alleges that Defendant’s Airtable collaborative application platform infringes two patents related to online information management and document collaboration.
• Technical Context: The technology at issue involves cloud-based platforms that allow users to create and manage collaborative databases and applications, a core component of the modern enterprise software market.
• Key Procedural History: The complaint alleges that Defendant has had actual knowledge of the asserted patents since June 15, 2021, a fact which forms the basis for the willfulness allegations. No other prior litigation, licensing, or post-grant proceedings are mentioned in the complaint.

Case Timeline

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

U.S. Patent No. 6,845,448 - Online Repository for Personal Information (Issued Jan. 18, 2005)

The Invention Explained

• Problem Addressed: The patent’s background section describes the inefficiency and annoyance for internet users who must repeatedly enter the same personal information into forms on various websites (’448 Patent, col. 1:12-28). It notes the lack of a centralized method for a user to store their information once and then selectively authorize its release to different entities (’448 Patent, col. 1:43-52).
• The Patented Solution: The invention describes a method and system where a user establishes an account on a server computer to store various pieces of personal data, referred to as "information objects." The user can then assign distinct "security levels" to each information object, allowing for granular control over what data can be released. When an authorized third party ("requester") requests information, the system verifies the request and transmits only the specific information objects for which the requester has been granted access. (’448 Patent, Abstract; col. 2:22-42).
• Technical Importance: At a time before the widespread adoption of modern federated identity or single sign-on solutions, this technology proposed a centralized, user-centric model for managing online data privacy and convenience. (’448 Patent, col. 1:34-42).

Key Claims at a Glance

• The complaint asserts infringement of independent claim 1 (Compl. ¶21).
• The essential elements of independent claim 1 (as amended by a 2013 Certificate of Correction) are:
  • A method performed by a server computer comprising the steps of:
  • establishing an account for a first party and assigning an identifier;
  • entering the first party’s personal information, which comprises a plurality of "information objects";
  • receiving from the first party an assignment of a security level to each information object at any granularity;
  • storing the first party identifier, the information object, and its assigned security level in a database;
  • receiving a request from a second party that includes the first party identifier;
  • in response, selecting and retrieving a portion of the personal information objects;
  • securely transmitting the retrieved portion to the second party;
  • obtaining a second party identifier; and
  • if the second party is not authorized to receive the information, recording the second party identifier and rejecting the request.
• The complaint alleges infringement of "at least Claim 1," reserving the right to assert other claims (Compl. ¶21).

U.S. Patent No. 8,117,644 - Method and System for Online Document Collaboration (Issued Feb. 14, 2012)

The Invention Explained

• Problem Addressed: The patent background discusses the limitations of conventional methods for sharing online information, such as web browser bookmarks that can become "stale" or non-functional over time, and the lack of a controlled environment for collaborative work on a single document. (’644 Patent, col. 1:46-61).
• The Patented Solution: The invention provides a system for online document collaboration where a first user can store a document on a server and associate a set of access restrictions with it. These restrictions define which other users can modify the document. When a second user requests to modify the document, the system verifies their identity and permits modification based on their granted access rights. The system is further configured to receive "approval or disapproval" for any modifications from one or more users and to store an audit trail identifying who approved or disapproved of the changes. (’644 Patent, Abstract).
• Technical Importance: The patent describes a foundational framework for permission-based, auditable online collaboration, anticipating the core features of modern cloud-based work platforms that enable teams to work on shared assets with version control. (’644 Patent, col. 2:42-47).

Key Claims at a Glance

• The complaint asserts infringement of independent claim 1 (Compl. ¶43).
• The essential elements of independent claim 1 are:
  • A method for online document collaboration performed by a server computer, comprising the steps of:
  • establishing an account for a plurality of users;
  • storing a document created by a first user;
  • associating a set of access restrictions with the document, including the ability to access it for modification by a first group of users;
  • receiving a request from a second user to modify the document, which includes the second user's identification information;
  • verifying the identity of the second user;
  • permitting the second user to modify the document based on their granted access rights;
  • receiving approval or disapproval for the modifications from one or more users; and
  • storing identifying information of the users who approved or disapproved the modifications.
• The complaint alleges infringement of "at least Claim 1," reserving the right to assert other claims (Compl. ¶43).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are the Airtable platform and its associated products, applications, and services, including its websites and constituent functionalities such as "views," "sync," "bases," "workspaces," and "tables" (Compl. ¶¶ 21, 43, 45).

Functionality and Market Context

The complaint characterizes the Airtable platform as a tool "where teams can use shared data to build their own apps, connecting work and teams across the organization" (Compl. ¶43). It alleges the platform allows users to create accounts, store and structure data, and set granular access permissions for collaborators, with roles including "Owner," "Creator," "Editor," "Commenter," and "Read only" (Compl. ¶¶ 22, 26, 46). The complaint provides a screenshot of Airtable's pricing tiers, suggesting a commercial model that serves individual users as well as large enterprises (Compl. p. 6). A screenshot in the complaint shows a dropdown menu for granting collaborator permissions such as "Creator," "Editor," and "Read only" (Compl. p. 8).

IV. Analysis of Infringement Allegations

'448 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A primary question may be whether the term "personal information," as understood in the patent’s 2000-era context of individual user data, can be construed to read on the collaborative, often business-oriented, data stored in a modern Airtable "base."
• Technical Questions: The complaint alleges that Airtable's general-purpose audit logs meet the specific limitation of recording a second party's identifier if a request is unauthorized and rejected. The analysis may question whether the evidence shows the platform performs this specific conditional recording-and-rejection function as claimed, or if the complaint's allegation is an inference based on the existence of general logging features.

'644 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The infringement analysis will raise the question of whether an Airtable "base"—a form of relational database—falls within the scope of the term "document" as used in the patent.
• Technical Questions: What evidence demonstrates that Airtable’s "record-level revision history," which tracks edits, inherently performs the claimed function of "receiving approval or disapproval"? The dispute may center on whether this is a native function of the accused platform or an optional workflow that a user must custom-build.

V. Key Claim Terms for Construction

• Term from '448 Patent: "personal information"

  • Context and Importance: Practitioners may focus on this term because the infringement theory depends on equating the collaborative, project-oriented data in an Airtable "base" with the "personal information" contemplated by the patent. The patent's context suggests a focus on an individual's own data for form-filling, creating a potential mismatch with the accused product's primary use case.
  • Intrinsic Evidence for a Broader Interpretation: The specification provides a very long and varied list of what may constitute personal information, including "employment-related information," "property-related information," and "design of a portal," which could be argued to encompass business or project data (’448 Patent, col. 7:1-9).
  • Intrinsic Evidence for a Narrower Interpretation: The patent’s background explicitly frames the problem as an individual user being annoyed by filling out forms on "the New York Times web site" or the "Adobe Corporation web site" (’448 Patent, col. 1:15-28). This context may support a narrower construction limited to an individual’s demographic and preference data.

• Term from '644 Patent: "document"

  • Context and Importance: The viability of the infringement claim against the '644 Patent hinges on whether a dynamic, relational database structure like an Airtable "base" or "workspace" can be considered a "document."
  • Intrinsic Evidence for a Broader Interpretation: The patent’s summary defines a related term, "digital item," very broadly to include "a web page, data, a document such as a news article, word processor document, spread sheet, presentation, e-book, software programs, music, video, movie, a graphical image..." (’644 Patent, col. 2:21-29). This broad definition could be argued to inform the meaning of "document."
  • Intrinsic Evidence for a Narrower Interpretation: The claim itself uses the specific term "document," not the broader term "digital item." The common understanding of "document" at the time of filing may suggest a more self-contained, static file (e.g., a text file or spreadsheet) rather than an interactive, multi-table database.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant "directly and jointly (e.g., with its users and customers)" infringes the patents (Compl. ¶¶ 21, 43). The allegations are sufficient to suggest a theory of induced infringement, where Defendant is alleged to provide the Airtable platform and instructional materials (e.g., support webpages) that encourage and enable its users to perform the steps of the claimed methods.
• Willful Infringement: The willfulness claim is based on alleged pre-suit knowledge. The complaint asserts that Defendant had "actual knowledge" of both asserted patents since at least June 15, 2021, the date it allegedly received a notice letter from the Plaintiff (Compl. ¶¶ 20, 42).

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

This case will likely present two central questions for the court:

• A core issue will be one of technological evolution and definitional scope: Can terms like "personal information" and "document," which are rooted in the context of the early 2000s internet, be construed broadly enough to encompass the functionalities of a modern, collaborative, database-centric platform like Airtable?
• A key evidentiary question will be one of functional specificity: Does the evidence show that Airtable’s general-purpose features, such as audit logs and revision histories, perform the precise, multi-step functions required by the claims (e.g., the specific rejection-and-logging sequence of '448 claim 1, or the distinct "approval or disapproval" step of '644 claim 1), or is there a material difference in their technical operation?