DCT
1:23-cv-00104
Web 20 Tech Inc v. Workfront Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Web 2.0 Technologies, Inc. (Texas)
- Defendant: Workfront Inc. (Delaware)
- Plaintiff’s Counsel: DEVLIN LAW FIRM LLC
- Case Identification: 1:23-cv-00104, D. Del., 01/27/2023
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation.
- Core Dispute: Plaintiff alleges that Defendant’s Adobe Workfront collaborative work management platform infringes two patents related to systems for the centralized storage and permission-based sharing of personal information and collaborative documents.
- Technical Context: The lawsuit concerns the field of cloud-based project and work management software, a market segment focused on enabling team collaboration, task tracking, and resource management through a centralized platform.
- Key Procedural History: The complaint alleges that Defendant has been on notice of the asserted patents and its alleged infringement since receiving a notice letter on or about June 15, 2021, a fact that forms the basis for the willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 2000-01-07 | Priority Date for U.S. Patent No. 6,845,448 |
| 2000-01-07 | Earliest Priority Date for U.S. Patent No. 8,117,644 |
| 2005-01-18 | Issue Date for U.S. Patent No. 6,845,448 |
| 2012-02-14 | Issue Date for U.S. Patent No. 8,117,644 |
| 2021-06-15 | Date Defendant allegedly received notice of infringement |
| 2023-01-27 | Complaint Filing Date |
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 identifies the inefficiency and annoyance faced by internet users who must repeatedly fill out forms with personal and demographic information on various websites, with no central method to control or selectively distribute this data (ʼ448 Patent, col. 1:12-32, 1:44-51).
- The Patented Solution: The invention proposes a method and system for a central online repository where a user can store various "information objects" (e.g., contact details, preferences, medical history). The user can assign distinct security levels to each object and then authorize third-party "requesters" to access specific, approved portions of that information, automating the data-sharing process while maintaining user control (ʼ448 Patent, col. 2:16-43).
- Technical Importance: The patent describes a user-centric data management model that allows for granular, permission-based access, a foundational concept for modern profile management, data portability, and single-sign-on systems (ʼ448 Patent, col. 1:52-58).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1, which was modified by a Certificate of Correction (Compl. ¶20).
- Essential elements of Claim 1 include:
- A method performed by a server computer for disbursing a first party's personal information to a second party.
- Establishing an account and assigning an identifier for the first party (user).
- Entering the user's personal information, which comprises a plurality of "information objects."
- Receiving from the user an assignment of a plurality of "security levels" to each information object at any granularity, enabling access to selected portions by different receiving parties.
- Storing the user identifier, the information objects, and their assigned security levels in a database.
- Receiving a request for information from a second party (requester).
- In response, selecting, retrieving, and securely transmitting the authorized portion of the user's information.
- Obtaining a second party identifier and, if the second party is not authorized, recording the identifier and rejecting the request.
- Plaintiff reserves the right to assert additional claims (Compl. ¶30).
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's background section describes the difficulties of managing digital items, noting that printing is unmanageable, downloading files to a local computer consumes resources and hinders sharing, and bookmarking web pages often leads to "stale" links that no longer point to useful data (ʼ644 Patent, col. 1:20-65).
- The Patented Solution: The invention discloses a method for an "online personal library" where users can store, manage, and collaborate on documents. The system allows a first user to create a document and associate a set of "access restrictions" that govern how a second user can interact with it, including permissions for modification and a formal process for approving or disapproving those modifications (ʼ644 Patent, col. 2:47-67).
- Technical Importance: The patent outlines a system for cloud-based document management with integrated, permission-based workflows for editing and review, a core paradigm of modern collaborative platforms like Google Docs or Microsoft 365 (ʼ644 Patent, col. 2:8-19).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶33).
- Essential elements of Claim 1 include:
- A method for online document collaboration performed by a server computer.
- Establishing accounts 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 for a specific group of known users to access it for modification.
- Receiving a request to modify the document from a second user, which includes the second user's identification.
- Verifying the identity of the second user.
- Permitting the modification based on the second user's access rights.
- Receiving "approval or disapproval for the modifications" from one or more users.
- Storing identifying information of the user(s) who approved or disapproved the changes.
- Plaintiff reserves the right to assert additional claims (Compl. ¶42).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant's Adobe Workfront software products and applications, including those for "work automation, goal alignment, scenario planning, workflow management, proofing and approvals" (Compl. ¶20, ¶33).
Functionality and Market Context
- The complaint alleges the accused products provide a platform for online project management and collaboration (Compl. ¶21, ¶34). The platform allegedly allows users to create accounts, input information (including personal information), and manage projects (Compl. ¶21, ¶23). A core accused feature is the system of "access levels" (e.g., System Administrator, Planner, Worker, Reviewer, Requestor, External User) that an administrator can assign to users (Compl. ¶22, ¶36). These access levels allegedly control a user's ability to view, create, edit, and share "Workfront objects" and other information within a project (Compl. ¶22, ¶36). The complaint also points to an "Approval process overview" feature, which it alleges is used to "make sure that designated users review certain changes before the object progresses" (Compl. ¶38). A visual in the complaint depicts a hierarchy of access levels associated with different license types. (Compl. p. 8). Another visual from the complaint illustrates how different access levels, such as "Worker," are granted varying "View access" and "Edit access" permissions for different types of project data (Compl. p. 10).
IV. Analysis of Infringement Allegations
'448 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a method for automatically disbursing a first party's personal information to a second party authorized by the first party by transmitting said first party's personal information from a server computer... | Defendant provides applications that provide a method for automatically sharing portions of personal information with authorized users via products offered by Workfront. | ¶20 | col. 2:23-40 |
| receiving, from the first party, assignment of at least one of a plurality of security levels to each information object at any granularity, thereby enabling access to individually selected portions... | Workfront allows an administrator to set up "access levels" (e.g., Planner, Worker, Reviewer) with permissions that allow or prevent team members from accessing personal information about other parties. A provided visual shows these distinct access levels. | ¶22; p. 8 | col. 8:56-65 |
| storing in the database the user identifier, the information object and the security level assigned to the information object; | The complaint alleges a first party can include personal information on the Workfront app, which is then shared with an authorized second party who has sufficient permissions in a role. This implies storage of the information and associated permissions. | ¶21 | col. 6:25-31 |
| if the second party is not authorized to receive the information...rejecting the second party's request for information. | The complaint alleges that if a requesting second party does not have an access level allowing it to view certain personal information, the request for such information is rejected. | ¶24 | col. 14:48-52 |
'644 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method for online document collaboration...storing, on the server computer, a document created by a first user; | The complaint alleges Workfront provides a platform for online applications, such as a project management app, that allow a user (administrator) to create documents and objects stored on a server. | ¶36 | col. 12:20-25 |
| associating a set of access restrictions with the document, said access restrictions including an ability to access the document for modification by one of a first group of users... | A first user (administrator) can restrict access to documents so that a second user (e.g., an External User) may not have access, while another user (e.g., a Worker) is granted permissions to access and modify documents. A visual depicts various user access levels. | ¶36; p. 14 | col. 13:40-49 |
| permitting the second user to modify the document based on a set of access rights granted to the second user; | If a second user is approved as a "Worker," that user may modify the Workfront project. A visual from the complaint shows that the "Worker" role can be granted "Edit access" for projects. | ¶37; p. 17 | col. 25:6-9 |
| receiving approval or disapproval for the modifications from one or more users; and storing identifying information of the one or more users who approved or disapproved... | The accused products allegedly provide an "approval process that shows acceptance or denial of edits to a document," thereby storing identifying information of the users who approved or disapproved. A visual illustrates this "Approval process overview." | ¶38; p. 18 | col. 26:10-14 |
Identified Points of Contention
- Scope Questions: A potential dispute for the ’448 Patent is whether the term "personal information", which the patent illustrates with examples like demographic, health, and biometric data (ʼ448 Patent, col. 7:4-16), can be construed to read on the primarily project- and business-related data (e.g., task assignments, status updates) allegedly stored in the accused Workfront platform (Compl. ¶21). For the ’644 Patent, a question may arise as to whether a "document" as claimed can encompass the various "Workfront objects" and data fields within the accused project management application (Compl. ¶36).
- Technical Questions: The infringement analysis for both patents may hinge on whether Workfront's system of assigning broad, role-based "access levels" (e.g., "Worker") to users (Compl. ¶22) is functionally the same as the patents' descriptions of assigning granular "security levels" to individual "information objects" (’448 Patent, Claim 1) or associating a "set of access restrictions" with a specific "document" (’644 Patent, Claim 1).
V. Key Claim Terms for Construction
Term from '448 Patent: "personal information"
- Context and Importance: The breadth of this term is central to the infringement case for the ’448 Patent. A narrow construction limited to personal-life data could weaken the infringement argument, whereas a broad construction covering any data associated with a user in a professional context may support it.
- Intrinsic Evidence for a Broader Interpretation: The claim itself does not limit the term, and the background refers generally to "demographic and other information" (ʼ448 Patent, col. 1:14-15), which could be argued as illustrative rather than exhaustive.
- Intrinsic Evidence for a Narrower Interpretation: The detailed description provides specific categories of information, including "personal demographic information," "health related information," and "biometric information" (ʼ448 Patent, col. 7:4-16). This detailed list could be used to argue that the invention is directed at personal-life data, not business or project data.
Term from '644 Patent: "storing identifying information of the one or more users who approved or disapproved the modifications"
- Context and Importance: This term defines the final step of the claimed collaborative workflow. Practitioners may focus on this term because the infringement analysis will require evidence that the accused "approval process" does more than just change a document's status; it must specifically record the identity of the approver/disapprover in connection with that decision.
- Intrinsic Evidence for a Broader Interpretation: The claim language does not specify the format or location for storing this information, potentially allowing any form of audit trail or log file that links a user ID to an approval event to satisfy the limitation.
- Intrinsic Evidence for a Narrower Interpretation: The patent's abstract describes a system for "storing identifying information of the one or more users who approved or disapproved the modifications to the document." This could be argued to require a specific data structure that permanently and explicitly links a user's identity to their approval/disapproval action, as opposed to a transient system status or a general activity log.
VI. Other Allegations
Indirect Infringement
- The complaint alleges that Defendant "directly and jointly" infringes the asserted patents (Compl. ¶27, ¶40). While the term "jointly" may suggest a divided infringement theory, the complaint does not plead specific facts to support inducement or contributory infringement, such as detailing how user manuals instruct infringement or how the accused products contain non-staple components.
Willful Infringement
- The complaint explicitly alleges willful infringement of both patents. The basis for this allegation is Defendant's alleged "actual knowledge" of the patents and the alleged infringement since on or about June 15, 2021, the date it purportedly received a notice letter from Plaintiff (Compl. ¶26, ¶29, ¶39, ¶42). The complaint alleges that infringement continued after this date, constituting knowing and deliberate disregard of Plaintiff's patent rights.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the term "personal information" in the ’448 Patent, which is exemplified in the specification with demographic and health data, be construed broadly enough to encompass the business-centric project and task data managed within the accused Adobe Workfront platform?
- A key evidentiary question will be one of functional mapping: Do the accused product's generalized, role-based "access levels" (e.g., "Worker," "Planner") function as the granular, object-specific "security levels" required by the ’448 Patent and the document-specific "set of access restrictions" required by the ’644 Patent, or is there a fundamental mismatch in the architecture of the permissioning systems?
- Given the specific allegation of a pre-suit notice letter, a central question regarding damages will be willfulness: If infringement is found, will the evidence show that Defendant's conduct after receiving notice on June 15, 2021 was objectively reckless, thereby opening the door to a finding of willfulness and the potential for enhanced damages?