DCT

1:23-cv-00107

Web 20 Tech LLC v. Mango Tech Inc

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Key Events
Amended Complaint
amended complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-00107, D. Del., 11/06/2023
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware based on Defendant's incorporation in Delaware and its business activities within the district.
  • Core Dispute: Plaintiffs allege that Defendant’s ClickUp collaborative work management platform infringes two patents related to the secure management of online information and permission-based document collaboration.
  • Technical Context: The technology at issue falls within the domain of cloud-based Software-as-a-Service (SaaS) platforms for project management, productivity, and team collaboration.
  • Key Procedural History: The complaint is a First Amended Complaint. U.S. Patent No. 8,117,644 is a continuation-in-part of the application that matured into U.S. Patent No. 6,845,448.

Case Timeline

Date Event
2000-01-07 Priority Date for '448 Patent and '644 Patent
2005-01-18 '448 Patent Issued
2012-02-14 '644 Patent Issued
2020-11-09 Alleged launch of Accused Instrumentality (by this date)
2023-11-06 First Amended Complaint Filed

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

U.S. Patent No. 6,845,448 B1, "Online Repository for Personal Information" (Issued Jan. 18, 2005)

The Invention Explained

  • Problem Addressed: The patent identifies the inefficiency and annoyance for users who are repeatedly required to fill out online forms with personal and demographic information across different websites ('448 Patent, col. 1:12-29). It further notes the lack of a centralized method for users to store this information once and then selectively authorize its release to various entities ('448 Patent, col. 1:45-51).
  • The Patented Solution: The invention describes a system where a user ("first party") can establish an account on a server to store various "information objects" (e.g., contact details, preferences, financial data). The user assigns different security levels to each piece of information. When an authorized entity ("second party" or "requester") requests information, the system verifies the request against the user-defined permissions and securely transmits only the authorized data, creating a centralized, user-controlled information gateway ('448 Patent, Abstract; col. 2:16-43).
  • Technical Importance: The technology aimed to provide users with granular control over their digital identity and streamline online data entry, a key challenge during the expansion of e-commerce and web-based services ('448 Patent, col. 1:39-51).

Key Claims at a Glance

  • The complaint asserts independent claim 1 ('448 Patent, col. 14:28-66, as amended by Certificate of Correction; Compl. ¶21).
  • Essential elements of claim 1 include:
    • Establishing an account for a first party and assigning an identifier.
    • Entering the first party's personal information, comprising information objects.
    • Receiving from the first party an assignment of security levels to each information object.
    • Storing the identifier, information objects, and their assigned security levels in a database.
    • Receiving a request from a second party that includes the first party's identifier.
    • Selecting, retrieving, and securely transmitting the authorized portion of the first party's personal information to the second party.
    • Obtaining a second party identifier and, if the second party is not authorized, recording the identifier and rejecting the request.
  • The complaint reserves the right to assert additional claims (Compl. ¶38).

U.S. Patent No. 8,117,644 B2, "Method and System for Online Document Collaboration" (Issued Feb. 14, 2012)

The Invention Explained

  • Problem Addressed: The patent addresses the challenges of managing and sharing digital documents and files. It notes that bookmarks can become "stale" if the source content is moved or deleted, and that downloading files to a local client computer consumes resources and makes controlled sharing difficult ('644 Patent, col. 1:46-65).
  • The Patented Solution: The invention proposes a method for online collaboration where a user can store a document on a server and associate it with specific access restrictions. Another user can then request to modify the document. The system is designed to verify the second user's identity, permit modifications according to their specific access rights, receive "approval or disapproval" for the changes from other users, and store a record of who approved or disapproved the modifications ('644 Patent, Abstract; col. 2:27-50).
  • Technical Importance: The technology provides a framework for permission-based, auditable collaboration on digital documents, a foundational concept for modern cloud-based office productivity and project management platforms ('644 Patent, col. 2:1-6).

Key Claims at a Glance

  • The complaint asserts independent claim 1 ('644 Patent, col. 25:51-26:12; Compl. ¶41).
  • Essential elements of claim 1 include:
    • Establishing accounts for a plurality of users on a server.
    • Storing a document created by a first user.
    • Associating a set of access restrictions with the document for modification by a group of users.
    • Receiving a request to modify the document from a second user, which includes 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.
    • Storing identifying information of the users who approved or disapproved the modifications.
  • The complaint reserves the right to assert additional claims (Compl. ¶56).

III. The Accused Instrumentality

Product Identification

  • Defendant's ClickUp platform, including its "tasks," "docs," and "whiteboard" functionalities (Compl. ¶¶ 21, 41).

Functionality and Market Context

  • The complaint describes the ClickUp platform as a comprehensive, web-based work management solution where users and teams can collaborate on projects (Compl. ¶¶ 21, 41).
  • Functionality relevant to the allegations includes user account creation, the ability to create and store various types of documents and work items (e.g., "Workspaces," "Docs," "Tasks"), and a system of granular, role-based permissions (e.g., "View only," "Comment," "Edit," "Full") that allows primary users to control how other users interact with the stored information (Compl. ¶¶ 22, 25, 43, 49). The complaint provides a screenshot of a ClickUp signup form to illustrate user account creation (Compl. p. 14).
  • The platform allegedly allows users to be identified via handles (e.g., "@Sam") and facilitates secure, permission-based access to information, which is transmitted using TLS encryption (Compl. ¶¶ 27, 30). It also includes a "Doc history" feature that tracks changes to documents (Compl. ¶51).

IV. Analysis of Infringement Allegations

'448 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
establishing an account for the first party with the server computer; The ClickUp platform allows users to create an account on its servers. A screenshot of the signup page is provided as evidence (Compl. p. 5). ¶22 col. 8:15-25
entering the first party's personal information, said personal information comprising at least one of a plurality of information objects; Users enter information such as name, email, photo, and work-related details into their ClickUp profiles and workspaces. ¶24 col. 8:41-46
receiving, from the first party, assignment of at least one of a plurality of security levels to each information object at any granularity... A user can set "granular permissions and security settings" for various information objects like Spaces, Folders, and Lists, controlling what other users can do. ¶25 col. 9:22-31
storing in the database the first party identifier, the information object and the security level assigned to the information object; The platform allegedly stores the user's identifier and the associated permission levels for information objects in its database. ¶26 col. 9:35-40
receiving a request, said request comprising at least the first party identifier; A second party can request to view information by referencing a first party's identifier, such as "@Sam." A screenshot shows a user being mentioned (Compl. p. 10). ¶27 col. 11:10-14
securely transmitting the retrieved first portion of personal information objects to the second party; In response to a request, the platform selects and transmits the relevant information objects (e.g., user profile data) to the second party using TLS encryption. ¶¶28-30 col. 12:36-43
if the second party is not authorized... rejecting the second party's request for information. The platform allegedly requires authentication for every user request and rejects requests from parties who are not authorized according to the set permissions. ¶¶32-33 col. 14:64-66
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the term "personal information" as used in the '448 Patent, which is primarily exemplified by static user-centric data (e.g., demographics, financial details, personal preferences), can be construed to encompass the dynamic, collaborative work-product data (e.g., project tasks, shared documents, whiteboards) that is central to the accused ClickUp platform.
    • Technical Questions: The analysis may focus on whether the act of setting permissions for a collaborative workspace in ClickUp is technically equivalent to the claimed step of a user "assigning... security levels to each information object" of their "personal information."

'644 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
establishing, on the server computer... an account for each of a plurality of users; The ClickUp platform allows multiple users to establish accounts on its servers to facilitate collaboration. ¶42 col. 2:27-29
storing, on the server computer, a document created by a first user; A user can create and store documents, such as "Workspaces," "docs," and "tasks," on the ClickUp server. ¶43 col. 2:29-30
associating a set of access restrictions with the document... including an ability to access the document for modification... ClickUp enables a user to associate access restrictions (permissions) with documents to control which other users can modify them. ¶44 col. 2:31-35
receiving, from a second user, a request to modify the document... Once granted access to a Workspace, a second user can request to modify constituent documents based on their permission level. ¶45 col. 2:38-42
verifying the identity of the second user; ClickUp requires users to log in with unique identification information (e.g., username and password) and verifies this identity before granting access. ¶¶46-47 col. 2:42-43
permitting the second user to modify the document based on a set of access rights granted to the second user; The platform's four permission levels ("View only," "Comment," "Edit," and "Full") permit a second user to modify a document according to their granted rights. ¶¶48-49 col. 2:43-45
receiving approval or disapproval for the modifications from one or more users; The complaint alleges that ClickUp's "built-in version control" enables the receiving of "approval or disapproval" for modifications. ¶50 col. 2:45-47
storing identifying information of the one or more users who approved or disapproved the modifications... The platform's "Check Doc history" feature allegedly stores identifying information of users who have edited or revised a document. A screenshot shows a document history interface (Compl. p. 19). ¶51 col. 2:47-50
  • Identified Points of Contention:
    • Technical Questions: A key technical question is whether the accused "Doc history" feature, which appears to function as a changelog by recording who made an edit and when, satisfies the claim limitation of "receiving approval or disapproval for the modifications." The language of the claim suggests an active, explicit step of approval or disapproval, which may be functionally distinct from a passive log of historical edits.

V. Key Claim Terms for Construction

For the '448 Patent

  • The Term: "personal information"
  • Context and Importance: The applicability of the '448 Patent to the accused platform hinges on the scope of this term. Practitioners may focus on this term because if it is construed narrowly to mean only static, individual-centric data, it may not read on the collaborative work-product data central to the ClickUp platform.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification includes "employment-related information" in its list of examples, which could be argued to cover work-related tasks and documents created on a collaborative platform ('448 Patent, col. 7:1-3).
    • Evidence for a Narrower Interpretation: The patent's title is "Online Repository for Personal Information", and the vast majority of examples in the detailed description refer to an individual's own demographic, health, financial, and preferential data, suggesting a focus on information about a person rather than work created by a person ('448 Patent, col. 7:4-38).

For the '644 Patent

  • The Term: "receiving approval or disapproval for the modifications"
  • Context and Importance: The infringement allegation for this element relies on the functionality of ClickUp's "version control" and "Doc history." The construction of this term will be critical in determining if a changelog feature meets the claimed limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that a system that logs all changes and allows for reversion implicitly facilitates "approval" (by choosing not to revert a change) and "disapproval" (by reverting a change). The abstract refers to "receiving approval or disapproval for the modifications from one or more users" without detailing the mechanism ('644 Patent, col. 2:45-47).
    • Evidence for a Narrower Interpretation: The plain language "receiving approval or disapproval" suggests an active, discrete input from a user, rather than a passive system record. The specification does not appear to explicitly define this term as being equivalent to a standard version history or changelog function.

VI. Other Allegations

  • Indirect Infringement: The complaint focuses its allegations on direct and joint infringement and does not plead separate counts for indirect infringement (Compl. ¶¶ 36, 54).
  • Willful Infringement: The complaint does not contain an explicit count for willful infringement or specific factual allegations regarding pre-suit knowledge of the patents-in-suit.

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

  • A core issue will be one of definitional scope: can the term "personal information" from the '448 Patent, rooted in the context of an individual's static data repository, be construed to cover the dynamic, collaborative work-product (e.g., project documents, tasks) managed by the accused enterprise software platform?
  • A key evidentiary question will be one of functional equivalence: does the accused platform's "Doc history" feature, which creates a passive log of edits, perform the specific, active function of "receiving approval or disapproval for the modifications" as required by claim 1 of the '644 Patent, or is there a fundamental mismatch in the claimed versus accused technical operation?