DCT

1:23-cv-00126

Oracle Corp v. Vilox Tech LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-00126, D. Del., 02/02/2023
  • Venue Allegations: Venue is based on a 2016 Settlement Agreement between the parties which contains a forum selection clause consenting to the exclusive jurisdiction of the U.S. District Court for the District of Delaware for any future litigation regarding the patents-in-suit.
  • Core Dispute: Plaintiff Oracle seeks a declaratory judgment that its products do not infringe Defendant Vilox's database search patents and that one patent is invalid, and further alleges that Vilox breached a prior settlement agreement by filing a separate lawsuit in Texas.
  • Technical Context: The patents relate to "on-the-fly" database search technology designed to simplify user interaction with complex databases and manage the display of large data sets.
  • Key Procedural History: The complaint alleges that Vilox previously sued an Oracle customer in 2015 over the patents-in-suit, a case that was resolved by a 2016 Settlement Agreement. That agreement allegedly established Delaware as the exclusive forum for future disputes and barred Vilox from using the 2015 litigation to establish knowledge for indirect or willful infringement claims. In 2022, Vilox sued Oracle in the Western District of Texas, allegedly in breach of both provisions. Both patents-in-suit are now expired, limiting potential remedies to past damages.

Case Timeline

Date Event
2000-02-25 Earliest Priority Date for '100 and '720 Patents
2004-07-06 '720 Patent Issue Date
2007-03-06 '100 Patent Issue Date
2015-11-30 Oracle Customer Litigation (Vilox v. Costco) Filed
2016-01-01 Settlement Agreement Date (approximate)
2022-12-05 Vilox v. Oracle Filed in W.D. Texas
2023-02-02 Complaint (Declaratory Judgment Action) Filed

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

U.S. Patent No. 7,188,100 - *“Search-on-the-Fly Report Generator”* (Issued Mar. 6, 2007)

The Invention Explained

  • Problem Addressed: The patent describes the problem that users of conventional database systems must possess detailed knowledge of the database's underlying structure, or "schema," to retrieve information, which prevents applications from working effectively across different database systems (Compl. ¶9; ’100 Patent, col. 2:1-22).
  • The Patented Solution: The invention claims to solve this with an intuitive data retrieval method that allows a user to obtain information without knowing the database structure. A key aspect is the creation of a "report template" from a search result, which contains links to data categories and can be saved and reused to generate subsequent, dynamic reports that reflect changes in the database content (’100 Patent, Abstract; col. 4:45-51).
  • Technical Importance: This approach aimed to simplify enterprise data analysis by enabling non-technical users to create and run reusable, dynamic reports against complex and evolving databases (Compl. ¶9).

Key Claims at a Glance

  • The complaint indicates Vilox asserted claims 1-38 in the related Texas litigation, with a focus on independent claim 1 (Compl. ¶23).
  • The essential elements of independent claim 1 include:
    • Receiving a query for an on-the-fly search.
    • A "query tweaker" generating a defined query from the received query, which includes the tweaker "performing transformations and corrections."
    • Accessing one or more databases per the defined query.
    • Generating a search result with descriptors for data categories.
    • Creating a "template of the search result" that comprises links to those data categories.
  • The complaint notes that Vilox has asserted infringement of claims 1-38, reserving the right to pursue dependent claims (Compl. ¶23).

U.S. Patent No. 6,760,720 - *“Search-on-the-Fly/Sort-on-the-Fly Search Engine for Searching Databases”* (Issued Jul. 6, 2004)

The Invention Explained

  • Problem Addressed: In addition to the schema-knowledge problem, the patent identifies that conventional search engines often return very large amounts of data, which can be difficult for a user to review on a display screen and may require navigating many pages of results (’720 Patent, col. 2:23-28).
  • The Patented Solution: The invention is a search engine that does not require knowledge of the database structure and, critically, executes a "truncation routine" if the search results are too large for convenient display. This routine iteratively reduces the data shown, for example by shortening the characters displayed for each entry (e.g., from full city names to just the first letter), until the list is manageable (’720 Patent, Abstract; col. 7:1-14).
  • Technical Importance: The truncation feature was designed to improve usability for data exploration by preventing user information overload and enabling an intuitive "drill-down" approach to navigating large datasets (’720 Patent, col. 8:13-25).

Key Claims at a Glance

  • The complaint indicates Vilox asserted claims 1-39 in the Texas litigation, with a focus on independent claim 1 (Compl. ¶29).
  • The essential elements of independent claim 1 include:
    • Determining a database schema and providing a list of its database fields.
    • Receiving a user's selection of a database field to search.
    • Determining the quantity of entries in that field.
    • If the quantity exceeds a specified amount, "truncating data" and displaying it, where the truncation "reduces characters in one or more entries."
    • If the quantity does not exceed the specified amount, displaying the full contents.
  • The complaint notes that Vilox has asserted infringement of claims 1-39 (Compl. ¶29).

III. The Accused Instrumentality

Product Identification

The complaint identifies "Oracle Database" and "Oracle ATG" Platform products as the accused instrumentalities (Compl. ¶¶23-24, 29-30).

Functionality and Market Context

  • The complaint describes the functionality of the accused products through Oracle's non-infringement positions.
  • Oracle Database: Oracle alleges its database software does not perform the claimed function of making "corrections on" improper user queries, but instead requires users to submit syntactically correct queries (Compl. ¶23). It further alleges the database does not create a "template comprised of links" as recited in the '100 Patent or perform the character-reducing "truncating" function recited in the '720 Patent (Compl. ¶¶23, 29).
  • Oracle ATG: Oracle alleges its e-commerce platform searches "text files of products and documents, not databases directly" and, similar to Oracle Database, does not create the claimed template or perform the character-reducing truncation (Compl. ¶¶24, 30).
  • The complaint does not provide specific allegations regarding the products' market positioning beyond identifying Oracle as their provider.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

'100 Patent Infringement Allegations

The complaint does not provide Vilox's infringement claim chart but summarizes Oracle's non-infringement position with respect to claim 1.

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a query tweaker generating a defined query... wherein generating the defined query includes the query tweaker performing transformations and corrections on the received query Oracle alleges its database does not use a "query tweaker" for this purpose, stating users must submit syntactically correct queries. ¶23 col. 46:21-27
creating a template of the search result, wherein the template comprises links to the data categories described by the one or more descriptors Oracle alleges its Database and ATG products do not include a feature that allows a user to create such a template. ¶¶23, 24 col. 46:34-39
accessing one or more databases, using a search engine, per the defined query Oracle alleges its ATG product searched text files and documents, not databases directly. ¶24 col. 46:28-30
  • Identified Points of Contention:
    • Scope Questions: A primary issue may be the definition of a "query tweaker." The dispute raises the question of whether this term requires a system to affirmatively fix or transform an incorrect user query, or if it could be construed more broadly to cover standard query validation that rejects improper queries.
    • Technical Questions: A key factual question will be whether the accused products, in operation, "creat[e] a template... compris[ing] links" as required by the claim. The analysis will depend on evidence showing the technical implementation of search result handling in the Oracle Database and ATG products.

'720 Patent Infringement Allegations

The complaint summarizes Oracle's non-infringement position with respect to claim 1.

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
if the quantity exceed[s] a specified amount, truncating data, and displaying the truncated data wherein the truncating reduces characters in one or more entries in the selected database field Oracle alleges its Database and ATG products do not perform this step, stating they do not reduce the number of characters in individual entries when displaying large result sets. ¶¶29, 30 col. 17:12-17
  • Identified Points of Contention:
    • Technical Questions: The core of this dispute appears to be a functional mismatch. The question is whether the accused products' method for handling large result sets (e.g., pagination) meets the specific claim limitation of "truncating" by "reduc[ing] characters in one or more entries." Evidence of how the accused products actually render large data sets will be central.

V. Key Claim Terms for Construction

  • Term: "query tweaker" (from '100 Patent)

    • Context and Importance: This term is central to the infringement allegations against the '100 Patent, as Oracle's defense relies on its products lacking such a component. Practitioners may focus on this term because its definition will determine whether standard query processing functionalities fall within the scope of the claim.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent abstract describes an "intuitive method" for accessing databases, which could support an argument that any feature simplifying the query process, including validation, acts as a "tweaker."
      • Evidence for a Narrower Interpretation: The claim itself requires the tweaker to perform "transformations and corrections on the received query" ('100 Patent, cl. 1), which suggests an affirmative modification of the query rather than mere rejection of a syntactically incorrect one.

  • Term: "truncating data, wherein the truncating reduces characters in one or more entries" (from '720 Patent)

    • Context and Importance: This term defines the core technical mechanism of the '720 Patent and is a primary point of dispute, as Oracle alleges its products do not perform this specific function. Its construction will likely determine the outcome of the infringement analysis for the '720 Patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party could argue that any method of reducing the total data presented on a screen, such as pagination, is a form of "truncating data" for display.
      • Evidence for a Narrower Interpretation: The claim language explicitly requires that the truncation "reduces characters in one or more entries" (’720 Patent, cl. 1). The specification reinforces this by describing examples where full city names are reduced to their first letter, or full book titles are shortened, to make the results list fit on a display (’720 Patent, col. 7:1-42). This suggests the term requires a reduction in the length of the data strings themselves, not just the number of strings displayed per page.

VI. Other Allegations

  • Indirect Infringement: The complaint states that in the separate Texas litigation, Vilox relied on the 2015 "Oracle Customer Litigation" as a basis for its claims of induced and contributory infringement against Oracle (Compl. ¶¶1, 20). Oracle alleges this action violates the 2016 Settlement Agreement.
  • Willful Infringement: The complaint alleges that Vilox's willfulness claims in the Texas litigation were also based on knowledge derived from the prior Oracle Customer Litigation, an act Oracle contends is a breach of the settlement agreement's covenant not to use that litigation for such purposes (Compl. ¶18).

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

  • A primary issue is contractual: did Vilox breach the 2016 Settlement Agreement's forum selection and notice-limitation clauses by filing suit in Texas and by relying on the 2015 litigation to allege willful and indirect infringement? The resolution of this question may precede any substantive patent analysis.
  • A key claim construction question for the '100 Patent will be the definitional scope of "query tweaker." The case may turn on whether the term requires affirmative correction of user queries, as Oracle's position suggests, or if it can be construed to cover more conventional query validation functions.
  • A central evidentiary question for the '720 Patent will be one of technical operation: do the accused Oracle products perform the specific "truncating" function recited in the claims—which requires reducing characters within data entries—or do they manage large result sets through other means, creating a fundamental mismatch with the claim language?