Web 20 Tech LLC v. Moxtra Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Web 2.0 Technologies, LLC (Texas) and Pennar Software Corporation (Texas)
  • Defendant: Moxtra Inc. (Delaware)
  • Plaintiff’s Counsel: DEVLIN LAW FIRM LLC
• Case Identification: 1:23-cv-00342, D. Del., 11/06/2023
• Venue Allegations: Venue is alleged to be proper in the District of Delaware as Defendant Moxtra Inc. is a Delaware corporation and its acts of infringement have purportedly taken place within the district.
• Core Dispute: Plaintiffs allege that Defendant’s Moxo client collaboration platform infringes two patents related to methods for securely managing and sharing personal information online and for online document collaboration.
• Technical Context: The technology at issue addresses the secure management, granular sharing, and collaborative modification of information and documents in a networked environment, a foundational element of modern enterprise software-as-a-service (SaaS) platforms for client management and workflow automation.
• Key Procedural History: The operative pleading is a First Amended Complaint. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the asserted patents.

Case Timeline

Date	Event
2000-01-07	Earliest Priority Date for '448 Patent and '644 Patent
2005-01-18	U.S. Patent No. 6,845,448 Issues
2012-02-14	U.S. Patent No. 8,117,644 Issues
2023-11-06	First Amended Complaint Filed

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 user annoyance resulting from having to repeatedly provide personal and demographic information to various entities on the internet, and the lack of a centralized method for a user to store, control, and selectively disseminate that information (ʼ448 Patent, col. 1:12-41).
• The Patented Solution: The invention proposes a method and system where a user can establish an account on a server computer to store various "information objects" (e.g., contact details, preferences, financial data). The user can assign different security levels to each piece of information, allowing them to authorize different requesters to access only specific, pre-approved portions of their data from a single, user-controlled repository (ʼ448 Patent, Abstract; col. 2:23-43).
• Technical Importance: This technology provided a framework for user-centric control over personal data, addressing privacy and efficiency concerns at a time when web-based services were increasingly requiring user data for registration and personalization (ʼ448 Patent, col. 1:33-41).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶21).
• The essential elements of the corrected Claim 1 (per Certificate of Correction dated Dec. 31, 2013) include:
  • A method, performed by a server computer, for automatically disbursing a first party's personal information to an authorized second party.
  • Establishing an account for the first party and assigning an identifier.
  • Entering the first party's personal information, comprising multiple "information objects."
  • Receiving from the first party an assignment of security levels to each information object "at any granularity," enabling selective access for different receiving parties.
  • Storing the identifier, information objects, and assigned security levels in a database.
  • Receiving a request from a second party that includes the first party's identifier.
  • In response, selecting and securely transmitting the authorized portion of the personal information to the second party.
  • If the second party is not authorized, recording the second party's identifier and rejecting the request.
• The complaint reserves the right to assert additional claims (Compl. ¶29).

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

The Invention Explained

• Problem Addressed: As a continuation of the '448 Patent, this invention addresses challenges specific to online document collaboration, such as controlling access for modification, tracking changes, and managing a formal approval process among multiple users in a networked environment (ʼ644 Patent, col. 1:20-34, col. 2:1-6).
• The Patented Solution: The patent describes a server-based method where a document is stored with associated access restrictions. The system allows authorized users to request and make modifications. Critically, the method includes steps for receiving "approval or disapproval for the modifications from one or more users" and then "storing identifying information of the one or more users who approved or disapproved the modifications," thereby creating an auditable record of the collaboration and approval workflow (ʼ644 Patent, Abstract).
• Technical Importance: The invention provides a system for structured, secure, and auditable online document workflows, a key requirement for business processes in fields like finance and law where version control and explicit, recorded approvals are critical (ʼ644 Patent, col. 26:7-14).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶32).
• The essential elements of Claim 1 include:
  • A method, performed by a server computer, for online document collaboration.
  • 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 first group of users to modify it.
  • Receiving a request to modify the document from a second user, which includes the second user's identification.
  • Verifying the second user's identity and permitting modification based on their access rights.
  • Receiving "approval or disapproval for the modifications" from one or more users.
  • Storing "identifying information of the one or more users who approved or disapproved the modifications."
• The complaint reserves the right to assert additional claims (Compl. ¶39).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendant's "Moxo client integration apps," the "Moxo app," and other related collaboration products and services offered on its website, collectively referred to as the Moxo platform (Compl. ¶¶21, 32).

Functionality and Market Context

• The complaint describes the Moxo platform as a solution for "managing client business in a digital world" that automates "routine business processes with interaction workflows" (Compl. p. 6). Functionally, it allows users to "streamline external projects, manage workflows," and collaborate with customers, vendors, and partners (Compl. p. 6). Key alleged features include the ability for a "conversation owner" to manage member access and capabilities (Compl. ¶23), a process for users to sign documents (Compl. p. 15), and "End-to-End Management Control" that provides an "auditable digital paper trail" of interactions (Compl. p. 15). The complaint positions the product in the market for digital client management and business process automation (Compl. p. 6).

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,845,448 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 operated by a service provider...	The Moxo platform provides a method for sharing information from a first party (e.g., project owner) with a second party (e.g., team member) from Moxtra's server computer. (Compl. ¶22)	¶22	col. 2:23-30
...receiving, from the first party, assignment of at least one of a plurality of security levels to each information object at any granularity...	A "project conversation owner" can decide which team members (second users) can access information about other team members and can manage member capabilities. (Compl. ¶23)	¶23	col. 2:32-36
...in response to the request, selecting a first portion of the first party's personal information objects that could be transmitted to a second party;	Once permitted by the owner, a second party can access the first party's personal information on Moxtra's server. (Compl. ¶24)	¶24	col. 14:46-51
...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 is not permitted to view certain information, the request is rejected. (Compl. ¶25)	¶25	col. 14:26-28

• Identified Points of Contention:
  • Scope Question: Does the term "personal information," which the ʼ448 Patent describes with examples like demographics, health records, and personal preferences, read on the "client business," "workflow," and "project conversations" data managed by the accused Moxo platform?
  • Technical Question: Does the accused platform's alleged ability for an "owner" to manage "member capabilities," as depicted in a screenshot from a support article (Compl. p. 9), meet the specific claim limitation of assigning "security levels to each information object at any granularity"? The analysis may focus on whether role-based access control (owner vs. member) is equivalent to assigning security levels to individual data objects.

U.S. Patent No. 8,117,644 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
...storing, on the server computer, a document created by a first user;	The Moxo platform allows users to create and engage in "project conversations" which can include documents stored on a server. (Compl. ¶34)	¶34	col. 25:56-58
...associating a set of access restrictions with the document...	A project conversation owner can designate team members with "certain permissions." (Compl. ¶33) A screenshot showing "Conversation owner and member capabilities" illustrates this control. (Compl. p. 14)	¶33	col. 25:61-65
...receiving, from a second user, a request to modify the document...permitting the second user to modify the document based on a set of access rights...	The platform allows a second user with suitable permissions to modify a document, for example by requesting access to "Sign Documents." (Compl. ¶34) This is illustrated by a screenshot describing the steps for signing a document. (Compl. p. 15)	¶34	col. 26:1-9
...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 modifications...	The platform allegedly stores identifying information of users who "approved or disapproved the modifications" by providing an "auditable digital paper trail" and recording all interactions. (Compl. ¶36) This is supported by a marketing screenshot promising "End-to-End Management Control." (Compl. p. 16)	¶36	col. 26:10-14

• Identified Points of Contention:
  • Technical Question: Does the accused platform's general "auditable digital paper trail" (Compl. p. 16) perform the specific, two-part function required by the claim: (1) "receiving approval or disapproval for the modifications" and (2) "storing identifying information of the...users who approved or disapproved"? The case may turn on whether a general activity log is sufficient to meet this limitation, or if a more explicit "approve/disapprove" mechanism is required by the claim language.

V. Key Claim Terms for Construction

For the ʼ448 Patent

• The Term: "personal information"
• Context and Importance: The resolution of this term's scope is central to whether the patent applies to the accused Moxo platform. Practitioners may focus on this term because Defendant may argue that the enterprise-level "client business" and "workflow" data managed by its platform is distinct from the individually-focused "personal information" contemplated by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification defines an "information object" as "any piece of information, however small in granularity or however agglomerated" ('448 Patent, col. 6:57-59), which could be argued to encompass any type of data, including business data.
  • Evidence for a Narrower Interpretation: The Background and Detailed Description sections provide extensive examples that are exclusively personal in nature, such as demographic data, property ownership, health records, travel preferences, and magazine subscriptions ('448 Patent, col. 1:12-20; col. 7:1-39). This focus could suggest the term is limited to data about an individual person, not a business entity or project.

For the ʼ644 Patent

• The Term: "receiving approval or disapproval for the modifications"
• Context and Importance: This term appears to capture a core novel aspect of the claimed invention. The infringement analysis for the ʼ644 Patent will likely depend heavily on whether the accused platform's functionality meets this specific requirement, as opposed to merely logging that a document was accessed or changed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff may argue the term should be read broadly to cover any user action that signifies assent to a document's modified state, such as applying an electronic signature or completing a task in a workflow that includes the modified document. The claim language itself does not specify the mechanism of approval ('644 Patent, col. 26:10-11).
  • Evidence for a Narrower Interpretation: The claim recites this step separately from the step of "permitting the second user to modify the document." A defendant may argue this structure implies that "receiving approval" is a distinct, subsequent event, such as a user clicking a dedicated "approve" or "disapprove" interface element, rather than being inherent in the act of modification or signing itself.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant infringes "jointly (e.g., with its users and customers)" (Compl. ¶¶21, 32). It further alleges that Defendant provides applications and instructs users on how to use the allegedly infringing features, for example through support documentation and descriptions of product capabilities (Compl. ¶¶23, 34-35). These allegations may form the basis for a claim of induced infringement, suggesting Defendant provides the platform and encourages users to perform the steps of the claimed methods.
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement.

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

The resolution of this dispute will likely depend on the court’s determination of several key questions regarding claim scope and technical function:

1. A core issue will be one of definitional scope: Can the term "personal information," as defined and exemplified in the ʼ448 Patent with a focus on individual user data, be construed to cover the "client business" and "project workflow" data managed by the accused enterprise collaboration platform?

2. A key evidentiary question will be one of functional specificity: Does the Moxo platform’s general-purpose "auditable digital paper trail" perform the specific, two-part logical function required by Claim 1 of the ʼ644 Patent—namely, "receiving approval or disapproval for...modifications" and "storing identifying information of the...users who approved or disapproved"—or is there a fundamental mismatch in the technical operation required by the claim versus that provided by the accused product?