Web 20 Tech LLC v. Proofhub LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Web 2.0 Technologies, LLC (Texas) and Pennar Software Corporation (Texas)
  • Defendant: ProofHub, LLC (Delaware)
  • Plaintiff’s Counsel: Devlin Law Firm LLC
• Case Identification: 1:23-cv-00343, D. Del., 11/06/2023
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation and has conducted acts of infringement within the district.
• Core Dispute: Plaintiffs allege that Defendant’s ProofHub project management and collaboration platform infringes patents related to permission-based sharing of personal information and online document collaboration.
• Technical Context: The technology concerns server-based systems that manage user access to stored information and documents, a foundational element of modern cloud-based collaboration and project management software.
• Key Procedural History: The complaint notes that the '644 Patent is a continuation-in-part of the application that led to the '448 Patent, suggesting a shared technical lineage. No other procedural events are mentioned.

Case Timeline

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

U.S. Patent No. 6,845,448, “Online Repository for Personal Information,” Issued January 18, 2005

The Invention Explained

• Problem Addressed: The patent describes the inefficiency and annoyance for users repeatedly filling out online forms with personal and demographic information for various websites, and the lack of a centralized method for a user to store and selectively authorize the distribution of this information ('448 Patent, col. 1:16-41).
• The Patented Solution: The invention proposes a method and system where a user stores various "information objects" (e.g., contact details, preferences, medical history) on a central server computer. The user can then assign different security levels to each piece of information "at any granularity" and authorize specific requesters (e.g., a travel agent, a doctor) to access only the relevant portions of that information ('448 Patent, col. 2:21-43; Fig. 1). The system is designed to verify authorization and reject requests from unauthorized parties ('448 Patent, col. 14:28-50).
• Technical Importance: This patent addresses the foundational concept of a centralized, permission-based digital identity repository, a precursor to modern single sign-on systems and federated identity management where users control the release of their data to third-party services ('448 Patent, col. 1:42-55).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1.
• Claim 1 (as corrected) requires 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, comprising one or more "information objects."
  • Receiving from the first party an "assignment of at least one of a plurality of security levels to each information object at any granularity," enabling selective access for different receiving parties.
  • Storing the identifier, information object, and its assigned security level in a database.
  • Receiving a request for the information from a second party.
  • Securely transmitting a selected portion of the 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 February 14, 2012

The Invention Explained

• Problem Addressed: The patent identifies the limitations of then-current methods for sharing and collaborating on online documents, such as printing, downloading, or using "stale" bookmarks, which lacked controlled, multi-user access and versioning ('644 Patent, col. 1:21-65).
• The Patented Solution: The invention describes a server-based system for online document collaboration. A first user stores a document on the server and associates "a set of access restrictions" that define who can modify it. A second, authorized user can then access and modify the document. Critically, the system provides for 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" ('644 Patent, col. 26:1-14; Fig. 4).
• Technical Importance: The technology relates to core features of modern collaborative platforms like Google Docs or Microsoft 365, specifically the integration of document storage, granular permissioning, and auditable approval workflows on a centralized server ('644 Patent, col.4:45-54).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1.
• Claim 1 requires a method performed by a server computer comprising the steps of:
  • Establishing accounts for multiple users.
  • Storing a document created by a first user.
  • Associating a set of access restrictions with the document for modification.
  • Receiving a request to modify the document from a second user.
  • Verifying the second user's identity and permitting modification based on access rights.
  • Receiving approval or disapproval for the modifications.
  • Storing identifying information of the user(s) who approved or disapproved.
• The complaint reserves the right to assert additional claims (Compl. ¶38).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are the project management and workflow applications and services offered on Defendant’s website, www.proofhub.com (Compl. ¶21, ¶32).

Functionality and Market Context

The complaint alleges that ProofHub provides a web-based platform for team collaboration, task management, and document sharing (Compl. ¶21). Key accused functionalities include the ability for users to create projects, assign tasks, store documents and notes, and manage team member access through a system of roles and permissions (Compl. ¶22-23, ¶33-34). A screenshot provided in the complaint describes ProofHub as "[t]he one place for all your projects and team collaboration" (Compl. p. 6). Another screenshot shows a user registration form requesting a user's full name, email, and company name (Compl. p. 8). The complaint alleges these features allow users to create and share information with other authorized users based on predefined access levels, such as "Owner," "Admin," and "Normal user," as well as more granular permissions like "View only," "View and add," and "View and manage" (Compl. ¶23, ¶33). The platform is also alleged to include features for approving files and tracking user activity in logs (Compl. ¶35).

IV. Analysis of Infringement Allegations

'448 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The primary question is whether the "personal information" contemplated by the '448 Patent (which describes demographic, financial, and health data) can be read to cover the type of project and user information managed within a collaboration tool like ProofHub. The complaint alleges user registration data and project information meet this limitation (Compl. ¶22).
• Technical Questions: What evidence demonstrates that ProofHub's role-based access control system meets the claim limitation of assigning security levels "to each information object at any granularity"? The court may need to determine if assigning a single role to a user for an entire project constitutes granular, object-level security as described in the patent.

'644 Patent Infringement Allegations

Identified Points of Contention

• Technical Questions: A key issue will be whether the "Activity logs" feature in ProofHub performs the specific function of "receiving approval or disapproval" and "storing identifying information of the...users who approved or disapproved" as required by the claim. The court may question whether a general activity log, which may record all actions, is equivalent to a specific, structured system for formally approving or disapproving modifications to a document.

V. Key Claim Terms for Construction

For the '448 Patent

• The Term: "personal information"
• Context and Importance: This term's scope is central to the infringement analysis. The patent's specification provides numerous examples like demographic, health, financial, and preference data. The complaint applies the term to user account details and project-related data within a business collaboration tool. The viability of the infringement claim may depend on whether the term is construed broadly to cover any information associated with a person, or narrowly to the types of personal-life data explicitly described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim itself uses the general term "personal information" without incorporating the specific examples from the specification, which may support an argument that the plain meaning should control.
  • Evidence for a Narrower Interpretation: The "BACKGROUND" and "DETAILED DESCRIPTION" sections repeatedly frame the invention as a solution for managing personal-life data like health records, travel preferences, and demographics, suggesting the invention's context is distinct from enterprise project data ('448 Patent, col. 7:4-38).

For the '644 Patent

• The Term: "storing identifying information of the one or more users who approved or disapproved the modifications"
• Context and Importance: This limitation requires a specific type of record-keeping. The infringement allegation relies on ProofHub's "Activity logs" (Compl. p. 18). The dispute may turn on whether a general-purpose log that records all activities (e.g., "User X edited document Y") is sufficient to meet this limitation, or if the claim requires a more formal system that explicitly stores a record of an "approval" or "disapproval" action.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language does not specify the format of the "identifying information," potentially allowing a simple log entry with a user's name to suffice.
  • Evidence for a Narrower Interpretation: The parallel claim language "receiving approval or disapproval" suggests a binary, deliberate act. This may support a narrower construction requiring the stored information to be explicitly linked to a formal approval or disapproval event, rather than just any modification action captured in a general log.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Defendant "directly and jointly (e.g., with its users and customers) infringed" (Compl. ¶21, ¶32). This suggests a theory of induced infringement. The complaint alleges that ProofHub provides applications that "allow or prevents team members...to access personal information" and provides documentation on setting up roles and permissions, which may be construed as alleging that Defendant instructs its users on how to perform the claimed methods (Compl. ¶23, ¶33).

Willful Infringement

The complaint does not contain specific allegations of pre-suit or post-suit knowledge of the patents that would typically support a willfulness claim. However, the prayer for relief requests a finding that this is an "exceptional case" under 35 U.S.C. § 285, which preserves the issue for a potential award of attorneys' fees (Compl. p. 19).

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

This dispute will likely center on questions of claim scope and the mapping of broad, early-internet-era patent claims onto the features of a modern, integrated software-as-a-service platform. The key questions for the court will be:

1. A core issue of definitional scope: Can the term "personal information" from the '448 Patent, described in the context of an individual's life data (health, finance, demographics), be properly construed to encompass the user and project data managed within a corporate collaboration platform?
2. A key evidentiary and functional question: Does the accused "Activity logs" feature of the ProofHub platform perform the specific function of "receiving" and "storing identifying information of...users who approved or disapproved" modifications, as required by Claim 1 of the '644 Patent, or is there a functional distinction between a general audit trail and a formal approval-tracking system?
3. A broader question of technological correspondence: Do the methods described abstractly in the patents-in-suit, which predate the widespread adoption of cloud-based collaboration suites, correspond to the specific technical implementation and operation of the accused ProofHub platform, or does the modern platform operate in a fundamentally different way not contemplated by the inventions?