DCT
1:23-cv-00345
Web 20 Tech LLC v. Workzone LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Web 2.0 Technologies, LLC (Texas)
- Defendant: Workzone, LLC (Delaware)
- Plaintiff’s Counsel: DEVLIN LAW FIRM LLC
- Case Identification: 1:23-cv-00345, D. Del., 03/27/2023
- Venue Allegations: Venue is based on Defendant's incorporation in Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s cloud-based project management and document collaboration platform infringes patents related to online information repositories and secure, multi-user document collaboration.
- Technical Context: The technology at issue falls within the market for Software-as-a-Service (SaaS) business collaboration tools, which enable teams to securely manage projects and files in a shared online environment.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the asserted patents and its alleged infringement on June 15, 2021, a fact which forms the basis for the willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 2000-01-07 | Priority Date for ’448 and ’644 Patents |
| 2005-01-18 | U.S. Patent No. 6,845,448 Issued |
| 2012-02-14 | U.S. Patent No. 8,117,644 Issued |
| 2021-06-15 | Plaintiff allegedly sent notice letters to Defendant |
| 2023-03-27 | Complaint Filed |
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’s background section identifies the inefficiency and annoyance for internet users of repeatedly filling out online forms with personal and demographic information for various services, and the lack of a central, user-controlled system for managing this data ('448 Patent, col. 1:12-32).
- The Patented Solution: The invention proposes a method and system where a user (a "first party") can store various "information objects" in a central online repository. The user can assign different security levels to each piece of information, thereby selectively authorizing different requesters (a "second party") to access only specific, approved portions of their data from a server computer operated by a service provider ('448 Patent, Abstract; col. 2:21-42).
- Technical Importance: The patent describes an early architecture for user-centric, permission-based data sharing over a network, a foundational concept for modern digital identity and data management platforms ('448 Patent, col. 1:45-54).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 ('448 Patent, Compl. ¶20).
- Essential elements of independent Claim 1 (as corrected December 31, 2013) include:
- A method, performed by a server computer, for disbursing a first party's personal information to an authorized second party.
- Establishing an account for the first party and entering their personal information as "information objects."
- Receiving from the first party an assignment of security levels to each information object at any granularity, enabling access to selected portions by individual receiving parties.
- Storing the first party's identifier, the information objects, and their 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 other claims (Compl. ¶30).
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, a continuation-in-part of the application leading to the '448 Patent, addresses problems with managing and sharing digital documents online. It notes that methods like bookmarking are unreliable due to "stale" links and downloading files consumes client-side resources and hinders sharing ('644 Patent, col. 1:20-49).
- The Patented Solution: The invention details a system for online document collaboration where a first user can store a document on a server and associate it with specific access restrictions. The system then allows a second, authorized user to modify the document and provides a mechanism for other users to register their approval or disapproval of those modifications, with the system storing identifying information about who rendered the approval/disapproval ('644 Patent, Abstract).
- Technical Importance: The patent outlines a system for permission-based collaborative editing and version control, a core feature of modern cloud-based productivity suites ('644 Patent, col. 2:42-49).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 ('644 Patent, Compl. ¶33).
- Essential elements of independent 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 on the server.
- Associating a set of access restrictions with the document, including the ability for a first group of users to modify it.
- Receiving a request from a second user to modify the document.
- Verifying the second user's identity and permitting modification based on granted 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 modifications.
- The complaint reserves the right to assert other claims (Compl. ¶40).
III. The Accused Instrumentality
Product Identification
- Defendant's Workzone "Project Management and other workflow applications" offered via its website, www.workzone.com (Compl. ¶¶20, 33).
Functionality and Market Context
- The complaint describes the accused instrumentality as a cloud-based platform allowing users to "Collaborate securely in the cloud" (Compl. p. 6). Its alleged functions include project management, secure document sharing with version control, and the ability for administrators to set granular "access levels" and permissions for different users (e.g., clients, employees, partners) to view, edit, and approve documents and project information (Compl. ¶¶21, 22, 35, 36).
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... performed by the server computer | The Workzone platform provides a method for sharing a first party's information, stored on a server, with an authorized second party. | ¶21 | col. 2:21-30 |
| receiving, from the first party, assignment of at least one of a plurality of security levels to each information object at any granularity | An administrator can set up "access levels" with specific permissions for team members, such as "Clients, Employees, Partners," to control access to information. A screenshot shows document permissions being set for individual users. | ¶22, p. 8 | col. 2:32-36 |
| storing in the database the first party identifier, the information object and the security level assigned to the information object | The Workzone platform stores user information and their associated permissions on a server computer coupled to a database. | ¶21, ¶23 | col. 2:36-39 |
| if the second party is not authorized to receive the information... rejecting the second party's request for information | If a user does not have the appropriate access level or permissions, the Workzone platform prevents them from accessing the information, thereby rejecting the request. | ¶24, p. 9 | col. 14:59-66 |
'644 Patent 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 Workzone platform allows a user to create and store documents, such as project plans and other resources, on its server. | ¶35 | col. 25:57-58 |
| associating a set of access restrictions with the document... 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, and a second user with the appropriate permissions can access and modify them. A screenshot illustrates "Secure File Sharing" with varying access levels. | ¶35, p. 14 | col. 26:1-6 |
| receiving approval or disapproval for the modifications from one or more users | The accused platform provides an "Approvals Workflow" that automates requests for approval and tracks responses. A screenshot shows an interface for submitting an "APPROVED" or "NOT APPROVED" response. | ¶36, p. 16 | col. 26:11-13 |
| storing identifying information of the one or more users who approved or disapproved the modifications to the document | The platform's "File Versioning" feature allegedly stores a record of revisions, including who made them and when, and the "Approvals Workflow" tracks and records responses. | ¶36, p. 15 | col. 26:14-17 |
Identified Points of Contention
- Scope Questions: A primary question for the ’448 Patent will be whether the term "personal information", which the patent illustrates with examples like demographic, financial, and health data ('448 Patent, col. 7:4-20), can be construed to read on the project-related data (e.g., tasks, deliverables, notes) that the complaint accuses (Compl. p. 5).
- Technical Questions: For the ’644 Patent, a key question may be whether the accused functionality of "File Versioning," which shows who last revised a document (Compl. p. 15), is sufficient to meet the claim limitation of "storing identifying information of the one or more users who approved or disapproved the modifications," or if only the more explicit "Approvals Workflow" functionality (Compl. p. 16) meets that element.
V. Key Claim Terms for Construction
Term from '448 Patent, Claim 1: "personal information"
- Context and Importance: The scope of this term is central to the infringement analysis for the ’448 Patent. The dispute will likely focus on whether this term is limited to personally identifiable information (PII) and user preferences as exemplified in the specification, or if it can be read more broadly to encompass any data associated with a user, including the project management data at issue.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses the general term without explicit limitation. The specification describes the problem as filling out forms with "demographic and other information," which may suggest a scope beyond a narrow list of examples ('448 Patent, col. 1:13-14).
- Evidence for a Narrower Interpretation: The specification provides an extensive list of exemplary information types, nearly all of which relate to personal demographics, health, finances, biometrics, and consumer preferences ('448 Patent, col. 7:1-34). The patent's title, "Online Repository for Personal Information," may also support a narrower construction focused on PII.
Term from '644 Patent, Claim 1: "storing identifying information of the one or more users who approved or disapproved the modifications"
- Context and Importance: Practitioners may focus on this term because the infringement case depends on whether the accused platform performs this specific type of record-keeping. The question is what constitutes "storing" the identity of an "approver/disapprover" versus merely storing the identity of an editor.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language does not specify the format of the stored information. A party could argue that a version history log that identifies a user who uploaded a revised version subsequent to a review request implicitly stores the identity of the approver.
- Evidence for a Narrower Interpretation: The plain language requires storing information about an "approval or disapproval" action, which is distinct from a modification or editing action. This suggests a requirement for a system that explicitly captures and logs an "approve" or "disapprove" status, not just a new version upload.
VI. Other Allegations
- Indirect Infringement: The complaint makes conclusory allegations of "jointly" infringing but does not plead specific facts to support claims for either induced or contributory infringement, such as specific actions taken with the intent to encourage infringement by others (Compl. ¶¶20, 27, 33, 38).
- Willful Infringement: Willfulness is alleged for both patents based on Defendant's continued infringement after receiving alleged actual notice via letters dated June 15, 2021 (Compl. ¶¶29, 40).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "personal information," as used in the ’448 Patent and described in the context of user demographics and preferences, be construed to cover the project and task-related data managed by the accused collaboration software?
- A key evidentiary question will be one of functional specificity: does the accused product's functionality, particularly its version history and approval workflow features, perform the precise sequence of steps required by Claim 1 of the ’644 patent, specifically the step of "storing identifying information" related to an explicit "approval or disapproval" action? The outcome may depend on whether a general version log is sufficient or if a more structured approval-tracking mechanism is required to meet the claim.