DCT
1:23-cv-01106
Rally Ag LLC v. Apple Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Rally AG LLC (Washington)
- Defendant: Apple, Inc. (Delaware)
- Plaintiff’s Counsel: Morris, Nichols, Arsht & Tunnell LLP
- Case Identification: [Rally AG LLC](https://ai-lab.exparte.com/party/rally-ag) v. [Apple, Inc.](https://ai-lab.exparte.com/party/apple-inc), 1:23-cv-01106, D. Del., 01/09/2024
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation, maintains a regular and established place of business in the district, and has allegedly committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s "Hide-My-Email" feature infringes a patent related to systems and methods for enabling private email communications by masking a user's true email address.
- Technical Context: The technology operates in the field of digital privacy, addressing the need for users to interact with third parties via email without exposing their permanent, personally identifiable email addresses.
- Key Procedural History: The patent-in-suit was originally assigned to AutoGraph Inc., a company founded by the inventor to solve privacy issues, and was subsequently transferred to Plaintiff Rally AG LLC.
Case Timeline
| Date | Event |
|---|---|
| 2019-05-01 | Earliest Priority Date for U.S. Patent No. 11,361,107 |
| 2021-09-01 | Approximate launch of Accused "Hide-My-Email" feature |
| 2022-06-14 | U.S. Patent No. 11,361,107 Issues |
| 2024-01-09 | Plaintiff files First Amended Complaint for Infringement |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,361,107 - "Privacy Friendly Communication by Operation of Cloaked/Decloaked Email"
- Patent Identification: U.S. Patent No. 11,361,107, "Privacy Friendly Communication by Operation of Cloaked/Decloaked Email", issued June 14, 2022.
The Invention Explained
- Problem Addressed: The patent’s background section describes the risks consumers face when providing their personal email addresses for online transactions, which can lead to data breaches, spam, and phishing ( Compl. ¶34; ’107 Patent, col. 2:59-61). Conventional email protocols like SMTP can expose a user's private information throughout an email chain, increasing these risks (Compl. ¶36).
- The Patented Solution: The invention is an "ID cloaking system" that functions as a privacy-protecting intermediary for email communications (’107 Patent, col. 4:6-13). When a third party sends an email to a user's "cloaked" address, the system intercepts it, replaces placeholder information with the user's real information ("de-cloaking"), and forwards it to the user's actual inbox. Conversely, when the user replies, the system intercepts the reply, replaces the user's real information with cloaked information ("re-cloaking"), and forwards it to the third party, thereby maintaining the conversation thread without exposing the user's real email address (’107 Patent, col. 4:40-54; Fig. 4).
- Technical Importance: This approach allows users to engage in robust, threaded email communications while preserving their privacy, without requiring modifications to the underlying email systems (e.g., Gmail) of either the user or the third party (Compl. ¶66).
Key Claims at a Glance
- The complaint asserts independent claim 13 (Compl. ¶77).
- Claim 13 recites a non-transitory computer-readable medium for an ID cloaking system that executes instructions to perform the following essential steps:
- Receive an email addressed to a cloaked end user address from a relying party email address.
- Identify an end user specified (real) address associated with the cloaked address via an end user profile.
- Determine whether the user profile contains a previous association between the relying party address and a cloaked relying party email address.
- If no previous association exists, generate a new cloaked relying party email address (with a domain different from the relying party's domain) and associate it with the user profile.
- Send the email to the user's real address, configured with a reply-to address comprising the newly generated cloaked relying party email address.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The "Hide-My-Email" feature, which is part of the "Apple Platform" and available on Apple devices running iOS 15, iPadOS 15, macOS Monterey, or later versions (Compl. ¶11, 22, 24).
Functionality and Market Context
- The complaint alleges that Hide-My-Email "lets you create unique, random email addresses that forward to your personal inbox so you can send and receive email without having to share your real email address" (Compl. ¶24). This feature is provided with an iCloud+ subscription and is presented as a privacy option when a user creates an account with an app or website, allowing the user to mask their true email address from the third party (Compl. ¶25, 27).
IV. Analysis of Infringement Allegations
’107 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receive an email addressed to a cloaked end user address, wherein the email is sent from a relying party email address... | Apple’s platform receives emails sent by third parties to a user’s unique, random email address generated by the Hide-My-Email feature. | ¶24, ¶74 | col. 31:11-17 |
| identify an end user specified address associated to the cloaked end user address by an end user profile; | The Apple Platform is alleged to look up the user's real email address that is associated with the specific random Hide-My-Email address. | ¶24 | col. 31:18-21 |
| determine whether the end user profile contains a previous association between the relying party address and a cloaked relying party email address... | The complaint's theory requires that Apple's system checks if the sender's email address has previously communicated with the user through this service. | ¶56 | col. 31:22-28 |
| where the end user profile does not contain a previous association...then generate a new cloaked relying party email address and associate the new cloaked relying party email address to the end user profile... | If the sender is new to the user, the Apple Platform allegedly generates a new, unique cloaked address for the sender to use for replies, associating it with the conversation. | ¶56 | col. 31:29-38 |
| send the email to the identified end user specified address, wherein the email is configured with a reply-to email address comprising the new cloaked relying party email address. | The email is delivered to the user's real inbox with the "from" and "reply-to" fields configured to route replies back through Apple's intermediary system. | ¶24, ¶58 | col. 31:39-44 |
The complaint includes a diagram from the patent, Figure 1, to illustrate the overall three-party architecture involving the end user, the relying party, and the intermediary "ID Cloaking System" (Compl. ¶60). It also presents Figure 4 to explain the technical flow of "de-cloaking" an incoming email and "re-cloaking" the user's reply to maintain privacy throughout a conversation thread (Compl. ¶64).
- Identified Points of Contention:
- Scope Questions: The infringement analysis may focus on whether the term "cloaked ID system," described in the patent as an intermediary, can be read to cover Apple's Hide-My-Email functionality, which is an integrated feature of its broader iCloud platform. A question exists as to whether the specific two-domain environment described in the patent is present in the accused system (Compl. ¶58-59).
- Technical Questions: A key factual question is whether the Accused Products perform the specific conditional logic of Claim 13: determining if a "previous association" with a sender exists and then generating a "new cloaked relying party email address" only if no such association is found. Evidence regarding the precise operational logic of Apple's servers will be central to this inquiry.
V. Key Claim Terms for Construction
The Term: "cloaked ID system"
- Context and Importance: This term defines the infringing entity itself. Its construction is critical because it will determine whether Apple's integrated iCloud infrastructure, which provides the "Hide-My-Email" service, constitutes the claimed "system."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the system’s function broadly as an "intermediary between the end user's email system and the relying-party's email system" that protects privacy (’107 Patent, col. 4:7-13). This functional description could support including integrated platform features.
- Evidence for a Narrower Interpretation: Figure 1 depicts the "Identity (ID) Cloaking System (108)" as a structurally separate component from the "End User Email System (104)" and the "Relying-party Email System (110)." This could support an argument that the claimed system must be architecturally distinct, not merely a feature within a larger service.
The Term: "new cloaked relying party email address"
- Context and Importance: This term is central to the claimed method for maintaining a private, threaded conversation. The specific characteristics of this address, particularly its domain, are an express limitation of Claim 13.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the general purpose of cloaked addresses as ensuring "any replies from the user to the sender get routed back through the ICS server" (’107 Patent, col. 10:10-13), suggesting a focus on function over form.
- Evidence for a Narrower Interpretation: Claim 13 explicitly requires that this address is "generated with a domain different than the relying party address" (’107 Patent, col. 32:1-3). This language, emphasized in the complaint (Compl. ¶57), suggests a specific technical requirement for a two-domain architecture that may be a focal point of claim construction.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Apple induces infringement by providing the Hide-My-Email feature and materials that instruct and encourage customers to use it in a way that practices the claimed method (Compl. ¶17, 76).
- Willful Infringement: The complaint does not contain explicit allegations of willful infringement or pre-suit knowledge of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim scope: can the term "cloaked ID system", which the patent illustrates as a distinct intermediary, be construed to cover Apple's Hide-My-Email feature, which is deeply integrated into its existing iCloud platform? The outcome of this construction may determine whether the accused architecture falls within the patent's claims.
- A key evidentiary question will be one of technical implementation: does Apple's Hide-My-Email service operate using the specific, conditional, two-step logic recited in Claim 13—namely, first checking for a "previous association" with a sender and only then generating a "new cloaked relying party email address" to manage the reply? The degree of correspondence between the patent's specific workflow and Apple's actual system logic will be a primary focus of the infringement analysis.