Data Resonance LLC v. Informatica Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Data Resonance LLC (New Mexico)
  • Defendant: Informatica Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Office, PC; Rabicoff Law LLC
• Case Identification: 1:23-cv-01473, D. Del., 12/28/2023
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation and has an established place of business in the District.
• Core Dispute: Plaintiff alleges that Defendant’s data management products infringe a patent related to methods for identifying and maintaining "families" of related data records to perform functions like de-duplication.
• Technical Context: The technology addresses the common problem of duplicate or near-duplicate records in large databases (e.g., customer relationship management systems), which can lead to inefficiencies and errors in marketing and data retrieval.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or specific licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 6,934,714 - “Method and system for identification and maintenance of families of data records”

• Patent Identification: U.S. Patent No. 6,934,714, “Method and system for identification and maintenance of families of data records,” issued August 23, 2005.

The Invention Explained

• Problem Addressed: The patent describes the problem of large databases being "plagued by... duplicate data records," which can be costly for businesses that rely on this data for marketing or customer contact (’714 Patent, col. 1:12-18). Such duplicates can also make data difficult to retrieve if information is stored under "minor variations of a field" (ʼ714 Patent, col. 1:28-31).
• The Patented Solution: The invention proposes a "Data Family Record Management System" that automatically identifies relationships among data records to group them into "families" (’714 Patent, Abstract). A "family" is defined as a plurality of data records related to each other "either directly or indirectly, in some type of embedded manner" (’714 Patent, col. 2:56-60). The system processes new records to normalize them, checks for relationships with existing records (e.g., based on a shared address or phone number), and associates them with a family, thereby preventing the entry of duplicates and allowing for more intelligent data retrieval (’714 Patent, col. 2:54-col. 3:5). Figure 3 illustrates the system's core components: a command interface, an auto de-duplication engine, a query engine, and a data repository (’714 Patent, Fig. 3).
• Technical Importance: This automated approach to de-duplication and relationship mapping was designed to improve the quality ("cleanliness") of large data repositories and reduce the manual effort typically required to find and merge related records (’714 Patent, col. 1:47-53).

Key Claims at a Glance

• The complaint asserts "one or more claims" without specifying them in the body of the complaint (Compl. ¶11). Claim 1, the first independent method claim, is representative.
• Independent Claim 1, essential elements:
  • Determining a set of records that are "directly-related" to a designated record based on a "common value" in at least one data field.
  • Using that set of directly-related records to automatically determine a "potential family of records" that includes both directly-related records and records that are "indirectly related to each other through a plurality of designated data fields."
  • Adding the designated record to the potential family after determining it is not a duplicate.
  • "Automatically setting an indicator" in each record of the potential family to indicate a family relationship.
• The complaint refers to "Exemplary '714 Patent Claims" in an attached Exhibit 2, but this exhibit was not filed with the complaint (Compl. ¶16).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products in its main body, referring generally to "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

The complaint alleges that Defendant makes, uses, sells, and imports products that "practice the technology claimed by the '714 Patent" (Compl. ¶16). The complaint states that these products are identified in an attached Exhibit 2, which was not provided with the filing (Compl. ¶11, ¶16). The complaint does not provide sufficient detail for analysis of the accused instrumentalities' specific functions or market position.

IV. Analysis of Infringement Allegations

The complaint alleges infringement but incorporates the specific comparisons into an "Exhibit 2," which was not filed with the public complaint document (Compl. ¶¶16-17). Therefore, a detailed claim chart analysis is not possible based on the provided documents.

The narrative infringement theory is that Defendant's "Exemplary Defendant Products" directly infringe by practicing the patented technology (Compl. ¶16). The complaint alleges that these products "satisfy all elements of the Exemplary '714 Patent Claims" either literally or under the doctrine of equivalents (Compl. ¶16). The complaint further alleges that Defendant's own employees internally test and use these products, constituting another act of direct infringement (Compl. ¶12).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Technical Questions: A central question will be whether the accused products perform the specific, multi-step process of first finding "directly-related" records and then recursively or iteratively using that set to find "indirectly related" records, as described in the patent. The dispute may turn on whether the accused functionality operates in the same way as the claimed method, or if it achieves a similar result (e.g., data linking) through a different technical approach.
  • Scope Questions: The infringement analysis will likely depend on the construction of the term "family" and the scope of "indirectly related." A key question will be what types of data links (e.g., shared name, address, phone number, etc.) and what degree of separation between records falls within the scope of the claims (’714 Patent, col. 5:14-24).

V. Key Claim Terms for Construction

• The Term: "family"

• Context and Importance: This term is central to every claim and is the core concept of the invention. Its definition will determine the fundamental nature of the infringing system—what it must create and maintain. Practitioners may focus on this term because the patent gives an explicit definition, which could be argued to limit the scope to the specific direct and indirect relationship-building process described.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests a broad applicability, stating a "family" is simply "a way to identify a plurality of data records that are related to each other" and can apply to various data types beyond contact information (’714 Patent, col. 2:56-58; col. 5:1-12).
  • Evidence for a Narrower Interpretation: The patent defines a family as being built upon both "direct" and "indirect" relationships, with indirect relationships being "embedded" (’714 Patent, col. 2:56-60). An argument could be made that a system that only links records based on direct, first-degree connections would not create a "family" as claimed. The detailed flowcharts (e.g., Figs. 9, 13) showing recursive searches could be cited to support a narrower, process-limited definition (’714 Patent, Fig. 13).

• The Term: "indirectly related"

• Context and Importance: This term defines the scope of the "family" and distinguishes the invention from simple de-duplication based on direct matches. The entire concept of an "embedded" relationship rests on this term, making its construction critical to infringement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes indirect relationships spanning "multiple levels of indirection," suggesting the term could cover any two records connected through a chain of intermediaries, no matter how long the chain (’714 Patent, col. 4:25-27).
  • Evidence for a Narrower Interpretation: The examples provided consistently rely on specific data fields like a common address or phone number to link otherwise unrelated records (’714 Patent, col. 5:35-51). A defendant might argue that "indirectly related" is limited to the specific types of transitive links disclosed (e.g., Record A shares a name with Record B, and Record B shares an address with Record C, making A and C indirectly related) and does not cover other forms of data association.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to operate the accused products in a manner that infringes the ’714 Patent (Compl. ¶14).
• Willful Infringement: The complaint does not use the word "willful" but alleges that the filing and service of the complaint provides Defendant with "Actual Knowledge of Infringement" (Compl. ¶13). It further alleges that despite this knowledge, Defendant "has also continued to sell the Exemplary Defendant Products," which may form the basis for a claim of post-suit willful infringement (Compl. ¶14).

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

1. A Definitional Question of Scope: A core issue will be whether the term "family," as defined and used in the 2002-era patent, can be construed to read on the architecture and functionality of the modern data management and integration products accused of infringement. The case may turn on how broadly the court interprets the concept of an "indirectly related" record.
2. An Evidentiary Question of Operation: As the complaint lacks specific factual allegations mapping product features to claim limitations, a key question will be whether discovery reveals evidence that the accused products actually perform the specific, two-stage process of identifying "directly-related" records and then using that set to find "indirectly related" ones. The central dispute will likely be whether the accused functionality is merely a form of data linking or if it operates in the specific, structured manner required by the claims.