Data Resonance LLC v. Backblaze Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Data Resonance LLC (New Mexico)
  • Defendant: Backblaze, Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:24-cv-01332, D. Del., 12/06/2024
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation and has an established place of business in the district, has committed acts of infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s data management products infringe a patent related to methods for identifying and maintaining relationships among data records.
• Technical Context: The technology at issue involves systems for cleaning and organizing large databases by automatically identifying direct and indirect relationships between records to group them into "families," thereby enabling more sophisticated data processing and de-duplication.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2002-03-04	Priority Date, U.S. Patent No. 6,934,714
2005-08-23	Issue Date, U.S. Patent No. 6,934,714
2024-12-06	Complaint Filing Date

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 (Issued August 23, 2005)

The Invention Explained

• Problem Addressed: The patent addresses the problem of large databases being "plagued by... duplicate data records," which can be costly and make data difficult to retrieve, especially when records are related but not identical (e.g., minor variations in names or addresses) (’714 Patent, col. 1:12-33). Existing systems are described as limited to matching one or more fields, a process that is highly dependent on uniform data entry and is often performed as a difficult "post-process" step ('714 Patent, col. 1:40-49).
• The Patented Solution: The invention proposes a "Data Family Record Management System" (DFRMS) that manages records using a concept of "families" ('714 Patent, Abstract). A family is a group of records related "either directly or indirectly, in some type of embedded manner" ('714 Patent, col. 4:15-20). The system automatically processes new records by normalizing the data, checking for duplicates, and identifying both direct relationships (e.g., a shared phone number) and indirect, "embedded" relationships (e.g., record A shares an address with record B, and record B shares a phone number with record C, thus linking A and C) to group them into a family ('714 Patent, col. 4:20-27; Fig. 1). This process is intended to create and maintain a "clean" (duplication-free) data repository ('714 Patent, col. 4:30-32).
• Technical Importance: This method of identifying multi-level, indirect relationships allows for more robust de-duplication and data organization than simple field matching, enabling more targeted actions like sending only one piece of marketing literature to a single household or business, even if multiple related contacts exist in the database ('714 Patent, col. 1:22-28).

Key Claims at a Glance

• The complaint asserts infringement of unspecified "Exemplary '714 Patent Claims" identified in an exhibit not attached to the publicly filed complaint (Compl. ¶11, ¶13). Analysis is therefore based on the first independent method claim, Claim 1.
• Independent Claim 1 requires:
  • Determining, from a plurality of data records, 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" which includes records that are "indirectly related" to each other.
  • Adding the designated record to the potential family after determining it is not a "duplicate" of a record already in the family.
  • Automatically setting an "indicator" in each record in the potential family to indicate the family relationship.
• The complaint does not specify if dependent claims are asserted but reserves the right to identify them later.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products in its main body. It refers to "Exemplary Defendant Products" that are identified in charts located in "Exhibit 2" (Compl. ¶13). This exhibit was not filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market context. It alleges generally that the "Exemplary Defendant Products practice the technology claimed by the '714 Patent" (Compl. ¶13).
No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's products infringe the '714 patent but incorporates the specific comparisons into "the claim charts of Exhibit 2," which was not provided with the filed complaint (Compl. ¶14). A detailed claim chart analysis is therefore not possible. The narrative infringement theory is that Defendant's products, by "making, using, offering to sell, selling and/or importing," practice the claimed method for identifying and maintaining families of data records (Compl. ¶11).

• Identified Points of Contention:
  • Scope Questions: A central question will concern the scope of the patent's claims, which appear directed at managing contact or entity records (e.g., names, addresses, companies as shown in Fig. 1), and whether this scope can read on the technology likely used by a cloud backup service like Backblaze. The dispute may turn on whether Backblaze's systems, which likely perform data de-duplication at a file or block level, can be characterized as managing "families of data records" in the manner described by the patent.
  • Technical Questions: The infringement analysis will raise the question of whether the accused products perform the specific multi-step process of first finding "directly-related" records and then using that set to find "indirectly related" records through "multiple levels of embedding" ('714 Patent, col. 2:25-29). A key factual dispute may be whether Defendant's de-duplication technology, which may identify identical data blocks across different user accounts, is technically equivalent to the patent's method of identifying relationships between discrete records (e.g., a record for "Tom Johnson" and a record for "Sally Johnson") based on shared, but non-identical, record content.

V. Key Claim Terms for Construction

1. "family" / "potential family of records"

• Context and Importance: This is the central concept of the invention. The definition of a "family" will determine the overall scope of the claims and is critical to the infringement analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states a family is "a way to identify a plurality of data records that are related to each other either directly or indirectly, in some type of embedded manner" ('714 Patent, col. 4:15-20). This functional definition could be argued to encompass any system that groups data based on relationships, not just the specific examples shown.
  • Evidence for a Narrower Interpretation: The specification's examples consistently depict families of contact records for individuals and businesses, linked by fields like name, address, and phone number ('714 Patent, Fig. 1, Fig. 11). This context may support a narrower construction limited to CRM-style or entity-based record management, as opposed to general-purpose data de-duplication.

2. "indirectly related"

• Context and Importance: This term defines the invention's reach beyond simple, direct matching. Its construction will be crucial for determining whether an accused system performs a novel step or a conventional one.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent describes indirect relationships as spanning "multiple levels of indirection" ('714 Patent, col. 4:25-27), suggesting a broad, transitive application of relationship logic.
  • Evidence for a Narrower Interpretation: The patent explains this concept through a specific example: "the first record [is related] with the third record in an indirect or embedded relationship" by way of a shared intermediate record ('714 Patent, col. 4:20-25). This could be argued to require a specific, multi-hop linking process between distinct records, not just a finding that two files share a common data block.

3. "duplicate"

• Context and Importance: The claim requires adding a record only after determining it is not a "duplicate." The definition of this term is key to whether this claim limitation is met.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states that the term refers to a "configurable definition of what is considered duplicate" and is not "necessarily an identical record (field for field) match" ('714 Patent, col. 6:25-30). This suggests flexibility in how a system can identify and exclude duplicates.
  • Evidence for a Narrower Interpretation: The de-duplication process is described in the context of consolidating records to create a "clean" repository ('714 Patent, col. 4:30-31), which could imply that "duplicate" refers to records representing the same real-world entity that should be merged, rather than merely identical blocks of binary data.

VI. Other Allegations

• Indirect Infringement: The complaint does not include specific factual allegations to support a claim for either induced or contributory infringement.
• Willful Infringement: The complaint does not contain specific factual allegations supporting a claim of willful infringement. The prayer for relief includes a request that the case be declared "exceptional" under 35 U.S.C. § 285 for the purpose of awarding attorneys' fees, but does not plead facts related to pre- or post-suit knowledge of the patent or infringement (Compl. ¶E.i).

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

1. A core issue will be one of definitional scope: Can the patent’s central concept of a "family of data records," which is described and illustrated in the context of managing contact and business entity information (e.g., CRM data), be construed to cover the data structures and de-duplication methods used by a cloud backup and storage service?
2. A key evidentiary question will be one of technical operation: Assuming the claims are construed broadly enough, does Backblaze’s accused technology actually perform the specific multi-step process required by the claims—namely, identifying "indirectly related" records by searching through transitive links between "directly-related" records—or does it use a different technical method, such as content-based hashing, to achieve data de-duplication?
3. A critical procedural question will arise from the complaint's structure: Given that the complaint's infringement allegations rely entirely on an external exhibit that was not filed, the initial stages of litigation may focus on whether the pleading provides sufficient notice of the infringement theory as required by federal rules.