Data Resonance LLC v. Egnyte Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Data Resonance LLC (New Mexico)
  • Defendant: Egnyte, Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:24-cv-01334, D. Del., 12/06/2024
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated there 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 the method and system for identifying and maintaining "families" of related data records.
• Technical Context: The technology addresses the de-duplication and organization of large databases by grouping records based on not only direct data matches but also indirect, multi-level relationships.
• 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	’714 Patent Priority Date
2005-08-23	’714 Patent Issue Date
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"

• 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 (’714 Patent).

The Invention Explained

• Problem Addressed: The patent's background describes the problem of duplicate and near-duplicate records in very large databases, which can be costly for marketing campaigns and make data retrieval difficult, particularly when records are "related but not identical" (’714 Patent, col. 1:12-39).
• The Patented Solution: The invention is a "Data Family Record Management System" (DFRMS) that automatically processes new data to identify "families" of records linked by direct or indirect relationships (’714 Patent, Abstract). For example, a first record may be linked to a third record through an intermediate second record, even if the first and third records share no data fields in common (’714 Patent, col. 4:15-26). The system normalizes data, identifies these direct and indirect links to form a "potential family list," de-duplicates new entries, and then associates all records in a family with a common identifier (’714 Patent, Abstract; Fig. 9).
• Technical Importance: This approach sought to automate the complex task of cleaning and organizing databases by looking beyond simple field-to-field matching to discover latent, "embedded" relationships between records, thereby improving data integrity (’714 Patent, col. 1:40-53).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring only to "exemplary method claims" identified in an unprovided exhibit (Compl. ¶11). Independent Claim 1 is representative of the patented method.
• Essential elements of Independent Claim 1 include:
  • Determining a set of "directly-related" records that share a common data field value with a designated record.
  • Using that set of directly-related records to automatically determine a "potential family of records" that includes both the directly-related records and records that are "indirectly related to each other."
  • Adding the designated record to the potential family if it is not a duplicate of an existing record in that family.
  • Automatically setting an indicator in each record of the potential family to indicate the family relationship.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any accused products by name, referring only to "Exemplary Defendant Products" listed in an unprovided exhibit (Compl. ¶11, 13).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context beyond the conclusory allegation that the products "practice the technology claimed by the '714 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint's infringement allegations are contained entirely within "charts incorporated into this Count" via Exhibit 2, which was not filed with the complaint (Compl. ¶¶ 11, 13, 14). Without these charts, there are no specific factual allegations in the complaint body to analyze how any accused product allegedly meets the limitations of the asserted claims.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the claim language and the nature of the technology, the infringement analysis may raise several key questions.

• Scope Questions: A central dispute may concern the scope of "indirectly related." The patent describes this concept as spanning "multiple levels of indirection" (’714 Patent, col. 4:23-26). A question for the court will be whether the accused system's method for linking records falls within the patent's definition, which involves using a set of directly-related records as a primer to find further, indirectly-linked records (’714 Patent, col. 18:11-19).
• Technical Questions: A significant evidentiary question will be what proof Plaintiff can offer that the accused products perform the automated, multi-step process recited in the claims. Specifically, what evidence shows that an accused system uses an initial set of "directly-related records" to then find "records that are indirectly related to each other," as required by Claim 1, rather than simply performing a different type of relationship analysis?

V. Key Claim Terms for Construction

The Term: "indirectly related"

• Context and Importance: This term is central to the patent’s novelty, distinguishing it from simple duplicate detection. The definition of "indirectly" will be critical to the scope of infringement, as it defines the core mechanism for creating a "family" of records. Practitioners may focus on this term because its construction will determine whether any transitive linking process in the accused system meets the claim limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests a broad, multi-level concept, stating a relationship can "span multiple levels of indirection" (’714 Patent, col. 4:25-26). Claim 2 defines one such indirect relationship where a first record links to a third record via a second record, even if the first and third do not share a common field, which could support a broad interpretation of any transitive linkage (’714 Patent, col. 18:30-38).
  • Evidence for a Narrower Interpretation: The detailed description and figures primarily provide examples in the context of business and personal contact information (e.g., shared addresses or phone numbers linking individuals and companies) (’714 Patent, Fig. 1; col. 5:14-53). A party could argue the term should be narrowed to the specific types of chained relationships disclosed in these embodiments.

The Term: "family"

• Context and Importance: This term defines the output of the claimed process. Its construction is important because infringement requires the creation of such a group.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent provides its own definition: "A 'family,' as used herein, 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. 2:55-59). This explicit definition could support a broad application to any set of records linked by the claimed method.
  • Evidence for a Narrower Interpretation: The patent’s "Background of the Invention" repeatedly frames the problem in terms of marketing literature and customer contacts (’714 Patent, col. 1:12-28). A party might argue that the context of solving this specific problem limits the term "family" to groups of records representing related people or business entities, as shown in the patent's examples.

VI. Other Allegations

Willful Infringement

• The complaint does not contain an allegation of willful infringement. It does, however, request in its prayer for relief that the case be declared "exceptional within the meaning of 35 U.S.C. § 285" but pleads no specific facts regarding pre-suit knowledge or objectively reckless conduct that would typically support such a finding (Compl. p. 4, ¶E(i)).

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

1. Pleading Sufficiency: An initial procedural issue is whether the complaint, which contains no factual allegations describing the accused products or their operation and relies entirely on an unprovided exhibit, provides sufficient notice of the infringement claim to satisfy the pleading standards of Federal Rule of Civil Procedure 8, as interpreted by Twombly and Iqbal.
2. Evidentiary Proof: A core challenge for the plaintiff will be one of technical evidence: what proof can be adduced to show that the accused systems, on a technical level, perform the specific two-step process of first finding "directly-related" records and then using that set to discover "indirectly related" records, as opposed to another method of data clustering or relationship mapping?
3. Definitional Scope: The case will likely turn on a question of claim construction: can the term "indirectly related", as taught in a patent focused on contact and business record de-duplication, be construed to cover the specific data-linking methodologies used in the defendant's modern data management platform?