DCT

1:24-cv-01335

Data Resonance LLC v. Resilio Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-01335, D. Del., 12/09/2024
  • Venue Allegations: Venue is alleged to be proper as Defendant is a Delaware corporation and has allegedly committed acts of patent infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s data management products and services infringe a patent related to identifying and maintaining "families" of related data records to remove duplicates.
  • Technical Context: The technology addresses the challenge of data de-duplication and record linkage in large databases by identifying not just identical records, but also records that are indirectly related through chains of common information.
  • 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
2024-12-09 Complaint Filing Date

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

  • 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 addresses the issue of large databases being "plagued by the presence of duplicate data records," which can be costly for marketing campaigns and can make it difficult to retrieve complete information when related data is stored under minor variations. (’714 Patent, col. 1:15-32).
  • The Patented Solution: The invention proposes a "Data Family Record Management System" (DFRMS) that uses the concept of a "family" to group related records. A family consists of records linked either directly (e.g., sharing an address) or indirectly through a chain of relationships (e.g., record A is linked to B, and B is linked to C). (’714 Patent, Abstract; col. 4:10-24). The system automatically processes, normalizes, and de-duplicates new data, associating it with the correct family to maintain a "clean" data repository. (’714 Patent, col. 2:55-65). Figure 1 illustrates this concept by showing how different contact records for individuals and businesses can be linked into a single family through shared addresses and names. (’714 Patent, Fig. 1).
  • Technical Importance: The technology aimed to provide a more robust method for de-duplication than simply matching fields, by automatically detecting complex, "embedded" relationships between records. (’714 Patent, col. 1:36-40; col. 2:25-29).

Key Claims at a Glance

  • The complaint asserts "exemplary method claims" of the '714 Patent. (Compl. ¶11). Independent method claim 1 is representative.
  • Independent Claim 1 requires:
    • Determining a set of "directly-related" records for a designated record based on at least one common data field value.
    • Using that set to automatically determine a "potential family of records" that includes both directly-related records and "indirectly related" records.
    • Adding the designated record to the potential family after determining it is not a "duplicate" of a record already in the family.
    • Setting an indicator on each record in the potential family to signify the "family relationship."
  • The complaint does not specify dependent claims but may implicitly reserve the right to assert them.

III. The Accused Instrumentality

Product Identification

  • The complaint accuses "Exemplary Defendant Products" but does not name them directly. (Compl. ¶11). It states that these products are identified in charts within Exhibit 2. (Compl. ¶13). As Exhibit 2 was not provided with the complaint, the specific accused instrumentalities cannot be identified from the pleading.

Functionality and Market Context

  • The complaint alleges that Defendant directly infringes by "making, using, offering to sell, selling and/or importing" the accused products and by having its employees "internally test and use" them. (Compl. ¶11-12). The complaint does not provide sufficient detail for analysis of the specific functionality or market context of the accused products beyond these general allegations.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim charts in an external Exhibit 2, which was not available for this analysis. The complaint's narrative theory alleges that the "Exemplary Defendant Products practice the technology claimed by the '714 Patent" and "satisfy all elements of the Exemplary '714 Patent Claims." (Compl. ¶13). No specific factual allegations mapping product features to claim elements are present in the body of the complaint itself.

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: The patent’s specification heavily relies on examples from customer and contact management, such as mailing lists, names, and business addresses. (’714 Patent, col. 1:21-28; Fig. 1). A potential point of contention may be whether the term "data record" as used in the patent can be construed to cover the types of data managed by Defendant’s products (e.g., computer files, synchronization data), or if its meaning is limited by the specification's examples.
    • Technical Questions: The core of the invention is the multi-step process for finding "indirectly related" records. A key technical question will be what evidence demonstrates that the accused products perform this specific function. The complaint does not describe the mechanism by which Defendant's products allegedly identify records related through "multiply nested, embedded relationships" as described in the patent. (’714 Patent, Abstract).

V. Key Claim Terms for Construction

  • The Term: "family relationship"

    • Context and Importance: This term is central to the patent's novelty, defining how records are grouped. The scope of this term will likely determine whether the accused products' method for linking data falls within the claims. Practitioners may focus on this term because its definition dictates whether a simple grouping of files is equivalent to the patent's more complex, multi-level relational concept.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification provides a general 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. 2:55-60). This language is not explicitly tied to a specific data type.
      • Evidence for a Narrower Interpretation: The patent’s examples and detailed descriptions are consistently focused on contact data. Figure 1 shows relationships between records containing names, business names, addresses, and phone numbers. (’714 Patent, Fig. 1). This context could be used to argue that a "family relationship" requires the specific types of relational data shown in the embodiments.

  • The Term: "duplicate"

    • Context and Importance: The step of adding a new record only if it is not a "duplicate" is a required element of claim 1. The definition of this term is critical because it determines when a new record should be rejected versus consolidated or added.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent states that the term refers to a "configurable definition" and that a duplicate is "not necessarily an identical record (field for field) match." (’714 Patent, col. 6:25-29). This suggests flexibility in how duplication is determined.
      • Evidence for a Narrower Interpretation: The patent links the de-duplication process to specific, table-driven rules based on matching fields like Name, Address, and Phone. (’714 Patent, col. 14:45-62; Appendix B). An argument could be made that the term requires a configurable, rule-based comparison of specific data fields, not just a simple check for identical content.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that "numerous other devices that infringed the claims... have been made, used, sold, imported, and offered for sale by Defendant and/or its customers." (Compl. ¶11). However, it does not plead specific facts to support the knowledge and intent required for a claim of induced infringement, nor does it allege facts to support contributory infringement.
  • Willful Infringement: The body of the complaint does not contain factual allegations to support a claim of willful infringement, such as pre- or post-suit knowledge of the patent. The prayer for relief, however, requests that the case be "declared exceptional within the meaning of 35 U.S.C. § 285." (Compl. p. 4, ¶E.i).

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

  • A core issue will be one of definitional scope: can the patent’s claims, which are explained and exemplified in the context of de-duplicating customer contact and mailing list data, be construed to cover the functionality of Defendant’s accused products, which operate in a different technical domain? The interpretation of terms like "data record" and "family relationship" will be central to this question.
  • A key evidentiary question will be one of operational correspondence: given the lack of technical detail in the pleading, the case will likely turn on whether Plaintiff can produce evidence that Defendant’s products perform the specific, multi-step method recited in the claims. In particular, Plaintiff will need to show how the accused products identify "indirectly related" records through intermediate links and manage them as a "family," as distinct from more conventional data synchronization or grouping functions.