DCT

1:25-cv-00169

DataCloud Tech LLC v. Medallia Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00169, D. Del., 02/11/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation and has conducted substantial business in the district, including committing the alleged acts of infringement.
  • Core Dispute: Plaintiff alleges that Defendant’s customer experience management platform, including its mobile application and web infrastructure, infringes three patents related to data organization, anonymous network communication, and remote file management.
  • Technical Context: The lawsuit concerns the software architecture for enterprise-level customer experience platforms, a market focused on collecting, analyzing, and acting upon customer feedback data in real-time.
  • Key Procedural History: The complaint alleges that Defendant was notified of its potential infringement of the Asserted Patents via a letter dated December 15, 2020, which may form the basis for a claim of willful infringement.

Case Timeline

Date Event
2000-01-28 Priority Date for U.S. Patent No. 6,651,063
2000-04-04 Priority Date for U.S. Patent No. 7,209,959
2002-03-29 Priority Date for U.S. Patent No. 7,398,298
2003-11-18 Issue Date for U.S. Patent No. 6,651,063
2004-02-03 Certificate of Correction issued for U.S. Patent No. 6,651,063
2007-04-24 Issue Date for U.S. Patent No. 7,209,959
2008-07-08 Issue Date for U.S. Patent No. 7,398,298
2020-12-15 Plaintiff allegedly informed Defendant of patent portfolio
2025-02-11 Complaint Filing Date

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

U.S. Patent No. 6,651,063 - “Data Organization And Management System And Method,” issued November 18, 2003

The Invention Explained

  • Problem Addressed: The patent addresses the difficulty faced by businesses and consumers in collecting and organizing an overwhelming amount of information from various sources, such as product manuals, solicitations, and updates, which are often misplaced or difficult to retrieve when needed (’063 Patent, col. 1:13-44).
  • The Patented Solution: The invention proposes a system where information "providers" send data in pre-categorized "information packs" to a user's "data repository." Each pack includes identifiers for the provider and the information category. The system allows a user to create custom categories and can communicate this custom organization back to the provider or a central processing station, enabling subsequent information from that provider to be sorted automatically into the user's preferred custom location (’063 Patent, Abstract; col. 4:31-61).
  • Technical Importance: The technology aimed to create a more structured and automated framework for managing digital information from disparate commercial sources, improving upon conventional, manual electronic filing systems (’063 Patent, col. 2:1-11).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 4 (Compl. ¶25).
  • Essential elements of Claim 4 (a method) include:
    • storing information in an information pack;
    • associating the pack with a user destination address, a category identifier, and a provider identifier;
    • communicating the pack over a network to a user data repository;
    • locating the pack in a pre-reserved category location;
    • creating a custom location in the user data repository and placing the information pack there;
    • associating a custom category identifier with the pack; and
    • sending a custom category signal to a processing station, which uses the stored provider identifier to automatically place subsequent information packs from the same provider into the custom location.

U.S. Patent No. 7,209,959 - “Apparatus, System, And Method For Communicating To A Network Through A Virtual Domain Providing Anonymity To A Client Communicating On The Network,” issued April 24, 2007

The Invention Explained

  • Problem Addressed: The patent identifies the privacy risks on the internet, where a user's identity and browsing activity can be tracked via their IP address, leading to unwanted solicitations and data collection (’959 Patent, col. 1:56-2:2).
  • The Patented Solution: The invention describes a system architecture that anonymizes a client's network session using three distinct functional components: a "deceiver," a "controller," and a "forwarder." A client's request is intercepted by the deceiver, which works with the controller to resolve the destination and assign a forwarder. The client then communicates with the destination website through the forwarder, whose IP address is used for the external communication, thereby masking the client's actual IP address from the destination server (’959 Patent, Abstract; col. 2:35-51).
  • Technical Importance: This technology provides a specific three-part architectural model for creating ad-hoc virtual domains that isolate and anonymize client network activity on a per-session basis.

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 1 (Compl. ¶35).
  • Essential elements of Claim 1 (a method) include:
    • in response to a client request, setting up a forwarding session to a destination website;
    • employing a "forwarder" between the client and destination server to transfer packets;
    • implementing the session such that neither the client nor the destination server is "aware of the employment of the forwarder";
    • employing a "controller" that communicates with the forwarder and a domain name server to resolve the destination website;
    • employing a "deceiver" that receives the client's request and initiates the controller to query the domain name server; and
    • initiating the forwarding session in response to the controller receiving the answer from the domain name server.

Multi-Patent Capsule

  • Patent Identification: U.S. Patent No. 7,398,298, “Remote Access And Retrieval Of Electronic Files,” issued July 8, 2008 (Compl. ¶39).
  • Technology Synopsis: The patent describes a system for allowing users to remotely access and manage their data and its underlying directory structure over a communications network (Compl. ¶40; ’298 Patent, Abstract). The system uses a server-side application to handle user requests, authenticate users, and manage access to data based on user profiles, with a specific focus on enabling users to control the directory structure itself, not just the files within it (’298 Patent, col. 2:15-36).
  • Asserted Claims: At least independent Claim 13 (a method) is asserted (Compl. ¶45).
  • Accused Features: The "Medallia web-based management of user roles and permissions" is the accused instrumentality (Compl. ¶44). The complaint specifically targets the "User Management/Crowd Management module in the Admin menu" for providing a method to remotely control data directory structures, such as webpages and functions accessible to users (Compl. ¶45).

III. The Accused Instrumentality

  • Product Identification: The complaint accuses the "Medallia Mobile 3 Android app," the "Medallia website infrastructure," and the "Medallia web-based management of user roles and permissions" (collectively, the Medallia Platform) (Compl. ¶16).
  • Functionality and Market Context:
    • The accused Medallia Platform is an enterprise software solution for managing customer experiences (Compl. ¶¶ 15-16). Figure 1 from the complaint provides a screenshot of the Medallia Mobile 3 Android app's page on the Google Play store, which describes the app as a tool for workforces to take quick action on customer feedback (Compl. p. 5).
    • The "Medallia website infrastructure" is alleged to support multiple domain names (e.g., access.medallia.com, blog.medallia.com) and to provide the technical means for setting up forwarding sessions between users and Medallia's servers (Compl. ¶¶ 34-35).
    • The "Medallia roles management" feature is described as a module within an "Admin menu" that allows for the management of user access to webpages and functions, effectively controlling data directory structures (Compl. ¶45).

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,651,063 Infringement Allegations

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint Citation Patent Citation
storing information to be provided in an information pack; The Medallia Mobile 3 Android app stores information, such as customer feedback data, to be provided to users (e.g., employees of a Medallia customer). ¶25 col. 23:27-28
associating with said information pack at least a user destination address...and a category identifier; The app associates this information with a user destination address and a category identifier. ¶25 col. 23:29-34
associating with said information pack a provider identifier; The app associates a provider identifier with the information. ¶25 col. 23:35-36
communicating said information pack by means of a network to said user data repository...; The app communicates the information pack over a network to a user data repository. ¶25 col. 23:37-40
further comprising...creating a custom location in said user data repository; placing said information pack in said custom location; associating a custom category identifier with said information pack; After communication, the method includes creating a custom location within the user's data repository, placing the information there, and associating it with a custom category identifier. ¶25 col. 23:45-51
sending a custom category signal to a processing station...said data processing means analyzing the provider identifier of subsequent...information packs...and in the event of a match...placing said one of the subsequent information packs in said custom location. The method includes sending a signal to a processing station, which stores the custom category and provider identifier together. The station then analyzes subsequent information packs, and if the provider identifier matches the stored one, automatically places the new pack in the same custom location. ¶25 col. 23:52-col. 24:10
  • Identified Points of Contention:
    • Scope Questions: A primary question is whether the data elements within the Medallia app (e.g., customer feedback, alerts) constitute an "information pack" as contemplated by the patent, which provides examples like car manuals and prescription drug information. It also raises the question of who qualifies as the "provider"—the end-customer giving feedback, or Medallia itself.
    • Technical Questions: The infringement theory hinges on the allegation that the Medallia app performs the final, automated sorting step of Claim 4. A key factual question will be what evidence the complaint provides that the app sends a "custom category signal" to a processing station that then uses a "provider identifier" to automatically route subsequent information packs into that same custom folder.

U.S. Patent No. 7,209,959 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
in response to a request by a client to initiate communication with a destination website; setting up a forwarding session between the client and a destination server... The Medallia infrastructure, in response to a client request, sets up a forwarding session between an internet device (client) and a WWW server (destination server). ¶35 col. 8:47-53
the forwarding session employing a forwarder disposed between the client and the destination server to forward packets... The session uses a "front-end server switch" that functions as the claimed "forwarder." ¶35 col. 8:53-58
wherein the forwarding session is set up and implemented such that neither the client or the destination server is aware of the employment of the forwarder; The system is allegedly implemented such that neither party is aware of the forwarder, because the destination server has a direct TCP connection with a local IP address, not the client's IP. ¶35 col. 8:58-63
employing a controller configured to communicate with the forwarder and a domain name server, wherein the controller queries the domain name server to resolve the name of the destination website... The system employs a "firewall" as the claimed "controller," which communicates with the "front-end server switch" (forwarder) and a DNS (domain name server) to resolve the destination website name. ¶35 col. 8:63-col. 9:1
employing a deceiver configured to communicate with the controller and the client, wherein the deceiver receives the request by the client...and initiates the controller to query the domain name server... The system employs a "router" as the claimed "deceiver." The router allegedly receives the client's request and initiates the "firewall" (controller) to query the DNS, making the router appear to be the source of data when the WWW server is the actual source. ¶35 col. 9:4-13
  • Identified Points of Contention:
    • Scope Questions: The core dispute will likely involve whether standard network components (router, firewall, switch) can be considered a "deceiver," "controller," and "forwarder" as defined by the patent. The claims require a specific, coordinated set of actions that may not be inherent in the routine operation of this hardware.
    • Technical Questions: A factual question is whether the client and destination server are truly "unaware" of the "forwarder" in the manner required by the claim. The plaintiff's theory that this is met merely by the server connecting to a local IP address will likely be contested. Further, the allegation that a standard router acts as a "deceiver" by making itself "appear to be the source of the data" raises a high evidentiary bar.

V. Key Claim Terms for Construction

For the ’063 Patent:

  • The Term: "information pack"
  • Context and Importance: The definition is critical, as infringement requires that the accused Medallia app stores and communicates data in the form of "information packs." Practitioners may focus on this term to determine if transient data like customer feedback alerts falls within a term whose examples in the patent are more akin to discrete, purchased-product-related document bundles.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states an "Information Pack" consists of "Static Information and/or Dynamic Information" and includes address means for a provider to connect a destination address with the pack, suggesting a broad, functional definition not limited to specific content types (’063 Patent, col. 6:30-38).
    • Evidence for a Narrower Interpretation: The preferred embodiments consistently describe "information packs" in the context of specific consumer or business-to-business transactions, such as for a purchased car, a prescription drug, or products at a trade show, suggesting the term implies a bundle of data related to a specific good or service (’063 Patent, Figs. 2, 3, 5).

For the ’959 Patent:

  • The Term: "deceiver"
  • Context and Importance: The "deceiver" is the lynchpin of the claimed method, as it is the component that intercepts the client's initial request and triggers the anonymizing process. The case may turn on whether a standard network router, as alleged by the plaintiff, performs the specific functions of a "deceiver."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent defines the components functionally and does not appear to limit their implementation to specific, non-standard hardware, which may support an argument that a router performing the claimed function is a "deceiver."
    • Evidence for a Narrower Interpretation: The claims and summary describe a specific sequence of operations: the deceiver "receives the request by the client...and initiates the controller to query the domain name server" and can make the router "appear to be the source of the data" (’959 Patent, col. 9:4-13). This suggests a more active and specific role of misdirection than what a standard router may perform in a typical network configuration.

VI. Other Allegations

  • Indirect Infringement: The complaint makes a general allegation of inducement and contributory infringement in its jurisdictional section (Compl. ¶10). However, the substantive counts for each patent allege direct infringement by Defendant, either through its own actions or through the operation of its systems (Compl. ¶¶ 25, 35, 45). The complaint does not plead specific facts to support a standalone claim for indirect infringement, such as by alleging that Medallia instructs its users to perform infringing acts.
  • Willful Infringement: The complaint alleges that Defendant had pre-suit knowledge of the asserted patents as of December 15, 2020, via a letter from the Plaintiff (Compl. ¶17). This allegation establishes a basis for a claim of willful infringement for any infringing conduct occurring after this date. The prayer for relief requests a finding of an exceptional case under 35 U.S.C. § 285, which is consistent with an allegation of willfulness (Compl. ¶49.D).

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

  • A core issue will be one of technical mapping: can the functional elements described in the patents, such as the '063 patent's "information pack" and "provider identifier" or the '959 patent's "deceiver," be persuasively mapped onto the components and data flows of a modern, multi-tenant, cloud-based platform like Medallia's? The plaintiff's case appears to rest on interpreting generic software concepts and standard network hardware as meeting specific, and arguably non-conventional, claim limitations.
  • A key evidentiary question will be one of functional proof: beyond high-level mapping, the case will likely turn on whether Plaintiff can demonstrate that the accused systems actually perform the specific, multi-step processes required by the asserted claims. For example, does the Medallia app execute the automated re-sorting feedback loop of '063 Claim 4, and does the Medallia network infrastructure orchestrate the precise anonymizing and misdirection sequence of '959 Claim 1?