TG 2006 Holdings LLC v. Arcserve USA LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TG--2006 Holdings, LLC (Texas)
  • Defendant: Arcserve (USA) LLC (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00296, D. Del., 03/11/2025
• Venue Allegations: Venue is alleged as proper because Defendant has an established place of business in the District of Delaware and has committed alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s software products infringe a patent related to systems and methods for tracking information, such as business tasks, using a hierarchical graphical user interface.
• Technical Context: The technology at issue involves user interface design for enterprise software, specifically using a tree-view or folder-based hierarchy to visually signal the status of underlying processes or data.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or specific licensing history concerning the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,583,514 - "System and method for tracking information in a business environment"

The Invention Explained

• Problem Addressed: The patent's background section identifies that tracking business information can be "time consuming and confusing," and if not done properly, a tracking system "defeats it own purpose." ('514 Patent, col. 1:12-19).
• The Patented Solution: The invention is a software system that provides "visual indications of the progress or status" of business tasks using a hierarchical "folder tree view." ('514 Patent, col. 1:21-26). The core concept is that "parent folders" automatically change their visual attributes (e.g., color) in response to status changes or triggered events (like a deadline passing) for the "child" items or sub-tasks contained within them, providing an at-a-glance status overview. ('514 Patent, Abstract; col. 1:30-32).
• Technical Importance: The described approach aims to simplify the monitoring of complex, multi-step business processes by translating detailed status data into a simple, intuitive visual signal within a familiar user interface metaphor. ('514 Patent, col. 3:10-16).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," identified as the "Exemplary ’514 Patent Claims," but does not specify which claims are asserted (Compl. ¶11). The first independent claim is Claim 1.
• Independent Claim 1 recites a method with the following essential elements:
  • Providing a computer and display.
  • Establishing a "parent folder" to contain documents or other folders.
  • Establishing a "child element" (e.g., a document or sub-folder) associated with the parent folder.
  • Correlating the child element with a time-critical task, inventory, or accounting activity.
  • Associating a "time trigger" with that task.
  • Providing a means for clearing the time trigger upon completion of the task.
  • "Changing an attribute of the parent folder based upon the state of the child element" when the time trigger is met before it is cleared.
• The complaint reserves the right to assert other claims, which may include dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name specific accused products, instead referring to them as the "Exemplary Defendant Products" identified in an incorporated but unattached claim chart exhibit (Compl. ¶11).

Functionality and Market Context

The complaint lacks specific allegations regarding the functionality of the accused products. It alleges only that Defendant makes, uses, sells, and tests these products, which infringe the ’514 Patent (Compl. ¶¶ 11, 12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim charts in its Exhibit 2, which was not publicly filed with the complaint (Compl. ¶¶ 16, 17). Therefore, a detailed element-by-element analysis based on the plaintiff's specific theories is not possible.

The complaint’s narrative infringement theory is conclusory. It alleges that the "Exemplary Defendant Products practice the technology claimed by the '514 Patent" and that they "satisfy all elements of the Exemplary '514 Patent Claims," incorporating the unattached charts by reference (Compl. ¶16). The complaint alleges direct infringement by Defendant through its own making, using, and testing of the products, as well as through its sales to customers (Compl. ¶¶ 11, 12).

Identified Points of Contention

The complaint does not provide sufficient detail for analysis of specific points of contention.

V. Key Claim Terms for Construction

"parent folder" / "child element"

• Context and Importance: These terms define the core hierarchical structure required by the claims. The infringement analysis will depend on whether the data organization and user interface of the accused Arcserve products can be mapped onto this specific "folder" and "child element" structure. Practitioners may focus on this term because the patent specification consistently illustrates this concept using a traditional, file-system-like graphical tree view ('514 Patent, Fig. 1, Fig. 3a-3c).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The parties may dispute whether the term "folder" is limited to its graphical representation. A broader reading could argue that any data structure establishing a parent-child relationship, regardless of its visual depiction, meets this limitation.
  • Evidence for a Narrower Interpretation: A narrower interpretation could argue that the term requires the specific visual metaphor of a "folder" in a "tree view," as this is the only embodiment described and depicted. The specification states the system employs a "typical hierarchical folder tree view" ('514 Patent, col. 1:26-27), language that could be used to limit the claim scope to that specific UI construct.

"changing an attribute of the parent folder"

• Context and Importance: This term is central to the novelty of the claimed invention, as it describes the mechanism for visually signaling status. The dispute will turn on what constitutes an "attribute" and whether it must be an attribute of the folder itself.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that any change on the screen that is logically associated with the parent container—such as a status icon appearing next to it or a text label changing—constitutes "changing an attribute."
  • Evidence for a Narrower Interpretation: The patent repeatedly describes the change as a modification of the folder's own properties, such as its color ('514 Patent, col. 4:1-3, "the parent folder changes color from green to red"). The Abstract refers to altering "visual attributes of the tree-view folders" ('514 Patent, Abstract). This focus on the folder's intrinsic visual properties could support a narrower construction that excludes status indicators that are merely adjacent to, but not part of, the folder icon itself.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct and encourage end users to use the accused products in an infringing manner (Compl. ¶14).

Willful Infringement

Willfulness is alleged based on knowledge of the ’514 Patent obtained via the service of the complaint and its attached claim charts. The complaint alleges that "at least since being served by this Complaint," Defendant has knowingly infringed (Compl. ¶15). This frames the allegation as one of post-suit willfulness.

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

• A central issue will be one of structural and definitional scope: Can the "parent folder" and "child element" structure, as described and claimed in the patent, be read to cover the data architecture and user interface paradigms of Defendant's modern data management products? The outcome may depend on whether the claims are limited to the specific tree-view GUI shown in the patent's figures.
• Another key question will be evidentiary and functional: Assuming a corresponding structure exists, does an accused product's method of signaling status—for example, through dashboard widgets, numerical counters, or textual alerts—constitute "changing an attribute of the parent folder" as required by the claims, or is there a functional mismatch with the specific mechanism taught in the patent?
• Finally, given the lack of specificity in the complaint, a primary initial focus will be on discovery and the plaintiff’s infringement contentions to understand which specific products are accused and which claims are asserted, as the complaint itself provides no details on either point.