TG 2006 Holdings LLC v. Notion Labs Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TG--2006 Holdings, LLC (Texas)
  • Defendant: Notion Labs, Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00299, D. Del., 03/11/2025
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation with an established place of business in the district, has committed alleged acts of infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s business productivity software infringes a patent related to systems for visually tracking information, such as tasks or projects, in a hierarchical environment.
• Technical Context: The technology concerns graphical user interfaces for project management and information organization, a field central to modern productivity and collaboration software.
• Key Procedural History: The patent-in-suit is a continuation of a chain of applications dating back to 2004, which may be relevant for determining the scope of the claims and the universe of applicable prior art. The complaint does not mention any prior litigation or administrative proceedings involving the patent.

Case Timeline

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

U.S. Patent No. 9,805,323 - System and method for tracking information in a business environment, issued October 31, 2017

The Invention Explained

• Problem Addressed: The patent describes the tracking of business information as being potentially "time consuming and confusing," noting that if information is not tracked properly or is "confusingly displayed, it accomplishes nothing or defeats its own purpose" ('323 Patent, col. 1:19-24). The patent seeks to provide a system for tracking information in a "visually clear and meaningful way" ('323 Patent, col. 1:26-27).
• The Patented Solution: The invention is a system and method that uses a "typical hierarchical folder tree view" to visually represent the status of tasks or other business items ('323 Patent, col. 1:31-33). The core mechanism involves parent folders automatically changing their visual attributes (e.g., color) in response to a status change in an item contained within a child folder ('323 Patent, Abstract; col. 4:62-65). For example, if a task in a sub-folder exceeds a pre-set time limit, its folder might turn red, which in turn causes its parent folder to also turn red, providing a "cascading" visual alert that is apparent even if the tree view is collapsed ('323 Patent, col. 4:10-13, 62-65).
• Technical Importance: This approach allows a user to monitor the timeliness and status of a complex production or sales process at a glance, without needing to inspect the details of every individual item or sub-folder ('323 Patent, col. 4:65-col. 5:2).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" but does not specify which claims are asserted, instead referencing charts in a non-proffered exhibit (Compl. ¶11, ¶13). Independent method claim 1 is representative of the core invention.
• Independent Claim 1 includes the following essential elements:
  • establishing a parent folder;
  • establishing a child folder associated with the parent folder;
  • correlating the child folder with a time critical task;
  • associating a first alert interval with the time critical task;
  • starting a system clock and monitoring system time;
  • changing an attribute of the child folder when system time equals or exceeds the first alert interval; and
  • changing an attribute of the parent folder when the attribute of the child folder changes.
• The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" generally (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products in the body of the filing. It refers to "Exemplary Defendant Products" that are identified in "charts incorporated into this Count" via Exhibit 2 (Compl. ¶11, ¶13). However, Exhibit 2 was not filed with the complaint. The defendant is Notion Labs, Inc.

Functionality and Market Context

The complaint provides no description of the accused instrumentality's functionality, features, or market position. It makes only the conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '323 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint references claim charts in an external exhibit (Exhibit 2) that was not provided with the public filing (Compl. ¶13-14). The narrative infringement theory is limited to the assertion that the accused products "satisfy all elements of the Exemplary '323 Patent Claims" (Compl. ¶13). In the absence of specific allegations or claim charts, a detailed element-by-element analysis is not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent's claims and the general nature of modern productivity software, the dispute may focus on several key questions:

• Scope Questions: A central question may be whether the data structures used in Defendant's products (e.g., nested pages, databases, or blocks) meet the definition of a "parent folder" and "child folder" as recited in the claims. The patent's specification and figures appear to depict a traditional, computer-style folder hierarchy, raising the question of whether more flexible, non-traditional data structures fall within the claim scope ('323 Patent, Fig. 1).
• Technical Questions: The infringement analysis will likely depend on the specific causal mechanism for visual updates in the accused products. A key question is whether the evidence shows that an "attribute of the parent folder" is changed because "the attribute of the child folder changes," as required by the final limitation of claim 1. This "cascading" cause-and-effect relationship must be demonstrated, as distinct from a system where a parent element independently calculates its status based on an aggregation of data from its children.

V. Key Claim Terms for Construction

The Term: "parent folder" / "child folder"

• Context and Importance: These terms define the fundamental hierarchical structure required by the claims. The outcome of the case may depend on whether the accused product's organizational elements (e.g., pages within pages, items in a database) are construed as meeting this "folder" structure.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification refers generally to "categorical containers" and a "hierarchical cal list of items," which could support an argument that the terms are not limited to a literal file-system folder but cover any form of nested data organization ('323 Patent, col. 1:49, col. 3:19-20).
  • Evidence for a Narrower Interpretation: The patent repeatedly references a "tree view control" and includes figures that exclusively depict a classic user interface with folder icons arranged in a tree, visually analogous to a computer's file explorer ('323 Patent, Fig. 1; col. 3:18, 27). This could support a narrower construction tied to this specific type of GUI element.

The Term: "changing an attribute of the parent folder when the attribute of the child folder changes"

• Context and Importance: This limitation recites the core inventive concept of a cascading visual alert. Practitioners may focus on this term because infringement depends on proving this specific, sequential cause-and-effect relationship.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "attribute" is broad and could encompass any visual change, such as color, text, or an icon, that reflects the child's status. The claim language does not specify the mechanism, only the result.
  • Evidence for a Narrower Interpretation: The specification describes a specific implementation where the "tree view control sends notification messages to the parent folder when events occur within the child folder," causing the parent's icon to change "correspondingly" ('323 Patent, col. 3:27-30; col. 4:62-65). This may suggest the change must be a direct, event-driven reaction to a change in the child object itself, rather than a more indirect reflection of the child's state.

VI. Other Allegations

• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. However, in the prayer for relief, Plaintiff requests a judgment that the case be declared "exceptional within the meaning of 35 U.S.C. § 285" and an award of attorneys' fees (Compl., Prayer for Relief ¶E.i). The complaint does not plead any specific facts, such as allegations of pre-suit knowledge of the patent, to support this request.

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

1. A central issue will be one of definitional scope: can the terms "parent folder" and "child folder", which are described in the patent in the context of a traditional "tree view," be construed to read on the potentially more flexible and database-driven organizational structures of modern productivity software?
2. A key evidentiary question will be one of causation: does the accused product operate via the specific "cascading" alert mechanism claimed—where a change in a child element causes a corresponding change in the parent element—or does it achieve a similar visual result through a different technical means, such as a parent-level summary or aggregation?
3. A threshold procedural question may be pleading sufficiency: given the complaint’s failure to identify specific accused products or provide the referenced claim chart exhibits, the court may need to address whether the allegations, as filed, meet the plausibility standard required to proceed to discovery.