TG 2006 Holdings LLC v. Opendrives Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TG--2006 Holdings, LLC (Texas)
  • Defendant: OpenDrives, Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00300, D. Del., 03/11/2025
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant has an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s data management and storage products infringe a patent related to a system for visually tracking business information using a hierarchical folder-based user interface.
• Technical Context: The technology concerns user interfaces for managing complex workflows, where the visual appearance of container elements like folders automatically changes to reflect the status of the tasks or documents they contain.
• Key Procedural History: The complaint does not reference any prior litigation involving the patent-in-suit, any post-grant proceedings before the U.S. Patent and Trademark Office, or any known licensing history.

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," issued November 12, 2013

The Invention Explained

• Problem Addressed: The patent addresses the problem that tracking business information can be "time consuming and confusing," and that if information is not displayed in a "visually clear and meaningful way," the tracking system defeats its own purpose ( Compl. ¶9; ’514 Patent, col. 1:12-21).
• The Patented Solution: The invention proposes a computer-implemented system that uses a familiar hierarchical "folder tree view" to manage business processes. The core innovation is that parent folders are programmed to change their visual attributes (e.g., color, icon) in response to the status of "child elements" (documents or other folders) they contain, particularly when time-based triggers or deadlines associated with those elements are met (’514 Patent, Abstract; col. 1:24-34). This system is described as "child driven," where an event occurring within a child folder sends a notification that can alter the appearance of its parent folder, providing an at-a-glance status update (’514 Patent, col. 3:20-23).
• Technical Importance: This method provides a centralized, visual dashboard for managing complex, time-sensitive operations such as manufacturing, sales, and inventory by translating the status of individual tasks into an easily digestible visual cue at a higher level in the organizational hierarchy (’514 Patent, col. 1:35-41).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying them (Compl. ¶11). Independent claim 1 is a representative method claim.
• Independent Claim 1 requires:
  • A method for tracking and displaying operational parameters on a computer.
  • Establishing a parent folder to contain other items.
  • 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.
  • "Changing an attribute" of the parent folder based on the state of the child element when the time trigger is met.
• The complaint notes that the asserted claims are identified in an attached exhibit and reserves the right to assert other claims (Compl. ¶11, ¶16).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶11). Specific product names are not provided in the body of the complaint.

Functionality and Market Context

• The complaint alleges that these products practice the technology claimed by the ’514 Patent but does not describe their specific functionality, instead incorporating by reference claim charts in "Exhibit 2" (Compl. ¶16). The complaint does not provide sufficient detail for analysis of the accused products' specific functions or market positioning.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" directly infringe the ’514 Patent and that a detailed comparison is provided in claim charts attached as Exhibit 2 (Compl. ¶16-17). However, Exhibit 2 was not filed with the public version of the complaint. Therefore, a claim chart summary cannot be constructed.

The narrative infringement theory is that the accused products, when used as intended, satisfy all elements of the asserted claims (Compl. ¶16). The complaint further alleges that Defendant's "product literature and website materials" demonstrate how end users are directed to use the products in a manner that infringes the patent (Compl. ¶14). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: The patent specification repeatedly frames the invention in the context of a "business environment," citing examples like production lines, sales invoices, and inventory management (’514 Patent, col. 1:12-21, 1:35-41). A potential dispute may arise over whether the claims should be limited to such specific business management applications or can be read more broadly to cover general-purpose data storage or file systems that may display status information (e.g., modification dates, file sizes).
  • Technical Questions: A central technical question will be whether the accused products perform the specific function of "changing an attribute of the parent folder" because a time trigger associated with a "child element" has been met, as required by claim 1. The court may need to determine if a general UI feature, such as updating a folder's "last modified" date, satisfies this limitation, or if the claim requires a more specific, pre-programmed status-change mechanism (e.g., changing a folder icon from green to red).

V. Key Claim Terms for Construction

• The Term: "changing an attribute of the parent folder"

  • Context and Importance: This term defines the primary output and visual feedback mechanism of the invention. Its construction will be critical for determining whether the functionality of the accused products falls within the scope of the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the alert as comprising "a change in the color, size, animation, or other visual attribute of the folder" and notes it "may also include audible and textual information" (’514 Patent, col. 4:51-54). This language could support a broad definition of "attribute" that includes any perceivable change.
    • Evidence for a Narrower Interpretation: The patent’s figures and embodiments consistently depict attributes that represent a specific, pre-defined status, such as a red folder for a task that is behind schedule or distinct icons for "New," "In Progress," and "Completed" tasks (’514 Patent, Fig. 3a; col. 5:46-50). This may support an interpretation where the "attribute" must be a change that directly communicates a specific business status, rather than a generic data update.

• The Term: "correlating the child element with a time critical task"

  • Context and Importance: This term describes the necessary link between a data object (the "child element") and a real-world, time-sensitive activity. The nature of this "correlation" will be a key point in the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is general and does not specify the method of correlation. This could suggest that any form of data link between a file and a deadline, such as embedded metadata or a database entry, would suffice.
    • Evidence for a Narrower Interpretation: The specification provides context for this correlation within specific "business enterprise" activities, such as "production," "sales and shipping," "labor consumption," and "purchasing of inventory" (’514 Patent, col. 1:35-41). Parties may argue that a valid "correlation" must exist within a structured system designed for managing such business operations, not merely a generic file with an associated calendar alert.

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 a manner that infringes the ’514 Patent (Compl. ¶14). Knowledge and intent are alleged to exist at least from the time of the complaint's service (Compl. ¶15).
• Willful Infringement: The complaint alleges that its service, along with the attached claim charts, provided Defendant with "actual knowledge" of infringement (Compl. ¶13). It further alleges that Defendant's continued infringing activities despite this knowledge are willful (Compl. ¶14).

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

• A core issue will be one of definitional scope: can the claim term "correlating the child element with a time critical task," which is described in the patent within the specific context of manufacturing and business workflows, be construed to cover the features of a general-purpose data management system?
• A key evidentiary question will be one of functional causality: what evidence will be presented to show that the accused products implement the "child driven" mechanism recited in the claims, where a status change in a "child element" directly causes a change in a "parent folder’s" visual attribute, as opposed to the system merely displaying independent status indicators for different items in a UI?
• The outcome may also hinge on claim construction: how broadly will the court interpret the term "attribute"? Will any visual change to a folder suffice for infringement, or must the change convey a specific, pre-defined business status as depicted in the patent's preferred embodiments?