TG 2006 Holdings LLC v. Spreadsheetcom Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TG--2006 Holdings, LLC (Texas)
  • Defendant: Spreadsheet.com Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00309, D. Del., 03/12/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant has an established place of business in the district, has committed acts of infringement there, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s software products infringe a patent related to systems and methods for visually tracking information in a business environment using a hierarchical, event-driven interface.
• Technical Context: The technology at issue involves using a hierarchical tree-view, common in computer file systems, to provide visual status alerts for business tasks, where the status of a parent item automatically reflects the status of its underlying child items.
• Key Procedural History: The asserted patent is part of a family tracing its priority back to an application filed in 2004. The patent is also subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier patent in the family.

Case Timeline

Date	Event
2004-08-13	Earliest Priority Date ('323 Patent Family)
2016-09-27	'323 Patent Application Filing Date
2017-10-31	'323 Patent Issue Date
2025-03-12	Complaint Filing Date

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 addresses the problem that tracking business information can be "time consuming and confusing," and that a method for displaying such information in a "visually clear and meaningful way is desired." ('323 Patent, col. 1:19-25).
• The Patented Solution: The invention provides a system that uses a "typical hierarchical folder tree view" to give "visual indications of the progress or status" of business tasks. ('323 Patent, col. 1:29-34). Parent folders in the tree view have visual attributes (e.g., color) that automatically change in response to events occurring in the documents or sub-folders contained within them, such as a task exceeding a user-defined time limit. ('323 Patent, col. 3:52-65). This creates a cascading alert system where a high-level folder can turn red to indicate a problem with a low-level task, allowing a user to quickly identify issues without inspecting every item. ('323 Patent, col. 4:1-8).
• Technical Importance: The described system offers a method to manage complex projects by translating the status of numerous, discrete tasks into a simple, high-level visual indicator within a familiar user interface paradigm. ('323 Patent, col. 3:17-23).

Key Claims at a Glance

• The complaint asserts infringement of "exemplary method claims" without specifying claim numbers (Compl. ¶¶ 11-12). Independent claims 1 and 8 are the only independent method claims.
• Independent Claim 1 recites a method with 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 refers broadly to "one or more claims." (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" but does not name specific products or services offered by Defendant Spreadsheet.com Inc. (Compl. ¶11).

Functionality and Market Context

The complaint does not describe the functionality of the accused products. It alleges that the products "practice the technology claimed by the '323 Patent" and that infringement is detailed in claim charts provided as Exhibit 2. (Compl. ¶13). Exhibit 2 was not attached to the publicly filed complaint. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's products directly infringe the '323 Patent by practicing its claimed methods (Compl. ¶¶ 11, 13). However, the complaint itself contains no specific, element-by-element comparison of any accused product to the patent claims. It instead incorporates by reference "charts comparing the Exemplary '323 Patent Claims to the Exemplary Defendant Products" in an unprovided Exhibit 2 (Compl. ¶13). The narrative theory of infringement is that these unidentified products perform a method that satisfies all elements of the asserted claims.

Identified Points of Contention

• Pleading Sufficiency: A primary issue may be whether the complaint's allegations, which defer all technical specifics of infringement to an external, unprovided exhibit, meet the plausibility pleading standards established by Federal Circuit case law applying Twombly and Iqbal.
• Technical Questions: The central technical question will be whether the accused software, presumably a spreadsheet or project management tool, performs the specific method steps of the asserted claims. For example, does the accused software "change an attribute of a parent folder" as a direct and automatic consequence of an attribute change in an associated "child folder," or does its functionality (e.g., conditional formatting) operate on a different logical basis?

V. Key Claim Terms for Construction

The Term: "parent folder" / "child folder" (from Claim 1)

• Context and Importance: These terms are foundational to the patent's hierarchical structure. The infringement analysis will depend on whether these terms, which are described in the patent in the context of a graphical user interface resembling a file system, can be construed to cover logical relationships in a different environment, such as nested rows or summary cells in a spreadsheet. Practitioners may focus on this term because its scope determines whether the patent can read beyond the specific GUI embodiments shown.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's title and background refer generally to tracking information in a "business environment," not just a specific file-management application, which could support a broader construction covering any logical parent-child data relationship. ('323 Patent, Title; col. 1:16-18).
  • Evidence for a Narrower Interpretation: The specification consistently uses the term in the context of a "hierarchical folder tree view," and the figures depict icons that are visually identifiable as folders. ('323 Patent, col. 1:32-33; Fig. 1, element 2). The detailed description explains that the "tree view control is manifested as child folders within a parent folder," language which may be argued to limit the terms to their conventional meaning in graphical user interfaces. ('323 Patent, col. 3:25-27).

The Term: "changing an attribute of the parent folder when the attribute of the child folder changes" (from Claim 1)

• Context and Importance: This limitation defines the core inventive concept of a cascading visual alert. The dispute will likely focus on whether the accused functionality performs this specific, sequential, and causal operation, or if any change in a "parent" element that happens to coincide with a change in a "child" element is sufficient.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 itself does not specify the mechanism of the change, only the condition for it. An interpreter could argue that any system where a parent-level indicator (e.g., a summary cell) updates based on child-level data (e.g., individual task cells) meets this limitation.
  • Evidence for a Narrower Interpretation: The specification describes this as a notification-based system where "the tree view control sends notification messages to the parent folder when events occur within the child folder," causing the parent's visual representation to change. ('323 Patent, col. 3:27-30). This suggests a specific cause-and-effect mechanism, not merely a recalculation. Furthermore, the patent explains that "when a child folder has an IHP that has triggered its user-defined time rule, the parent's icon changes color," directly linking the parent's attribute change to the child's event. ('323 Patent, col. 3:62-65).

VI. Other Allegations

Willful Infringement

The complaint does not explicitly allege "willful infringement." However, in the prayer for relief, it requests that the case be "declared exceptional within the meaning of 35 U.S.C. § 285" and seeks an award of attorneys' fees. (Compl. ¶ E(i)). The complaint does not allege any facts regarding pre-suit or post-suit knowledge by the Defendant.

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

• A central issue will be one of definitional scope: Can the claim terms "parent folder" and "child folder," which are described and depicted in the patent as elements of a specific file-system-like GUI, be construed broadly enough to read on the logical data structures within Defendant’s accused spreadsheet or project management software?
• A key procedural and evidentiary question will be whether the complaint's complete reliance on an unprovided exhibit for all factual allegations of infringement is sufficient to state a plausible claim for relief, or if it will be found deficient at the pleading stage.
• The case will also turn on a question of functional operation: Does the accused software perform the specific, two-step cascading notification method recited in the claims (i.e., a child's attribute changes, which causes the parent's attribute to change), or is the visual updating in the accused product achieved through a different, non-infringing technical mechanism?