DataCloud Tech LLC v. Teradata Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DataCloud Technologies, LLC (Georgia)
  • Defendant: Teradata Corporation (Delaware)
  • Plaintiff’s Counsel: STAMOULIS & WEINBLATT LLC; Rozier Hardt McDonough PLLC
• Case Identification: 1:25-cv-00559, D. Del., 05/06/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation and conducts substantial business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s cloud platform, website infrastructure, mobile application, and database security products infringe four patents related to file system management, categorized data delivery, anonymous network communication, and remote data access.
• Technical Context: The patents address foundational technologies in operating systems, network management, and data organization developed in the early 2000s, concepts that are central to the operation of modern cloud computing and data analytics platforms.
• Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the patents since at least December 15, 2020, through a letter and numerous follow-up communications. Additionally, U.S. Patent No. 6,560,613 was the subject of an Inter Partes Review (IPR2021-00361), which resulted in the cancellation of claims 1, 2, 5, 7, 14, and 17. The asserted claim in this litigation, claim 11, was not cancelled in that proceeding.

Case Timeline

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

U.S. Patent No. 6,560,613 - "Disambiguating File Descriptors," issued May 6, 2003

The Invention Explained

• Problem Addressed: The patent addresses the problem in certain operating systems where the same system calls are used to access both files stored on physical media (e.g., a hard disk) and communication channels (e.g., a network socket), making it difficult to apply different security or access rules to these distinct resource types (’613 Patent, col. 2:26-41).
• The Patented Solution: The invention proposes a method of intercepting system calls using a "system call wrapper" to maintain an "indicator table." This table stores an indicator that flags what type of resource a given file descriptor is associated with (e.g., file vs. communication channel), allowing a process to check the table and selectively permit or deny operations based on the resource type ('613 Patent, Abstract; Fig. 3, elements 111, 127).
• Technical Importance: This approach enables more granular and flexible security policies within an operating system, a critical function for servers managing remote user processes ('613 Patent, col. 2:15-24).

Key Claims at a Glance

• The complaint asserts independent claim 11 (Compl. ¶22).
• The essential elements of method claim 11 are:
  • intercepting system calls that establish a file stored on media;
  • intercepting system calls that create a copy of at least one file descriptor;
  • storing at least one indicator that a file descriptor established by an intercepted system call is associated with a file stored on media;
  • storing at least one indicator concerning a created copy of a file descriptor; and
  • examining at least one stored indicator to determine with what file type a file descriptor is associated.
• The complaint does not explicitly reserve the right to assert dependent claims.

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 describes the difficulty for users to organize the large volume of information they receive, such as product manuals and warranties, which often arrive in decentralized, non-digital formats (’063 Patent, col. 1:15-39).
• The Patented Solution: The invention provides a system where a "provider" sends an "information pack" containing categorized data to a user's "User Data Repository." The user can accept the information into a pre-defined category or create a "custom location." This custom categorization can then be communicated back to a central processing station, which ensures that future information from the same provider is automatically routed to the user's preferred custom location ('063 Patent, Abstract; Fig. 1).
• Technical Importance: The system automates the "filing" of digital information for a user and creates a feedback mechanism for personalized data organization, reducing manual effort ('063 Patent, col. 2:5-15).

Key Claims at a Glance

• The complaint asserts independent claim 4 (Compl. ¶33).
• The essential elements of method claim 4 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" and placing it in a location corresponding to its category;
  • creating a "custom location" within the repository, placing the pack there, and associating it with a "custom category identifier"; and
  • sending a "custom category signal" to a processing station that analyzes subsequent information packs from the same provider and automatically places them in the user's custom location.
• The complaint does not explicitly reserve the right to assert dependent claims.

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

Technology Synopsis

The patent discloses a system for enabling anonymous network activity. The architecture uses a "deceiver," a "controller," and a "forwarder" to create a temporary, ad hoc virtual session where the client's IP address is masked from the destination server, and the server's true address is masked from the client (’959 Patent, Abstract; col. 2:35-51).

Asserted Claims

Independent claim 1 is asserted (Compl. ¶44).

Accused Features

The complaint accuses Teradata's website infrastructure ("www.teradata.com") of infringement. It alleges the infrastructure functions as the claimed "forwarder" to create an appearance of a direct connection between a user and the web server, while actually anonymizing the communication path (Compl. ¶45).

U.S. Patent No. 7,398,298 - "Remote Access And Retrieval Of Electronic Files," issued July 8, 2008

Technology Synopsis

The patent describes a system for remote management of data and directory structures on a server. A computing application processes user requests for remote control, queries a "profile data store" to verify access permissions, delivers the requested data or control, and sends a notification confirming delivery (’298 Patent, Abstract; col. 2:38-56).

Asserted Claims

Independent claim 13 is asserted (Compl. ¶55).

Accused Features

The complaint accuses Teradata's "DataSunrise Database Firewall" product. It alleges that the firewall's functionality—enforcing access control via DBA-defined rules, user groups, and ML-powered log analysis—performs the claimed method of managing remote access to data directory structures based on a profile store (Compl. ¶56).

III. The Accused Instrumentality

Product Identification

The complaint accuses multiple Teradata products and services:

1. Teradata's cloud platform, specifically its use of KVM and QEMU virtualization (for the ’613 patent) (Compl. ¶23).
2. The "Teradata Corporation Events mobile app" and its download/update process (for the ’063 patent) (Compl. ¶34).
3. The "Teradata's website infrastructure (www.teradata.com)" (for the ’959 patent) (Compl. ¶45).
4. The "DataSunrise Database Firewall" product (for the ’298 patent) (Compl. ¶56).

Functionality and Market Context

• The accused instrumentalities represent core components of Teradata's enterprise data analytics and cloud offerings. The complaint alleges that the virtualization infrastructure creates ambiguity in file descriptors (Compl. ¶23); that the mobile app installation process mirrors the claimed data organization method (Compl. ¶34); that the website infrastructure anonymizes traffic (Compl. ¶45); and that the database firewall controls remote data access through user-based rules (Compl. ¶56). The complaint does not contain specific allegations regarding the products' market positioning beyond their general use by Teradata. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits A-D) that are not provided; the following tables summarize the narrative infringement theories.

’613 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Question: The complaint provides a high-level allegation but lacks specific evidence of how Teradata's KVM/QEMU implementation performs the claimed steps. A central question will be whether discovery reveals a mechanism analogous to the patent's "system call wrapper" and "indicator table," or if Teradata uses an entirely different technique to manage host/guest file descriptors.
  • Scope Questions: Does the "ambiguity in file descriptors due to similar values for both host and guest" (Compl. ¶23) constitute the same technical problem of disambiguating between files-on-media and communication channels as described in the ’613 patent?

’063 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The infringement theory maps the highly specific, multi-party data organization system of the patent onto the generic, industry-standard process of downloading and updating an iOS application. A key dispute will be whether a standard app IPA file can be considered a claimed "information pack" and whether an OS-created app directory can be considered a user-defined "custom location" that triggers a feedback loop.
  • Technical Questions: What evidence does the complaint provide that "updating the app" functions as a "custom category signal" that causes a "processing station" to analyze a "provider identifier" for automated routing of subsequent updates, as claimed? This appears to be a significant departure from how standard mobile app updates are managed by platforms like Apple's App Store.

V. Key Claim Terms for Construction

Analysis of Terms in the ’613 Patent

• The Term: "indicator"
• Context and Importance: This term is the core of the invention. The infringement claim hinges on whether Teradata's system "stor[es] at least one indicator" to track file descriptor types. Practitioners may focus on this term because its definition will determine whether any metadata Teradata uses to manage virtualization can be equated with the specific "indicator" taught in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the indicators generally as being "stored" and "examined" to "determine the associated file type" ('613 Patent, col. 4:3-7). This could support a broad reading on any flag, bit, or data entry used for this purpose.
  • Evidence for a Narrower Interpretation: The patent consistently describes the indicators as being stored in a specific "indicator table" (127) that is maintained by a "system call wrapper" (111) ('613 Patent, Fig. 3; col. 7:35-39). This context suggests the "indicator" is not just any metadata, but a specific component of the claimed intercept-and-log architecture.

Analysis of Terms in the ’063 Patent

• The Term: "custom location"
• Context and Importance: The patent's feedback loop, a key inventive concept, is triggered by the user placing an "information pack" into a "custom location." The complaint alleges an app's default installation directory is a "custom location" (Compl. ¶34). The case may turn on whether this standard OS function meets the claim's requirements.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language states "creating a custom location in said user data repository; placing said information pack in said custom location" without explicitly requiring the user to perform the creation ('063 Patent, col. 23:49-51).
  • Evidence for a Narrower Interpretation: The summary of the invention and detailed description frame this as a user-driven choice to re-organize information, which is then fed back to the provider or system ('063 Patent, col. 4:8-12, col. 9:20-28). This implies an act of user preference, not an automated, default action by an operating system, which may support a narrower construction requiring active user input to define the location.

VI. Other Allegations

• Indirect Infringement: The complaint includes general allegations of inducement and contributory infringement but does not provide specific facts to support the knowledge and intent elements beyond those alleged for direct infringement (Compl. ¶10).
• Willful Infringement: The complaint alleges a specific, years-long history of notice, beginning with a letter to Teradata's Chief Legal Officer on December 15, 2020, followed by at least eight subsequent follow-up communications (Compl. ¶14). These allegations, if proven, may support a finding of pre-suit and ongoing willful infringement.

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

• A central issue will be one of definitional scope: can the specific, and often elaborate, system architectures described in these patents from the early 2000s be construed to cover modern, industry-standard computing functions? For example, does the standard process of an iOS app creating its own directory upon installation constitute the claimed user-driven "custom location" and feedback system of the '063 patent?
• A key evidentiary question will be one of functional equivalence: the complaint makes high-level, conclusory allegations of infringement. The case will likely depend on whether Plaintiff can produce technical evidence that Teradata's products operate in the specific manner required by the claims (e.g., using an "indicator table" to track file types or a "custom category signal" to route app updates), or if there is a fundamental mismatch in technical operation.
• For the '613 patent, a significant question will be the impact of the prior IPR proceeding. While the asserted claim survived, the arguments and prior art that invalidated related claims may provide Defendant with a roadmap for a narrow construction of claim terms or a defense of invalidity based on similar grounds.