DCT

1:25-cv-00914

DataCloud Tech LLC v. Staples Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00914, D. Del., 10/14/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation that conducts substantial business in the state, including offering for sale and selling the accused products and services.
  • Core Dispute: Plaintiff alleges that Defendant’s Staples Advantage Mobile App and its public website infrastructure infringe three patents related to data organization, anonymous network communication, and remote file access and management.
  • Technical Context: The asserted patents relate to foundational internet-era technologies for managing digital information, ensuring user privacy online, and providing remote control over data, which are relevant to modern e-commerce platforms and mobile applications.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the asserted patents through a series of letters and emails beginning on December 15, 2022, nearly three years prior to the filing of the complaint.

Case Timeline

Date Event
2000-01-28 U.S. Patent No. 6,651,063 Priority Date
2000-04-04 U.S. Patent No. 7,209,959 Priority Date
2002-03-29 U.S. Patent No. 7,398,298 Priority Date
2003-11-18 U.S. Patent No. 6,651,063 Issued
2004-02-03 U.S. Patent No. 6,651,063 Certificate of Correction Issued
2007-04-24 U.S. Patent No. 7,209,959 Issued
2008-07-08 U.S. Patent No. 7,398,298 Issued
2022-12-15 Plaintiff sent initial notice letter to Defendant
2025-10-14 Complaint Filed

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

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’s background section describes a society “inundated with information” in both physical and electronic forms, where individuals lack a “reliable, easy-to-use, centralized information storage system.” Existing methods were described as “cumbersome, decentralized and otherwise inefficient,” requiring users to manually create categories and organize information themselves (Compl. ¶¶ 21-22; ’063 Patent, col. 1:42-60).
  • The Patented Solution: The invention proposes a system where the “provider” of information (e.g., a seller) attaches identifiers for the provider and a generic category to an “Information Pack.” This pack is sent to a recipient’s unique “User Destination Address” and is automatically filed into a corresponding location within the recipient’s “User Data Repository.” This shifts the organizational burden from the recipient to the provider, while still allowing the recipient to create custom categories, block providers, or forward the information (Compl. ¶¶ 23, 28; ’063 Patent, col. 2:37-53). A schematic diagram from the '063 patent shows a system architecture where a “Provider” sends an “Information Pack” to a “Recipient's” “User Data Repository” (Compl. ¶24).
  • Technical Importance: The invention describes a method to streamline the management of digital records for consumers and businesses by making the categorization of information an automated function initiated by the information’s source (Compl. ¶23).

Key Claims at a Glance

  • The complaint focuses on independent claim 4 (Compl. ¶39).
  • Essential elements of 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;
    • locating the pack in a repository location corresponding to the category identifier;
    • creating a custom location in the repository and placing the pack there;
    • associating a custom category identifier with the pack; and
    • sending a custom category signal to a processing station, which uses the provider identifier to place subsequent packs from that provider into the custom location.
  • The complaint notes that its arguments also apply to the other four independent claims in the patent (Compl. ¶39).

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

The Invention Explained

  • Problem Addressed: The patent describes how standard internet protocols like HTTP can expose a user’s identity and activities, creating privacy threats such as tracking and unwanted solicitations. Existing privacy tools like proxy servers are described as flawed because they merely substitute one identity for another, which can still be traced back to the same client (Compl. ¶¶ 65, 67; ’959 Patent, col. 1:57–col. 2:7).
  • The Patented Solution: The patent discloses a system termed “DNS Misdirection” that uses three distinct algorithmic components: a “deceiver,” a “controller,” and a “forwarder.” A client’s request is intercepted by the deceiver and passed to the controller, which resolves the destination IP address and establishes a session with a forwarder. The controller then provides the forwarder's IP address back to the client, deceiving the client into communicating with the forwarder as if it were the final destination. This architecture is designed to ensure that neither the client nor the destination server is aware of the other’s true IP address, creating a virtual and anonymous communication channel (Compl. ¶¶ 69, 73, 77; ’959 Patent, Abstract). Figure 1 from the '959 patent illustrates the 'DNS Misdirection' architecture, showing communication flow between a 'Client,' 'Deceiver,' 'Controller,' 'Forwarder,' and 'Website Server' (Compl. ¶70).
  • Technical Importance: The invention provides a specific, multi-component architecture for anonymizing network communications that isolates the client from the destination server more completely than a standard proxy (Compl. ¶80).

Key Claims at a Glance

  • The complaint focuses on independent claim 1 (Compl. ¶83).
  • Essential elements of claim 1 include:
    • setting up a forwarding session employing a forwarder between a client and a destination server;
    • implementing the session such that neither the client or the destination server is aware of the forwarder’s employment;
    • employing a controller to communicate with the forwarder and a domain name server to resolve the website name;
    • employing a deceiver to receive the client’s request and initiate the controller to query the domain name server; and
    • initiating the forwarding session in response to the controller receiving the answer from the domain name server.
  • The complaint also explicitly references and reproduces several dependent claims (2, 4-6, 9-15) and discusses independent claim 16 (Compl. ¶¶ 83-84).

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

Technology Synopsis

The patent addresses shortcomings in then-existing remote access systems, where users allegedly lacked the ability to manage remote data directory structures or receive confirmation that data had been successfully delivered (Compl. ¶¶ 106-108). The patented solution is a system that gives users remote control over data storage management, including directory structures, and provides notifications upon the delivery of data to intended targets (Compl. ¶109). The complaint includes a figure from the patent showing an exemplary system for remote data access, connecting various devices over a network to a web server hosting the application (Compl. ¶111, referencing '298 Patent, Fig. 5 at p. 42).

Asserted Claims

The complaint focuses its infringement analysis on independent claim 13 (Compl. ¶118).

Accused Features

The complaint alleges that the Staples Advantage app infringes by offering remote management capabilities that allow administrators to control user access and permissions, manage user profiles and data directories, and receive instant notifications of account activity (Compl. ¶129).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses the Staples Advantage Mobile App of infringing the ’063 and ’298 patents and Staples’ website infrastructure (www.staples.com) of infringing the ’959 patent (Compl. ¶¶ 50, 93, 128).

Functionality and Market Context

  • The Staples Advantage Mobile App is described as an application distributed as an APK file that is downloaded and placed in a custom directory on a user’s device. It is alleged to provide remote management capabilities, allowing administrators to control user access and permissions, manage user profiles in real-time, and receive notifications about account activity (Compl. ¶¶ 51, 129).
  • The Staples website infrastructure is the system that hosts www.staples.com. It is alleged to establish a direct TCP connection with a user’s device and to use a domain name server to resolve requests for various subdomains that may share the same public IP address. The complaint alleges this infrastructure operates in a way that makes an intermediary appear to be the source of data sent to the user (Compl. ¶94).

IV. Analysis of Infringement Allegations

'063 Patent Infringement Allegations

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint Citation Patent Citation
storing information to be provided in an information pack The Staples Advantage Mobile App is stored as an APK file, which is alleged to be the "information pack." ¶51 col. 6:26-34
associating with said information pack at least a user destination address ... and a category identifier The APK file is associated with a user’s IP address (the "user destination address"). The "category identifier" is not explicitly mapped. ¶51 col. 6:23-25
associating with said information pack a provider identifier The APK certificate, containing "Staples Inc" as the organization, is alleged to be the "provider identifier." ¶51 col. 6:29-32
communicating said information pack by means of a network to said user data repository The APK file is downloaded over a network to the user's device (the "user data repository"). ¶51 col. 6:54-59
locating said information pack in a location of said user data repository ... reserved for information corresponding to a category The APK file is located in a user data repository. ¶51 col. 7:1-8
creating a custom location in said user data repository; placing said information pack in said custom location Staples creates a custom directory (e.g., in the "data" folder) for the app and places subdirectories for the APK there. ¶51 col. 9:12-27
associating a custom category identifier with said information pack The digital signature or modulus of the APK is alleged to be the "custom category identifier." ¶51 col. 9:28-32
sending a custom category signal to a processing station ... placing said one of the subsequent information packs in said custom location Updating the app is alleged to be an example of "sending a custom category signal." ¶51 col. 9:42-54
  • Identified Points of Contention:
    • Scope Questions: A central dispute may be whether the term "information pack", which the patent exemplifies with product manuals and warranty information, can be construed to read on an executable software file like an Android Application Package (APK).
    • Technical Questions: The complaint alleges that technical artifacts of a mobile app's installation and update process correspond to specific claim elements. This raises questions such as: What evidence demonstrates that an app "update" functions as the claimed "custom category signal" sent to a "processing station" for the purpose of automatically routing subsequent packs? Does an APK’s digital signature perform the claimed function of a "custom category identifier" for data routing, or does it primarily serve a security function?

'959 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
setting up a forwarding session ... employing a forwarder disposed between the client and the destination server The complaint does not identify a specific component as the "forwarder" but alleges the overall session is a forwarding session. ¶94 col. 4:20-24
wherein the forwarding session is set up and implemented such that neither the client or the destination server is aware of the employment of the forwarder The complaint alleges a direct TCP connection exists, and from this infers that neither party is aware of an intermediary. ¶94 col. 4:46-52
employing a controller configured to communicate with the forwarder and a domain name server The system queries a domain name server to resolve subdomain names (e.g., www002.staples.com) to an IP address. ¶94 col. 4:14-18
employing a deceiver configured to communicate with the controller and the client, wherein the deceiver receives the request by the client Staples' website infrastructure receives the user's request and later sends data back in a manner that allegedly makes the intermediary appear to be the source. ¶94 col. 3:46-48
in response to the controller receiving the answer from the domain name server ... initiating a forwarding session After the DNS query is resolved, the system establishes the connection. ¶94 col. 4:18-24
  • Identified Points of Contention:
    • Scope Questions: Does standard web server architecture, which resolves DNS requests for subdomains and serves content, constitute the specific three-part "deceiver, controller, and forwarder" system required by the claim?
    • Technical Questions: What evidence does the complaint provide that the client is actively "deceived" into thinking an intermediary is the destination server, as opposed to simply communicating with the public-facing IP address of the web service? The complaint alleges this occurs but does not specify the mechanism.

V. Key Claim Terms for Construction

'063 Patent

  • The Term: "information pack"
  • Context and Importance: The plaintiff's entire infringement theory regarding the Staples Advantage Mobile App rests on construing an Android Application Package (APK) file as an "information pack". The definition of this term is therefore dispositive for this part of the case.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes an Information Pack as containing "Static Information" and/or "Dynamic Information," a "Provider Identifier," and a "Category Identifier" (Compl. ¶26; ’063 Patent, col. 6:26-34). This functional definition could be argued to encompass any digital data bundle with associated metadata.
    • Evidence for a Narrower Interpretation: The patent’s detailed examples describe "information packs" containing user-facing content like prescription drug information, car manuals, warranties, and product details from a trade show (Compl. ¶¶ 24-38; ’063 Patent, Figs. 2, 4-5). This may support an interpretation limited to informational documents rather than executable software.

'959 Patent

  • The Term: "deceiver"
  • Context and Importance: The "deceiver" is a specific, named component of the claimed three-part system for anonymization. To prove infringement, the plaintiff must demonstrate that the accused Staples website infrastructure contains a component that performs the functions of the claimed "deceiver". Practitioners may focus on this term because its existence is a prerequisite for the rest of the claimed method.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states the "deceiver" "provides name resolution for clients" and "works the same as a standard name server, except when a query is received from a client, the deceiver allows the controller to supply the information" (Compl. ¶73; ’959 Patent, col. 2:37-40). This functional language could be argued to apply to any front-end component that handles initial requests.
    • Evidence for a Narrower Interpretation: The patent’s architecture diagram (Figure 1) depicts the "deceiver" (104) as a distinct element that sits between the client (101) and the controller (106) and transparently processes packets sent from the client (Compl. ¶70; ’959 Patent, col. 3:46-55). This may support a narrower construction requiring a specific network component designed to intercept and reroute traffic in the claimed manner.

VI. Other Allegations

  • Indirect Infringement: The complaint makes a general allegation of inducement and contributory infringement but does not plead specific facts to support these theories, such as identifying instructions given to third parties to perform infringing acts (Compl. ¶9). The infringement counts focus on Defendant’s direct performance of the claimed methods.
  • Willful Infringement: The complaint alleges that Defendant had pre-suit knowledge of the asserted patents and its infringement based on a series of eight communications (a letter and seven follow-up emails) sent by Plaintiff to Defendant's Chief Legal Counsel, beginning on December 15, 2022 (Compl. ¶13).

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

  • A core issue will be one of definitional scope and analogy: Can the claim terms of the ’063 patent, such as "information pack" and "custom category signal", which are rooted in the context of organizing user documents, be construed to cover the technical functions of installing and updating a mobile software application (APK)?
  • A key evidentiary question will be one of architectural correspondence: Does the accused Staples website infrastructure implement the specific, three-component "deceiver, controller, forwarder" architecture for anonymization as claimed in the ’959 patent, or is there a fundamental mismatch between its standard web-serving operations and the claimed method?
  • The case may also turn on a question of functional mapping: Do the administrative features of the Staples Advantage app, which manage user profiles and permissions, perform the specific steps of the '298 patent's claims for providing "remote management control of data directory structures," including the selection and modification of a "single directory structure"?