DCT

1:25-cv-00992

Accelor Corp v. Mayo Foundation for Medical Education Research

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00992, D. Del., 10/21/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant HIRC is a Delaware corporation and has allegedly committed acts of infringement in the district. Venue over the other defendants is based on allegations that they acted in concert with HIRC or that HIRC serves as their alter ego.
  • Core Dispute: Plaintiff alleges that Defendants developed and marketed a competing supply chain risk management platform by misappropriating Plaintiff's trade secrets and infringing two patents related to managing partner organizations and cross-organizational supply chains.
  • Technical Context: The technology domain is software-as-a-service (SaaS) platforms for assessing and managing risks across complex, multi-tiered supply chains, a function of significant importance in global industries such as healthcare and electronics.
  • Key Procedural History: The complaint alleges a prior business relationship beginning in 2018, where Plaintiff Accelor provided its supply chain risk management software and proprietary information to Defendant Mayo under various confidentiality, product evaluation, and master service agreements. The complaint asserts that Defendants used this confidential access to develop a competing product.

Case Timeline

Date Event
2007-01-01 Accelor introduces earliest version of its SRS Product
2008-01-23 Earliest Priority Date for ’804 and ’754 Patents
2013-08-20 U.S. Patent No. 8,515,804 Issues
2018-01-01 Accelor expands its SRS Product for the healthcare industry
2018-05-16 Confidentiality Agreement between Accelor and Mayo Foundation
2018-11-30 Product Evaluation Agreement between Accelor and Mayo Foundation
2019-01-25 Master Agreement between Accelor and Mayo Foundation
2019-01-01 HIRC is founded by Mayo Clinic and another entity
2020-12-01 U.S. Patent No. 10,853,754 Issues
2022-03-01 Sponsorship and Collaboration Agreement between Accelor and HIRC
2025-03-01 HIRC Agreement expires
2025-03-01 Accelor learns of Defendants' competing "Vault" product
2025-10-21 Complaint Filing Date

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

U.S. Patent No. 8,515,804 - "System and Method for Managing Partner Organizations"

The Invention Explained

  • Problem Addressed: The patent's background describes the difficulty large organizations face in managing the capabilities (e.g., quality, regulatory compliance, disaster preparedness) of their numerous partners, such as suppliers in a supply chain. Traditional methods focusing only on top-tier partners leave an organization exposed to significant risks from the vast majority of unmanaged, lower-tier partners (’804 Patent, col. 1:33-41).
  • The Patented Solution: The invention proposes a computer-implemented method to systematically manage capabilities across a large number of partner organizations. It achieves this by defining a multi-layered "consumer/producer hierarchy," setting capability objectives for each layer, automatically collecting capability "facts" from partners through questionnaires, identifying gaps between the facts and objectives, and then automating the process of improving and monitoring those capabilities across the entire hierarchy (’804 Patent, Abstract; col. 6:11-53).
  • Technical Importance: The claimed method provided a scalable, software-based framework for holistic supply chain risk management, in contrast to prior resource-intensive, manual reviews limited to a small subset of partners (’804 Patent, col. 2:36-41).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 1 (Compl. ¶87).
  • Independent Claim 1 requires a computer-implemented method of managing partner organizations, comprising the essential elements of:
    • Defining a "consumer/producer hierarchy" of three or more layers for partner organizations.
    • Defining partner capability objectives for organizations at each layer.
    • Generating and transmitting partner capability questions corresponding to the objectives.
    • Automatically collecting "partner capability facts" from the organizations.
    • Identifying gaps in capabilities as a function of the collected facts.
    • Selecting one or more partner capabilities for improvement.
    • Automatically improving the selected capabilities by informing partners of gaps and collecting new facts.
    • Monitoring partner capabilities to ensure improvements remain in place.
    • Reporting current partner capability information up through the hierarchy.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,853,754 - "System and Method for Managing Supply Chains Across Separate Organizations"

The Invention Explained

  • Problem Addressed: Managing supply chain risk across separate, independent companies is challenging because each entity controls its own data, uses different data formats, and has no common platform for securely sharing sensitive information with its partners (’754 Patent, col. 1:13-2:67).
  • The Patented Solution: The invention describes a computer-implemented method centered on a networked database management system that manages data for multiple separate organizations. The system defines a supply chain hierarchy, creates a database of item records reflecting that hierarchy, and associates users with specific organizations. It uses a permissioning system to grant a user remote access only to their own organization's data while preventing access to others' data, and it includes processes for handling data received in a "non-standardized format" and generating risk reports (’754 Patent, Abstract; col. 9:24-34).
  • Technical Importance: The technology provides a trusted, centralized, and permission-based platform enabling multiple independent entities in a supply chain to collaborate on risk management by sharing specific data without exposing all of their proprietary information (’754 Patent, col. 2:57-62).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 1 (Compl. ¶99).
  • Independent Claim 1 requires a computer-implemented method of managing supply chains across a plurality of separate organizations, comprising the essential elements of:
    • Defining a supply chain hierarchy for the organizations.
    • Creating a supply chain database on a networked database management system with item records reflecting the hierarchy.
    • Associating users with each organization and creating permissions to provide remote access to their organization's records while preventing access to others'.
    • Receiving information from a user in a "non-standardized format" and authenticating the user.
    • Updating the respective item record by converting the non-standardized information to a standardized format, validating it, and storing it.
    • Receiving a request from a user in a first organization to update information for a second organization and conveying that request.
    • Receiving and storing the updated information from the second organization.
    • Detecting a supply chain risk event.
    • Generating and sending a real-time report about the event to impacted organizations.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

  • The "Mayo and HIRC Supply Chain Risk Product," which is offered to healthcare provider members through a product called "Vault" (Compl. ¶71).

Functionality and Market Context

  • The accused product is described as a Software-as-a-Service (SaaS) platform for supply chain risk management (Compl. ¶78). Its alleged functionality includes using risk assessment questions to measure supplier capabilities, providing feedback to suppliers on capability gaps, storing supply chain information in a data repository, managing permissions for data access, and using templates to collect data on supplier site locations, operations, and relationships (Compl. ¶72). The system is also alleged to incorporate monitoring of supply chain risk events and alerts (Compl. ¶81).
  • The complaint alleges that the accused product is a "derivative" of Accelor's own SRS Product and that HIRC offers it in competition with Accelor's products (Compl. ¶71, 77).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

U.S. Patent No. 8,515,804 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a computer-implemented method of managing partner organizations, comprising: The Mayo and HIRC Supply Chain Risk Product implements a computer-implemented method of managing partner organizations. ¶88 col. 5:46-53
defining, for each partner organization, the partner organizations that consume what it produces and the partner organizations that produce what it consumes, wherein the partner organizations form a consumer/producer hierarchy of three or more layers... The Accused Product defines, for each partner organization, the organizations that consume what it produces and that produce what it consumes, forming a consumer/producer hierarchy of three or more layers. ¶89 col. 12:28-44
defining, in a computer, partner capability objectives associated with the partner organizations at each of the first, second and third layer; The Accused Product defines partner capability objectives associated with the partner organizations at each layer. ¶90 col. 6:15-18
generating partner capability questions corresponding to one or more of the defined partner capability objectives, transmitting the questions...and automatically collecting partner capability facts... The Accused Product generates and transmits partner capability questions corresponding to the objectives and automatically collects capability facts from the partner organizations. ¶91 col. 6:19-25
identifying gaps in partner capabilities as a function of the collected partner capability facts; The Accused Product identifies gaps in partner capabilities based on the collected facts. ¶92 col. 6:26-28
selecting one or more partner capabilities; The Accused Product selects one or more partner capabilities. ¶93 col. 6:29-30
automatically improving the selected partner capabilities... The Accused Product automatically improves capabilities by informing partners of gaps, collecting facts, measuring improvement, and promulgating information up the hierarchy. ¶94 col. 6:31-48
monitoring partner capabilities, in a computer, to ensure that improvements remain in place... The Accused Product monitors partner capabilities in a computer to ensure improvements remain in place. ¶95 col. 6:49-53
reporting to each partner organization the current partner capability information associated with partner organizations for which they are a consumer... The Accused Product reports current capability information from lower-tier organizations up through the hierarchy to consumer organizations on higher layers. ¶97 col. 7:1-8
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the relationships between entities in the accused product (healthcare providers, suppliers, distributors) constitute the specific "consumer/producer hierarchy of three or more layers" as described and claimed in the ’804 Patent. The defense may argue its system architecture differs from the claimed hierarchy.
    • Technical Questions: The analysis may focus on the degree of automation in the accused product. The claim requires steps like "automatically collecting," "automatically improving," and "monitoring." A key question will be what evidence the complaint provides that the accused product performs these specific automated functions, as opposed to merely facilitating manual data entry and review.

U.S. Patent No. 10,853,754 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a computer-implemented method of managing supply chains across a plurality of separate organizations... The Accused Product implements a computer-implemented method of managing supply chains across separate organizations. ¶100 col. 39:67-40:2
defining a supply chain hierarchy for the supply chains... The Accused Product defines a supply chain hierarchy, defining for each organization which other organizations supply items to it and receive items from it. ¶101 col. 40:3-12
creating a supply chain database on a database management system... wherein the supply chain database includes a plurality of item records which reflect the hierarchy... The Accused Product creates a supply chain database with a plurality of item records reflecting the hierarchy, where each record is associated with an item and its supplying organization and includes risk management information. ¶102 col. 40:13-28
associating one or more users with each organization... creating permissions that provide the user with remote access... while preventing access to the item records... of the other organizations... The Accused Product associates users with organizations, authenticates them, and creates permissions that provide access to their own organization's records while preventing access to others'. ¶103 col. 40:51-64
receiving... information associated with one of the item records, wherein the information received is in a non-standardized format... The Accused Product receives information associated with item records from users in a non-standardized format. ¶104 col. 41:1-8
updating the respective item record based on the information received... wherein updating includes converting the information received in the non-standardized format to a standardized format, validating the information and storing... The Accused Product updates the item record by converting the received non-standardized information to a standardized format, validating it, and storing it. ¶105 col. 41:9-17
receiving, from a user associated with the first organization, a request to update the supply chain risk management information of one of the item records associated with the second organization. The Accused Product receives a request from a user in a first organization to update information for a record associated with a second organization. ¶106 col. 41:18-22
conveying the request to one or more users associated with the second organization. The Accused Product conveys the request to users at the second organization. ¶107 col. 41:23-25
...receiving... updated supply chain risk management information. The Accused Product receives updated information from the second organization. ¶108 col. 41:26-29
detecting a supply chain risk event impacting one of the items... The Accused Product detects a supply chain risk event impacting an item. ¶110 col. 41:30-38
generating... a report for each organization impacted by the supply chain risk event... The Accused Product generates a report for each organization impacted by the risk event. ¶111 col. 41:39-45
sending the report in real time over the network... The Accused Product sends the report in real time over the network via messaging software. ¶112 col. 41:46-51
  • Identified Points of Contention:
    • Scope Questions: The interpretation of "non-standardized format" will be critical. The defense may argue that data entered into the accused product's "templates" (Compl. ¶72) is, by definition, submitted in a standardized format, and therefore does not meet this limitation.
    • Technical Questions: The claim requires a specific workflow: a request from a first organization to a second, a conveyance of that request, and receipt of an update. The infringement analysis will turn on whether the accused product actually implements this specific cross-organizational communication protocol as claimed.

V. Key Claim Terms for Construction

For the ’804 Patent:

  • The Term: "consumer/producer hierarchy"
  • Context and Importance: This term is the foundational structure of Claim 1. The infringement case depends on whether the relationships between the entities managed by the accused product (e.g., hospitals, device manufacturers, distributors) can be mapped onto this specific claimed structure. Practitioners may focus on this term because its definition will determine if the patent's scope is limited to a rigid manufacturing context or can extend more broadly to other business relationships.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the hierarchy in general terms as organizations that "consume what it produces" and vice-versa, which could be argued to apply to any buyer-seller or service-provider relationship (’804 Patent, claim 1).
    • Evidence for a Narrower Interpretation: The claim language requires a specific structure of "three or more layers" with defined relationships between layers (e.g., layer one supplies layer two, which supplies layer three). The detailed description often uses manufacturing examples, which might be used to argue for a more limited, tangible-good-focused interpretation (’804 Patent, col. 12:28-44).

For the ’754 Patent:

  • The Term: "non-standardized format"
  • Context and Importance: This term is central to the data-handling portion of Claim 1. The allegation of infringement hinges on the accused product receiving data in such a format and then converting it. The definition will be critical to determining if data entered via web forms or templates falls within the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not explicitly define the term. A broad reading could suggest that any data format that is not the final, validated format stored in the database is "non-standardized," including raw data entered into fields of a web form.
    • Evidence for a Narrower Interpretation: The specification discusses the difficulty of managing data across different organizations, which suggests "non-standardized" may refer to disparate data from different companies' internal systems (e.g., one provides an Excel file, another a CSV, a third a PDF). The defense could argue that data entered into a uniform template provided by the accused system is inherently "standardized" at the point of entry. The claim's subsequent step of "converting" the information may support this narrower view (’754 Patent, col. 41:4-13).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendants Mayo and Schafer induced infringement by knowingly encouraging and inducing HIRC to use the accused product to infringe the ’804 and ’754 Patents (Compl. ¶119, 131).
  • Willful Infringement: Willfulness is alleged for both patents based on Defendants' alleged "actual knowledge" of the patents and upon receiving "actual notice" of infringement from Accelor (Compl. ¶98, 113, 121, 133). The complaint asserts the infringement was "intentional, knowing, willful, deliberate, without license or justification" (Compl. ¶122, 134).

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

This case presents an overlap between allegations of trade secret misappropriation and patent infringement. The central questions for the court will likely involve disentangling these claims to focus on the specific requirements of the patent claims.

  • A core issue will be one of definitional scope: can the specific structural terms of the patents, such as the "consumer/producer hierarchy" of the ’804 Patent and the "non-standardized format" data handling of the ’754 Patent, be construed to read on the architecture and data-intake methods of the accused "Vault" platform?
  • A key evidentiary question will be one of operational fidelity: beyond the surface-level similarities alleged in the complaint, does the accused product actually perform the specific, multi-step automated processes required by the claims, such as the complete "automatically improving" and "monitoring" cycles of the ’804 Patent's Claim 1, or the precise cross-organizational request-and-update workflow of the ’754 Patent's Claim 1?