DCT
1:25-cv-01068
DataCloud Tech LLC v. Autel Robotics USA LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: DataCloud Technologies, LLC (Georgia)
- Defendant: Autel Robotics USA LLC (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Rozier Hardt McDonough PLLC
- Case Identification: 1:25-cv-01068, D. Del., 08/25/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation that conducts substantial business and has committed alleged acts of infringement in the state.
- Core Dispute: Plaintiff alleges that Defendant’s website infrastructure, mobile applications, and drone management platforms infringe four patents related to network content delivery, data organization, anonymous communication, and remote file management.
- Technical Context: The patents-in-suit relate to foundational technologies for internet infrastructure and data management, including methods for operating content delivery networks (CDNs), organizing application data, anonymizing network traffic, and managing remote file systems.
- Key Procedural History: An Inter Partes Review (IPR) proceeding (IPR2021-00361) for the ’613 Patent resulted in the cancellation of claims 1, 2, 5, 7, 14, and 17. The complaint asserts independent claim 11, which was not canceled in the IPR. The ’613 and ’063 Patents were also subject to Certificates of Correction.
Case Timeline
| Date | Event |
|---|---|
| 2000-01-28 | ’063 Patent Priority Date |
| 2000-02-08 | ’613 Patent Priority Date |
| 2000-04-04 | ’959 Patent Priority Date |
| 2003-05-06 | ’613 Patent Issued |
| 2003-08-26 | ’613 Patent Certificate of Correction Issued |
| 2003-11-18 | ’063 Patent Issued |
| 2004-02-03 | ’063 Patent Certificate of Correction Issued |
| 2007-03-23 | ’298 Patent Priority Date |
| 2007-04-24 | ’959 Patent Issued |
| 2008-07-08 | ’298 Patent Issued |
| 2022-10-05 | ’613 Patent Inter Partes Review Certificate Issued |
| 2025-08-25 | Complaint Filed |
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’s background section explains that many operating systems use identical system calls to access different types of resources, such as files stored on physical media (e.g., a hard disk) and network communication channels. This makes it difficult to create security or customization policies that treat these resource types differently, as intercepting a system call for one affects the other (’613 Patent, col. 2:26-50).
- The Patented Solution: The invention proposes a method to distinguish, or "disambiguate," between file descriptors for different resource types. The system intercepts the initial system calls that create file descriptors and stores an "indicator" in a table to mark the descriptor's type (e.g., "file on media"). When subsequent system calls attempt to use that descriptor, a "system call wrapper" first checks the indicator table. Based on the identified type, the wrapper can then selectively permit or block the requested operation, enabling more granular system control (’613 Patent, Abstract; col. 3:4-12; Fig. 1).
- Technical Importance: This technology provides a mechanism for finer-grained security control within an operating system, allowing, for example, a program to be granted network access while being denied access to the local file system (’613 Patent, col. 2:10-24).
Key Claims at a Glance
- The complaint asserts independent claim 11 (Compl. ¶21).
- Essential elements of claim 11, a method for disambiguating file descriptors, include:
- 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.
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 addresses the challenge faced by consumers and businesses in managing a large volume of information, such as product manuals, warranties, and service updates, which are often disorganized and difficult to retrieve when needed (’063 Patent, col. 1:19-40).
- The Patented Solution: The invention describes a system where "providers" (e.g., vendors) send pre-categorized "information packs" to a recipient's "User Data Repository." The system associates these packs with both a category identifier and a provider identifier. Recipients can further process the information by placing it into "custom locations." The system can be configured to learn this custom organization, so that subsequent information packs from the same provider are automatically routed to the user-defined custom location (’063 Patent, Abstract; Fig. 1).
- Technical Importance: The system aims to simplify information management by shifting the initial burden of categorization from the recipient to the provider and automating subsequent filing based on user preferences (’063 Patent, col. 2:5-11).
Key Claims at a Glance
- The complaint asserts independent claim 4 (Compl. ¶32).
- Essential elements of claim 4, a method for providing information, 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 via 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 information pack there;
- associating a custom category identifier with the pack; and
- sending a custom category signal to a processing station, which stores the custom category and provider identifiers to analyze and route subsequent packs from that provider.
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 describes a system for enabling anonymous network activity by routing a client's communications through a series of intermediaries termed a "deceiver," a "controller," and a "forwarder." This architecture is designed so that neither the client nor the destination server is aware of the forwarder's role, thereby masking the client's identity and creating a temporary, anonymous session (’959 Patent, Abstract; Compl. ¶40).
Asserted Claims
At least independent claim 1 (Compl. ¶43).
Accused Features
The complaint accuses Autel Robotics' website infrastructure of infringement, alleging it uses an intermediary forwarder in a manner that conceals the forwarder's employment from both the client and the destination web server (Compl. ¶44).
U.S. Patent No. 7,398,298, "Remote Access And Retrieval Of Electronic Files," issued July 8, 2008
Technology Synopsis
The patent discloses a system for remote management of data and directory structures over a network. The system involves a computing application on a server that processes user requests for remote control. It queries a "profile store" to verify access permissions for specific directory structures, delivers the requested data, and provides confirmation of delivery to the user (’298 Patent, Abstract; Compl. ¶51).
Asserted Claims
At least independent claim 13 (Compl. ¶54).
Accused Features
The complaint accuses the "Autel SkyCommand Center," a drone flight control platform. It alleges that the platform's features for managing tasks, equipment, and team member roles and permissions constitute the claimed method for providing remote management control of data directory structures (Compl. ¶55).
III. The Accused Instrumentality
Product Identification
The complaint accuses multiple instrumentalities:
- Autel Robotics' website and its use of Amazon CloudFront, a Content Delivery Network (CDN) (accused of infringing the ’613 Patent) (Compl. ¶22).
- The Autel Robotics Starlink App for iOS, distributed via Apple's App Store (accused of infringing the ’063 Patent) (Compl. ¶33).
- Autel Robotics' general website infrastructure (accused of infringing the ’959 Patent) (Compl. ¶44).
- The Autel SkyCommand Center, a flight control platform for managing drones (accused of infringing the ’298 Patent) (Compl. ¶55).
Functionality and Market Context
- The complaint describes Amazon CloudFront as a CDN that intercepts user requests to optimize content delivery by serving assets from edge caches based on "predefined file patterns" (Compl. ¶22).
- The Autel Starlink App is described as a downloadable application (IPA file) for iOS devices. The complaint alleges the download and update process involves associating the app file with a user IP address, a provider identifier (from a certificate), and a custom directory on the user's device (Compl. ¶33).
- The Autel SkyCommand Center is alleged to be a platform enabling users to manage drone-related tasks, equipment, and team roles and permissions from a computer or mobile device (Compl. ¶55).
IV. Analysis of Infringement Allegations
U.S. Patent No. 6,560,613 Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| intercepting system calls that establish a file stored on media | Amazon CloudFront intercepts user requests and determines whether to serve content from its edge cache or origin server. | ¶22 | col. 10:25-39 |
| intercepting system calls that create a copy of at least one file descriptor | CloudFront's use of cache behaviors to manage and handle static and dynamic assets. | ¶22 | col. 9:65-10:20 |
| storing at least one indicator that a file descriptor established by an intercepted system call is associated with a file stored on media | CloudFront uses "predefined file patterns" to manage different types of content. | ¶22 | col. 11:1-11 |
| storing at least one indicator concerning a created copy of a file descriptor | CloudFront's management of cached assets based on file patterns. | ¶22 | col. 10:11-20 |
| examining at least one stored indicator to determine with what file type a file descriptor is associated | CloudFront manages different content types (images, scripts, videos) based on predefined file patterns to ensure efficient handling. | ¶22 | col. 12:44-50 |
Identified Points of Contention
- Scope Questions: A central question may be whether a high-level network "request" intercepted by a CDN service can be properly construed as a low-level "system call" within an operating system, as the term is described in the patent.
- Technical Questions: The complaint does not specify how the accused CDN functionality maps to the distinct claimed steps of intercepting calls that establish a file versus those that create a copy of a file descriptor. The question is what evidence supports the allegation that CloudFront performs separate actions corresponding to both of these claimed steps.
U.S. Patent No. 6,651,063 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 Autel Robotics Starlink App is provided as an IPA file. | ¶33 | col. 6:26-34 |
| associating with said information pack at least a user destination address ... and a category identifier | The IPA file is associated with a user's IP address. | ¶33 | col. 3:17-21 |
| associating with said information pack a provider identifier | The IPA file is associated with a provider identifier from its certificate, such as the Common Name (CN) of "*.autelrobotics.com". | ¶33 | col. 6:30-34 |
| creating a custom location in said user data repository; [and] placing said information pack in said custom location | The iOS device is the data repository, and the Starlink App creates a custom directory (e.g., subdirectories for apps in "Apps") and is placed there. | ¶33 | col. 9:11-24 |
| associating a custom category identifier with said information pack | The "digital signature, or modulus" of the IPA file is alleged to be a custom category identifier. | ¶33 | col. 9:53-58 |
| sending a custom category signal to a processing station ... said data processing means analyzing the provider identifier of subsequent information packs | Updating the app is alleged to be an example of sending a custom category signal. The data repository (iOS device) contains data storage and processing means. | ¶33 | col. 10:30-53 |
Identified Points of Contention
- Scope Questions: The analysis may turn on whether an end-user's smartphone and its operating system's file structure constitute a "user data repository" and "processing station" as contemplated by the patent, which depicts a more centralized client-server architecture.
- Technical Questions: A key question will be whether a file's "digital signature, or modulus"—primarily a security and authenticity feature—can be construed as a "custom category identifier," which the patent describes as an organizational tool created by the user.
No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
For the ’613 Patent
- The Term: "system call"
- Context and Importance: The patent specification consistently describes "system calls" in the context of low-level operating system functions involving a kernel, software interrupts, and a system call vector table. The complaint accuses a high-level, distributed Content Delivery Network (CDN) of intercepting "requests." The construction of "system call" will be critical to determining whether the patent's scope can extend from an OS-level mechanism to a web service architecture.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term could be argued to generically cover any programmatic request for a system resource, which might include a network request for a file handled by a server.
- Evidence for a Narrower Interpretation: The patent’s detailed description explains that a system call involves loading arguments into CPU registers and generating a "software interrupt," and that system calls are accessed via a "system call vector table" in the operating system's address space (’613 Patent, col. 1:45-67). This language may support a narrower construction limited to such specific OS-level interactions.
For the ’063 Patent
- The Term: "custom category identifier"
- Context and Importance: The patent describes a system where a user organizes information by creating "custom locations" (e.g., folders). This term appears to be the label or tag associated with that user-created organizational structure. The complaint alleges this limitation is met by an app's "digital signature." Practitioners may focus on this term because its definition will determine if a feature designed for security and authenticity can satisfy a claim limitation directed at user-defined data organization.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that any unique data associated with an information pack after it is placed in a custom location by a user could function as a "custom category identifier."
- Evidence for a Narrower Interpretation: The specification links the creation of custom categories to a user's action of re-assigning an information pack to a location like "My Medicine," suggesting the identifier is an organizational label applied by the user, not an inherent technical property of the file itself like a cryptographic signature (’063 Patent, col. 11:47-52, Fig. 2).
VI. Other Allegations
- Indirect Infringement: The complaint includes general allegations that Defendant contributes to and induces infringement by third parties (Compl. ¶10). However, it does not plead specific facts to support the knowledge and intent elements required for such claims, such as identifying specific instructions or actions aimed at encouraging infringement.
- Willful Infringement: The complaint does not include a count for willful infringement and does not allege any facts suggesting Defendant had pre-suit knowledge of the patents-in-suit.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technological analogy: can the specific, low-level operating system mechanisms described in the ’613 Patent, such as a "system call" and "file descriptor," be construed to cover the high-level, distributed functions of a web-based Content Delivery Network, such as intercepting a "user request" and managing "file patterns"?
- A key evidentiary question will be one of functional distinction: for the ’063 patent, does an application file's inherent "digital signature," a feature for ensuring security and authenticity, perform the function of a "custom category identifier," which the patent describes as an organizational tool created and applied by a user to sort information?
- A central dispute for the ’959 patent may be one of purpose and structure: does the accused website infrastructure, which likely uses intermediaries for conventional purposes like load balancing, implement the specific "deceiver-controller-forwarder" architecture whose claimed function is to create anonymity by ensuring neither the client nor the server is aware of the intermediary's role?