DCT
1:25-cv-01069
DataCloud Tech LLC v. Reddit Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: DataCloud Technologies, LLC (Georgia)
- Defendant: Reddit, Inc. (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
- Case Identification: 1:25-cv-01069, D. Del., 08/25/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation and conducts substantial business, including the alleged acts of infringement, within the district.
- Core Dispute: Plaintiff alleges that Defendant’s social media platform, including its website, mobile applications, and content delivery infrastructure, infringes seven patents related to data organization, network communication, content management, and software deployment.
- Technical Context: The asserted patents relate to fundamental technologies in computer networking, file system management, and dynamic content delivery, which are foundational to the operation of large-scale, interactive web and mobile platforms.
- Key Procedural History: Prior to filing the complaint, Plaintiff alleges it provided Defendant with notice of the asserted patents and its infringement contentions on three separate occasions via letters and emails sent to Defendant’s Chief Legal Officer between March and November 2023.
Case Timeline
| Date | Event |
|---|---|
| 2000-01-28 | Earliest Priority Date for U.S. Patent No. 6,651,063 |
| 2000-02-08 | Earliest Priority Date for U.S. Patent No. 6,560,613 |
| 2000-04-04 | Earliest Priority Date for U.S. Patent No. 7,209,959 |
| 2000-04-25 | Earliest Priority Date for U.S. Patent No. 8,156,499 |
| 2001-02-20 | Earliest Priority Date for U.S. Patent No. 7,246,351 |
| 2002-03-29 | Earliest Priority Date for U.S. Patent No. 7,398,298 |
| 2003-05-06 | U.S. Patent No. 6,560,613 Issues |
| 2003-11-18 | U.S. Patent No. 6,651,063 Issues |
| 2004-04-29 | Earliest Priority Date for U.S. Patent No. 8,607,139 |
| 2007-04-24 | U.S. Patent No. 7,209,959 Issues |
| 2007-07-17 | U.S. Patent No. 7,246,351 Issues |
| 2008-07-08 | U.S. Patent No. 7,398,298 Issues |
| 2011-11-22 | U.S. Patent No. 8,156,499 Issues |
| 2013-12-10 | U.S. Patent No. 8,607,139 Issues |
| 2023-03-15 | Plaintiff sends first licensing letter to Defendant |
| 2023-10-24 | Plaintiff sends second licensing email to Defendant |
| 2023-11-08 | Plaintiff sends follow-up email to Defendant |
| 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 describes a shortcoming in operating systems like UNIX, where the same system calls are used to access different types of "files," such as a data file stored on a hard disk versus a network communication channel (Compl. ¶16; ’613 Patent, col. 2:26-34). This ambiguity prevents a program from selectively intercepting system calls based on the underlying file type, limiting options for enhanced security or customized functionality (’613 Patent, col. 3:12-24).
- The Patented Solution: The invention proposes a method to "disambiguate" file types at a low level. It involves intercepting the system calls that first create a file descriptor (a handle to a file or network connection) and storing an "indicator" in a table that marks the descriptor’s type. A "system call wrapper" can then examine this table whenever a file access is requested, determine the file's true type, and decide whether to permit the operation, thereby enabling selective interception based on file type (’613 Patent, Abstract; col. 4:1-8).
- Technical Importance: This approach allows for more granular control over system resources than provided by the operating system itself, enabling, for example, a security policy that blocks a downloaded applet from accessing the local file system while still permitting it to communicate over the network (’613 Patent, col. 2:15-24).
Key Claims at a Glance
- The complaint asserts at least independent method claim 11 (Compl. ¶22).
- The essential elements of claim 11 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.
- The complaint alleges infringement of "one or more claims," reserving the right to assert additional claims (Compl. ¶21).
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 problem of information overload, where consumers and businesses are inundated with product guides, updates, and solicitations from various sources and lack an efficient, centralized system to organize this information (’063 Patent, col. 1:15-40).
- The Patented Solution: The invention describes a system where "providers" (e.g., retailers, manufacturers) send pre-categorized "information packs" to a user's digital "data repository." The user can accept the default category or move the information pack to a custom location. The system is designed to recognize this user preference and, through a feedback mechanism to a central "processing station," automatically route subsequent information packs from the same provider to the user's chosen custom category (’063 Patent, Abstract; col. 4:7-12, 29-39).
- Technical Importance: The system shifts the initial burden of data organization from the recipient to the information provider and introduces an automated learning mechanism to personalize information management for the user (’063 Patent, col. 2:5-11).
Key Claims at a Glance
- The complaint asserts at least independent method claim 4 (Compl. ¶33).
- The essential elements of claim 4 include storing information in an "information pack," associating it with a user address, a category identifier, and a provider identifier, and communicating it to a "user data repository." A key aspect involves creating a "custom location" for the pack and sending a signal to a "processing station," which then analyzes the provider identifier of subsequent packs and, upon a match, places them in the same custom location.
- The complaint alleges infringement of "one or more claims," reserving the right to assert additional claims (Compl. ¶32).
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 method for anonymizing network communications by routing a client's request to a destination website through a system of intermediaries: a "deceiver," a "controller," and a "forwarder." This architecture is designed to ensure that neither the client nor the destination server is aware of the other's true network address or of the forwarder's employment (Compl. ¶¶38, 44).
- Asserted Claims: At least independent method claim 1 is asserted (Compl. ¶44).
- Accused Features: Plaintiff accuses Reddit's website infrastructure (www.reddit.com) of infringing by performing the claimed method, alleging it uses a system that responds to website requests in a manner where neither the client nor the destination server is aware of the employment of an intermediary forwarder (Compl. ¶45).
U.S. Patent No. 7,398,298 - "Remote Access And Retrieval Of Electronic Files," Issued July 8, 2008
- Technology Synopsis: The patent discloses a method for providing remote management of data directory structures on a computer server. The system allows participating users to select and modify directory structures stored in a profile store and to receive notifications upon the delivery of data (Compl. ¶¶49, 55).
- Asserted Claims: At least independent method claim 13 is asserted (Compl. ¶55).
- Accused Features: The complaint targets Reddit's Moderation Tools, which allegedly provide remote management capabilities allowing moderators to control user access and permissions across communities, manage user profiles and data directories, and receive notifications (Compl. ¶56).
U.S. Patent No. 8,156,499 - "Methods, Systems and Articles of Manufacture for Scheduling Execution of Programs on Computers Having Different Operating Systems," Issued November 22, 2011
- Technology Synopsis: The technology involves a method for scheduling tasks across different computer operating systems. A scheduling computer directs a first computer (with a first OS) to execute a program, receives a result, and based on that result meeting a criterion, schedules a second computer (with a different, second OS) to execute a second program (Compl. ¶¶60, 66).
- Asserted Claims: At least independent method claim 1 is asserted (Compl. ¶66).
- Accused Features: The infringement allegations focus on the process for updating the Reddit app on different mobile platforms, such as iOS and Android, which are different operating systems (Compl. ¶67).
U.S. Patent No. 7,246,351 - "System And Method For Deploying And Implementing Software Applications Over A Distributed Network," Issued July 17, 2007
- Technology Synopsis: The patent describes a method for deploying software by storing a module on a client device that assembles a functioning application from text files containing embedded program logic. This assembled application provides a graphical user interface (GUI) for user interaction (Compl. ¶¶71, 77).
- Asserted Claims: At least independent method claim 14 is asserted (Compl. ¶77).
- Accused Features: Plaintiff accuses Reddit's system for viewing video content on mobile devices. It alleges that a software module like the Reddit website runs on the device and fetches program logic as text-based files from a server to assemble a functional video player with a GUI (Compl. ¶78).
U.S. Patent No. 8,607,139 - "System and process for managing content organized in a tag-delimited template using metadata," Issued December 10, 2013
- Technology Synopsis: This patent relates to a method for displaying a graphical interface based on a metadata template. The template defines the structure and appearance of a web page via an object based on a class, and the system generates a data entry form corresponding to that object (Compl. ¶¶82, 88).
- Asserted Claims: At least independent method claim 8 is asserted (Compl. ¶88).
- Accused Features: The complaint targets the Reddit website's "Submit a request" form, alleging it is configured with input fields whose structure and appearance are determined by an object based on a template (Compl. ¶89).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are Reddit's services and infrastructure, including its website (www.reddit.com), its mobile applications for platforms such as iOS and Android, its use of the Fastly Content Delivery Network (CDN), its "Moderation Tools," and its "Submit a request" form (Compl. ¶¶23, 34, 45, 56, 89).
Functionality and Market Context
The complaint alleges that Reddit operates a high-traffic social media platform that relies on the accused functionalities for its core operations. These include: using a high-performance CDN for efficient data delivery to users (Compl. ¶23); distributing its mobile application as an APK file for Android devices, which contains a certificate identifying "reddit Inc." as the provider (Compl. ¶34); managing web traffic through a complex infrastructure that handles user requests (Compl. ¶45); providing tools for community moderators to manage user permissions and content (Compl. ¶56); and deploying application updates across different mobile operating systems (Compl. ¶67).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
'613 Patent 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; | The complaint alleges Defendant infringes by performing a method that includes this step, without providing specific facts on which system calls are intercepted or how Reddit’s use of a CDN constitutes such interception (Compl. ¶22). | ¶22 | col. 5:17-23 |
| storing at least one indicator that a file descriptor established by an intercepted system call is associated with a file stored on media; | The complaint alleges Defendant performs this step by tracking file descriptors, but does not specify what "indicator" is stored, where it is stored, or how this is accomplished within the accused CDN infrastructure (Compl. ¶22). | ¶22 | col. 5:21-23 |
| examining at least one stored indicator to determine with what file type a file descriptor is associated. | The complaint alleges that Defendant’s system examines a stored indicator to determine a file type. The allegation tracks the claim language without detailing the technical mechanism by which Reddit's systems are purported to perform this examination (Compl. ¶22). | ¶22 | col. 5:42-50 |
'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 Reddit mobile application, in the form of an APK file, is alleged to be the "information pack" (Compl. ¶34). | ¶34 | col. 10:20-21 |
| associating with said information pack at least a user destination address… and a category identifier; | When a user downloads the app, Reddit is alleged to associate the APK file with a user's IP address (the "destination address") (Compl. ¶34). The complaint does not specify the alleged "category identifier" in this context. | ¶34 | col. 10:22-25 |
| associating with said information pack a provider identifier; | The "provider identifier" is alleged to be the organization name ("reddit Inc.") contained within the APK file's digital certificate (Compl. ¶34). | ¶34 | col. 10:33-34 |
| creating a custom location in said user data repository; placing said information pack in said custom location; | A custom location (e.g., a directory) is allegedly created in the user's data repository (e.g., the device's file system), and the Reddit APK is placed there (Compl. ¶34). | ¶34 | col. 8:12-14 |
| comparing said provider identifier of said subsequent information packs with said provider identifier stored…and in the event of a match…placing said one of the subsequent information packs in said custom location. | App updates are alleged to satisfy this element. The mobile OS allegedly uses the signature (public key) in subsequent APK files to identify the author, which corresponds to the stored provider identifier (Compl. ¶34). | ¶34 | col. 8:20-29 |
Identified Points of Contention
- Factual Sufficiency: For the ’613 Patent, the infringement allegations are conclusory and appear to recite the claim elements without supporting factual detail. A potential point of contention is whether these allegations meet the plausibility standard required for federal court pleadings.
- Technical Analogy: For the ’063 Patent, a key dispute may arise over whether the process of distributing, installing, and updating a mobile application (an APK file) via an app store and operating system constitutes the claimed method of managing "information packs" in "user data repositories" via a "processing station." Questions may be raised as to whether a mobile OS's signature verification for app updates performs the specific comparison and placement steps recited in the claim.
V. Key Claim Terms for Construction
For the ’613 Patent
- The Term: "intercepting system calls"
- Context and Importance: This term is central to the claimed invention. The complaint alleges that Reddit's use of a CDN constitutes "interception." Practitioners may focus on whether this term should be construed narrowly to mean modifying the operating system's kernel-level "system call vector table," as described in the patent's embodiment, or broadly enough to cover higher-level network traffic redirection performed by a CDN.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the "interception of system calls... is useful to extend and customize operating system functionality" generally, which could suggest the specific mechanism is not limiting (’613 Patent, col. 2:9-11).
- Evidence for a Narrower Interpretation: The detailed description of the preferred embodiment repeatedly refers to a specific implementation: "a pointer in the system call vector table to the system call is replaced with a pointer to alternative object code" (’613 Patent, col. 2:66–col. 3:2).
For the ’063 Patent
- The Term: "information pack"
- Context and Importance: The complaint equates this term with a mobile application package (an APK file) (Compl. ¶34). The viability of the infringement theory for the ’063 patent may depend on whether this construction is adopted.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims use the general term "information" without express limitation to non-executable data (’063 Patent, col. 23:30).
- Evidence for a Narrower Interpretation: The specification's examples of what constitutes an "information pack" consistently refer to user-facing documents, not executable code. For instance, Figure 5 lists "STATIC INFORMATION (MANUAL, MAINTENANCE SCHEDULE, RECEIPT, DMV REGISTRATION FORMS, WARRANTY, ETC.)" as the contents of an information pack (’063 Patent, Fig. 5, element 418).
VI. Other Allegations
Indirect Infringement
The complaint includes general language suggesting inducement and contributory infringement by alleging Defendant acts "through intermediaries, by contributing to and through the inducement of third parties" (Compl. ¶10). However, the complaint does not set forth specific facts to support the knowledge and intent elements required for such claims (e.g., specific instructions to users to perform infringing acts).
Willful Infringement
While the complaint does not contain a specific count for willful infringement, it alleges pre-suit knowledge of the asserted patents based on three notice letters sent to Defendant’s Chief Legal Officer beginning on March 15, 2023 (Compl. ¶14). Furthermore, the prayer for relief requests that the court declare the case "exceptional" and award attorneys' fees under 35 U.S.C. § 285, a remedy often sought in conjunction with findings of willful infringement (Compl. ¶93.D).
VII. Analyst’s Conclusion: Key Questions for the Case
- A threshold issue will be one of factual sufficiency: for several asserted patents, particularly the ’613 patent concerning low-level system call interception, does the complaint provide sufficient factual matter beyond a conclusory recitation of claim elements to state a plausible claim for relief?
- A central technical question will be one of definitional scope: can claim terms rooted in the context of early-2000s technology, such as "information pack" (’063 patent) and "intercepting system calls" (’613 patent), be construed to cover the distinct functionalities of modern mobile application packages and cloud-based content delivery networks?
- A key strategic question will be the viability of the portfolio assertion: given the assertion of seven patents covering a wide range of technologies from network anonymity to UI generation, the case may test whether infringement theories can be sustained across such a broad technical front or if the dispute will narrow to the patents where the alleged technological overlap is most arguable.