DCT
1:25-cv-01111
Onepass Data Technology LLC v. AT&T Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: OnePass Data Technology LLC (Ohio)
- Defendant: AT&T Inc., AT&T Communications LLC, and AT&T Mobility LLC (Delaware)
- Plaintiff’s Counsel: Wilks Law LLC; Leichtman Law PLLC
- Case Identification: 1:25-cv-01111, D. Del., 09/05/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because each Defendant is incorporated in and resides in Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s systems and methods for cleansing mailing list data to comply with U.S. Postal Service standards infringe patents related to single-pass data processing architecture.
- Technical Context: The technology concerns high-efficiency data processing, specifically for standardizing and correcting large databases of mailing addresses to qualify for postal service discounts, a common practice in bulk mailing industries.
- Key Procedural History: The complaint notes that U.S. Patent No. 7,376,680, one of the two patents-in-suit, was the subject of an Ex Parte Reexamination, which concluded with the issuance of a Reexamination Certificate confirming the patentability of the issued claims.
Case Timeline
| Date | Event |
|---|---|
| 2003-04-07 | Priority Date for ’680 and ’866 Patents |
| 2008-05-20 | U.S. Patent No. 7,376,680 Issues |
| 2011-08-01 | USPS CASS Cycle N Begins |
| 2014-03-25 | U.S. Patent No. 8,682,866 Issues |
| 2017-04-26 | Reexamination Certificate for ’680 Patent Issues |
| 2023-08-01 | USPS CASS Cycle O Begins |
| 2025-09-05 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,376,680 - "System And Method For Cleansing And Appending Data Records Of A Database"
The Invention Explained
- Problem Addressed: Conventional database cleansing systems were inefficient because they performed one operation at a time (e.g., postal coding, then address change, then telephone number appending) (Compl. ¶15; ’680 Patent, col. 1:57-65). This required reading a data record from remote storage (like a disk drive), performing one process, and writing it back, a sequence repeated for each subsequent process, consuming significant time and computer resources (’680 Patent, col. 2:1-5).
- The Patented Solution: The invention describes a "single pass" system where a data record is read from remote storage only once, held in local memory (RAM), and processed sequentially against multiple different reference files (Compl. ¶15; ’680 Patent, Fig. 2). After all processing is complete, the final, cleansed record is written back to remote storage only once, greatly improving efficiency (’680 Patent, col. 3:13-22).
- Technical Importance: This architectural approach was aimed at reducing the processing time and computational cost of handling very large databases, which could contain millions or billions of records (’680 Patent, col. 1:35-39).
Key Claims at a Glance
- The complaint asserts claims 1-7, with Claim 1 being the sole independent claim in that group (Compl. ¶35).
- Claim 1 (Method):
- Selecting an input file and a reference file.
- Computing a search key.
- For each data record in the input file, performing a series of steps (retrieving, searching, matching, cleansing, writing) to create a new cleansed data record.
- Crucially, these steps are performed in a "single pass," such that each input record is read from remote storage once, each matching record is read from remote storage once, and each new cleansed record is written to remote storage once.
U.S. Patent No. 8,682,866 - "System And Method For Cleansing, Linking And Appending Data Records Of A Database"
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’680 Patent, the ’866 Patent addresses the same problem: the inefficiency of multi-pass data hygiene systems that require multiple, costly read/write operations to remote storage for each data record being processed (’866 Patent, col. 1:60-col. 2:8).
- The Patented Solution: The patent claims methods and systems for "data hygiene" where an input data record is obtained from remote storage once, stored in local memory, and then processed through a "series of updating processes successively performed" (’866 Patent, Claim 1). The output from one updating process serves as the input for the next, with each process using a different reference file, all while the record remains in local memory before being written back to remote storage a single time (’866 Patent, Claim 1).
- Technical Importance: This solution provides a structured framework for performing a sequence of distinct data cleansing operations in an efficient, single read/write cycle (’866 Patent, col. 2:56-61).
Key Claims at a Glance
- The complaint asserts claims 1-3 and 9, as well as system claim 16 (Compl. ¶¶57, 68). The complaint provides infringement allegations for independent method Claim 1 and independent system Claim 16.
- Claim 1 (Method):
- Obtaining an input data record from remote storage and storing it in local memory.
- Processing the record through a "series of updating processes successively performed at least one time."
- Each updating process uses a different reference file, and the output of one process is the input for the next.
- The final output is a cleansed record, which is then outputted from local memory to remote storage.
- Claim 16 (System):
- A system comprising a local memory and a plurality of reference files.
- A "matcher" that includes "means for obtaining" candidate records, "means for selecting" a matching record, and "means for updating" the input record while it remains in local memory.
- A "secondary matcher" that performs another match using a second reference file.
- "Means for writing" the handled input data record to an output file, where the record is read and written only once.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are the "Accused Systems" and "Accused Methods" that AT&T uses for cleansing its customer mailing lists (Compl. ¶25).
Functionality and Market Context
- The complaint alleges that AT&T uses these systems and methods to standardize, correct, and verify mailing addresses in compliance with the U.S. Postal Service's Coding Accuracy Support System (CASS) requirements for "Cycle N" or "Cycle O" (Compl. ¶¶28, 29). This process is allegedly performed to qualify for reduced "automation prices" on its First-Class and Standard Mail (Compl. ¶27). The complaint alleges the Accused Systems are comprised of non-volatile memory for storing input, reference, and output files; volatile memory for processing; and CASS-certified software (Compl. ¶28). The complaint provides a photograph of an AT&T mailpiece with a "First-Class Mail U.S. Postage Paid AT&T" permit imprint as evidence of AT&T's participation in bulk mailing that would utilize such cleansing methods (Compl. ¶26).
IV. Analysis of Infringement Allegations
’680 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A computer-implemented method for creating a cleansed output file containing a plurality of business data records from a single pass through an input file. | AT&T uses its methods to create a cleansed customer mailing list to qualify for automation prices. | ¶39 | col. 3:13-22 |
| selecting an input file containing a plurality of data records. | AT&T selects an input customer mailing list containing address records. | ¶40 | col. 9:3-6 |
| selecting a reference file, said reference file containing a plurality of data records. | AT&T selects multiple USPS reference files (e.g., ZIP + 4, DPV, LACSLink, SuiteLink). | ¶41 | col. 9:21-24 |
| computing a search key. | AT&T computes a unique key from elements like street address and postal code. | ¶42 | col. 9:35-39 |
| retrieving said data record from said input file on remote storage. | AT&T retrieves an address record from a customer mailing list maintained in non-volatile memory. | ¶43 | col. 9:46-48 |
| searching said reference file with a matcher process...thereby generating a candidate data record list. | AT&T searches the USPS reference files with a matching process to generate a candidate address record list. | ¶44 | col. 10:5-13 |
| wherein said steps...are performed in a single pass...such that each data record of said input file is read from a remote storage location only once...and each said new cleansed data record...is written to a remote storage location only once. | AT&T's method performs the steps in a single pass through the input list and reference files, such that each record is read from and written to non-volatile memory only once. | ¶50 | col. 11:46-55 |
’866 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| obtaining an input data record of an input file maintained in remote storage. | AT&T obtains an address record from a customer mailing list maintained on non-volatile memory. | ¶62 | col. 3:15-18 |
| storing said input data record in a local memory. | AT&T stores the address record in volatile memory. | ¶63 | col. 3:45-49 |
| processing said input data record, through a series of updating processes successively performed at least one time...wherein a reference file from a plurality of reference files is only used for a single updating process... | AT&T processes the address record through a series of cleansing processes using different USPS reference files (e.g., postal coding, address verification, address conversion). | ¶64 | col. 3:28-36 |
| wherein after said at least one time of performing said updating processes a final output stored in local memory is a cleansed input data record. | Upon completion of the series of updating processes, the final output in volatile memory is a cleansed address record. | ¶64 | col. 3:45-49 |
| outputting said cleansed input data record from said local memory to said remote storage, wherein said input data record is retrieved from said remote storage a single time for performing data hygiene. | AT&T writes the cleansed address record from volatile memory to nonvolatile memory, having retrieved the input record only once. | ¶67 | col. 3:15-22 |
- Identified Points of Contention:
- Scope Questions: A central question will be whether AT&T's multi-function CASS-compliant process constitutes the claimed "single pass" architecture. The defense may argue that the series of distinct CASS functions (postal coding, verification, conversion) are not a "single pass" as envisioned by the patent, even if executed efficiently. The meaning of "remote storage" versus "local memory" in the context of modern data center architecture may also be a point of dispute.
- Technical Questions: For the ’866 Patent system claims, the analysis will focus on the "means for" limitations (e.g., "means for updating"). The scope of these terms is limited to the specific structures (i.e., algorithms) disclosed in the patent's specification. A key question will be whether the accused "matcher software module" is structurally equivalent to the detailed, vector-based matching algorithms described in the patent.
V. Key Claim Terms for Construction
The Term: "single pass" (from ’680 Patent, Claim 1)
Context and Importance: This term is the central feature of the ’680 Patent's asserted claims. The infringement allegation hinges on whether the accused method, which performs multiple distinct data cleansing functions, can be characterized as a "single pass" where the data record is read from remote storage once and written back once for the entire end-to-end process.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself defines the functional result: "wherein said steps...are performed in a single pass...such that each data record of said input file is read from a remote storage location only once...and...is written to a remote storage location only once" (’680 Patent, col. 11:46-55). This language focuses on the number of I/O operations to remote storage, not the number of internal processing steps.
- Evidence for a Narrower Interpretation: The specification contrasts the invention with conventional systems that "perform one operation at a time," resulting in a record being "read from the input file and written to an output file three different times—one for each required action or process" (’680 Patent, col. 1:57-col. 2:2). This context may be used to argue that "single pass" implies a monolithic process, not just an efficient sequence of separate processes.
The Term: "matcher" (from ’866 Patent, Claim 16)
Context and Importance: This term is part of a means-plus-function limitation under 35 U.S.C. § 112(f). Its construction will not be its plain and ordinary meaning but will be limited to the corresponding structure disclosed in the specification and its equivalents. The dispute will concern whether the accused "matcher software module" is structurally equivalent to the patent's disclosed algorithms.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint alleges the function is met by a "matcher software module" (Compl. ¶75), suggesting any software that performs the matching function could be equivalent.
- Evidence for a Narrower Interpretation: The specification discloses a specific corresponding structure: a "weights and penalty matcher" that uses a "vector of degrees of matching" with specific criteria detailed in a multi-page table (’866 Patent, col. 15:21-col. 18:68, including Table 2). This detailed algorithmic disclosure provides a basis for a narrow structural definition, requiring an accused system to use a similar vector-based approach to be equivalent.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that to the extent any steps are performed by a third party, AT&T "directed and/or controlled each such step" (Compl. ¶¶37, 59). This provides a basis for a potential claim of induced infringement, though the complaint does not elaborate with specific factual allegations of intent.
- Willful Infringement: The complaint does not allege pre-suit knowledge of the patents-in-suit. The prayer for relief includes a request for enhanced damages for willful infringement "in the event that evidence is adduced through discovery" (Compl., Prayer for Relief ¶d), which is a placeholder for potential post-filing willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural equivalence: Does AT&T’s use of CASS-certified software to perform a sequence of distinct postal data hygiene functions constitute the "single pass" method claimed in the patents, where a record is read from remote storage only once at the beginning of the entire sequence and written back only once at the end?
- A second key question will be one of structural scope, specific to the ’866 Patent: Is the accused "matcher software module" structurally equivalent to the specific, vector-based matching algorithm disclosed in the patent's specification as the corresponding structure for the "matcher" means-plus-function limitation?
- The case will also present a central evidentiary challenge: What evidence demonstrates how the accused system actually manages data flow between non-volatile "remote storage" and volatile "local memory" during the CASS cleansing process, and does that evidence support the allegation of a single read/write cycle per record for the entire process?