DCT

1:25-cv-01563

DataCloud Tech LLC v. Alteryx Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01563, D. Del., 12/26/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is incorporated in the state of Delaware.
  • Core Dispute: Plaintiff alleges that Defendant’s website infrastructure and its Alteryx AppBuilder product infringe three patents related to anonymous network communication, distributed software deployment, and metadata-based content management.
  • Technical Context: The technologies at issue concern foundational methods for providing secure network communications and for efficiently developing and deploying dynamic, data-driven web applications across distributed networks.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the asserted patents through a series of communications directed to its Chief Legal Officer, beginning with a letter on November 4, 2020, and including a notice letter with a draft complaint on June 27, 2025. This history of alleged notice may form the basis for a claim of willful infringement.

Case Timeline

Date Event
2000-02-15 U.S. Patent No. 8,607,139 Priority Date
2000-04-04 U.S. Patent No. 7,209,959 Priority Date
2001-02-20 U.S. Patent No. 7,246,351 Priority Date
2007-04-24 U.S. Patent No. 7,209,959 Issued
2007-07-17 U.S. Patent No. 7,246,351 Issued
2013-12-10 U.S. Patent No. 8,607,139 Issued
2020-11-04 First notice letter sent to Defendant
2025-06-27 Notice letter and draft complaint sent to Defendant
2025-12-26 Complaint Filed

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

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”*

The Invention Explained

  • Problem Addressed: The patent describes the problem of user privacy on the internet, where a client’s identifying information (such as an IP address) can be recorded and tracked by web servers, leading to privacy threats like unwanted solicitations and user profiling through "cookies" (’959 Patent, col. 1:56-65).
  • The Patented Solution: The invention proposes a system using three distinct logical components—a "deceiver," a "controller," and a "forwarder"—to create an anonymous communication session. The deceiver intercepts the client's initial request, the controller resolves the true destination and establishes a session with a forwarder, and the forwarder relays traffic such that neither the client nor the destination server are aware of each other's true identity or the forwarder's role as an intermediary (’959 Patent, Abstract; col. 2:35-51). Figure 1 illustrates this three-part architecture (’959 Patent, Fig. 1).
  • Technical Importance: This method was designed to provide session-specific anonymity that was more robust than conventional proxy servers, allowing for the creation of "virtual namespaces" for secure and private group communications (’959 Patent, col. 2:51-65).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶18).
  • The essential elements of claim 1 include:
    • In response to a client request, setting up a forwarding session using a "forwarder" disposed between the client and a destination server.
    • Implementing the session such that neither the client nor the destination server is aware of the "forwarder's" employment.
    • Employing a "controller" to communicate with the "forwarder" and a domain name server (DNS), where the "controller" queries the DNS for the destination and initiates communication with the "forwarder".
    • Employing a "deceiver" to receive the client's initial request and instruct the "controller" to query the DNS.
    • Initiating the forwarding session after the "controller" receives the DNS response and communicates with the "forwarder".
  • The complaint states infringement of "one or more claims" of the ’959 Patent (Compl. ¶17).

U.S. Patent No. 7,246,351 - *“System And Method For Deploying And Implementing Software Applications Over A Distributed Network”*

The Invention Explained

  • Problem Addressed: The patent addresses the difficulties of deploying and updating software on remote devices, particularly resource-constrained wireless devices. Standard browser-based applications require constant network connectivity, while traditional locally installed applications are large, difficult to install, and costly to update (’351 Patent, col. 2:25-63).
  • The Patented Solution: The invention describes an "Application Virtual Machine" (AVM), a small, lightweight assembler program that resides on the client device. The AVM downloads text files (e.g., XML) containing application-specific program logic from a server and "assembles" this logic on-the-fly into a functioning graphical application in the device's temporary memory. This separates the application logic from the execution engine, allowing for easy updates and reducing the size of initial downloads (’351 Patent, Abstract; col. 3:9-24).
  • Technical Importance: This thin-client architecture aimed to provide the rich user experience of a native application with the simplified deployment and maintenance of a web-based application, which was particularly significant for the emerging mobile computing market (Compl. ¶25; ’351 Patent, col. 3:1-7).

Key Claims at a Glance

  • The complaint asserts at least independent claim 14 (Compl. ¶28).
  • The essential elements of claim 14 include:
    • Storing and running a "software module" on a user's client device.
    • Providing text files to the client device that contain "embedded program logic".
    • The "software module" uses the logic to "assemble" a computer program that provides a graphical user interface (GUI).
    • Running the assembled computer program on the client device.
    • Enabling user interaction with the running program.
  • The complaint states infringement of "one or more claims" of the ’351 Patent (Compl. ¶27).

U.S. Patent No. 8,607,139 - *“System and process for managing content organized in a tag-delimited template using metadata”*

Technology Synopsis

The patent addresses the inefficient process of creating and updating multiple web pages that share a common structure but contain different content. The invention provides a system for managing content using a "metadata template" that defines the structure, appearance, and data types for a set of content, which can then be used to automatically generate data entry forms and the final web pages without requiring custom programming for each page (’139 Patent, Abstract; col. 2:40-54).

Asserted Claims

The complaint asserts at least claim 8 (Compl. ¶38).

Accused Features

Defendant's "Alteryx AppBuilder" is accused of infringing by allegedly providing a method to display a graphical interface based on a metadata template, generate a corresponding data entry form, and then generate a web page based on the content entered into the form (Compl. ¶38).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses "Defendant's website infrastructure" of infringing the ’959 and ’351 patents, and the "Alteryx AppBuilder" product of infringing the ’139 patent (Compl. ¶¶18, 28, 38).

Functionality and Market Context

  • The complaint alleges that the "website infrastructure" operates by setting up forwarding sessions for communications between clients and destination websites, suggesting a system architecture involving proxies, load balancers, or similar network intermediaries (Compl. ¶18). This infrastructure is also alleged to deploy software to client devices by providing text files with embedded logic that assemble into a functional web application (Compl. ¶28).
  • The "Alteryx AppBuilder" is alleged to be a tool that uses metadata templates to define the structure of a web page, generate data entry interfaces, and subsequently create the final web page based on user-provided content (Compl. ¶38).
  • The complaint does not provide specific details regarding the market positioning or commercial importance of the accused instrumentalities beyond general allegations of commercial activity (Compl. ¶¶17, 27, 37).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

7,209,959 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 to forward packets... Setting up a forwarding session using a forwarder disposed between the client and destination server to forward packets between them. ¶18 col. 6:50-58
...wherein the forwarding session is set up and implemented such that neither the client nor the destination server is aware of the employment of the forwarder... The forwarding session is set up and implemented so that the client and destination server are unaware of the forwarder. ¶18 col. 3:45-53
...employing a controller configured to communicate with the forwarder and a domain name server, wherein the controller queries the domain name server to resolve the name of the destination website... Employing a controller that communicates with the forwarder and a domain name server, which it queries to resolve the destination website's name. ¶18 col. 3:14-21
...employing a deceiver configured to communicate with the controller and the client, wherein the deceiver receives the request by the client... and initiates the controller to query the domain name server... Employing a deceiver that communicates with the controller and the client, receiving the client's request and initiating the controller to query the domain name server. ¶18 col. 2:38-43
...in response to the controller receiving the answer from the domain name server and initiating communication with the forwarder, initiating the forwarding session. In response to the controller receiving the answer from the domain name server and communicating with the forwarder, the forwarding session is initiated. ¶18 col. 7:10-14

7,246,351 Patent Infringement Allegations

Claim Element (from Independent Claim 14) Alleged Infringing Functionality Complaint Citation Patent Citation
storing and running a software module on a client device of a user; Storing and running a software module on a user's client device. ¶28 col. 4:30-32
providing to the client device text files containing embedded program logic for the software module to assemble into the computer program... Providing text files with embedded program logic that the software module assembles into a functioning application, such as a website application. ¶28 col. 3:14-19
...wherein the computer program provides a graphical user interface for receiving and interpreting user inputs to the client device... The assembled application provides a graphical user interface for receiving and interpreting user inputs. ¶28 col. 5:59-62
...enabling user interaction with the computer program running on the client device. Enabling user interaction with the computer program running on the client device. ¶28 col. 11:26-30

Identified Points of Contention

  • Scope Questions: For the ’959 Patent, a central question may be whether the Defendant's "website infrastructure" embodies the discrete "deceiver", "controller", and "forwarder" components required by the claim, or if it uses a different, more integrated architecture. For the ’351 Patent, the dispute may focus on whether a standard web browser rendering a modern web application qualifies as a "software module" that "assembles" a "computer program," as the patent appears to distinguish its "Application Virtual Machine" from conventional browser technology (’351 Patent, col. 2:31-41).
  • Technical Questions: For the ’959 Patent, a key factual question is what evidence demonstrates that "neither the client nor the destination server is aware of the employment of the forwarder" within the accused system (Compl. ¶18). For the ’351 Patent, the analysis may require identifying the specific "software module" on the client device, separate from a generic web browser, that performs the claimed "assembling" of program logic (Compl. ¶28).

V. Key Claim Terms for Construction

  • The Term: "deceiver" (’959 Patent, Claim 1)
  • Context and Importance: The validity of the infringement theory for the ’959 Patent depends on mapping the accused infrastructure to the claim's three-part architecture. The construction of "deceiver" as a distinct logical or structural entity, separate from the "controller" and "forwarder," will be critical. Practitioners may focus on this term because if its function is integrated with another component in the accused system, it could suggest non-infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the deceiver as an "algorithm" or "routine" that "provides name resolution for clients," which could support a construction covering any function that intercepts and redirects a client's initial network request, regardless of its structural implementation (’959 Patent, col. 2:38-43).
    • Evidence for a Narrower Interpretation: The patent's figures, particularly Figure 1, depict the Deceiver (104) as a distinct block in the system architecture, separate from the Controller (106) and Forwarder (107), which may support an argument that the claim requires structural or at least logical separateness (’959 Patent, Fig. 1).
  • The Term: "software module to assemble" (’351 Patent, Claim 14)
  • Context and Importance: This term is central to determining whether the patent reads on modern web application technology. The defendant may argue that a web browser merely "interprets" or "renders" code, while the patent requires a more active "assembling" process akin to compiling or linking. Practitioners may focus on this term because the patent repeatedly contrasts its "AVM" technology with standard browser-based solutions (’351 Patent, col. 2:31-41).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the AVM as a program that "interprets XML and other code downloaded from a web server... to render a full-featured application," language that could be argued to encompass a browser processing JavaScript and data files to create a dynamic web app (’351 Patent, col. 5:22-25).
    • Evidence for a Narrower Interpretation: The patent's abstract describes a process where program logic is retrieved and "assembles the retrieved program logic into a functioning application," which suggests a step beyond mere rendering (’351 Patent, Abstract). The consistent distinction from browser-based solutions could further support a narrower construction limited to a dedicated, non-browser "module."

VI. Other Allegations

  • Indirect Infringement: The complaint does not provide sufficient detail for analysis of indirect infringement. The infringement counts focus on Defendant's direct performance of the claimed methods (Compl. ¶¶18, 28, 38).
  • Willful Infringement: The complaint alleges that Defendant had pre-suit knowledge of the asserted patents and its alleged infringement based on a series of letters and emails sent to its Chief Legal Officer beginning on November 4, 2020 (Compl. ¶10). These allegations form the basis for a potential claim of willful infringement.

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

  • A core issue will be one of architectural mapping: does the defendant's allegedly infringing "website infrastructure" implement the distinct three-part "deceiver-controller-forwarder" architecture required by the ’959 patent, or does it utilize a different system that falls outside the claim's structural limitations?
  • A key evidentiary question will be one of technological equivalence: does a modern web browser's process of rendering a dynamic single-page application from server-sent data and scripts constitute the claimed method of a dedicated "software module" that "assembles" "embedded program logic" as described in the ’351 patent, or is there a fundamental mismatch in technical operation?
  • The case may also turn on the definitional scope of "metadata template" in the ’139 patent. Can the functionality of the accused Alteryx AppBuilder be distinguished from the claimed method of using a template to define the structure of content, generate data entry forms, and ultimately produce a web page?