DCT
1:06-cv-21359
Rothschild Trust v. Citrix Systems Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Rothschild Trust Holdings, LLC (Florida)
- Defendant: Citrix Systems, Inc. (Delaware); Citrix Online, LLC (Delaware)
- Plaintiff’s Counsel: Broad and Cassel
- Case Identification: 1:06-cv-21359, S.D. Fla., 05/31/2006
- Venue Allegations: Venue is alleged to be proper as Defendants reside in the district, a substantial part of the events giving rise to the claim occurred in the district, and Plaintiff has suffered injury in the district.
- Core Dispute: Plaintiff alleges that Defendant’s GoToMyPC remote computer access system, and associated products, infringe a patent related to an interactive, remote computer interface system.
- Technical Context: The technology at issue addresses slow internet download speeds by proposing a hybrid system where large data files are stored on a local, portable medium (e.g., a CD-ROM) and are utilized in conjunction with data from a remote server to provide a seamless user experience.
- Key Procedural History: The complaint notes that the patent-in-suit was assigned to the Plaintiff, Rothschild Trust Holdings, LLC, from a predecessor entity, with the assignment attached as an exhibit.
Case Timeline
| Date | Event |
|---|---|
| 1997-09-03 | U.S. Patent No. 6,101,534 Priority Date |
| 2000-08-08 | U.S. Patent No. 6,101,534 Issue Date |
| 2006-03-24 | Patent Assignment Execution Date |
| 2006-05-31 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,101,534 - Interactive, Remote, Computer Interface System
The Invention Explained
- Problem Addressed: The patent's background section identifies the significant time required to download large files like "animated three dimensional images" or "video and/or audio information" over "on-line" connections, which prevents a "seamless and/or continuous presentation." (’534 Patent, col. 3:11-30). This limitation made it difficult to deliver rich, interactive experiences, such as virtual real estate tours, via the internet.
- The Patented Solution: The invention proposes a system where a "remote server assembly" (e.g., a website) holds "primary site data," while a user's "local processor assembly" has access to a "compact, portable and interchangeable computer readable medium" (e.g., a CD-ROM or DVD) containing "auxiliary site data." (’534 Patent, Abstract). When a user connects to the remote server, instead of downloading large media files, the remote server can instruct the local computer to access and utilize the pre-stored auxiliary data from the portable medium in conjunction with the primary data, thereby avoiding lengthy downloads. (’534 Patent, col. 14:11-25).
- Technical Importance: This architecture was designed to significantly enhance the capabilities of a website by enabling the use of "high content data such as full motion video" without the extensive download times that were a major bottleneck for internet applications in the late 1990s. (’534 Patent, col. 5:56-59).
Key Claims at a Glance
- The complaint alleges infringement of "one or more of the claims" but does not identify any specific claims. (’Compl. ¶11). Independent claim 1 is representative of the core invention.
- The essential elements of independent claim 1 include:
- A remote server assembly with primary site data and a primary site address on a computer network.
- A local processor assembly coupled in communication with the remote server.
- A data storage assembly associated with the local processor, which includes a "compact, portable and interchangeable computer readable medium."
- This portable medium contains "auxiliary site data" and "remotely accessible, auxiliary site addresses."
- The system is structured such that the "remote server assembly" can remotely access the auxiliary site addresses on the user's portable medium to "initiate utilization" of the auxiliary data by the local processor.
III. The Accused Instrumentality
Product Identification
The complaint identifies the accused instrumentality as a system "known as 'GoToMyPC,' as well as associated products." (Compl. ¶11).
Functionality and Market Context
The complaint describes the accused product only as an "interactive, remote, computer interface system." (Compl. ¶11). It does not provide any specific technical details regarding the architecture or operation of the GoToMyPC system.
IV. Analysis of Infringement Allegations
The complaint does not provide sufficient detail for a substantive analysis of its infringement allegations. The sole allegation is a conclusory statement that the GoToMyPC system infringes the patent. (Compl. ¶11). No claim chart is provided, nor are any specific features of the accused product mapped to the elements of any patent claim.
No probative visual evidence provided in complaint.
’534 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a remote server assembly...including a quantity of primary site data | The complaint does not provide sufficient detail for analysis. | ¶11 | col. 16:46-47 |
| said remote server assembly including at least one primary site address... | The complaint does not provide sufficient detail for analysis. | ¶11 | col. 16:48-52 |
| a local processor assembly | The complaint does not provide sufficient detail for analysis. | ¶11 | col. 16:53 |
| said local processor assembly being coupled in data transmitting and receiving communication with said remote server assembly | The complaint does not provide sufficient detail for analysis. | ¶11 | col. 16:54-56 |
| said local processor assembly being structured to access said primary site address... | The complaint does not provide sufficient detail for analysis. | ¶11 | col. 16:57-60 |
| at least one data storage assembly...structured to contain a quantity of auxiliary site data thereon... | The complaint does not provide sufficient detail for analysis. | ¶11 | col. 16:61-64 |
| said data storage assembly including a compact, portable and interchangeable computer readable medium | The complaint does not provide sufficient detail for analysis. | ¶11 | col. 16:65-67 |
| said compact, portable and interchangeable computer readable medium including a plurality of remotely accessible, auxiliary site addresses... | The complaint does not provide sufficient detail for analysis. | ¶11 | col. 17:1-4 |
| said remotely accessible, auxiliary site addresses being structured to be remotely accessed by said remote server assembly so as to initiate utilization of said select portions of said quantity of auxiliary site data... | The complaint does not provide sufficient detail for analysis. | ¶11 | col. 17:5-10 |
Identified Points of Contention
- Architectural Questions: The primary point of contention will likely be whether the GoToMyPC system, understood to be a remote desktop access service, employs the hybrid architecture required by the claims. A key question is whether it uses any form of "auxiliary site data" stored on a "compact, portable and interchangeable computer readable medium" that is then triggered by a remote server, as the patent describes for delivering pre-packaged rich media content.
- Evidentiary Questions: Given the lack of specific factual allegations, a central issue will be what evidence, if any, the Plaintiff can present to show that the GoToMyPC product actually contains the physical and functional components required by the claims, such as the portable medium and the specific method of initiating its use by the remote server.
V. Key Claim Terms for Construction
The Term: "auxiliary site data"
Context and Importance: This term is fundamental to the inventive concept of offloading data delivery from the remote server to a local medium. The viability of the infringement claim depends on whether any data used by the GoToMyPC system can be properly characterized as "auxiliary site data" that is associated with "primary site data" from a server.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes this data broadly as including "video images, audio signals, graphical displays, etc. and various combinations thereof." (’534 Patent, col. 14:1-4). This could be argued to encompass a wide variety of data types beyond a single application.
- Evidence for a Narrower Interpretation: The specification consistently frames the auxiliary data as content that is "substantially difficult to quickly and effectively download" (’534 Patent, col. 14:6-10) and is used to enhance a specific "on-line experience" with a "primary site address or 'web site'" (’534 Patent, col. 14:13-15). This context suggests pre-authored, high-bandwidth content intended to supplement a website, not the dynamic screen data of a remote computer's operating system.
The Term: "compact, portable and interchangeable computer readable medium"
Context and Importance: This term appears to recite a specific physical component of the claimed system. Infringement will require proving that the GoToMyPC system uses such a medium. Practitioners may focus on this term because it appears to be a concrete limitation that may not map onto a modern, software-based remote access product.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue the term is not limited to a specific format and could cover any portable data storage, including software distributed on a medium that is later installed.
- Evidence for a Narrower Interpretation: The specification provides specific examples, stating the medium "preferably will include a CD-ROM or DVD medium." (’534 Patent, col. 13:30-34). Further, a subsequent ex-parte reexamination of the patent resulted in a new claim (Claim 23) that explicitly requires the portable medium to be "distinct from a fixed hard drive of said local processor assembly," reinforcing the interpretation that the invention requires a physically separate, portable storage device, not merely software residing on the local hard drive. (US 6,101,534 C1, col. 2:49-51).
VI. Other Allegations
- Indirect Infringement: The complaint makes conclusory allegations of contributory and induced infringement but offers no specific factual basis to support the required elements of knowledge and intent. (Compl. ¶11; WHEREFORE ¶A).
- Willful Infringement: The complaint does not contain an allegation of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural applicability: can the patent’s claims, which describe a system for enhancing a website experience by combining remote data with data from a local, portable medium (like a CD-ROM), be construed to read on the accused GoToMyPC product, a service that provides real-time access to a remote computer's desktop environment?
- A key evidentiary question will be one of technical proof: what evidence can the Plaintiff provide to demonstrate that the accused GoToMyPC system actually performs the functions claimed, specifically the step of a remote server accessing "auxiliary site addresses" on a user's "compact, portable" medium to "initiate utilization" of locally-stored data?