DCT
1:20-cv-24742
MindbaseHQ LLC v. Alphabet Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: MindbaseHQ LLC (Florida)
- Defendant: Alphabet, Inc. (Delaware)
- Plaintiff’s Counsel: Weiss Serota Helfman Cole & Bierman, P.L.; Iaconis Law Office; Rath, Young and Pignatelli, P.C.
- Case Identification: 1:20-cv-24742, S.D. Fla., 11/17/2020
- Venue Allegations: Venue is alleged to be proper because Defendant Alphabet has committed acts of infringement and maintains a physical place of business in the Southern District of Florida.
- Core Dispute: Plaintiff alleges that Defendant’s Google Search and Google Ads services infringe two patents related to a specific database structure that categorizes information into "tangible" and "intangible" elements.
- Technical Context: The technology concerns a method for structuring databases intended to mimic the human mind's organizational principles to improve the integration of heterogeneous data sources.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 1997-06-04 | Earliest Priority Date for ’433 and ’680 Patents |
| 2003-01-21 | U.S. Patent No. 6,510,433 Issued |
| 2003-12-16 | U.S. Patent No. 6,665,680 Issued |
| 2020-10-19 | Date Plaintiff last accessed Google’s informational webpages cited in the complaint |
| 2020-11-17 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,510,433 - "Database Structure Having Tangible and Intangible Elements and Management System Therefor," Issued January 21, 2003
The Invention Explained
- Problem Addressed: The patent describes several problems inherent in conventional database systems, including the difficulty and expense of integrating heterogeneous databases, the inability to keep all data relationships "on line at all times," and data duplication across multiple storage locations (Compl. ¶16; ’433 Patent, col. 1:41-58).
- The Patented Solution: The invention proposes a new database structure that organizes all information by categorizing data elements into two fundamental types: "tangible data elements" (representing physical things with weight) and "intangible data elements" (representing concepts, words, and actions with no weight). The intangible elements are further divided into "effect" data (e.g., verbs) and "descriptive" data. This structure, purported to be modeled on the human mind, is intended to provide a "single unique format for all data" to allow for the seamless integration of disparate databases (’433 Patent, Abstract; col. 2:10-43).
- Technical Importance: The claimed approach sought to solve the persistent problem of database interoperability by creating a universal, foundational classification system for all types of data, thereby reducing the need for expensive, custom reprogramming to merge different systems (’433 Patent, col. 2:51-64).
Key Claims at a Glance
- The complaint asserts independent claim 13 (’433 Patent, Compl. ¶23).
- The essential elements of claim 13 are:
- A database of information stored in a fixed medium,
- comprising a set of tangible data elements, representing things which have physical weight and can cause an effect;
- a set of intangible data elements, representing words and concepts which have no physical weight and cannot be weighed;
- the set of intangible data elements including a first subset of effect data elements (representing verbs describing actions, objectives, etc.);
- the set of intangible data elements including a second subset of descriptive data elements (describing the tangible elements, effect elements, and degrees of performance);
- wherein each tangible data element is linked to each effect data element it causes, and each effect element is linked to each tangible data element required for the effect;
- wherein at least one link between a tangible and an intangible element is itself linked to a specific degree of performance describing the cause-effect relationship.
- The complaint reserves the right to assert other unspecified claims of the ’433 Patent (Compl. ¶23).
U.S. Patent No. 6,665,680 - "Database Structure Having Tangible and Intangible Elements and Management System Therefor," Issued December 16, 2003
The Invention Explained
- Problem Addressed: As a continuation of the application that led to the ’433 Patent, the ’680 Patent addresses the same technical problems of integrating heterogeneous databases and managing complex data relationships (’680 Patent, col. 1:43-58).
- The Patented Solution: The solution is identical in concept to the ’433 Patent: a database structure based on the fundamental division of data into "tangible" (cause) and "intangible" (effect/descriptive) elements to create a universal format for information (’680 Patent, Abstract; col. 2:19-44).
- Technical Importance: The patent aims to provide a pre-programmable format that can "automatically integrate an unlimited number of heterogeneous databases" without the repeated, customized programming required by other systems (’680 Patent, col. 2:60-64).
Key Claims at a Glance
- The complaint asserts infringement of claim 13 (Compl. ¶35). However, the complaint quotes the language of independent claim 1 in its overview of the patent's technology (Compl. ¶13). The infringement allegations in the body of the complaint track the language of claim 1, with the final limitation of dependent claim 13 included in the final allegation (Compl. ¶¶37-42).
- The essential elements of independent claim 1 are:
- A database of information stored in a fixed medium,
- comprising a set of tangible data elements (representing things with physical weight);
- a set of intangible data elements (representing words/concepts with no weight);
- the intangible elements including a first subset of "effect data elements" (describing actions, objectives, etc.);
- the intangible elements including a second subset of "descriptive data elements" (describing tangible elements, effect elements, degrees of performance, etc.);
- wherein each tangible element is linked to the effect element it causes, and each effect element is linked to the tangible element required for it to occur.
- Dependent claim 13 adds the limitation that "at least one of each said link... is itself linked to at least one specific degree of performance that describes in more detail said cause-effect relationship" (’680 Patent, col. 36:15-21; Compl. ¶42).
III. The Accused Instrumentality
- Product Identification: The complaint identifies "the Google internet search and Google Ads" services as the "Alphabet Accused Services" (Compl. ¶19).
- Functionality and Market Context: The complaint alleges that the Accused Services operate using databases that infringe the patents-in-suit (Compl. ¶21). The infringement theory is based on Google's use of "structured data," which the complaint describes as a "standardized format for providing information about a page and classifying the page content" (Compl. ¶24, ¶36). A screenshot from a Google developer webpage explains Google's use of structured data to understand and classify page content (Compl. ¶24). This structured data allegedly allows Google to "gather information about the web and the world in general" (Compl. ¶24, ¶36). The complaint also alleges that Google Ads uses search queries "to deliver highly targeted, relevant ads" (Compl. p. 7).
IV. Analysis of Infringement Allegations
’433 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A database of information stored in a fixed medium... | The technology behind the Alphabet Accused Services includes a database of information stored in a fixed medium. | ¶25 | col. 3:62-63 |
| a set of tangible data elements, said tangible data elements representing things which have physical weight and can cause an effect; | The technology behind the Alphabet Accused Services includes a set of tangible data elements representing things which have physical weight and can cause an effect. | ¶26 | col. 4:1-4 |
| a set of intangible data elements, said intangible data elements representing words and concepts which have no physical weight and cannot be weighed; | The technology behind the Alphabet Accused Services includes a set of intangible data elements representing words and concepts which have no physical weight and cannot be weighed. | ¶27 | col. 4:4-6 |
| said set of intangible data elements including a first subset of effect data elements... which describe actions, objectives, results, missions, procedures and processes; | The Alphabet Accused Services includes a set of intangible data elements with a first subset of effect data elements representing verbs which describe actions, objectives, etc. | ¶28 | col. 4:7-11 |
| said set of intangible data elements including a second subset of descriptive data elements... describing said tangible data elements, said effect data elements and degrees of performance... | The Alphabet Accused Services includes a set of intangible data elements with a second subset of descriptive data elements describing the tangible elements, effect elements, and degrees of performance. | ¶29 | col. 4:11-15 |
| wherein each said tangible data element is linked to each said effect data element... and each said effect element is linked to each said tangible data element required for said effect to occur; | The Alphabet Accused Services include a structure wherein each tangible data element is linked to each effect data element it causes, and each effect element is linked to each tangible data element required for the effect. | ¶30 | col. 4:15-19 |
| wherein at least one of each said link... is itself linked to at least one specific degree of performance that describes in more detail said cause-effect relationship... | The Alphabet Accused Services include a structure wherein at least one link is itself linked to a specific degree of performance describing the cause-effect relationship in more detail. | ¶30 | col. 4:20-25 |
’680 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A database of information stored in a fixed medium... | The technology behind Alphabet Accused Services includes a database of information stored in a fixed medium. | ¶37 | col. 4:21-22 |
| a set of tangible data elements, said tangible data elements representing things which have physical weight and can cause an effect; | The technology behind the Alphabet Accused Services includes a set of tangible data elements representing things which have physical weight and can cause an effect. | ¶38 | col. 4:24-26 |
| a set of intangible data elements, said intangible data elements representing words and concepts which have no physical weight and cannot be weighed; | The technology behind the Alphabet Accused Services includes a set of intangible data elements representing words and concepts which have no physical weight and cannot be weighed. | ¶39 | col. 4:27-30 |
| said set of intangible data elements including a first subset having effect data elements... which describe... actions, objectives, results, missions, procedures and processes; | The Alphabet Accused Services includes intangible data elements with a first subset of effect data elements describing actions, objectives, etc. | ¶40 | col. 4:31-37 |
| said set of intangible data elements including a second subset having descriptive data elements... describing... said tangible data elements, said effect data elements, degrees of performance... and the nature of the relationship... | The Alphabet Accused Services includes intangible data elements with a second subset of descriptive data elements describing tangible elements, effect elements, degrees of performance, and the nature of the relationship. | ¶41 | col. 4:38-45 |
| wherein: each said tangible data element is linked to each said effect data element... and, each said effect element is linked to each said tangible data element required for said effect to occur; | Alphabet Accused Services include a structure wherein each tangible data element is linked to each effect element it causes, and each effect element is linked to each tangible element required for the effect to occur. | ¶42 | col. 4:46-51 |
| (From dependent claim 13) wherein at least one of each said link... is itself linked to at least one specific degree of performance... | The linking structure is itself linked to at least one specific degree of performance that describes the cause-effect relationship in more detail. A screenshot from a Google webpage describes how 'AdSense ads designed for search results pages' use search queries to deliver targeted ads (Compl. p. 9). | ¶42 | col. 36:15-21 |
- Identified Points of Contention:
- Scope Questions: The complaint alleges that Google's use of structured data (e.g., classifying recipe ingredients) infringes claims requiring a specific categorization of all data. A central dispute may arise over whether data elements in Google's systems, such as a string representing "cooking time," can be properly classified as a "tangible data element" (a thing with physical weight) or an "intangible data element" (a concept with no weight) as those terms are defined in the patents.
- Technical Questions: The infringement allegations consist of conclusory statements that parrot the claim language (Compl. ¶¶25-30, 37-42). The complaint relies on high-level, public-facing documentation about "structured data" (Compl. ¶24, ¶36) but provides no specific factual allegations about the internal architecture of Google's back-end databases. This raises the evidentiary question of what proof exists that the accused databases actually implement the specific hierarchical linking structure between discrete "tangible" and "intangible" elements as required by the claims.
V. Key Claim Terms for Construction
The Term: "tangible data elements"
Context and Importance: This term forms the foundation of the patents' classification scheme. The infringement case depends entirely on whether data within the Alphabet Accused Services can be categorized as "tangible" under the patent's definition. Practitioners may focus on this term because its construction appears to be outcome-determinative for both infringement and potentially patent eligibility.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of evidence supporting a broader interpretation.
- Evidence for a Narrower Interpretation: The claim language itself provides a specific definition: "tangible data elements representing things which have physical weight and can cause an effect" (’433 Patent, cl. 13). The specification reinforces this, defining them as "physical data elements that have weight" (’433 Patent, col. 2:34-35). This explicit, and arguably restrictive, definition may limit the scope of data that falls under this category.
The Term: "intangible data elements"
Context and Importance: As the counterpart to "tangible data elements," the construction of this term is equally critical. The patents require that all data be classifiable into one of these two categories.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests this is a catch-all category, stating they are "all other data elements" besides tangible ones (’433 Patent, col. 2:36).
- Evidence for a Narrower Interpretation: The claim language defines the term as "representing words and concepts which have no physical weight and cannot be weighed" (’433 Patent, cl. 13). The specification further divides this category into specific subsets of "effect" data (verbs) and "descriptive" data, which could be argued to narrow its meaning to only those types of concepts rather than any and all non-physical data.
VI. Other Allegations
The complaint pleads only direct infringement under 35 U.S.C. § 271(a) and does not contain allegations to support indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of definitional scope and patent eligibility: Can the patents' core classification scheme, which divides all information into "tangible data elements" (having physical weight) and "intangible data elements" (having no weight), be construed to read on the data elements in a modern search index? Further, does this method of organizing data by abstract criteria represent patent-eligible subject matter under 35 U.S.C. § 101, a question foreshadowed by the plaintiff's pre-emptive assertion that the claims are directed to "patent-eligible concepts" (Compl. ¶14).
- A key evidentiary question will be one of technical proof: Given that the complaint relies on high-level public documentation, what evidence can be produced to show that the internal back-end architecture of the Alphabet Accused Services actually implements the specific, granular cause-and-effect linking structures between discrete "tangible" and "intangible" elements as recited in the asserted claims?