DCT

1:11-cv-11970

DataTern Inc v. Blazent Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:11-cv-11970, D. Mass., 11/07/2011
  • Venue Allegations: Venue is alleged to be proper based on Defendant having committed acts of infringement and regularly conducted business in the District of Massachusetts.
  • Core Dispute: Plaintiff alleges that Defendant’s "Blazent for Enterprise IT" product infringes a patent related to systems and methods for interfacing object-oriented software applications with relational databases.
  • Technical Context: The technology at issue addresses the "object-relational impedance mismatch," a well-known challenge in software engineering, by automating the translation between object-oriented code and relational database structures.
  • Key Procedural History: The complaint notes that the asserted patent, U.S. Patent No. 6,101,502, underwent USPTO reexamination between 2007 and 2009. The proceeding concluded with the reconfirmation of the patentability of all original claims and the confirmation of new claims, a fact that may be raised to support the patent's presumption of validity.

Case Timeline

Date Event
1997-09-26 ’502 Patent Priority Date
2000-08-08 ’502 Patent Issue Date
2009-11-10 ’502 Patent Reexamination Certificate Issued
2011-11-07 Complaint Filing Date

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

U.S. Patent No. 6,101,502 - "Object Model Mapping and Runtime Engine for Employing Relational Database with Object Oriented Software," issued August 8, 2000

The Invention Explained

  • Problem Addressed: The patent's background section describes the inefficiency and complexity of interfacing object-oriented applications with relational databases. Translating object operations into database queries is described as "processor-intensive," while translating database information back into objects can be inaccurate and requires "substantial effort" to maintain when the database structure changes (’502 Patent, col. 1:25-53).
  • The Patented Solution: The invention provides a system that automates this interface. It uses a "mapping tool" to generate a "map" that defines the relationships between a given object model and the database schema (’502 Patent, Fig. 1). This map is then used by a "code generator" to create "interface objects" and a "runtime engine" to manage data access, including the automatic generation of SQL code. This system is intended to provide "transparent access" to the database, so that application programmers do not need direct knowledge of the underlying database structure (’502 Patent, Abstract; col. 2:61-64).
  • Technical Importance: This approach sought to provide a more efficient and maintainable solution to the "object-relational impedance mismatch," a persistent challenge in enterprise software development during the late 1990s and 2000s (’502 Patent, col. 1:25-34).

Key Claims at a Glance

  • The complaint asserts infringement of "one or more of the claims of the ’502 Patent" without specifying any particular claims (Compl. ¶10). Independent claim 1 is a representative method claim.
  • Independent Claim 1 requires:
    • selecting an object model;
    • generating a map of at least some relationships between schema in the database and the selected object model;
    • employing the map to create at least one interface object associated with an object corresponding to a class associated with the object oriented software application; and
    • utilizing a runtime engine which invokes said at least one interface object with the object oriented application to access data from the relational database.
  • The complaint does not explicitly reserve the right to assert dependent claims, but its general allegation covers all claims.

III. The Accused Instrumentality

Product Identification

The complaint identifies "Blazent's Blazent for Enterprise IT" as an accused product and/or service (Compl. ¶10).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality, technical architecture, or method of operation. It is identified only by its marketing name. The complaint alleges that Blazent has "profited" from its infringement but offers no specific details regarding the product's market position or commercial importance (Compl. ¶14).

IV. Analysis of Infringement Allegations

The complaint alleges that the "Blazent for Enterprise IT" product infringes one or more claims of the ’502 Patent, both literally and under the doctrine of equivalents (Compl. ¶10). However, the complaint does not provide specific, element-by-element allegations of infringement or include a claim chart. The infringement theory is asserted in a conclusory manner, and the pleading does not contain sufficient detail to enable a substantive analysis of the infringement allegations. No probative visual evidence provided in complaint.

Identified Points of Contention

  • Architectural Questions: The central factual dispute will be whether the "Blazent for Enterprise IT" product embodies the architecture recited in the asserted claims. A foundational question is whether the accused product utilizes a "map" between an object model and a relational database to generate "interface objects," which are in turn invoked by a "runtime engine" to access the database, as claimed. The complaint provides no information to address this.
  • Functional Questions: What evidence will show that the components of the accused product, if they exist, perform the specific functions required by the claims? For example, does the accused system "employ[] the map to create at least one interface object," or does it use a different mechanism for database abstraction that may fall outside the claim scope?

V. Key Claim Terms for Construction

The complaint’s lack of detail makes it difficult to identify specific claim construction disputes. However, based on the technology, practitioners may focus on the following terms from independent claim 1.

"runtime engine"

  • Context and Importance: This term defines a core component of the claimed invention. Its construction will be critical in determining what types of software architectures are covered by the claims.
  • Intrinsic Evidence for a Broader Interpretation: The specification describes the runtime engine as comprising a plurality of dynamic link libraries (DLLs) that "form the core of the runtime engine 24" and provide functionality for accessing data (’502 Patent, col. 6:1-10; Fig. 5). A party may argue this term should encompass any software component or set of libraries that manages the interaction between an application and a database at runtime.
  • Intrinsic Evidence for a Narrower Interpretation: The specification also discloses a specific implementation, including components named RtCore.dll, OObject, and OOBase, and details a specific sequence of operations for data retrieval and saving (’502 Patent, col. 6:8-29; Fig. 7). A party may argue the term should be limited to this more specific architectural arrangement.

"interface object"

  • Context and Importance: This term describes the entity that bridges the application and the runtime engine. The definition of what constitutes an "interface object" is central to the infringement analysis.
  • Intrinsic Evidence for a Broader Interpretation: The patent states these objects are "employed by the object oriented software application... to access the relational database... via a runtime engine" (’502 Patent, col. 2:35-39). This language could support an interpretation where the term covers any data access object (DAO) or software layer that abstracts database interaction.
  • Intrinsic Evidence for a Narrower Interpretation: A more specific description notes that the generated DLLs "contain one COM interface and implementation class for each class defined by a mapping model" (’502 Patent, col. 6:65-col. 7:1). This may support a narrower construction limited to objects generated with a specific technology (e.g., COM objects) based on the mapping model.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Blazent contributes to and/or induces infringement by "offering and/or selling its... products and/or services... to customers, buyers, sellers, users and others that directly infringe" (Compl. ¶11). The complaint does not plead specific facts to support the knowledge and intent elements of these claims.

Willful Infringement

The complaint alleges that Blazent "has been, and now is, aware of the existence of the ’502 Patent and, its validity after re-examination," and that despite this knowledge, it "continues to willfully, wantonly and deliberately engage in acts of infringement" (Compl. ¶13). This allegation does not specify when Blazent allegedly became aware of the patent.

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

  • A primary issue in this case will be one of evidentiary proof and architectural mapping: Given the complaint's lack of technical specifics, the case will depend entirely on whether discovery reveals that the "Blazent for Enterprise IT" product uses an architecture that corresponds to the claimed system of a "map," "interface objects," and a "runtime engine." The absence of this architecture would likely be fatal to the infringement claim.
  • The case will also turn on claim construction and definitional scope: The central legal dispute will likely be the interpretation of key architectural terms such as "runtime engine" and "interface object". The outcome may hinge on whether these terms are construed broadly to cover general object-relational mapping principles or are limited to the specific COM-based implementations and operational sequences detailed in the patent's specification.