DCT

1:25-cv-02264

Audacious Inquiry LLC v. Chesapeake Regional Information System for Our Patients

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Audacious Inquiry LLC v. Chesapeake Regional Information System for our Patients, 1:25-cv-02264, D. Md., 09/22/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Maryland because both Defendants reside in Maryland, maintain a regular and established place of business in the district, and have committed the alleged acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s CRISP Event Notification Delivery (CEND) system infringes three patents related to managing, routing, and creating notifications from disparate healthcare data streams.
  • Technical Context: The technology at issue involves Health Information Exchanges (HIEs), which aggregate patient data from multiple healthcare providers to facilitate care coordination and Event Notification Services (ENS) that alert care teams to patient encounters like hospital admissions.
  • Key Procedural History: The complaint alleges a long history between the parties, beginning with a collaboration to develop the ENS technology at issue. Plaintiffs allege they acquired the intellectual property, including pending patent applications that matured into the patents-in-suit, from Defendant CRISP in 2014. Defendants then licensed this technology from Plaintiffs until 2024, at which point they allegedly ceased the license and launched the accused CEND system as a "copycat product." The complaint asserts assignor estoppel against Defendants for the ’962 and ’475 patents, based on the prior assignment of rights by CRISP and its inventor-officer. The complaint also notes that the ’194 patent overcame a 35 U.S.C. § 101 subject matter eligibility rejection during its prosecution.

Case Timeline

Date Event
2013-03-15 Earliest Priority Date for ’962 and ’475 Patents
2014-04-01 CRISP executes agreement to sell ENS technology and IP to Audacious
2015-10-01 Priority Date for ’194 Patent
2021-03-02 ’962 Patent Issues
2021-09-07 ’194 Patent Issues
2024-07-23 ’475 Patent Issues
2024-09-01 ENS License between parties lapses
2025-09-22 Complaint Filed

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

U.S. Patent No. 10,938,962 - "Network Architecture for Multiple Data Stream Management and Endpoint Visualization,"

  • Patent Identification: U.S. Patent No. 10,938,962, "Network Architecture for Multiple Data Stream Management and Endpoint Visualization," issued March 2, 2021.

The Invention Explained

  • Problem Addressed: Healthcare information is often spread across disparate data streams controlled by different organizations using various communication protocols, making it difficult to aggregate and view relevant information efficiently (Compl. ¶37). Prior art networks required complex, individualized configurations for each data source and forced providers to sift through large volumes of irrelevant data to find what they needed (’962 Patent, col. 1:10-21, col. 3:44-60).
  • The Patented Solution: The patent describes a network architecture with multiple, specialized protocol interfaces designed to connect to these different data streams (’962 Patent, col. 4:18-24). A data stream engine "multiplexes or otherwise aggregates" the incoming signals into a single data stream, which is then provided to a data cluster that can filter the information based on content (such as specific HL7 Admit, Discharge, Transfer messages) and client input, before displaying it on a unified graphical user interface (GUI) (Compl. ¶38; ’962 Patent, Abstract).
  • Technical Importance: The invention provides a specific technological solution for improving HIEs by creating a single, interactive interface where providers can view filtered, relevant patient information aggregated in real-time from multiple, otherwise incompatible sources (Compl. ¶40).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 (Compl. ¶121).
  • Independent Claim 1 requires:
    • A network comprising a plurality of data streams, including real-time data and HL7 Admit, Transfer, Discharge (ADT) Messages.
    • A plurality of protocol interfaces, with at least one configured for HL7.
    • A processor and an output interface coupled to a display for a GUI.
    • A memory with instructions that cause the processor to:
      • "multiplex" signals from the data streams into a "single output" based on the identity of the originating data stream.
      • "dispose a portion" of the HL7 ADTs based on their content and client input.
      • "output the single output" to the GUI, populating fields based on the data stream's identity in real-time.
  • The complaint notes infringement of dependent claims 8 and 10 as well (Compl. ¶121).

U.S. Patent No. 11,114,194 - "Network-Based Systems and Methods for Providing Readmission Notifications,"

  • Patent Identification: U.S. Patent No. 11,114,194, "Network-Based Systems and Methods for Providing Readmission Notifications," issued September 7, 2021.

The Invention Explained

  • Problem Addressed: Conventional HIE notification systems were unreliable, often passing along poor-quality information based on erroneous, manually entered patient data from sources like HL7 ADT messages (Compl. ¶43). This resulted in either failing to route critical information or overwhelming providers with irrelevant alerts, making it difficult to effectively track patient readmissions (’194 Patent, col. 4:34-54).
  • The Patented Solution: The patent discloses a method and system for generating targeted readmission notifications. The system electronically receives healthcare information (including HL7 ADT messages) from multiple distinct sources, parses it, and stores patient-identifying information in a standardized format (’194 Patent, Abstract). It then determines a "readmission time" by comparing a new ADT message against a previously stored ADT message for the same patient. If this time falls within a predefined threshold, the system generates a real-time notification for the healthcare provider (Compl. ¶44, 46; ’194 Patent, col. 10:48-11:1).
  • Technical Importance: The invention provides a specific improvement to computer technology by automating the accurate and efficient identification of patient readmissions, which is a key metric for care quality and cost management in the healthcare industry (Compl. ¶46-47).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 (Compl. ¶125).
  • Independent Claim 1 requires a method comprising:
    • "Electronically receiving" healthcare information in different formats from a plurality of distinct healthcare information sources.
    • "Parsing" the information for HL7 ADT messages and storing patient-identifying information in a standardized format.
    • "Determining... a readmission time" for a patient by "comparing a first HL7 ADT message" (indicating admission) "against a second HL7 ADT message", where the time is the difference between the two.
    • "Generating in real-time" a readmission notification if the readmission time is within a stored threshold and the patient-identifying information indicates the messages are for the same patient.
    • "Transmitting" the notification to the first healthcare provider.
  • The complaint also asserts infringement of dependent claims 10, 13, and 16 (Compl. ¶125).

U.S. Patent No. 12,047,475 - "Parallel Network Architecture for Aggregate Data Routing,"

  • Patent Identification: U.S. Patent No. 12,047,475, "Parallel Network Architecture for Aggregate Data Routing," issued July 23, 2024.
  • Technology Synopsis: The patent addresses problems arising from inconsistent data formats and low-quality information in HIE networks (Compl. ¶51-52). The claimed solution is a network architecture with an "intake interface" that receives user-defined parameters, and a processor that uses these parameters to limit the flow of data from parallel streams, ensuring users receive only the most relevant information (e.g., only specific portions of an HL7 ADT stream) in real-time (Compl. ¶53, 55).
  • Asserted Claims: Independent Claim 1 is asserted (Compl. ¶129).
  • Accused Features: The complaint alleges the CEND system uses this patented network architecture to condition and route aggregated data streams based on user parameters (Compl. ¶129).

III. The Accused Instrumentality

Product Identification

  • The "CRISP Event Notification Delivery" system, also referred to as "CEND" (Compl. ¶8).

Functionality and Market Context

  • The CEND system is alleged to be a "copycat product" and a replacement for Plaintiffs' ENS technology (Compl. ¶8). Its core functionality is described as combining "various vital healthcare encounter data streams into a single output and generates real-time notifications of those encounters" (Compl. ¶11). The complaint alleges Defendants launched CEND almost immediately after giving notice of their intent to let their license to Plaintiffs' patents lapse, and that CEND is offered to customers in Maryland, Florida, and across the United States as part of Defendants' HIE services (Compl. ¶8-9, 121).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts attached as exhibits, but those exhibits were not filed with the complaint. Therefore, the infringement theories are summarized below in prose based on the complaint's narrative allegations.

’962 Patent Infringement Allegations

The complaint alleges that the CEND system is a network that meets the limitations of Claim 1 of the ’962 Patent (Compl. ¶121). The narrative suggests CEND functions as a network comprising multiple data streams (including HL7 ADT messages from healthcare providers), protocol interfaces to connect to them, a processor, and a GUI. The core of the infringement allegation is that CEND's processor executes instructions to perform the claimed functions: multiplexing signals from these disparate streams into a single output, disposing of or filtering portions of the incoming HL7 data based on content and user input, and displaying the resulting filtered information on a GUI for end-users (Compl. ¶9, 11).

’194 Patent Infringement Allegations

The complaint alleges that the CEND system performs a method that meets the limitations of Claim 1 of the ’194 Patent (Compl. ¶125). The theory is that CEND provides event notifications, and in doing so, necessarily performs the claimed steps. This includes electronically receiving healthcare information like HL7 ADT messages from different providers, parsing them, and comparing a new admission ADT message against a prior ADT message for the same patient to determine if a readmission has occurred within a specified timeframe. Upon such a determination, the CEND system allegedly generates and transmits a readmission notification to the relevant healthcare provider in real-time (Compl. ¶11).

  • Identified Points of Contention:
    • Scope Questions: A central question for the ’962 patent will be whether the CEND system's method of data aggregation constitutes "multiplexing" as that term is used in the patent's claims and specification. For the ’194 patent, a key question is whether CEND’s notification functionality is specifically for "readmissions" as distinct from general patient encounter alerts.
    • Technical Questions: What evidence does the complaint provide that the CEND system performs the specific comparison of a "first HL7 ADT message" against a "second HL7 ADT message" to calculate a "readmission time" as required by Claim 1 of the ’194 patent? The complaint does not detail the specific algorithm or technical process used by CEND, raising the question of whether it achieves a similar outcome through a different, non-infringing method.

V. Key Claim Terms for Construction

’962 Patent, Claim 1: "multiplex a plurality of signals ... into a single output"

  • The Term: "multiplex ... into a single output"
  • Context and Importance: This term is central to defining the core function of the claimed network architecture. The dispute may turn on whether the CEND system's data aggregation process falls within the scope of "multiplexing." Practitioners may focus on this term because Defendants could argue that their system combines, blends, or aggregates data in a manner distinct from the technical meaning of multiplexing.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states, "Data stream engine 1402 multiplexes or otherwise aggregates incoming signals" (’962 Patent, col. 4:36-37). This "or otherwise aggregates" language may support a construction that is not limited to traditional time-division or frequency-division multiplexing and could encompass a broader range of data combination techniques.
    • Evidence for a Narrower Interpretation: The claim requires multiplexing to be "based on an identity of the one of the data stream from which the signal originated." This, combined with embodiments showing distinct data streams populating distinct fields in a GUI (’962 Patent, Figs. 4-6), could support a narrower construction requiring a process that maintains source-stream identity through to the final output, rather than simply blending data together.

’194 Patent, Claim 1: "determining ... a readmission time ... by comparing a first HL7 ADT message ... against a second HL7 ADT message"

  • The Term: "determining ... a readmission time ... by comparing a first HL7 ADT message ... against a second HL7 ADT message"
  • Context and Importance: This phrase describes the specific, novel mechanism for identifying a readmission. Infringement will likely depend on whether the accused CEND system performs this exact sequence of operations. Practitioners may focus on this term because it appears to be a precise algorithmic step, and Defendants may argue their system uses a different logic (e.g., checking a patient's status flag upon a new admission rather than directly comparing two historical messages).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue "comparing" should be interpreted broadly to encompass any logical process that uses information derived from two distinct messages to determine if a readmission has occurred, even if the messages themselves are not directly compared.
    • Evidence for a Narrower Interpretation: The claim language is highly specific: "wherein the readmission time is a difference in time between the first HL7 ADT message and the second HL7 ADT message." This provides strong intrinsic evidence that the claim requires a direct calculation based on the two messages, not an indirect status check. This specificity was likely added to overcome prior art and the § 101 rejection mentioned in the complaint (Compl. ¶48).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges indirect infringement (inducement) for the ’194 patent (Compl. ¶125). However, it does not plead specific facts to support the knowledge and intent elements, such as referencing user manuals or marketing materials that instruct customers on how to use the CEND system in an infringing manner.
  • Willful Infringement: The complaint alleges willful infringement for all three patents-in-suit (Prayer for Relief ¶e). The basis for this allegation is Defendants' alleged pre-suit knowledge of the patents, stemming from a multi-year license agreement for the patented technology that immediately preceded the launch of the accused CEND system (Compl. ¶8, 12, 104).

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

  • A core threshold issue will be one of estoppel: To what extent will the doctrine of assignor estoppel, as raised in the complaint, prevent Defendants from challenging the validity of the ’962 and ’475 patents, given that Defendant CRISP previously assigned the underlying intellectual property to Plaintiffs?
  • A key evidentiary question will be one of technical mechanism: Does the accused CEND system's notification logic perform the specific, multi-step process required by Claim 1 of the ’194 patent—namely, calculating a "readmission time" by directly comparing two distinct HL7 ADT messages—or does it achieve a similar result through a fundamentally different, non-infringing technical method?
  • A central dispute will likely be one of definitional scope: Can the term "multiplex," as used in the ’962 patent, be construed broadly enough to read on the data aggregation and filtering methods allegedly used by the CEND system, or is it limited to a narrower technical meaning that the accused system does not practice?