Robolaw Corp v. File Right Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Robolaw Corporation (Nevada)
  • Defendant: File Right, Inc. (Nevada)
  • Plaintiff’s Counsel: Troy Law, PLLC
• Case Identification: 2:25-cv-02208, D. Nev., 11/07/2025
• Venue Allegations: Venue is alleged to be proper in the District of Nevada because Defendant is headquartered there and has committed alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s online immigration form preparation services infringe two patents related to automated, network-based systems for generating customized legal documents.
• Technical Context: The technology at issue involves using a client-server architecture to guide users through a question-and-answer process to automatically populate and customize complex documents, aiming to simplify legal and administrative paperwork for consumers.
• Key Procedural History: The complaint notes that in 2018, Defendant (then operating as Forms Direct) stipulated to a court order with the Federal Trade Commission related to deceptive business practices, which included an injunction and a monetary judgment.

Case Timeline

Date	Event
1998-12-14	Earliest Priority Date for ’569 and ’663 Patents
2010-11-30	U.S. Patent No. 7,844,569 Issues
2018-01-01	Defendant's predecessor Forms Direct merges with File Right, LLC
2018-10-15	Court order entered in FTC action against Defendant
2019-05-14	U.S. Patent No. 10,289,663 Issues
2019-05-XX	Plaintiff alleges Defendant's intent to induce infringement began
2020-06-17	Defendant's predecessor Forms Direct changes name to File Right, Inc.
2024-05-XX	Plaintiff alleges Defendant gained knowledge of patents
2025-11-07	Complaint Filed

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

U.S. Patent No. 7,844,569 - Method and System for Electronic Negotiation of Documents

The Invention Explained

• Problem Addressed: The patent's background describes the creation of documents, particularly legal documents, as a difficult and largely manual process that often requires skilled professionals, making it inefficient and inaccessible for many (ʼ569 Patent, col. 1:32-42).
• The Patented Solution: The invention proposes a network-based system where a user on a local machine requests a document, and a server sends back an "interview question set." The server then uses the user's answers, in conjunction with pre-programmed "expert legal logic," to automatically generate a customized document and send it back to the user, often in a protected, non-editable format (ʼ569 Patent, Abstract; Fig. 1A; col. 4:47-67).
• Technical Importance: The technology provided a framework for automating complex document creation over the internet, centralizing the "expert" rules on a server while providing a simplified interface for end-users, thereby reducing the need for direct expert intervention (ʼ569 Patent, col. 2:48-59).

Key Claims at a Glance

• The complaint asserts independent claim 18 and dependent claims 19-22 (Compl. ¶146).
• Independent Claim 18 requires:
  • selecting a document template for a user of a local machine;
  • sending a customization request from the local machine to a server machine;
  • retrieving an interview question set from the server machine for the template;
  • sending the interview question set to the local machine;
  • displaying questions from the set on the local machine;
  • sending answers from the local machine to the server machine;
  • performing expert processes to produce a customized document based on the template and answers; and
  • sending the customized document to the local machine via the network.

U.S. Patent No. 10,289,663 - Method and System for Formation of Electronic Documents

The Invention Explained

• Problem Addressed: The patent addresses the same technical problem as its parent ’569 Patent: the difficulty and inefficiency of manually drafting and customizing documents, which traditionally requires specialized skill or experience (ʼ663 Patent, col. 1:35-51).
• The Patented Solution: The invention describes a server machine that receives a request to customize a document template from a user's local machine. The server retrieves a predetermined question set associated with that template, sends it to the user, receives answers, and then performs "expert processes" using computer code to control the "content and verbiage" of the final customized document, which is then transmitted back to the user ('663 Patent, Abstract; col. 2:15-32).
• Technical Importance: The patented system enables the automated, on-demand creation of professional-quality documents over a network, offering an efficient and cost-effective alternative to manual document preparation ('663 Patent, col. 2:52-65).

Key Claims at a Glance

• The complaint asserts claims 1-46, with a focus on claim 1 in its narrative allegations (Compl. ¶163). Independent claims include 1, 12, and 33.
• Independent Claim 1 is directed to a server machine and requires the processor be configured to:
  • receive a customization request for a legal document template from a local machine;
  • retrieve an interview question set for the template from a group of predetermined question sets;
  • send the interview question set to the local machine;
  • receive answers to the questions from the local machine;
  • perform expert processes, implemented by computer code that controls content and verbiage, to produce a customized electronic legal document; and
  • electronically transmit the customized legal document to the local machine.

III. The Accused Instrumentality

Product Identification

• The "File Right Services," which consist of online services for preparing and completing U.S. immigration forms and applications (Compl. ¶145, ¶162).

Functionality and Market Context

• The complaint describes the accused services as an "interactive e-commerce system" that allows consumers to complete paperwork for processes such as Green Card renewal, U.S. Citizenship applications, and Travel Documents (Compl. ¶145, ¶146). Plaintiff alleges these services are a core part of Defendant's business and generate millions of dollars in annual revenue (Compl. ¶15). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s "File Right Services" directly infringe the asserted patents by operating an "interactive e-commerce system" that performs all steps of the claimed methods (Compl. ¶146, ¶163). The complaint refers to preliminary infringement claim charts in Exhibits 3 and 4; however, these exhibits were not attached to the publicly filed complaint. The body of the complaint itself does not map specific features of the accused services to the claim limitations, instead making conclusory allegations that the services satisfy all limitations (Compl. ¶146, ¶163).

• Identified Points of Contention:
  • Scope Questions: A likely point of dispute will be whether the logic employed by the "File Right Services" qualifies as the "expert processes" or "expert legal logic" required by the claims. The analysis may question whether simple data insertion into a form template meets this limitation, or if a more sophisticated, rule-based system that actively "controls content and verbiage" is required by the patent language.
  • Technical Questions: The claims in both the ’569 and ’663 Patents describe a specific system architecture involving the retrieval of a distinct "interview question set" from storage that is associated with a "document template." A key factual question for the court may be whether the accused system actually implements this architecture. For instance, what evidence does the complaint provide that Defendant's system "retrieves" a question set as a discrete data object, as opposed to generating questions through more integrated web application code?

V. Key Claim Terms for Construction

The Term: "expert processes" / "expert legal logic"

(appearing in ’569 Patent, Claim 18; ’663 Patent, Claim 1)

Context and Importance

• The definition of this term appears central to the dispute, as it quantifies the level of automated intelligence the claimed invention must possess. Practitioners may focus on this term because its construction will likely determine whether the accused system's automated form-filling functionality is sophisticated enough to fall within the scope of the claims.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The patent specification describes the function of the expert logic as being used to "automatically customize a particular document template in accordance with the answers to the particular question set" ('663 Patent, col. 4:37-42). This language could support an interpretation that covers any automated, rule-based system for generating document text from user inputs.
• Evidence for a Narrower Interpretation: The background repeatedly frames the invention as a solution to the problem of needing "skilled or experienced persons" or "expert assistance" like an attorney ('663 Patent, col. 1:45-51). This context could support a narrower construction requiring a system that performs functions analogous to a human expert, such as complex conditional logic, rather than simple data mapping.

The Term: "interview question set"

(appearing in ’569 Patent, Claim 18; ’663 Patent, Claim 1)

Context and Importance

• This term defines a key structural element of the claimed system. The infringement analysis may turn on whether a modern, dynamic web form constitutes a "set" that is "retrieved" from storage.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The claims do not specify a particular data structure for the "set," which may support an argument that any collection of questions presented to a user for a specific document template meets the limitation, regardless of how it is stored or generated.
• Evidence for a Narrower Interpretation: The patent specification explicitly illustrates a "question set storage" as a distinct architectural component from the "document template storage" ('663 Patent, Fig. 1B; col. 4:35-38). This depiction may support a narrower construction requiring the "set" to be a discrete, retrievable object, as opposed to questions embedded within the code of a web page or application.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides its services with "documentation and instructional materials," "user guides," and "website content" that instruct and encourage customers to use the File Right Services in a manner that directly infringes the patents (Compl. ¶60, ¶171).
• Willful Infringement: Willfulness is alleged based on Defendant's purported knowledge of the patents and its infringement. The complaint alleges this knowledge dates back to "at least May 2024," and that Defendant has known its actions would induce infringement by its users since "at least as of May 2019" (Compl. ¶152, ¶153, ¶169, ¶170). The complaint does not provide a specific factual basis for these dates, such as a notice letter or prior litigation.

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

• A core issue will be one of definitional scope: can the term "expert processes," which the patents frame in the context of replacing skilled human drafters, be construed to cover the automated form-filling and data-mapping logic of the accused online service, or does it require a more complex, rule-based engine that actively "controls content and verbiage"?
• A key evidentiary question will be one of architectural correspondence: does the accused "File Right Services" platform embody the specific client-server architecture required by the claims, particularly the discrete steps of retrieving a pre-associated "interview question set" from storage, or does its technical operation fall outside this claimed structure?
• A significant factual dispute may concern the basis for willfulness: what evidence will be presented to substantiate the allegation that Defendant had knowledge of the patents as early as May 2024 and intended for its users to infringe as early as May 2019, and will this evidence be sufficient to support a finding of willful infringement?