DCT
1:23-cv-05864
Kaufman v. Mondaycom Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Michael Philip Kaufman (New York)
- Defendant: Monday.com Ltd. (Israel)
- Plaintiff’s Counsel: Liston Abramson LLP
- Case Identification: 1:23-cv-05864, S.D.N.Y., 07/10/2023
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is an alien corporation subject to personal jurisdiction in the district, has committed alleged acts of infringement in the district, and maintains a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s online work management services infringe patents related to technology for automatically generating a user interface for relational databases.
- Technical Context: The technology addresses the automated creation of user interfaces for complex relational databases, a foundational element for database-driven software applications and services.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the Asserted Patents.
Case Timeline
| Date | Event |
|---|---|
| 2000-10-31 | Priority Date for ’981, ’220, and ’801 Patents |
| 2011-02-08 | U.S. Patent No. 7,885,981 Issues |
| 2018-07-17 | U.S. Patent No. 10,025,801 Issues |
| 2021-04-13 | U.S. Patent No. 10,977,220 Issues |
| 2023-07-10 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,885,981 - "System and method for automatically generating user interface for arbitrarily complex or large databases"
The Invention Explained
- Problem Addressed: The patent's background describes the development of database systems as a bifurcated process requiring separate, manually intensive efforts to build both the back-end database schema and the front-end user application. This manual coding for the user interface (UI) can become "unwieldy and eventually, untenable" as database models grow in scale and complexity (’981 Patent, col. 7:27-34).
- The Patented Solution: The invention proposes a system that automates the creation of a fully functional UI by directly "interrogating" the back-end database's data model. This automated process generates all necessary user interaction modes (e.g., browse, search, edit, add) for all database tables and integrates mechanisms for navigating and managing the relationships between those tables (’981 Patent, Abstract; col. 8:1-10).
- Technical Importance: This approach sought to significantly reduce the manual programming required to create database applications, thereby accelerating development and ensuring the UI remains synchronized with the underlying database structure (’981 Patent, col. 7:35-40).
Key Claims at a Glance
- The complaint asserts independent claims 1 (method), 4 (system), and 5 (computer-readable media) (Compl. ¶¶ 17, 21, 22).
- The essential elements of independent claim 1 include:
- Automatically generating an end-user interface for working with data in a relational database.
- (a) Providing an output stream from a server that defines a UI paradigm with "create, retrieve, update and delete" modes for a given database table.
- (b) Causing the server to scan the database and apply rules to determine the table structures, constraints, and relationships of the data model, and storing representations of them.
- (c) Causing the server to use these representations to construct a client application that provides a connection to the database, displays table contents for each mode, and integrates processes for representing, navigating, and managing relationships across tables while enforcing relational interdependencies.
- The complaint also asserts dependent claims 2 and 3 (Compl. ¶¶ 19, 20).
U.S. Patent No. 10,977,220 - "Systems and methods for automatically generating user interface elements for complex databases"
The Invention Explained
- Problem Addressed: Similar to its parent patent, the '220 Patent addresses the considerable work involved in "building a complete, fully functional UI for a back-end schema of any appreciable size or complexity," which requires extensive manual coding (’220 Patent, col. 7:27-34).
- The Patented Solution: The patent describes a method for automatically generating a UI by first programmatically discovering the structure of the database. The steps include scanning the database to determine its tables and relationships, creating machine-readable representations of that structure, and then using those representations to construct a client application that provides database connectivity and user interaction mechanisms without requiring "incremental human intervention on a per table basis" (’220 Patent, Claim 1).
- Technical Importance: The invention aims to provide a system that can create a comprehensive database application dynamically, allowing the UI to adapt to any underlying database schema, regardless of complexity (’220 Patent, col. 8:11-18).
Key Claims at a Glance
- The complaint asserts independent claims 1 (method), 11 (system), and 14 (non-transitory computer-readable storage medium) (Compl. ¶¶ 25, 27, 28).
- The essential elements of independent claim 1 include:
- Automatically generating a user interface for working with data in a relational database.
- (a) Scanning the database to determine the tables, constraints, and relationships of the data model.
- (b) Creating machine representations of those tables, constraints, and relationships.
- (c) Constructing from the representations a client application that provides a database connection, displays for CRUD operations, and mechanisms for managing relationships, where the construction "does not require any incremental human intervention on a per table basis."
- The complaint also asserts dependent claim 10 (Compl. ¶ 26).
U.S. Patent No. 10,025,801 - "Systems and methods for automatically generating user interface elements for complex databases"
Technology Synopsis
This patent focuses on a specific UI enhancement within the automatically generated interface. The invention addresses the problem of user-unfriendly foreign key values (often numerical IDs) by automatically replacing, or supplanting, them in the UI with more descriptive, human-readable data derived from the related foreign table (’801 Patent, Abstract; Claim 1).
Asserted Claims
The complaint asserts independent claims 1 (method) and 5 (computer-readable media), along with dependent claims 9, 11, 16, and 18 (Compl. ¶¶ 32, 33, 34).
Accused Features
The complaint alleges that when displaying related data, Monday.com's servers automatically replace an internal numeric "pointer" value (the foreign key) with a more human-friendly description (e.g., a text name) derived from the linked table (Compl. ¶ 31). A screenshot displaying a "Projects" board with a "Tasks" column is provided as an example of this functionality (Compl. ¶ 31).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are the "Monday.com Services," which include online work management, sales/customer relationship management (CRM), and development/product team services, accessible through the Monday.com website (Compl. ¶ 8).
Functionality and Market Context
- The complaint alleges that the Monday.com Services are built upon multi-tenant relational databases that house end-user data (Compl. ¶ 9). Data is presented to users in "boards," which the complaint equates to database tables (Compl. ¶ 10).
- The services allegedly use primary and foreign keys to create relationships between data in different boards, as illustrated by sample API code for a "Connect Boards" feature (Compl. ¶ 11).
- A core allegation is that the Monday.com UI dynamically adapts to structural changes made by the user to the database, automatically generating an interface that works with the modified structure without advance knowledge of those changes (Compl. ¶ 13). The UI provides functionality to create, retrieve, update, and delete relational data (Compl. ¶ 14).
IV. Analysis of Infringement Allegations
’981 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) providing an output stream from said server, for user display and input devices, defining a user interface paradigm comprising a set of modes for interacting with a given database table, said modes comprising create, retrieve, update and delete... | Monday.com provides an HTTP protocol stream from its servers to the user's web browser, defining a UI with modes for create, retrieve, update, and delete operations. | ¶18 | col. 9:56-61 |
| (b) causing said server to scan said database and apply a body of rules to determine the table structures, constraints and relationships... and store representations thereof... | On information and belief, the server scans the user's database and applies rules to determine its structure, evidenced by the UI's observed ability to dynamically adapt to user modifications like adding a "Connect Boards" column. | ¶18 | col. 10:29-35 |
| (c) causing said server to use said representations to construct a corresponding client application for access through said user display and input devices | The server uses the stored representations to construct the client application, as seen when screens reflecting a user-modified database are rendered. | ¶18 | col. 10:36-40 |
| wherein said client application... integrates into each said mode display processes for representing, navigating, and managing said relationships across tables... | The UI integrates processes for managing inter-table relationships. The complaint provides a screenshot showing a "Mirror" and "Tasks" display to illustrate "Representing" relationships (Compl. ¶18). | ¶18 | col. 10:45-53 |
Identified Points of Contention
- Evidentiary Questions: The allegations for internal server-side actions, such as "scan[ning] said database" and "stor[ing] representations," are based on "information and belief" and inferred from the externally observable behavior of the UI dynamically adapting to schema changes (Compl. ¶ 18). A central question may be whether this inference is sufficient to plead, and later prove, that the accused system performs these specific, claimed internal steps.
- Scope Questions: The case may turn on the construction of "automatically generating an end-user interface." A question for the court could be whether this requires the specific sequence of scanning, storing representations, and constructing a client application as laid out in the claim, or if it could be read more broadly to cover other methods of dynamically rendering a UI based on a database schema.
’220 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) scanning the database to determine the tables, constraints, and relationships of the data model; | Monday.com's systems allegedly scan the user's database to determine its structure, which is inferred from the UI's ability to dynamically adapt to changes made by users. | ¶25 | col. 38:20-23 |
| (b) creating machine representations of the tables, constraints, and relationships; and | The systems allegedly create machine representations of the database structure, also inferred from the UI's dynamic adaptation to user changes. | ¶25 | col. 38:24-25 |
| (c) constructing from the representations a corresponding client application that provides... (iii) mechanisms for representing, managing, and navigating the relationships... wherein constructing the corresponding client application does not require any incremental human intervention on a per table basis. | The system uses the representations to build a client application with mechanisms for managing relationships, as shown in screenshots for "Representing," "Navigating," and "Managing" (referenced from Compl. ¶18). This construction is alleged to be done automatically "regardless of the number of tables." | ¶25 | col. 38:26-38 |
Identified Points of Contention
- Technical Questions: Similar to the '981 patent, the key technical question is what evidence exists to show that the accused system actually performs the "scanning" and "creating machine representations" steps. The complaint's theory relies on the UI's dynamic adaptation as circumstantial evidence of these internal workings (Compl. ¶ 25).
- Scope Questions: The limitation "does not require any incremental human intervention on a per table basis" may become a focal point. The dispute could center on what level of automation is required to meet this element and whether Monday.com's system, which may use pre-configured templates or other structures, performs the construction in a way that is truly free of per-table human intervention as contemplated by the patent.
V. Key Claim Terms for Construction
The Term: "automatically generating"
Context and Importance
This term appears in the preamble of the asserted independent claims of both the ’981 and ’220 patents and is foundational to the alleged invention. Its construction will be critical for determining whether the accused system's process for creating and updating its UI falls within the scope of the claims. Practitioners may focus on whether "automatically" requires the specific multi-step process recited in the claims (scan, represent, construct) or can encompass other methods of dynamic UI creation.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification describes an objective of providing a UI "without any custom software programming," suggesting the term may be interpreted broadly to cover any system that achieves this outcome (’981 Patent, col. 7:38-40).
- Evidence for a Narrower Interpretation: The claim bodies explicitly recite a sequence of steps (e.g., scanning the database, creating representations, constructing an application from them). This suggests "automatically generating" might be limited to a process that includes these specific steps (’981 Patent, Claim 1).
The Term: "scan said database" / "scanning the database"
Context and Importance
This term, found in claim 1(b) of the ’981 Patent and claim 1(a) of the ’220 Patent, describes a specific action the server allegedly performs. Because this is an internal process not directly visible to an end-user, its definition is crucial. The plaintiff infers this action from the UI's behavior, and the defendant may argue its system does not "scan" as required by the patent.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification uses the term "interrogate" synonymously with scanning, stating the system "can automatically 'interrogate' this schema, and 'absorb' its structure into an internal cache" (’981 Patent, col. 7:44-46).
- Evidence for a Narrower Interpretation: The detailed description discusses interrogating an RDBMS to derive specific information like tables, column complements, datatypes, constraints, and relationships, suggesting the "scan" may need to be a comprehensive discovery of the formal data model (’981 Patent, col. 15:19-24).
VI. Other Allegations
Indirect Infringement
The complaint focuses on allegations of direct infringement under 35 U.S.C. § 271(a), based on Defendant's alleged operation of servers in the U.S. that perform the patented methods (Compl. ¶¶ 17, 25, 32). No separate counts for indirect infringement are included.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of evidentiary sufficiency: The complaint's allegations of key internal server functions—"scanning" the database and "creating representations"—are based on inference from the UI's externally-observed dynamic behavior. A key question for the court will be whether this circumstantial evidence is sufficient to plausibly allege, and ultimately prove, that the accused system performs the specific internal processes recited by the claims.
- A second central issue will be one of claim scope: The case will likely involve significant debate over the meaning of "automatically generating." The key question is whether this term requires the specific, ordered process of schema interrogation, representation, and construction laid out in the claim bodies, or if it can be interpreted more broadly to cover any system that dynamically adapts its UI to database schema changes without requiring manual recoding by a developer.