Data Resonance LLC v. RELX

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Data Resonance LLC (New Mexico)
  • Defendant: RELX, INC. d/b/a LEXISNEXIS (Massachusetts)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:23-cv-11136, S.D.N.Y., 12/22/2023
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business and having committed alleged acts of infringement in the Southern District of New York.
• Core Dispute: Plaintiff alleges that Defendant’s data aggregation and search products infringe a patent related to methods for identifying and managing "families" of related data records.
• Technical Context: The technology concerns automated data cleansing and relationship mapping in large databases, a critical function for industries that rely on accurate entity data, such as legal research and business intelligence.
• Key Procedural History: The complaint states that Plaintiff is the assignee of the patent-in-suit. No other procedural history, such as prior litigation or administrative patent challenges, is mentioned.

Case Timeline

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

U.S. Patent No. 6,934,714 - "Method and system for identification and maintenance of families of data records"

• Patent Identification: U.S. Patent No. 6,934,714, "Method and system for identification and maintenance of families of data records," issued August 23, 2005. (Compl. ¶9; ’714 Patent, cover).

The Invention Explained

• Problem Addressed: The patent’s background section describes the problem of large databases being "plagued by the presence of duplicate data records," which can be costly for marketing campaigns and make accurate data retrieval difficult, especially when data is not entered consistently. (’714 Patent, col. 1:15-38).
• The Patented Solution: The patent discloses a "Data Family Record Management System" (DFRMS) that automatically processes and manages data records by grouping them into "families." (’714 Patent, Abstract). A family is a set of records related either directly (e.g., sharing a common name) or indirectly. An indirect relationship is formed through an embedded, multi-level connection; for example, a first record sharing an address with a second record, which in turn shares a phone number with a third record, thereby linking the first and third records into a single family. (’714 Patent, col. 4:15-26). This system aims to create a "clean" (duplication-free) data repository by identifying these complex relationships. (’714 Patent, col. 2:27-32).
• Technical Importance: The described approach seeks to improve upon simple field-matching for de-duplication by identifying more complex, non-obvious relationships between records, which is valuable in managing large and diverse datasets. (’714 Patent, col. 4:36-46).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims" without specifying them, incorporating infringement charts in an unattached exhibit. (Compl. ¶11, 16). Representative independent claims include Claim 1 (a method) and Claim 41 (a system).

• Independent Claim 1 (Method):

  • Determining, from a plurality of data records, a set of records that are directly-related to a designated record, where at least one data field has a common value.
  • Using the set of directly-related records to automatically determine a potential family of records that includes the directly-related records and records that are indirectly related to each other.
  • Adding the designated record to the potential family when it is determined not to be a duplicate of another record in the family.
  • Automatically setting an indicator in each data record in the potential family to indicate a family relationship.

• Independent Claim 41 (System):

  • An automatic de-duplication engine that, upon receiving a designated data record:
    • automatically determines a set of data records...that relate directly to the designated record and data records that relate indirectly to the designated record;
    • adds the designated record to the determined set when it is automatically determined that the designated record is not a duplicate; and
    • automatically associates with each record of the determined set an indication of a family of related data records.

The complaint reserves the right to assert other claims, including by the doctrine of equivalents. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name specific products, instead referring to "Exemplary Defendant Products" identified in charts incorporated as Exhibit 2, which was not filed with the complaint. (Compl. ¶11, 16). The defendant, LexisNexis, is a provider of legal, corporate, and public records information services.

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the '714 Patent." (Compl. ¶16). This suggests the accused functionality involves systems that ingest, process, and link vast quantities of data records concerning individuals, companies, and other entities. The core accused function would be the automated identification of relationships between different records—even where they are not identical—to present consolidated or linked information to a user. The complaint alleges Defendant engages in "systematic and continuous business activities" in the district. (Compl. ¶6).

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim charts in Exhibit 2, which is not publicly available. (Compl. ¶17). The analysis below is therefore based on the general allegations in the complaint and the language of a representative claim.

No probative visual evidence provided in complaint.

'714 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central dispute may concern the patent's specific, sequential process for finding relationships. A question for the court will be: "Does the term 'automatically determines,' which the patent describes as a multi-step process of first finding 'directly-related' records and then using that set to find 'indirectly-related' records, read on the accused systems' proprietary entity resolution algorithms, which may use a different, holistic approach?"
• Technical Questions: The case may turn on the specific mechanism of relationship detection. This raises the question: "What evidence will show that the accused products identify relationships through 'multiple levels of embedding' (col. 2:25) in a manner that maps onto the claim limitations, as opposed to using fundamentally different techniques like global similarity scoring or graph-based network analysis?"

V. Key Claim Terms for Construction

The Term: "indirectly related"

• Context and Importance: This term is at the heart of the patent's asserted novelty. The outcome of the case may depend on whether the methods used by LexisNexis to link non-identical records fall within the scope of this term. Practitioners may focus on this term because it distinguishes the claimed invention from simple duplicate detection.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent suggests the concept is expansive, referring to records "related indirectly through multiple levels of embedding." (’714 Patent, col. 2:24-26). This could be argued to encompass any form of multi-step connection between records.
  • Evidence for a Narrower Interpretation: The patent provides a specific example: a first record linked to a second by a common address, with the second linked to a third by a common phone number. (’714 Patent, col. 4:18-26). A party could argue the term should be limited to this type of sequential, field-based linking process.

The Term: "family"

• Context and Importance: Infringement requires that the accused system creates or identifies a "family" of records. The definition of this term will determine what type of data structure or association meets the claim limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent offers a broad definition: "A 'family,' as used herein, is a way to identify a plurality of data records that are related to each other either directly or indirectly." (’714 Patent, col. 2:54-57).
  • Evidence for a Narrower Interpretation: The specification also discusses assigning a "family identifier" to records. (’714 Patent, col. 5:11-13, 22:2-5). A party might argue that forming a "family" requires the creation and assignment of a persistent, formal identifier to a group of records, not just the transient display of linked search results.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to use the products in an infringing manner. (Compl. ¶14). The factual basis for this allegation is incorporated by reference from an unattached exhibit. (Compl. ¶14).

Willful Infringement

The complaint alleges that service of the complaint itself provides "actual knowledge of infringement." (Compl. ¶13). The willfulness allegation appears to be based on Defendant's alleged continuation of infringing activities after receiving this notice. (Compl. ¶14-15).

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

• A core issue will be one of technical scope: Can the patent’s disclosed method—which appears to describe a sequential process of finding direct relationships and then using that set to find indirect ones—be construed to cover the proprietary, and likely more complex, entity resolution algorithms used in modern data aggregation services?
• The case will present an evidentiary question of operational transparency: Given the "black box" nature of the accused services, a central challenge for the plaintiff will be to obtain and present evidence demonstrating how those systems actually function internally, and whether that operation aligns with the specific steps recited in the patent’s claims.