Data Resonance LLC v. TIBCO Software Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Data Resonance LLC (New Mexico)
  • Defendant: TIBCO Software Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:23-cv-11139, S.D.N.Y., 12/22/2023
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Southern District of New York and has committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s software products infringe a patent related to methods for identifying, de-duplicating, and grouping related data records into "families."
• Technical Context: The technology addresses the challenge of data cleanliness in large databases by automatically finding and associating records that are related but not identical, such as varied contact entries for the same person or entity.
• Key Procedural History: The complaint asserts that its service provides Defendant with actual knowledge of infringement, forming a basis for allegations of post-complaint indirect and willful infringement. No prior litigation or administrative proceedings are 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," issued August 23, 2005

The Invention Explained

• Problem Addressed: The patent addresses the problem of duplicate and near-duplicate records in large databases, which are costly for businesses (e.g., sending multiple marketing mailings) and make data retrieval difficult, especially when data is "related but not identical." (’714 Patent, col. 1:12-41).
• The Patented Solution: The invention discloses a "Data Family Record Management System" (DFRMS) that introduces the concept of "families" to group related data records. (’714 Patent, col. 1:53-58). When a new record is added, the system automatically normalizes it, checks for relationships with existing records, de-duplicates it, and assigns it to a family. (’714 Patent, Abstract). The system is designed to identify not only directly related records (e.g., sharing an address) but also indirectly related ones through "multiply nested, embedded relationships," as illustrated in Figure 1 where several distinct business and personal records are linked into a single family. (’714 Patent, Abstract; Fig. 1).
• Technical Importance: The technology aimed to automate the complex, time-intensive, and often manual process of data cleansing and de-duplication in large-scale databases where simple field matching proved insufficient. (’714 Patent, col. 1:42-52).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" and references "Exemplary '714 Patent Claims" in an external exhibit not filed with the complaint (Compl. ¶11, ¶16).
• As an example, independent claim 1 is a method claim that includes the following essential elements:
  • Determining a set of records that are "directly-related" to a new "designated record" based on a common data field value.
  • Using that set of "directly-related records" to automatically determine a "potential family of records" which also includes records that are "indirectly related to each other."
  • Adding the designated record to the potential family if it is not a duplicate of a record already in the family.
  • Setting an indicator in the records of the potential family to signify their relationship. (’714 Patent, col. 18:6-35).

III. The Accused Instrumentality

Product Identification

The complaint identifies infringement by "Exemplary Defendant Products" but details them only in an external exhibit (Exhibit 2) that was not provided with the public filing of the complaint (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality. It makes the conclusory allegation that the products "practice the technology claimed by the '714 Patent" (Compl. ¶16). The complaint further alleges that Defendant's employees directly infringe by "internally test[ing] and us[ing] these Exemplary Products" (Compl. ¶12).

IV. Analysis of Infringement Allegations

The complaint incorporates claim charts from Exhibit 2 by reference, but this exhibit was not provided with the complaint (Compl. ¶16, ¶17). In prose, the complaint alleges that the "Exemplary Defendant Products" satisfy all elements of the "Exemplary '714 Patent Claims" (Compl. ¶16). The specific mapping of accused functionality to claim limitations is not available for analysis. No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question may be whether the patent's teachings, which are exemplified almost exclusively with contact and company data records (e.g., names, addresses, phone numbers), can be read to cover the potentially more abstract or complex data entities and relationships managed by Defendant's enterprise software products (’714 Patent, Fig. 1; col. 5:13-24).
• Technical Questions: A technical question will be what evidence supports the allegation that the accused products perform the specific multi-step process recited in the claims, such as first identifying a "set of directly-related records" and subsequently "using" that specific set to determine "indirectly related" records as required by claim 1 (’714 Patent, col. 18:18-24).

V. Key Claim Terms for Construction

The Term: "family" / "potential family of records"

Context and Importance

This term is the central concept of the patent. Its construction will be critical to defining the boundaries of infringement. Practitioners may focus on this term because its scope determines whether the patent is limited to the contact-list examples provided or can cover more abstract data structures in enterprise software.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification provides a broad definition: "a way to identify a plurality of data records that are related to each other either directly or indirectly, in some type of embedded manner" (’714 Patent, col. 1:58-62). It also suggests applicability to other domains like "medical diagnosis" and "criminal investigation." (’714 Patent, col. 5:2-9).
• Evidence for a Narrower Interpretation: All of the patent's detailed examples and figures depict families of personal and business contact information linked by name, address, or phone number (’714 Patent, Fig. 1, Figs. 11-12). A party might argue that these consistent embodiments implicitly define the scope of a "family" and the nature of the "embedded manner" of the relationship.

The Term: "indirectly related"

Context and Importance

This term distinguishes the invention from basic de-duplication systems. The method of determining "indirectly related" records is a key step in the asserted claims, and its definition will be a focal point of the infringement analysis.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The patent states that relationships can "span multiple levels of indirection," suggesting a recursive or transitive process that could cover complex, multi-hop links within a dataset (’714 Patent, col. 3:24-25).
• Evidence for a Narrower Interpretation: The primary example of an indirect relationship involves a transitive link: Record A is linked to Record B, which is linked to Record C, thus relating A and C (’714 Patent, col. 3:18-23). A party could argue that the term should be construed as being limited to this type of transitive connection via common data fields, rather than other forms of indirect relationships.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement based on Defendant's distribution of "product literature and website materials" that allegedly instruct end users to operate the accused products in an infringing manner (Compl. ¶14). Knowledge for post-suit inducement is alleged to arise from the service of the complaint (Compl. ¶15).

Willful Infringement

The complaint alleges that service of the complaint and its attached (but un-filed) claim charts provides Defendant with "Actual Knowledge of Infringement" (Compl. ¶13). It further alleges that "Despite such actual knowledge, Defendant continues to" infringe, which establishes a basis for post-complaint willful infringement (Compl. ¶14).

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

• A core issue will be one of definitional scope: can the term "family of data records", which is consistently exemplified in the patent using customer contact information, be construed to cover the potentially more abstract data entities and relationships managed by Defendant's enterprise software?
• A key evidentiary question will be whether Plaintiff can produce evidence demonstrating that the accused products perform the patent's specific, multi-step method of first identifying directly related records and then using that initial set to iteratively discover indirectly related ones to form a "family."
• The case may also raise a pleading sufficiency question under Twombly/Iqbal, as the infringement allegations rely heavily on conclusory statements and an external exhibit that was not filed with the complaint, leaving the specific factual basis for the infringement claim unstated in the public record.