Data Resonance LLC v. Ziff Davis

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Data Resonance LLC (New Mexico)
  • Defendant: Ziff Davis, Inc. (Sugarsync) (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:24-cv-10002, S.D.N.Y., 12/30/2024
• 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 patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s Sugarsync service and other products infringe a patent related to identifying and managing related "families" of data records in a database.
• Technical Context: The technology concerns automated data cleansing and relationship mapping within large databases, a key function for customer relationship management (CRM), marketing, and data integrity systems.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit.

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 describes the problem of large databases being "plagued by... duplicate data records," which can be costly for marketing campaigns (e.g., sending multiple mailings to the same household) and can make data retrieval difficult (e.g., tracking duplicate billing charges) (ʼ714 Patent, col. 1:12-30). Existing de-duplication systems are described as limited and often require manual, post-entry cleanup, which is inefficient (ʼ714 Patent, col. 1:40-53).
• The Patented Solution: The invention proposes a "Data Family Record Management System" (DFRMS) that uses the concept of "families" to manage records (ʼ714 Patent, Abstract). A "family" is a group of records related directly or indirectly, such as through a shared address, phone number, or company name, even if the records are not identical (ʼ714 Patent, col. 2:58-62; Fig. 1). When a new record is imported, the system automatically normalizes the data, checks for relationships with existing records to identify its "potential family," de-duplicates it, and then adds it to the database, linking it to the appropriate family (ʼ714 Patent, Abstract; col. 2:54-65).
• Technical Importance: This automated approach to identifying complex, embedded relationships aims to maintain a "clean" (duplication-free) data repository in real-time as new data is added, which the patent notes can be "quite beneficial" for managing complex information networks (ʼ714 Patent, col. 4:30-44).

Key Claims at a Glance

• The complaint states it is asserting "one or more claims" and refers to "Exemplary '714 Patent Claims" in an attached exhibit, but does not identify specific claims in the body of the complaint (Compl. ¶11). System claim 41 is a representative independent claim.
• Essential Elements of Independent Claim 41 (System Claim):
  • An automatic de-duplication engine that, upon receiving a designated data record:
  • automatically determines a set of data records... that relate directly... and indirectly to the designated record;
  • adds the designated record to the determined set when it 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 does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint names Defendant Ziff Davis, Inc. parenthetically as "Sugarsync" (Compl. p. 1). The accused instrumentalities are referred to generally as "the Defendant products identified in the charts" and "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the '714 Patent" (Compl. ¶13). It does not, however, describe the specific functionality of the Sugarsync service or other products. The complaint alleges that Defendant directly infringes by "making, using, offering to sell, selling and/or importing" these products within the district (Compl. ¶11). No further details on the products' technical operation or market position are provided.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement of the ’714 Patent but does not provide a claim chart or detailed infringement theory in the body of the pleading (Compl. ¶11). It instead incorporates by reference "charts comparing the Exemplary '714 Patent Claims to the Exemplary Defendant Products" contained in Exhibit 2 (Compl. ¶13-14). As Exhibit 2 was not provided with the complaint, a detailed claim chart summary cannot be constructed. The infringement theory is based on the general assertion that the accused products "satisfy all elements of the Exemplary '714 Patent Claims" (Compl. ¶13). No probative visual evidence provided in complaint.

Identified Points of Contention

• Technical Questions: A primary question will be evidentiary: what proof will be offered to show that the accused products, such as the Sugarsync file synchronization service, perform the specific database management and de-duplication functions recited in the claims? The patent is directed toward managing records with fields like name, address, and phone number to create "families," a process seemingly distinct from cloud-based file storage and synchronization (ʼ714 Patent, Fig. 1; col. 5:13-34). The court will need to examine whether the operational reality of the accused products aligns with the claimed methods.
• Scope Questions: The dispute may turn on the scope of the patent's core concepts. For example, a question for the court could be whether the '714 Patent's claims, which arise from a specification focused on cleaning CRM-style contact databases, can be read to cover the processes for managing user accounts and file metadata in a cloud storage service.

V. Key Claim Terms for Construction

• The Term: "family of related data records" (from claim 41)
• Context and Importance: This term is the central concept of the invention. The outcome of the case will likely depend on whether the data structures and relationships managed by the accused Sugarsync service can be characterized as a "family of related data records." Practitioners may focus on this term because its definition will determine whether the patent's teachings apply to the accused technology domain.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a high-level 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, in some type of embedded manner" (ʼ714 Patent, col. 2:58-62). This language could be argued to support a broad, functional definition not strictly tied to one type of data.
  • Evidence for a Narrower Interpretation: The patent’s examples, figures, and detailed descriptions consistently illustrate "families" in the context of business and personal contact information (e.g., name, address, phone number, company) ('714 Patent, Fig. 1; col. 5:13-43). The problem statement itself is framed around marketing and billing databases (ʼ714 Patent, col. 1:12-39). This may support a narrower construction limited to records containing such contact-oriented data.

VI. Other Allegations

Willful Infringement

The complaint does not contain an explicit allegation of willful infringement or any facts to support pre-suit knowledge by the Defendant. However, the prayer for relief requests that the case "be declared exceptional within the meaning of 35 U.S.C. § 285" and seeks an award of attorneys' fees (Compl. Prayer ¶E.i).

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

• A core issue will be one of definitional scope: can the central claim term "family of related data records," which is described and exemplified in the context of contact/CRM database management, be construed to cover the user account and file metadata management performed by a cloud synchronization service like Sugarsync?
• A key evidentiary question will be one of operational mapping: given the complaint's lack of specific technical allegations, what evidence can be produced to demonstrate that the accused products perform the complex, multi-step method of automatically identifying direct and indirect relationships, de-duplicating, and consolidating records as claimed in the '714 Patent?