DCT
2:16-cv-00583
Zeno Holdings LLC v. Zoho Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Zeno Holdings, LLC (Texas)
- Defendant: Zoho Corporation (California)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
- Case Identification: 2:16-cv-00583, E.D. Tex., 06/02/2016
- Venue Allegations: Plaintiff alleges venue is proper because Defendant conducts substantial business in the district, including committing at least a portion of the alleged infringing acts within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Zoho CRM Mobile Edition infringes three patents related to automated techniques for prompting a user to log call details and create notations on a mobile device after a communication event.
- Technical Context: The technology addresses methods for automatically capturing and organizing information related to phone calls on mobile devices, a function of significant importance in the Customer Relationship Management (CRM) software market.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2011-06-13 | Earliest Priority Date for ’233, ’836, and ’773 Patents |
| 2013-04-09 | U.S. Patent No. 8,417,233 Issues |
| 2014-06-10 | U.S. Patent No. 8,750,836 Issues |
| 2015-08-25 | U.S. Patent No. 9,118,773 Issues |
| 2016-06-02 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,118,773 - Automated Prompting Techniques Implemented Via Mobile Devices and Systems
- Patent Identification: U.S. Patent No. 9,118,773, “Automated Prompting Techniques Implemented Via Mobile Devices and Systems,” issued August 25, 2015 (Compl. ¶8).
The Invention Explained
- Problem Addressed: The patent family addresses the difficulty for mobile device users to easily record and organize personal notes related to telephone conversations they have just conducted, a task that is often manual and easily forgotten (’233 Patent, col. 1:26-33).
- The Patented Solution: The invention provides for a mobile application that automatically detects the end of a phone call (an "End of Call" or "EoC" event) and, if certain predefined conditions are met, displays a prompt on the user interface, inviting the user to record a note or other content to be associated with the just-completed call (’233 Patent, Abstract; col. 2:15-39).
- Technical Importance: This solution automates a critical data-entry task in business environments, such as sales and support, where maintaining a record of customer interactions within a CRM system is essential for operational efficiency (’836 Patent, col. 5:10-18).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶13).
- Claim 1 of the ’773 Patent includes the following essential elements:
- A method for operating a mobile communication device comprising a processor, a memory, a display, and a user interface.
- Identifying a set of threshold criteria for causing a display of a user interface message.
- Detecting an occurrence of an end of call (EOC) event.
- Determining if the threshold criteria have been satisfied.
- Automatically displaying the user interface message prompting the user to initiate a procedure.
- Initiating the procedure in response to user input, which includes:
- Generating, using input from the user, a portion of digital content.
- Accessing information which includes details relating to the phone call.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 8,750,836 - Automated Prompting Techniques Implemented Via Mobile Devices and Systems
- Patent Identification: U.S. Patent No. 8,750,836, “Automated Prompting Techniques Implemented Via Mobile Devices and Systems,” issued June 10, 2014 (Compl. ¶9).
The Invention Explained
- Problem Addressed: As part of the same patent family, the ’836 Patent addresses the same technical challenge of facilitating timely and organized note-taking on mobile devices following a phone conversation (’233 Patent, col. 1:26-33).
- The Patented Solution: The invention enables a user to define criteria that, when met after a call ends, trigger an automatic on-screen prompt to initiate a procedure for creating and saving an electronic record of the call, associating user-generated content (like notes) with call details (’836 Patent, Abstract). The system is designed to create a durable, accessible record of the interaction for future reference (’836 Patent, col. 2:43-46).
- Technical Importance: By creating a seamless workflow from call completion to data logging, the invention aims to improve the accuracy and completeness of records in professional contexts where such documentation is vital (’836 Patent, col. 5:10-18).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶17).
- Claim 1 of the ’836 Patent includes the following essential elements:
- A method for operating a mobile communication device associated with a first user.
- Enabling the first user to identify a first set of threshold criteria for enabling automatic display of a user interface message.
- Detecting a first event relating to an initiation of a first phone call.
- Determining if an occurrence of a first end of call (EOC) event has been detected.
- Determining if the first set of threshold criteria has been satisfied.
- Automatically displaying the user interface message prompting the user to initiate a first procedure.
- Initiating the procedure in response to user input, which includes:
- Generating, using input from the user, a first portion of digital content.
- Accessing information including details of the first phone call.
- Creating a first electronic data file associating the digital content with call details.
- Saving the electronic data file to a storage device for future access.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 8,417,233 - Automated Notation Techniques Implemented Via Mobile Devices and/or Computer Networks
- Patent Identification: U.S. Patent No. 8,417,233, "Automated Notation Techniques Implemented Via Mobile Devices and/or Computer Networks," issued April 9, 2013 (Compl. ¶10).
Technology Synopsis
- This patent, the parent of the other patents-in-suit, discloses a method for operating a mobile device that detects a "communication event" (such as the end of a phone call). Based on whether user-defined "threshold criteria" are met, the system automatically displays a prompt for the user to initiate a "recommended procedure," such as creating a digital note associated with the event, and then saves that note for future reference (’233 Patent, Abstract).
Asserted Claims
- At least claims 1 and 2, with claim 1 being independent (Compl. ¶21).
Accused Features
- The complaint alleges that the Zoho CRM Mobile Edition's "Log a Call" feature, which prompts users to log call details after a communication event based on whether the call logging feature is enabled and the contact is in the CRM database, infringes the ’233 Patent (Compl. ¶22).
III. The Accused Instrumentality
Product Identification
- Zoho CRM Mobile Edition (Compl. ¶13).
Functionality and Market Context
- The accused product is a mobile application available for Android and other platforms that provides users with access to their online Zoho CRM data (Compl. ¶14, Fig. on p. 3). The complaint focuses on the "Log Calls" functionality, which, after a phone call with a contact in the user's CRM database concludes, presents a "Log this call?" prompt on the device's display. The complaint includes a screenshot illustrating this prompt after an incoming call (Compl. ¶14, Fig. on p. 5). If the user taps "Yes," the application opens a "Call Information" page where details such as call duration, date, time, and user-entered notes can be recorded and saved as an electronic file for future reference (Compl. ¶14, Figs. on p. 8-9).
IV. Analysis of Infringement Allegations
9,118,773 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a method for operating a mobile communication device...comprising: a processor, a memory, a display, and a user interface | The Zoho CRM Mobile Edition is an application that executes on an Android mobile device, which contains a processor, memory, display, and user interface. | ¶14 | col. 9:60-10:11 |
| identifying...a set of threshold criteria for causing a display...of a user interface message | The application identifies as a threshold criterion whether an incoming call's phone number is available in the user's Zoho CRM account. | ¶14 | col. 12:26-35 |
| detecting an occurrence of an end of call (EOC) event... | The application detects when a call is over to determine whether to present the logging option. | ¶14 | col. 7:4-8 |
| automatically displaying...a first user interface message prompting the user to initiate a first procedure... | After a call ends and the threshold criteria are met, the application displays a "Log this call?" message prompting the user to log the call. A screenshot shows this prompt on the mobile device's display (Compl. ¶14, Fig. on p. 5). | ¶14 | col. 7:8-12 |
| initiating the first procedure...in response to receiving an input from the user authorizing initiation | The procedure is initiated when the user taps "Yes" in response to the "Log this call?" prompt. | ¶14 | col. 7:13-17 |
| generating, using the input from the user, a first portion of digital content... | After initiation, the user is presented with a "Call Information" page where they can enter notes and other details, which constitutes digital content. | ¶14 | col. 8:37-40 |
| accessing information which includes details relating to the first phone call | The "Call Information" page comprises details of the call such as call duration, date, and time, which are saved for future reference. | ¶14 | col. 8:40-43 |
8,750,836 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| enabling the first user...to identify a first set of threshold criteria for enabling automatic display... | The complaint's allegations against the related '233 Patent include a screenshot showing a settings page where a user can enable or disable the "Call Logging" feature, thereby identifying the criteria for the prompt's display (Compl. ¶21, Fig. on p. 21). | ¶18 | col. 2:21-24 |
| determining if an occurrence of a first end of call (EOC) event has been detected... | The application determines when an outgoing or incoming call is completed to trigger the logging prompt. A figure in the complaint annotates this as "Determining occurrence of first event" (Compl. ¶18, Fig. on p. 14). | ¶18 | col. 2:29-32 |
| automatically displaying...a first user interface message prompting the user to initiate a first procedure... | When a call is over and the threshold criteria are met, a message is displayed on the mobile device prompting the user to initiate the call log. | ¶18 | col. 2:25-32 |
| initiating the first procedure...in response to receiving input from the first user authorizing initiation | The procedure is initiated when the user taps "Yes," which opens the "Call Information" page where the user can log the call. A screenshot annotates this user action as "Initiating" (Compl. ¶18, Fig. on p. 16). | ¶18 | col. 2:32-38 |
| creating a first electronic data file which associates the first portion of digital content with...details relating to the first phone call | The "Log a Call" functionality allows the user to create an electronic file comprising details such as call duration, date, time, and user notes. | ¶18 | col. 2:41-44 |
| saving the first electronic data file at a first storage device such that the first electronic data file is accessible to the first user for future reference | The complaint alleges that the call details are saved so that they are accessible to the user for future reference, and includes a screenshot annotating this as "Keeping track of calls for future reference" (Compl. ¶18, Fig. on p. 18). | ¶18 | col. 2:44-46 |
Identified Points of Contention
- Scope Questions: The infringement theory for the ’836 Patent relies on a user's ability to enable or disable the entire call logging feature as satisfying the "enabling the first user... to identify a first set of threshold criteria" limitation. A point of contention may be whether a simple on/off toggle for a feature constitutes "identifying" a "set of threshold criteria," as the patent specification also describes more granular user-defined rules (e.g., setting specific active hours or triggering prompts only for pre-selected contacts) (’836 Patent, col. 3:5-13).
- Technical Questions: The complaint alleges the primary "threshold criteria" is the presence of the caller's phone number in the Zoho CRM database. This raises the question of whether this single, system-level condition meets the scope of a "first set of threshold criteria including a first portion of user-defined threshold criteria" as required by claim 1 of the parent ’233 Patent, which is foundational to the asserted family (’233 Patent, col. 2:21-24).
V. Key Claim Terms for Construction
The Term: "threshold criteria"
- Context and Importance: This term is central to the infringement analysis for all three patents, as it defines the conditions that trigger the automatic prompt. The dispute will likely focus on whether the accused product's single condition—the presence of a phone number in a database—meets the definition of a "set of threshold criteria," and whether it can be considered "user-defined" as required by related claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of potential criteria, including "the determined identity of the other call participant" (’233 Patent, col. 3:8-9). This language may support an argument that checking a contact database for a number falls within the disclosed scope.
- Evidence for a Narrower Interpretation: The specification repeatedly describes and illustrates user-configurable settings, such as setting "working hours only," a "Dialog Box Time Limit," and selectively enabling the feature for specific contacts (’233 Patent, FIGS. 13, 21). This may support a narrower construction requiring more active and granular user control over the criteria than what is alleged in the complaint.
The Term: "enabling the first user of the mobile communication device to identify a first set of threshold criteria"
- Context and Importance: This limitation from claim 1 of the ’836 Patent is crucial because it requires an affirmative capability be provided to the user. Practitioners may focus on this term because the plaintiff's case appears to rest on the user's ability to turn the "Call Logging" feature on or off as satisfying this element.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not explicitly state how the user must "identify" the criteria. An argument could be made that by choosing to enable the feature, the user is implicitly identifying the underlying system logic (e.g., check the CRM database) as the operative set of criteria.
- Evidence for a Narrower Interpretation: The patent specification includes detailed examples of user interface screens where the user can configure specific rules, such as activating the feature only during "business hours on weekdays" or selecting specific days of the week (’836 Patent, FIGS. 18-19). This may support an interpretation that requires the system to provide tools for defining the substance of the criteria, not merely a master switch for the feature itself.
VI. Other Allegations
The complaint does not contain explicit allegations of indirect infringement or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "threshold criteria," which the patents describe with examples of granular, user-configurable rules like time-of-day or specific contact lists, be construed to cover the accused product's single, system-level check of whether a caller's phone number exists in a CRM database?
- A key question of claim construction will be whether providing a user with a simple on/off toggle for the entire "Call Logging" feature satisfies the ’836 Patent’s requirement of "enabling the first user... to identify a first set of threshold criteria," or if the claim requires that the user be enabled to define the specific logical rules that constitute those criteria.