DCT

2:22-cv-00350

Alto Dynamics LLC v. Roadget Business Pte Ltd

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Alto Dynamics, LLC (Georgia)
- Defendant: Roadget Business Pte. Ltd. (Singapore)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
Case Identification: 2:22-cv-00350, E.D. Tex., 01/23/2023
Venue Allegations: Plaintiff alleges that venue is proper because Defendant is a foreign entity not resident in the United States, pursuant to 28 U.S.C. § 1391(c)(3).
Core Dispute: Plaintiff alleges that Defendant’s SHEIN e-commerce website and mobile applications infringe seven U.S. patents related to database query methods, automated data extraction, user activity monitoring, and stateless user authentication.
Technical Context: The technologies at issue relate to foundational e-commerce operations, including how data is retrieved and presented to users, how user behavior is tracked via cookies, and how user sessions are securely managed.
Key Procedural History: The operative pleading is a First Amended Complaint. The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the asserted patents.

Case Timeline

Date	Event
2000-02-09	U.S. Patent No. 6,604,100 Priority Date
2001-03-20	U.S. Patent No. 6,662,190 Priority Date
2001-04-19	U.S. Patent Nos. 7,657,531, 8,051,098, and RE46,513 Priority Date
2002-12-18	U.S. Patent Nos. 7,152,018 and 7,392,160 Priority Date
2003-08-05	U.S. Patent No. 6,604,100 Issued
2003-12-09	U.S. Patent No. 6,662,190 Issued
2006-12-19	U.S. Patent No. 7,152,018 Issued
2008-06-24	U.S. Patent No. 7,392,160 Issued
2010-02-02	U.S. Patent No. 7,657,531 Issued
2011-11-01	U.S. Patent No. 8,051,098 Issued
2017-08-15	U.S. Patent No. RE46,513 Issued
2023-01-23	First Amended Complaint Filed

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

U.S. Patent No. 6,604,100 - “Method For Converting Relational Data Into A Structured Document”

Issued: August 5, 2003.

The Invention Explained

Problem Addressed: The patent describes the technical challenge of converting data stored in traditional relational databases (which are tabular and flat) into the nested, structured format of XML, which was becoming a standard for data exchange between applications. Existing tools were described as inefficient or not general enough to handle complex mappings to arbitrary XML formats (’100 Patent, col. 1:40-55).
The Patented Solution: The invention provides a method, referred to as "SilkRoute," for creating a virtual XML "view" of relational data. An application can then send a query for a specific piece of information against this view. Instead of generating the entire XML document, the system partitions the query, sends an optimized query to the underlying relational database to retrieve only the necessary data tuples, and then merges that data with a template to construct the final, structured XML document fragment needed by the application (’100 Patent, Abstract; col. 5:26-40).
Technical Importance: This approach enabled more dynamic and efficient use of vast relational data stores for web-based applications that required data in the flexible XML format (’100 Patent, col. 2:26-42).

Key Claims at a Glance

The complaint asserts independent claim 1 (Compl. ¶21).
The essential elements of claim 1 include:
- storing a view query that defines a structured document view of the relational database, where the view's structure is independent of the database's data structure
- receiving a user query against the structured document view
- forming an executable query by composing the view query and the user query
- partitioning the executable query into a data extraction portion and a construction portion
- transmitting the data extraction portion to the relational database
- receiving at least one tuple stream from the database
- merging the tuple stream and the construction portion to generate a structured document
The complaint alleges infringement of "one or more claims," reserving the right to assert additional claims (Compl. ¶20).

U.S. Patent No. 6,662,190 - “Learning Automatic Data Extraction System”

Issued: December 9, 2003.

The Invention Explained

Problem Addressed: The patent addresses the limitations of automatic data extraction systems that rely on predefined vocabularies or "domain knowledge" to identify and extract data from text. These vocabularies are labor-intensive to create and maintain, and they are unable to recognize new or unknown values (’190 Patent, col. 2:42-54).
The Patented Solution: The invention proposes an improved data extractor that can learn new vocabulary through use. After identifying the structure of data in a text file (e.g., columns in a table), the system recognizes values that are already in its vocabulary. It then "gleans" new values by deducing them from the data's structure (e.g., a value in the "make" column must be a car make), adds the new value to the extracted data record, and adds the new value to its vocabulary for future recognition (’190 Patent, Abstract).
Technical Importance: This "learning" capability allows a data extraction system to automatically increase the size and relevance of its vocabulary, improving the completeness of data extraction over time with less manual intervention (’190 Patent, col. 2:55-65).

Key Claims at a Glance

The complaint asserts independent claim 1 (Compl. ¶33).
The essential elements of claim 1 include:
- identifying an area of interest in a text file
- parsing the area of interest to identify a list of values of attributes
- recognizing a first set of values in the list that match an attribute value vocabulary
- forming a record using the first set of values
- gleaning a second set of values in the list that do not match the vocabulary
- adding the second set of values to the record
The complaint reserves the right to assert additional claims beyond claim 1 (Compl. ¶32).

U.S. Patent No. 7,152,018 - “System And Method For Monitoring Usage Patterns”

Patent Identification: 7,152,018, issued December 19, 2006 (Compl. ¶40).
Technology Synopsis: This patent describes a method for monitoring user activity on a system like a website. A "state object" (e.g., a cookie) containing a user profile is stored on the client's machine and passed to a central server with each interaction, allowing the profile to be modified to reflect user behavior without the server needing to manipulate it directly (’018 Patent, Abstract).
Asserted Claims: At least independent claim 1 (Compl. ¶45).
Accused Features: The use of cookies to track user activities and preferences on the SHEIN platform (Compl. ¶46).

U.S. Patent No. 7,392,160 - “System And Method For Monitoring Usage Patterns”

Patent Identification: 7,392,160, issued June 24, 2008 (Compl. ¶57).
Technology Synopsis: This patent, related to the ’018 Patent, also describes monitoring user usage with a client-side state object. It adds that the central server audits and analyzes the profile passed to it in order to direct services or information back to the client that are suited to that profile (’160 Patent, Abstract).
Asserted Claims: At least independent claim 1 (Compl. ¶62).
Accused Features: The use of cookies to track user preferences and the server's analysis of that data to provide customized content, such as targeted advertisements (Compl. ¶63).

U.S. Patent No. 7,657,531 - “Systems And Methods For State-Less Authentication”

Patent Identification: 7,657,531, issued February 2, 2010 (Compl. ¶74).
Technology Synopsis: This patent describes a method for "state-less" authentication in a distributed computing environment. A user receives a "security-context" that allows access to resources; the invention includes a process for renewing this security context by comparing it against stored identity information and generating an updated context if the user's identity is verified (’531 Patent, Abstract).
Asserted Claims: At least independent claim 1 (Compl. ¶79).
Accused Features: The website and user authentication processes, including the use of cookies containing authentication and session data to manage user logins and access to secured parts of the SHEIN platform (Compl. ¶80).

U.S. Patent No. 8,051,098 - “Systems And Methods For State-Less Authentication”

Patent Identification: 8,051,098, issued November 1, 2011 (Compl. ¶86).
Technology Synopsis: This patent, related to the ’531 patent, describes a state-less authentication method where a user establishes a single secure session with a logon component. This logon generates a unique security context that allows the user to access a plurality of different resources (which may be on different systems) without requiring follow-on authorization communications for each one (’098 Patent, Abstract).
Asserted Claims: At least independent claim 1 (Compl. ¶91).
Accused Features: The single sign-on functionality of the SHEIN platform, where a user logs in once and can then access different parts of the site (e.g., from us.shein.com to help.shein.com) without re-authenticating (Compl. ¶92).

U.S. Patent No. RE46,513 - “Systems And Methods For State-Less Authentication”

Patent Identification: RE46,513, issued August 15, 2017 (Compl. ¶98).
Technology Synopsis: This patent, a reissue of a patent in the same family as the '531 and '098 patents, describes a method of enabling access where a user establishes a secure session with a logon component. The system generates a security context comprising a plaintext header (with an ID and key handle) and an encrypted body, which is provided to the user for subsequent access requests (’513 Patent, Abstract).
Asserted Claims: At least independent claim 1 (Compl. ¶103).
Accused Features: The website's secure session and authentication system, which allegedly uses cookies with authentication data that functions as the claimed security context (Compl. ¶104).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's website, https://us.shein.com, and its associated mobile applications, along with the related hardware and software that operate the e-commerce platform (Compl. ¶14).

Functionality and Market Context

The complaint alleges the accused instrumentalities constitute an online sales platform for clothing and fashion accessories (Compl. ¶6, ¶14). The specific functionalities accused of infringement include database searching and viewing capabilities, text mining for processing resumes, user activity tracking via cookies, and website user authentication through login processes and secured sessions (Compl. ¶14, ¶22, ¶34, ¶46, ¶80).
No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

6,604,100 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
storing a view query that defines a structured document view of the relational database...	Storing a query for a product category (e.g., dresses) that defines how product data from a relational database (e.g., MySQL) is presented as a structured document (e.g., a webpage).	¶22	col. 5:5-10
receiving a user query against the structured document view...	Receiving a user's search for a specific product (e.g., a type of dress) on the website's product category page.	¶22	col. 5:11-19
forming an executable query by determining a composition of the view query and the user query...	Combining the general category query and the specific user search to form a single executable query for the database.	¶22	col. 5:17-25
partitioning the executable query into a data extraction portion and a construction portion...	The complaint alleges this partitioning occurs, for example, by separating data retrieval from sorting operations.	¶22	col. 5:26-31
transmitting the data extraction portion to the relational database...	Sending the composed query to the backend MySQL database to retrieve product information.	¶22	col. 5:36-40
receiving at least one tuple stream from the relational database...	An application server receiving the data stream of product information returned from the MySQL database.	¶22	col. 5:41-47
merging the at least one tuple stream and the construction portion to generate a structured document...	Combining the received data stream with formatting information (e.g., webpage template, sorting rules) to generate the final webpage displaying the search results.	¶22	col. 5:44-50

Identified Points of Contention

Scope Questions: A central question may be whether the standard operation of an e-commerce search function, which queries a database and renders results on a webpage, can be mapped to the specific, multi-step "SilkRoute" method as claimed. The defense may argue that common database interactions do not perform the claimed "composition" and "partitioning" in the specific manner required by the patent.
Technical Questions: The complaint's allegation that the executable query is "partitioned" into a "data extraction portion" and a "construction portion" is a specific technical assertion about the internal software architecture. A key factual question is what evidence the complaint provides, or that discovery may yield, to show that Defendant's system actually performs this distinct partitioning step, as opposed to simply executing a standard SQL query that includes sorting and filtering commands.

6,662,190 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
identifying an area of interest in a text file...	An applicant tracking system identifying a section of an uploaded resume, such as the "experience" section.	¶34	col. 2:5-8
parsing said area of interest in order to identify a list of values of attributes...	Analyzing the "experience" section to identify a list of potential attribute values (e.g., job titles, skills, dates).	¶34	col. 5:56-63
recognizing a first set of values in said list that match values contained in an attribute value vocabulary...	Identifying values within the list that are already known to the system because they exist in a predefined vocabulary of terms (e.g., recognizing "Software Engineer" as a known job title).	¶34	col. 5:64-67
forming a record using said first set of values...	Creating a data record for the applicant using the recognized values.	¶34	col. 6:1-2
gleaning a second set of values in said list that do not match values contained in said attribute value vocabulary...	Identifying values in the list that are not in the predefined vocabulary, such as a new or niche skill (e.g., "Quantum AI Optimization").	¶34	col. 6:2-5
adding said second set of values to said record...	Adding the newly gleaned, unrecognized values to the applicant's data record.	¶34	col. 6:5-7

Identified Points of Contention

Scope Questions: The dispute may turn on the scope of the term "gleaning." Defendant may argue that its system simply extracts all text from a resume section and does not perform the claimed process of first recognizing known values and then separately "gleaning" unknown values by comparing them against a vocabulary.
Technical Questions: Claim 1 requires "gleaning a second set of values... that do not match" the vocabulary and "adding said second set of values to said record." While not explicitly part of this claim, the patent's abstract and a dependent claim discuss adding these new values back to the vocabulary itself (the "learning" step). A factual question for the case will be whether Defendant's system merely captures all text data, or if it performs the specific comparison and segregation process required by the claim and, potentially, the learning function that gives the patent its name.

V. Key Claim Terms for Construction

For the ’100 Patent

The Term: "partitioning the executable query into a data extraction portion and a construction portion"
Context and Importance: This term describes a core technical step of the claimed method. The infringement analysis will likely depend on whether the Defendant's standard process for querying a database and formatting the results can be characterized as this specific type of "partitioning." Practitioners may focus on this term because it appears to describe a more complex process than a standard, monolithic SQL query.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the data extraction part as "one or more SQL queries" and the construction part as an "XML template" (’100 Patent, col. 5:28-30). This could support an interpretation where any process that separates database querying from result formatting meets the limitation.
- Evidence for a Narrower Interpretation: The detailed description of the "translator" module suggests a specific software component that performs this partitioning (’100 Patent, col. 5:26-40). This could support a narrower construction requiring a distinct software module or algorithmic step that explicitly divides the query before execution.

For the ’190 Patent

The Term: "gleaning a second set of values... that do not match values contained in said attribute value vocabulary"
Context and Importance: This is the central inventive concept of the patent—identifying new information. The infringement determination depends on whether the accused system performs this specific comparison-based identification, or if it simply performs a bulk data extraction without differentiating between known and unknown terms.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The summary states the invention "gleans new values by deducing them from the structure of the text data" (’190 Patent, col. 1:4-5), which might be argued to cover any process that uses text structure to extract previously uncategorized data.
- Evidence for a Narrower Interpretation: The claim language requires a multi-step process: first "recognizing" a set that does match the vocabulary, and then "gleaning" a second set that does not match. This structure suggests a narrower interpretation where a direct comparison against a vocabulary must occur to segregate the "gleaned" values from the "recognized" ones, rather than simply capturing all data.

VI. Other Allegations

Indirect Infringement: For the '018 and '160 patents, the complaint alleges induced infringement by encouraging customers to use the accused website and apps, and contributory infringement by providing features (e.g., cookie-based tracking) that allegedly have no substantial non-infringing use (Compl. ¶¶47-48, ¶¶64-65).
Willful Infringement: The complaint alleges willful infringement for all asserted patents. This is based on allegations that Defendant was "objectively reckless" and on an alleged "policy or practice of not reviewing the patents of others" (Compl. ¶23, ¶35, ¶50, ¶67, ¶81, ¶93, ¶106). For the '018, '160, and '513 patents, willfulness is also based on alleged knowledge of the patents since at least the time of receiving the complaint (Compl. ¶52, ¶69, ¶108).

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

A core issue will be one of technical specificity: do the general operations of a modern, large-scale e-commerce platform perform the particular, multi-step methods recited in the claims—such as partitioning queries ('100 patent) and gleaning new data against a vocabulary ('190 patent)—or is there a fundamental mismatch between standard industry practice and the specific technical steps required by the patents?
A key evidentiary question will be one of proof of internal operation: given that the infringement allegations concerning Defendant's backend systems are based on "public information," the case will likely turn on what factual evidence Plaintiff can develop through discovery to demonstrate that Defendant's software architecture actually implements the specific, granular steps mandated by the asserted claims.
A central legal question will be one of claim construction: the viability of the infringement claims will depend heavily on whether key terms like "partitioning" ('100 patent), "gleaning" ('190 patent), and "state-less authentication" ('531, '098, '513 patents) are construed broadly enough to read on the functionalities of a modern web architecture that was developed long after the patents' priority dates.