Decapolis Systems LLC v. Steward Health Care Network Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Decapolis Systems, LLC (Florida)
  • Defendant: Steward Health Care Network, Inc. and Steward Health Care System LLC (Delaware)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:22-cv-00407, E.D. Tex., 10/18/2022
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains operating hospitals, physical locations, and employees within the District, constituting a regular and established business presence.
• Core Dispute: Plaintiff alleges that Defendant’s electronic health records platforms and patient portal services infringe patents related to managing access to healthcare data and automating the generation of insurance claims.
• Technical Context: The patents address methods for computerizing healthcare information management, focusing on enhancing data security, patient privacy, and administrative efficiency in billing and claims processing.
• Key Procedural History: The complaint notes that the asserted patents have been cited as prior art in patents issued to numerous technology and healthcare companies. It also alleges that the claims were allowed by three different patent examiners over extensive prior art, which Plaintiff presents as evidence of the claims' unconventionality and patent eligibility.

Case Timeline

Date	Event
1999-12-18	U.S. Patent No. 7,464,040 Priority Date
2001-04-25	U.S. Patent No. 7,490,048 Priority Date
2008-12-09	U.S. Patent No. 7,464,040 Issued
2009-02-10	U.S. Patent No. 7,490,048 Issued
2022-07-01	Defendant Launches New Patient Portal (approximate date)
2022-10-18	Complaint Filed

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

U.S. Patent No. 7,490,048 - Apparatus and Method for Processing and/or for Providing Healthcare Information and/or Healthcare-Related Information

The Invention Explained

• Problem Addressed: The patent's background describes problems in maintaining the privacy of patient healthcare records, safeguarding those records, and providing notification to patients when others have accessed or made changes to them (’048 Patent, col. 2:20-29). It also identifies a need for enabling patients to restrict or limit access to their healthcare files ('048 Patent, col. 2:25-29).
• The Patented Solution: The invention is a computer-implemented method that processes requests from users (e.g., doctors, insurers) to access or modify a patient's electronic health record. A core feature is generating and transmitting a notification message to the patient's own communication device (e.g., a personal computer or mobile device) about the access request, potentially before the access or modification is completed, thereby giving the patient visibility and a measure of control over their data ('048 Patent, Abstract; Fig. 16A-16B).
• Technical Importance: The technology provides a framework for auditable, patient-centric control over sensitive electronic health information, addressing privacy concerns that arise when records are digitized and networked.

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 20, an independent method claim (Compl. ¶37).
• Claim 20 recites the essential elements of:
  • Receiving and storing information about a "restriction or limitation" regarding the ability of a person or entity to access, change, or modify a patient's healthcare record.
  • Processing a request from a person or entity to access, change, or modify the record.
  • Using the stored "restriction or limitation" information to determine if the requesting person or entity is authorized.
  • Generating a message that includes information about the requestor and any actual change made to the record.
  • Transmitting that message to the patient's communication device over a network.
• The complaint reserves the right to assert numerous other claims (Compl. ¶37).

U.S. Patent No. 7,464,040 - Apparatus and Method for Processing and/or for Providing Healthcare Information and/or Healthcare-Related Information

The Invention Explained

• Problem Addressed: The patent identifies inefficiencies and rising costs in the healthcare system associated with paper-based and slow processing of insurance claims, as well as the potential for fraudulent claims (’040 Patent, col. 2:4-15).
• The Patented Solution: The invention describes a comprehensive healthcare processing system where a provider enters patient information (e.g., diagnosis, treatment) into a central computer. In response to this information being stored or the patient's record being updated, the system is designed to "automatically" generate a corresponding insurance claim and transmit it electronically to the appropriate payer or insurer ('040 Patent, Abstract; col. 6:54-58). This process is depicted in a flowchart showing the direct sequence from updating a patient's records to generating and transmitting a claim form (ʼ040 Patent, Fig. 14B).
• Technical Importance: This automated approach aims to reduce administrative overhead, decrease payment cycle times, and minimize errors by directly linking the clinical event of treating a patient with the administrative event of billing for that treatment.

Key Claims at a Glance

• The complaint asserts infringement of at least Claims 1 and 46, which are independent apparatus and method claims, respectively (Compl. ¶57).
• Claim 1 recites the essential elements of an apparatus comprising:
  • A receiver for receiving patient information from a healthcare provider's computer.
  • A database for storing information about patients, providers, and insurers.
  • A processing device that processes the received information by storing it or updating the patient's healthcare record.
  • The processing device "automatically generates an insurance claim in response to the storing of the information... or the updating of the healthcare record."
  • The processing device then transmits the generated claim to the insurer's computer.
• Claim 46 recites a corresponding method with analogous steps.

III. The Accused Instrumentality

Product Identification

• The "Accused Instrumentalities" are identified as Defendant's "plurality of electronic healthcare systems, platforms and services," which include a cloud-based electronic health records ("EHR") system, a practice management system, and a "New Patient Portal" launched in July 2022 (Compl. ¶32, Fig. 1).

Functionality and Market Context

• The complaint alleges these systems provide a "cloud database and framework to receive and send data and messages," and manage functions including patient care, referrals, scheduling, billing, collections, and reporting (Compl. ¶32). A screenshot in the complaint shows a webpage announcing the new patient portal, stating it is intended to "improve our patients' experience and enhance access to their health information" from various devices (Compl. Fig. 1, p. 9). Plaintiff alleges Defendant controls the operation of these systems and derives substantial revenue from them (Compl. ¶36).

IV. Analysis of Infringement Allegations

’048 Patent Infringement Allegations

Claim Element (from Independent Claim 20)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
receiving information regarding a restriction or limitation regarding an ability of a person or an entity to at least one of access, obtain, change, alter, and modify, information contained in an individuals or patients healthcare record...	Defendant's systems receive information that restricts or limits the ability of persons or entities to access, obtain, or modify patient healthcare records.	¶39	col. 49:7-24
storing the information regarding a restriction or limitation...	The Accused Instrumentalities store the information regarding the restriction or limitation on access.	¶42	col. 49:25-27
processing, with a processor, a request by a person or an entity to at least one of access, obtain, change, alter, and modify, the information contained in an individuals or patients healthcare record...	The systems process requests from persons or entities seeking to access or modify information within a patient's healthcare record.	¶42	col. 49:32-42
determining, using the information regarding the restriction or limitation, whether the person or the entity is allowed or authorized to at least one of access, obtain, change, alter, and modify, the information...	Using the stored restriction information, the systems determine whether the requesting person or entity is authorized to access or modify the patient's record.	¶42	col. 50:1-3
generating a message containing at least one of information regarding the person or the entity making the request... and further wherein the message contains an actual change, alteration, or modification, made to the information...	The systems generate a message that contains information about the person making the request and details of any actual change or modification made to the healthcare record.	¶42	col. 46:45-64
transmitting the message to a communication device of the individual or patient via, on, or over, a communication network.	The generated message is transmitted over a network to a communication device belonging to the patient.	¶42	col. 46:65-67

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the general user authentication and access controls inherent in any secure patient portal constitute the specific "information regarding a restriction or limitation" required by the claim. The defense may argue the claim requires a more specific, patient-defined rule set for restricting access, rather than a system-wide login protocol.
  • Technical Questions: The complaint alleges the generation and transmission of a "message" containing details of an "actual change" to the patient's device (Compl. ¶42). A key factual question will be whether Defendant's portal system actually sends such specific, real-time notifications to patients whenever their record is accessed or modified by a third party, as distinct from simply making an updated record available for the patient to view upon their next login.

’040 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a receiver, wherein the receiver receives information regarding an individual... transmitted from a first computer... associated with a healthcare provider...	The Accused Instrumentalities receive patient information (symptoms, diagnosis, treatment, etc.) transmitted from a healthcare provider's computer over the internet.	¶59	col. 27:17-24
a database or a memory device... wherein the database or the memory device stores information regarding a plurality of individuals, a plurality of healthcare providers, and a plurality of healthcare insurers or healthcare payers...	Defendant's systems include a database located remotely from the provider that stores information regarding numerous individuals, providers, and insurers/payers.	¶59	col. 17:1-14
a processing device, wherein the processing device processes the information regarding an individual... for at least one of storing the information... and updating the healthcare record...	Defendant's systems include a processing device that processes the received information by storing it in the database and updating the individual's healthcare record.	¶61	col. 29:1-10
and further wherein the processing device automatically generates an insurance claim in response to the storing of the information... or the updating of the healthcare record...	The processing device automatically generates an insurance claim as a direct response to the act of storing the new information or updating the patient's healthcare record.	¶61	col. 6:54-58
and further wherein the processing device transmits the insurance claim to the second computer or to the second communication device.	The processing device transmits the automatically generated insurance claim to a computer associated with the relevant healthcare insurer or payer.	¶61	col. 40:29-32

• Identified Points of Contention:
  • Scope Questions: The analysis will likely focus on the scope of "automatically generates an insurance claim in response to the storing... or the updating." A question for the court will be whether this language requires the claim generation to be an immediate, direct, and non-intervened consequence of the data update, or if it can cover a system where records are updated and claims are generated later in a separate, albeit automated, batch process.
  • Technical Questions: The complaint alleges the accused system performs this automatic generation and transmission (Compl. ¶61). A key evidentiary question will be what facts support this causal link. The complaint does not provide specific detail on the internal workflow of Defendant's billing and practice management software, raising the question of how Plaintiff will prove that the act of a provider updating a record directly triggers the generation of a claim, as opposed to merely creating a data entry that is later used in a separate billing workflow.

V. Key Claim Terms for Construction

For the ’048 Patent:

• The Term: "information regarding a restriction or limitation"
• Context and Importance: This term is the foundation of Claim 20. Its construction will determine whether the claim covers standard secure-access systems or is limited to systems that allow for more granular, user-defined rules. Practitioners may focus on this term because the infringement theory appears to equate general system access controls with the claimed "restriction or limitation."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests that the system can utilize various security measures, including "passwords, electronic signatures, and/or any other information" ('048 Patent, col. 44:14-16), which could support an argument that standard authentication falls within the term's scope.
  • Evidence for a Narrower Interpretation: The detailed embodiment of this concept involves a patient actively entering specific restrictions, such as limiting a provider's access to only certain information for designated purposes like a "second opinion" or "insurance claim" processing ('048 Patent, col. 49:7-24; col. 50:11-19). This suggests the term implies a patient-configurable rules engine, which may be narrower than general login security.

For the ’040 Patent:

• The Term: "automatically generates an insurance claim in response to the storing of the information... or the updating of the healthcare record"
• Context and Importance: This functional language defines the core inventive concept of linking clinical data entry directly to administrative claim generation. The case may turn on whether the accused system's workflow meets this "in response to" requirement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue "automatically" simply means "without subsequent human intervention," allowing for a time delay or batch process to occur after the initial data update, as long as that subsequent process is itself computerized.
  • Evidence for a Narrower Interpretation: The patent's flowchart in Figure 14B depicts "UPDATE PATIENT'S RECORDS" (1408) as immediately preceding "GENERATE CLAIM FORM" (1409). This sequential flow supports a reading that requires a direct and temporally proximate causal link between the update and the claim generation, potentially excluding systems with separate, decoupled billing modules. The specification also states the claim can be submitted "once a final diagnosis and treatment has been prescribed" ('040 Patent, col. 6:54-58), tying the automatic event to the completion of the clinical record.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement for both patents, but provides only a general recitation that Defendant has knowledge and continues its actions, injuring the Plaintiff (Compl. ¶¶45, 64). The complaint does not specify which third parties are being induced or the specific acts of inducement.
• Willful Infringement: Willfulness is alleged for both patents. The basis for willfulness is post-suit knowledge, with the complaint asserting that infringement "will now be willful through the filing and service of this Complaint" (Compl. ¶¶44, 63). The complaint also alleges willful blindness, stating on information and belief that Defendant has a "practice of not performing a review of the patent rights of others first for clearance... prior to launching products and services" (Compl. ¶¶49, 68).

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

This dispute will likely center on questions of claim scope and the sufficiency of factual allegations. The central issues for the court may be framed as:

1. A core issue will be one of definitional scope: Does the term "information regarding a restriction or limitation" in the ’048 Patent encompass the general user authentication protocols of a standard patient portal, or does the patent's specification limit the term to more specific, patient-configurable access rules?
2. A key evidentiary question will be one of causality and automation: For the ’040 Patent, does the complaint provide sufficient factual basis to plausibly allege that Defendant's system "automatically generates an insurance claim in response to" a provider updating a patient's record, as required by the claims, or is there a functional gap between the clinical record-keeping and the administrative billing processes that places the accused system outside the claim scope?