Data Resonance LLC v. Ataccama Corporation

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Data Resonance LLC (New Mexico)
  • Defendant: Ataccama Corporation (Canada)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:23-cv-00625, E.D. Tex., 12/22/2023
• Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s data management products infringe a patent related to identifying and maintaining "families" of related data records to perform functions like de-duplication.
• Technical Context: The technology addresses the challenge of managing large databases by identifying not just identical duplicate records, but also records that are indirectly related through chains of common information (e.g., shared addresses or phone numbers).
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings involving the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Patent No. 6,934,714, "Method and system for identification and maintenance of families of data records," issued August 23, 2005. (Compl. ¶9; ’714 Patent, front page).

The Invention Explained

• Problem Addressed: The patent’s background section describes the problem of duplicate data records in large databases, which are costly for businesses (e.g., sending multiple marketing mailings to the same household) and difficult to clean up once incorrect information is entered. (’714 Patent, col. 1:12-40). Existing systems are described as being limited to simple field matching, which fails to identify more complex relationships. (’714 Patent, col. 1:41-44).
• The Patented Solution: The invention proposes a "Data Family Record Management System" (DFRMS) that groups related records into "families." (’714 Patent, Abstract). When a new data record is imported, the system normalizes it and searches for other records that are related either directly (e.g., sharing a phone number) or indirectly through "multiple levels of embedding" (e.g., record A is linked to B, and B is linked to C, thus relating A and C). (’714 Patent, col. 2:24-30). This family association allows for more intelligent data retrieval, such as generating a mailing list that sends only one item to a household, regardless of how many individual contacts are listed at that address. (’714 Patent, Fig. 4).
• Technical Importance: The patented approach provides a method for managing complex, non-obvious relationships in data, moving beyond simple duplicate detection to create a more holistic view of related entities within a database. (’714 Patent, col. 4:12-28).

Key Claims at a Glance

• The complaint does not identify specific claims, referring only to the "Exemplary '714 Patent Claims" identified in an unattached exhibit. (Compl. ¶¶11, 16). For the purpose of analysis, independent claim 41, a system claim, is representative.
• Independent Claim 41 requires:
  • A record management system comprising:
  • an automatic de-duplication engine that, upon receiving a designated data record, automatically determines a set of data records from a plurality of data records in a data repository that relate directly to the designated record and data records that relate indirectly to the designated record;
  • adds the designated record to the determined set when it is automatically determined that the designated record is not a duplicate of a data record in the determined set; and
  • automatically associates with each record of the determined set an indication of a family of related data records.

III. The Accused Instrumentality

Product Identification

• The complaint does not name specific products, referring only to "at least the Defendant products identified in the charts incorporated into this Count" as the "Exemplary Defendant Products." (Compl. ¶11).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' functionality. It makes the conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '714 Patent." (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references claim charts in an "Exhibit 2" to detail its infringement allegations but does not attach the exhibit. (Compl. ¶¶16-17). The narrative infringement theory is that the accused products "satisfy all elements of the Exemplary '714 Patent Claims." (Compl. ¶16). Without the specific allegations from the claim charts, a detailed element-by-element analysis is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent and the general nature of the allegations, the infringement analysis will likely raise several questions:
  • Technical Questions: A central question will be what specific components of the accused products constitute the claimed "automatic de-duplication engine." (’714 Patent, col. 21:2-3). Further, what evidence demonstrates that this engine performs the specific functions of determining both "direct" and "indirect" relationships as those terms are used in the patent? (’714 Patent, col. 21:9-11).
  • Scope Questions: The analysis may turn on whether the accused products' method for grouping or linking records constitutes an "indication of a family" as required by the claim. (’714 Patent, col. 21:14-16). The scope of this term—whether it requires a persistent database flag, a temporary identifier, or some other data structure—will be a critical issue.

V. Key Claim Terms for Construction

• The Term: "relate indirectly" (’714 Patent, col. 21:10-11)

• Context and Importance: This term is at the core of the patent's purported advance over simple de-duplication. The definition of what constitutes an "indirect" relationship will be central to determining infringement, as it defines the required capability of the accused system beyond basic record matching.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides a high-level example: "The second data record, in turn, may share a phone number with the third data record, thus, relating the first record with the third record in an indirect or embedded relationship." (’714 Patent, col. 4:20-24). This could support a broad definition covering any transitive link between records.
  • Evidence for a Narrower Interpretation: The detailed description and flowcharts disclose a specific recursive search process for finding indirect relations (e.g., the "FindIndirectRelations" routine). (’714 Patent, Fig. 13). A defendant may argue this disclosure limits the term to systems that employ such a multi-level, exhaustive search algorithm.

• The Term: "an indication of a family of related data records" (’714 Patent, col. 21:14-16)

• Context and Importance: This limitation requires the system to not only find related records but also to formally associate them as a "family." Practitioners may focus on this term because its construction will determine what type of data structure or metadata in the accused system satisfies this element.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification generally refers to associating records with "an indication of the family relationship," which could be argued to cover a wide range of implementation methods. (’714 Patent, col. 2:9-11).
  • Evidence for a Narrower Interpretation: The patent’s figures and detailed process flows repeatedly reference setting a specific "FamID" or "family identifier" field in the data records. (’714 Patent, Fig. 22A, steps 2203, 2207). This could support a narrower construction requiring a persistent, designated identifier field to be stored with the records.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '714 Patent." (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based on post-suit knowledge. The complaint asserts that service of the complaint itself provides "actual knowledge of infringement" and that Defendant’s continued alleged infringement thereafter is willful. (Compl. ¶¶13-14).

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

1. Evidentiary Sufficiency: Given the complaint’s lack of specific factual allegations mapping product features to claim limitations, a primary issue will be whether Plaintiff can produce evidence to survive a potential early challenge to the pleadings and ultimately prove that the accused products perform the specific functions of determining indirect relationships and associating family indicators as claimed.
2. Definitional Scope: The case will likely turn on claim construction. A core question for the court will be whether the term "relate indirectly" is limited to the specific recursive search algorithms disclosed in the patent’s embodiments or can be construed more broadly to cover any system that resolves transitive data relationships.
3. Proof of Inducement: A key question for the indirect infringement claim will be whether Plaintiff can demonstrate that Defendant’s product manuals and marketing materials contain specific instructions that would necessarily lead a user to operate the accused systems in a manner that practices all limitations of an asserted claim, thereby showing the requisite specific intent for inducement.