DCT

2:23-cv-00626

Data Resonance LLC v. IBM Corporation

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00626, E.D. Tex., 12/22/2023
  • Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the district and committing acts of patent infringement there.
  • Core Dispute: Plaintiff alleges that certain unidentified IBM products and services infringe a patent related to methods for identifying, de-duplicating, and maintaining relationships among data records in a database.
  • Technical Context: The technology concerns advanced database management, specifically systems for cleaning data and mapping complex, indirect relationships between records to create "families" of related data.
  • Key Procedural History: The complaint does not allege any prior litigation, inter partes review (IPR) proceedings, or specific licensing history related to the patent-in-suit.

Case Timeline

Date Event
2002-03-04 U.S. Patent No. 6,934,714 Application/Priority Date
2005-08-23 U.S. Patent No. 6,934,714 Issues
2023-12-22 Complaint Filed

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”

  • Patent Identification: U.S. Patent No. 6,934,714, issued August 23, 2005.

The Invention Explained

  • Problem Addressed: The patent addresses the common problem in large databases of duplicate or near-duplicate data records. Such records can be costly for marketing campaigns (e.g., sending multiple mailings to the same household) and make it difficult to retrieve a complete set of information about a single entity, especially when data is entered inconsistently (U.S. Patent No. 6,934,714, col. 1:12-39).
  • The Patented Solution: The invention proposes a "Data Family Record Management System" that automatically processes new data records to group them into "families." A family is a set of records related either directly (e.g., sharing a phone number) or indirectly (e.g., Record A is linked to Record B by address, and Record B is linked to Record C by phone, thus relating A and C) ('971 Patent, col. 4:18-26; Abstract). The system normalizes and de-duplicates records before adding them to the repository, and then uses these family associations to enable more sophisticated data queries and retrieval ('971 Patent, col. 2:54-67; Fig. 3).
  • Technical Importance: The invention provided a method for automatically discovering and managing complex, transitive relationships between data records, moving beyond simple one-to-one duplicate checks to maintain a "clean" and intelligently structured data repository ('971 Patent, col. 2:30-34).

Key Claims at a Glance

  • The complaint asserts infringement of one or more unspecified "exemplary claims" (Compl. ¶11). Independent claim 1 is representative of the system claims.
  • Independent Claim 1 (System Claim) Elements:
    • Determining, from a plurality of data records, a set of records that are "directly-related" to a designated record.
    • Using the set of directly-related records to automatically determine a "potential family of records" that includes both directly-related records and records that are "indirectly related."
    • Adding the designated record to the potential family after determining it is not a duplicate of an existing record in that family.
    • Automatically setting an "indicator" in each record of the potential family to signify the family relationship.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers to "Exemplary Defendant Products" that are purportedly identified in an exhibit, Exhibit 2, which was not filed with the complaint (Compl. ¶¶11, 16).

Functionality and Market Context

The complaint alleges in conclusory terms that the accused products "practice the technology claimed by the '714 Patent" (Compl. ¶16). Without access to the referenced Exhibit 2, it is not possible to describe the specific functionality of the accused instrumentalities. The complaint contains no allegations regarding the products' specific market context or commercial importance.

IV. Analysis of Infringement Allegations

The complaint references but does not include its claim charts (Exhibit 2), which compare the patent claims to the accused products (Compl. ¶17). It alleges that these charts demonstrate that the accused products "satisfy all elements of the Exemplary '714 Patent Claims" (Compl. ¶16). In the absence of the charts or any specific factual allegations mapping product features to claim elements, a detailed infringement analysis is not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Factual Questions: The central factual question will be whether the accused IBM products perform the specific, multi-step process recited in the claims. Discovery will likely focus on whether IBM's technology first identifies a set of "directly-related records" and then iteratively uses that set to find "indirectly related" records to form a "potential family." The complaint provides no non-conclusory facts on this point.
  • Scope Questions: A likely point of dispute will be the definition of an "indirect" relationship. The patent describes this as a transitive link (A is related to B, B is related to C), but the infringement analysis will question whether the accused products' method of linking disparate data points falls within the scope of this claimed functionality.

V. Key Claim Terms for Construction

  • The Term: "potential family of records" (Claim 1)

  • Context and Importance: This term is the central construct of the invention. Its definition is critical because infringement will depend on whether the accused products create a grouping of records that meets the definition of a "potential family." Practitioners may focus on whether this term is limited by the specific process for its creation described in the specification.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The brief summary describes a "family" simply as "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" ('971 Patent, col. 2:56-60). This could support a construction covering any system that groups records with any kind of direct or indirect link.
    • Evidence for a Narrower Interpretation: The detailed description and flowcharts (e.g., Fig. 9) describe a specific, two-part process: a "direct relationship search is first done" (step 901) to create a list, and then that list is used to "find indirect relationships" (step 903) ('971 Patent, col. 10:56-65). This may support a narrower construction requiring this specific sequence of operations to create a "potential family."

  • The Term: "indirectly related" (Claim 1)

  • Context and Importance: This term captures the invention's asserted novelty over simple duplicate detection. The case's outcome may depend on whether the way the accused products link records constitutes an "indirect" relationship as contemplated by the patent.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification states that records are related indirectly through "multiple levels of embedding" and can be determined by "examining the related records for each record progressively" ('971 Patent, col. 2:25-30). This could support a broad definition covering any form of transitive relationship.
    • Evidence for a Narrower Interpretation: The patent provides a concrete example: a first record sharing an address with a second, and the second sharing a phone number with a third, "thus, relating the first record with the third record in an indirect or embedded relationship" ('971 Patent, col. 4:18-26). An argument could be made that the term is limited to relationships established through such intermediate records sharing common field values.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users... to use its products in the customary and intended manner that infringes the '714 Patent" (Compl. ¶14).
  • Willful Infringement: The allegation of knowledge is based entirely on the filing of the lawsuit. The complaint asserts that the "service of this Complaint, in conjunction with the attached claim charts... constitutes actual knowledge of infringement" and that any continued infringement would be willful (Compl. ¶¶13-15).

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

  • An Evidentiary Question of Operation: Given the complaint’s lack of specific factual allegations, a primary issue for the court will be an evidentiary one: what is the actual method of operation of the accused IBM products? The plaintiff will bear the burden of demonstrating that these products perform the specific, multi-stage process of identifying direct relationships and then leveraging those to find indirect relationships, as recited in the claims.
  • A Definitional Question of Scope: The case will likely turn on the construction of the term "potential family of records." The key question for claim construction will be whether this term is limited to a set of records generated by the specific, iterative process detailed in the patent’s specification and flowcharts, or if it can be interpreted more broadly to cover any grouping of records that are linked by some form of transitive logic.