DCT
2:23-cv-00627
Rule 14 LLC v. UiPath Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Rule 14 LLC (Nevada)
- Defendant: UiPath Inc. (Delaware)
- Plaintiff’s Counsel: Reichman Jorgensen Lehman & Feldberg LLP; Gillam & Smith LLP
- Case Identification: 2:23-cv-00627, E.D. Tex., 12/22/2023
- Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas based on Defendant UiPath Inc. maintaining a regular and established place of business in Plano, Texas, and employing numerous individuals within the district who are knowledgeable about the accused products.
- Core Dispute: Plaintiff alleges that Defendant’s automation software platform, including its Communications Mining and Document Understanding products, infringes two patents related to real-time and adaptive data mining.
- Technical Context: The technology concerns methods for automatically identifying, extracting, and analyzing relevant information from large volumes of unstructured and real-time data sources, a core challenge in the field of enterprise automation and data analytics.
- Key Procedural History: The U.S. Patent No. 11,048,712 is a continuation-in-part of U.S. Patent No. 9,229,977. The ’712 Patent is subject to a terminal disclaimer, which may limit the effective term of the patent to that of the earlier ’977 Patent and could impact the calculation of damages.
Case Timeline
| Date | Event |
|---|---|
| 2012-08-02 | Priority Date for ’977 and ’712 Patents |
| 2016-01-05 | U.S. Patent No. 9,229,977 Issued |
| 2021-06-29 | U.S. Patent No. 11,048,712 Issued |
| 2023-12-22 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,229,977 - "Real-Time And Adaptive Data Mining," issued January 5, 2016
The Invention Explained
- Problem Addressed: The patent identifies the shortcomings of prior art search engines, which were limited to searching for exact terms within indexed websites and were not designed to analyze multiple, unstructured, and real-time data points, such as data from "web sites behind firewalls, and/or comment sections on a web page" (’977 Patent, col. 1:32-43).
- The Patented Solution: The invention describes a multi-step method for analyzing data. The process begins with a user-generated query, expands the search terms, executes the expanded query across various data sources, and then selects specific sources for ongoing monitoring based on accuracy thresholds. The system then extracts relevant data from these monitored sources and uses it to establish a communication channel with a second user (’977 Patent, Abstract; col. 3:10-56).
- Technical Importance: The technology provided a structured method to address the increasing demand for real-time information extraction from the vast and dynamic datasets emerging in the internet era (’977 Patent, col. 1:45-48).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶40).
- The essential elements of claim 1 include:
- generating, via a first user, a query based at least in part on a topic of interest;
- expanding search terms of the query;
- executing the query on a plurality of data sources;
- selecting at least one data source from the plurality of data Sources, where selection is based on query results meeting or exceeding accuracy thresholds;
- monitoring the selected data source(s) on a set schedule to extract new or updated data that matches the query; and
- establishing a communication channel with a second user based on the extracted data.
- The complaint alleges infringement of "one or more claims" but provides infringement analysis only for claim 1, reserving the right to assert others (Compl. ¶39).
U.S. Patent No. 11,048,712 - "Real-Time And Adaptive Data Mining," issued June 29, 2021
The Invention Explained
- Problem Addressed: The patent addresses the same general problem as the ’977 Patent but extends the focus to the analysis of non-textual data, which conventional search engines were ill-equipped to handle (’712 Patent, col. 4:22-30).
- The Patented Solution: The invention discloses a method similar to that of the ’977 Patent but is directed specifically to receiving and processing a "query for non-textual data." The method includes receiving the query, expanding its search terms, executing it, selecting data sources based on accuracy, monitoring them for new non-textual data matching the query, and establishing a communication channel with a second user based on the extracted non-textual data (’712 Patent, Abstract; Fig. 13). The specification gives an image of a beach as an example of a non-textual query (’712 Patent, col. 4:48-50).
- Technical Importance: The invention aims to provide a system for real-time data mining of non-textual data like images, audio, or video, which represents a significant and growing portion of internet content (’712 Patent, col. 4:22-30, 4:46-50).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶56).
- The essential elements of claim 1 include:
- receiving, from a first user, a query for non-textual data;
- expanding search terms of the query;
- executing the query on a plurality of data sources;
- selecting at least one data source based on results meeting or exceeding accuracy thresholds;
- monitoring the selected data source(s) on a set schedule to extract non-textual data that matches the query; and
- establishing a communication channel with a second user based on the extracted non-textual data.
- The complaint alleges infringement of "one or more claims" but provides infringement analysis only for claim 1 (Compl. ¶55).
III. The Accused Instrumentality
Product Identification
- The accused products are UiPath's Automation Cloud and Automation Suite, along with their standalone deployments. The complaint specifically names components including Communications Mining, Process Mining, Task Mining, Document Understanding, Studio, Robots, and Orchestrator (collectively, the "Accused Products/Services") (Compl. ¶30, ¶32).
Functionality and Market Context
- The complaint alleges the Accused Products/Services function as an end-to-end "hyperautomation" platform (Compl. ¶13). The platform's "Discovery products," such as Communications Mining, are alleged to analyze data from business communications and employee desktop activities to identify automation opportunities (Compl. ¶34). A marketing diagram included in the complaint depicts this workflow, showing how discovery products feed into an "Automation Hub" to prioritize and accelerate automations. (Compl. p. 12). The resulting data is then allegedly used by other products, such as UiPath Robots, to "extend automation into service and conversation-based processes," including automating workflows and transactional requests (Compl. ¶35, ¶47).
IV. Analysis of Infringement Allegations
U.S. Patent No. 9,229,977 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| generating, via a first user, a query based at least in part on a topic of interest | A user of UiPath Communications Mining initiates the process by uploading a taxonomy or a "predefined list of labels" that the system should look for in business communications. A screenshot shows the user interface for this step (Compl. p. 17). | ¶42 | col. 3:13-17 |
| expanding search terms of the query | The system analyzes communications and creates "a cluster of similar looking emails that all have similar wording," which the complaint alleges constitutes an expansion of the initial query terms. A screenshot shows the system grouping "similar verbatims" (Compl. p. 18). | ¶43 | col. 3:18-28 |
| executing the query on a plurality of data sources | The Communications Mining product is alleged to look through large volumes of data, such as "hundred and thirteen thousand emails," from various business communication channels. | ¶44 | col. 5:1-5 |
| selecting at least one data source ... when results of the query are greater than or equal to an accuracy thresholds | The platform uses "confidence thresholds" to make a binary decision on whether a predicted label applies to a communication, and these communications are then put into a data stream for further action. A screenshot shows a user setting a "confidence threshold" (Compl. pp. 19-20). | ¶45 | col. 7:31-35 |
| monitoring, based on a set schedule, the at least one data source to extract data ... when at least an update to stored data that matches the query ... | The platform allegedly provides a "custom-filtered, real-time view of all service channels" and uses "real-time alerts," which constitutes monitoring data sources for new or updated information matching the query. | ¶46 | col. 5:32-40 |
| establishing a communication channel with a second user based at least in part on the data extracted from the at least one monitored data source | UiPath Robots allegedly use the data from Communications Mining to automate processes, such as by adding tasks to an Orchestrator queue. The complaint asserts this automated workflow constitutes the claimed communication channel. A workflow diagram shows data being fed to an "Orchestrator queue" (Compl. p. 21). | ¶47 | col. 5:41-48 |
- Identified Points of Contention:
- Scope Question: A central question may be whether the automated process of sending analyzed data to a "UiPath Robot" or an "Orchestrator queue" meets the claim limitation of "establishing a communication channel with a second user." The defense may argue that "user" implies a human, whereas the complaint's theory appears to rely on a machine-to-machine or process-to-process communication path.
- Technical Question: It may be disputed whether creating "a cluster of similar looking emails" (Compl. ¶43), a function of natural language processing, is equivalent to "expanding search terms of the query" as described in the patent, which focuses on using lexicons and synonym trees (’977 Patent, col. 3:18-28).
U.S. Patent No. 11,048,712 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving, from a first user, a query for non-textual data | A user provides a textual query (a taxonomy of labels) to find and process documents that contain non-textual data, such as "PDFs, images, handwriting, and scans" processed by UiPath Document Understanding. | ¶58 | col. 4:46-50 |
| expanding search terms of the query | The system creates "a cluster of similar looking emails that all have similar wording," allegedly expanding the query to find documents containing the non-textual data. | ¶59 | col. 4:51-60 |
| executing the query on a plurality of data sources | The platform executes the query across business communications channels, including emails and tickets that may contain or be attachments with non-textual data. | ¶60 | col. 5:58-61 |
| selecting at least one data source ... when results of the query are greater than or equal to an accuracy thresholds | The platform uses "confidence thresholds" to select communications containing relevant data (which may be non-textual) for inclusion in an automated process stream. | ¶61 | col. 6:58-62 |
| monitoring, based on a set schedule, the at least one data source to extract non-textual data ... when at least an update to stored data matches the query ... | The platform provides a "real-time view of all service channels" and "custom real-time alerts," which the complaint alleges constitutes monitoring for new or updated non-textual data. | ¶62 | col. 6:63-col. 7:4 |
| establishing a communication channel with a second user based at least in part on the data extracted from the at least one monitored data source | UiPath Robots use the extracted non-textual data (e.g., from a scanned document) to automate workflows, such as by creating a case or updating customer information. | ¶63 | col. 7:5-9 |
- Identified Points of Contention:
- Scope Question: The primary point of contention will likely be the interpretation of "query for non-textual data." The complaint alleges that a textual query (uploading labels) used to find documents that contain non-textual data satisfies this limitation. The defense may argue that the claim requires the query itself to be non-textual (e.g., an image search with a sample image), as contemplated by the patent’s specification (’712 Patent, col. 4:48-50).
V. Key Claim Terms for Construction
The Term: "a communication channel with a second user" (’977 Claim 1; ’712 Claim 1)
- Context and Importance: This term is critical because the plaintiff’s infringement theory relies on an automated workflow (data being sent to an Orchestrator queue for a software robot) constituting this "channel." The definition will determine whether a human-to-human or human-to-system interaction is required, or if a fully automated process-to-process data transfer suffices.
- Intrinsic Evidence for a Broader Interpretation: The specification states a communication channel may be established with "other users based on the analyzed data" and does not explicitly require the user to be human (’977 Patent, col. 5:41-44). The system is described as being for "automated data extraction" (’977 Patent, col. 1:49-50), which may support a broader, machine-centric interpretation.
- Intrinsic Evidence for a Narrower Interpretation: The patent provides examples of communication channels such as "a message board, phone, SMS, or email" (’977 Patent, col. 5:51-53) and discusses a "customer communication module" (col. 9:16-19), all of which typically involve a human recipient. The plain meaning of "user" often implies a person.
The Term: "query for non-textual data" (’712 Claim 1)
- Context and Importance: The viability of the infringement allegation for the ’712 patent hinges on this term. Practitioners may focus on this term because the complaint's theory is that a textual query (a list of labels) satisfies the limitation because its purpose is to find and retrieve documents containing non-textual elements.
- Intrinsic Evidence for a Broader Interpretation: The patent broadly states the system is for analyzing "textual and/or non-textual data" (’712 Patent, col. 4:32-33). One could argue that the "for" in the claim phrase modifies the purpose of the query, not its format, meaning any query intended to retrieve non-textual data would qualify.
- Intrinsic Evidence for a Narrower Interpretation: The specification explicitly describes a non-textual query as including, for example, "an image of a beach" used to "find images of a beach and/or people with images at the beach" (’712 Patent, col. 4:48-50). This suggests the query itself is non-textual in format, creating a potential mismatch with the complaint's allegation of a text-based taxonomy upload.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement of infringement for both patents. It claims UiPath encourages infringement by marketing the Accused Products, providing technical assistance and tutorials, and operating the UiPath Marketplace, all of which allegedly instruct customers on using the products in an infringing manner (Compl. ¶51-52, ¶67-68, fn. 21).
- Willful Infringement: Willfulness is alleged for both patents based on knowledge acquired, at the latest, upon the filing of the complaint. The plaintiff alleges that UiPath has "made no attempts to design around" the patents and continues to act in "wanton disregard of Rule 14's patent rights" (Compl. ¶49, ¶65).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "communication channel with a second user", which the patent illustrates with examples like email and SMS, be construed to cover a fully automated workflow where data is passed from one software module to another (e.g., an Orchestrator queue for a software robot)?
- A key question of claim interpretation for the ’712 patent will be whether a "query for non-textual data" requires the query itself to be in a non-textual format (e.g., an image), or if a text-based query (e.g., a list of labels) intended to retrieve documents containing non-textual information meets the claim limitation.
- An evidentiary and technical question will be one of functional operation: does the accused system's method of creating "cluster[s] of similar looking emails" perform the same function in substantially the same way as the patent's disclosure of "expanding search terms" using predefined lexicons and synonym trees?