TG 2006 Holdings LLC v. Synccom Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TG--2006 Holdings, LLC (Texas)
  • Defendant: Sync.com Inc. (Canada)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00075, E.D. Tex., 02/02/2024
• Venue Allegations: Venue is alleged to be proper as the defendant is a foreign corporation, has committed acts of infringement in the district, and caused harm in the district.
• Core Dispute: Plaintiff alleges that Defendant’s cloud storage services infringe patents related to systems for tracking business information using a hierarchical folder interface where folder attributes change visually to reflect time-sensitive status updates.
• Technical Context: The technology at issue falls within the domain of graphical user interfaces for business process and project management, where visual cues are used to convey the status of time-critical tasks.
• Key Procedural History: The patents-in-suit, U.S. Patent Nos. 9,454,741 and 9,805,323, are part of the same patent family and claim a common priority date. The ’323 patent is a continuation of the application that led to the ’741 patent and is subject to a terminal disclaimer. The complaint does not mention any prior litigation or administrative proceedings involving these patents.

Case Timeline

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

U.S. Patent No. 9,454,741 - "System and method for tracking information in a business environment," issued September 27, 2016

The Invention Explained

• Problem Addressed: The patent’s background section identifies that tracking business information can be "time consuming and confusing," and that a poorly designed tracking system "defeats it own purpose" (’741 Patent, col. 1:15-23).
• The Patented Solution: The invention provides a system for visually tracking the status of business operations using a hierarchical folder tree on a computer display (’741 Patent, col. 1:26-31). In this system, parent folders contain child folders or documents which are associated with tasks, deadlines, and time triggers (’741 Patent, col. 1:33-36). The core innovation is that the "visual attributes of the parent folders are altered in response to conditions of the items contained within the folders and subfolders," such as a folder’s color changing from green to red to indicate a task is overdue (’741 Patent, col. 1:36-39; col. 4:21-23).
• Technical Importance: The described method aims to provide an intuitive, at-a-glance visual management tool for complex, time-critical business processes, such as manufacturing, allowing for rapid identification of workflow problems (’741 Patent, col. 3:1-4).

Key Claims at a Glance

• The complaint asserts at least Claim 1, the sole claim of the patent (Compl. ¶12; ’741 Patent, col. 11:5-21).
• Independent Claim 1 requires a method comprising the following essential elements:
  • Establishing a parent folder and an associated child folder.
  • Establishing an "in-house product" and associating it with at least one "task," "products," and "labor codes."
  • Assigning a "time trigger" to the in-house product and a "first alert interval" to the task.
  • Starting and monitoring a system clock.
  • Changing the color of the child folder when the system time meets or exceeds the alert interval.
  • Changing the color of the parent folder in response to the child folder’s color change.

U.S. Patent No. 9,805,323 - "System and method for tracking information in a business environment," issued October 31, 2017

The Invention Explained

• Problem Addressed: As with its parent, the ’323 Patent addresses the problem that conventional business information tracking is often "confusingly displayed" and ineffective (’323 Patent, col. 1:19-21).
• The Patented Solution: The patent describes a similar system based on a hierarchical folder tree view where visual status indicators are used (’323 Patent, col. 1:30-39). The method involves correlating a child folder with a "time critical task," setting an "alert interval," and then "changing an attribute" of the child folder when that interval is exceeded (’323 Patent, Claim 1, col. 11:5-15). This change then triggers a corresponding change in an "attribute" of the parent folder, creating a cascading visual alert (’323 Patent, col. 11:16-18).
• Technical Importance: This system provides a flexible visual framework for monitoring workflows, allowing for user-definable alerts that signal when time-sensitive tasks require attention (’323 Patent, col. 4:55-63).

Key Claims at a Glance

• The complaint asserts exemplary claims from the patent, including independent claims 1 and 8 (Compl. ¶21; ’323 Patent, col. 11:5-12:21).
• Independent Claim 1 requires a method comprising:
  • Establishing a parent folder and an associated child folder.
  • Correlating the child folder with a "time critical task" and associating a "first alert interval" with that task.
  • Starting and monitoring a system clock.
  • Changing an "attribute" of the child folder when the time equals or exceeds the alert interval.
  • Changing an "attribute" of the parent folder when the child folder's attribute changes.
• Independent Claim 8 is substantively identical to Claim 1 of the '741 patent, requiring the changing of folder "color."
• The complaint reserves the right to assert dependent claims (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" but does not name them, instead identifying them in referenced exhibits (Compl. ¶12, ¶21). Based on the defendant's corporate identity, the accused instrumentality is understood to be the Sync.com cloud storage and file sharing service.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused product's specific functionality. It alleges that the products practice the claimed technology and incorporates by reference claim charts in Exhibits 3 and 4, which were not filed with the complaint (Compl. ¶17, ¶26). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" directly infringe the asserted claims of the '741 and '323 patents (Compl. ¶¶ 12, 21). The infringement allegations are supported by claim charts in Exhibits 3 and 4, which are incorporated by reference but were not publicly available for review (Compl. ¶¶ 17-18, 26-27). The complaint asserts narratively that these charts demonstrate how the accused products "satisfy all elements" of the exemplary claims (Compl. ¶¶ 17, 26). Without access to the specific mapping of product features to claim elements, a detailed analysis of the infringement theory is not possible based on the complaint alone.

• Identified Points of Contention:
  • Scope Questions ('741 Patent): A central question may be whether the elements of the accused cloud storage service can be mapped to the specific business-process terminology of Claim 1. For instance, the analysis may focus on whether a digital file shared via Sync.com constitutes an "in-house product" and whether user actions correspond to "associating labor codes," as those terms are used in the context of the patent's manufacturing-focused disclosure (’741 Patent, col. 11:10-12).
  • Technical Questions ('323 Patent): For the '323 patent, a key technical question may be whether the accused service performs the specific cascading alert mechanism required by Claim 1. The claim requires that a change in the "attribute of the parent folder" occurs specifically "when the attribute of the child folder changes," suggesting a direct, programmatic dependency that Plaintiff will need to prove exists in the accused system (’323 Patent, col. 11:16-18).

V. Key Claim Terms for Construction

'741 Patent

• The Term: "in-house product"
• Context and Importance: This term appears in asserted Claim 1 and seems to anchor the invention to a specific type of business environment. The viability of the infringement case may depend on whether this term can be construed broadly enough to cover digital files in a general-purpose cloud storage service. Practitioners may focus on this term because the patent's specification heavily implies a manufacturing or production context.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff might argue that the term is not limited to physical goods, pointing to the general purpose of tracking "information in a business environment" and defining an "in-house product" (IHP) as "a product that a company manufactures that has specific tasks that lead to its completion," which could arguably include a complex digital work product (’741 Patent, Title; col. 3:32-35).
  • Evidence for a Narrower Interpretation: The specification consistently discusses IHPs in the context of "production subassemblies," "kits," and manufacturing process screens, suggesting a tangible or complex deliverable distinct from a simple file (’741 Patent, col. 1:41-42; Fig. 2).

'323 Patent

• The Term: "attribute"
• Context and Importance: This term is foundational to Claim 1 of the '323 patent, which requires the changing of folder "attributes." The scope of infringement will hinge on how broadly this term is defined, as it could encompass a wide range of user interface behaviors.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list, stating an alert "will typically comprise a change in the color, size, animation, or other visual attribute of the folder, but may also include audible and textual information" (’323 Patent, col. 4:59-63). Dependent Claim 7 further lists "visual, color, animation, textual, size and audible," supporting a broad construction covering various UI notifications (’323 Patent, col. 12:7-12).
  • Evidence for a Narrower Interpretation: A defendant may argue that the claim's structure—"changing an attribute of the parent folder when the attribute of the child folder changes"—implies a change to a persistent state or property of the folder object itself, not a transient notification like a temporary badge or pop-up (’323 Patent, col. 11:16-18).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents. The factual basis for inducement is Defendant’s alleged sale of the accused products along with the distribution of "product literature and website materials" that instruct customers on how to use the products in an infringing manner (Compl. ¶¶ 15-16, 24-25).
• Willful Infringement: Willfulness allegations are based on post-suit knowledge. The complaint alleges that the filing and service of the complaint and its attached claim charts provide Defendant with "actual knowledge of infringement" and that any continued infringement is therefore willful (Compl. ¶¶ 14-15, 23-24). No allegations of pre-suit knowledge are made.

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

• A core issue will be one of definitional scope: can terms such as "in-house product", "task", and "labor codes", which are described in the patent specification within a manufacturing and business process context, be construed to read on the general-purpose files, folders, and user activities within the accused cloud storage service?
• A key evidentiary question will be one of functional mapping: what specific evidence will show that the accused service performs the claimed multi-step method, particularly the cascading change of "attributes" from a child folder to a parent folder that is programmatically triggered by a "system clock" monitoring a user-defined "alert interval"?
• A third area of focus may involve the breadth of the claimed invention, raising the question of how the claimed method, which covers changing a folder's visual attribute based on a time-based status change, will be distinguished from other user interface paradigms for displaying status updates in hierarchical data structures that may have existed before the patents' 2004 priority date.