Alto Dynamics LLC v. Getyourguide Deutschland GmbH

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Alto Dynamics, LLC (Georgia)
  • Defendant: GetYourGuide Deutschland GmbH (Germany)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:24-cv-01016, E.D. Tex., 12/10/2024
• Venue Allegations: Plaintiff alleges that venue is proper because Defendant is a foreign corporation not resident in the United States and may therefore be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s online travel marketplace website infringes five U.S. patents related to database-to-XML data conversion, client-side user activity monitoring, and state-less user authentication methods.
• Technical Context: The patents relate to foundational web technologies for structuring data presentation, personalizing user experiences through activity tracking, and managing secure user sessions in a distributed environment.
• Key Procedural History: The complaint notes that U.S. Patent No. RE 46,513 is a reissue of U.S. Patent No. 7,020,645. Certificates of Correction have been issued for U.S. Patent Nos. 6,604,100, 7,152,018, and 7,657,531. No other significant procedural events are mentioned.

Case Timeline

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

U.S. Patent No. 6,604,100 - "Method For Converting Relational Data Into A Structured Document," issued August 5, 2003

• The Invention Explained:
  • Problem Addressed: The patent describes the technical challenge of automatically converting data from traditional "tabular, flat, normalized" relational databases into the "nested and un-normalized" structure of XML, which was becoming a standard for web-based data exchange (Compl. ¶24; ’100 Patent, col. 1:41-46). Existing tools were allegedly inflexible, inefficient, and often limited to fixed, "canonical" mappings of the database schema rather than arbitrary XML formats (Compl. ¶24; ’100 Patent, col. 1:47-2:4).
  • The Patented Solution: The invention proposes a system, referred to as "SilkRoute," that creates a virtual XML "view" of the relational data using a specialized query language. This allows an application to query the data as if it were already in XML. The system then composes the application's XML query with the view definition to generate an efficient SQL query that extracts only the necessary data fragments from the database, which are then merged into the final structured XML document (Compl. ¶25; ’100 Patent, col. 2:27-42, Fig. 1).
  • Technical Importance: The technology aimed to bridge the gap between the vast amount of data stored in legacy relational database systems and the growing demand for flexible, XML-formatted data by modern internet applications (Compl. ¶23; ’100 Patent, col. 1:35-40).
• Key Claims at a Glance:
  • The complaint asserts at least independent Claim 1 (Compl. ¶30).
  • Essential elements of Claim 1 include:
    • Storing a "view query" that defines a "structured document view" of a relational database, where the "structure of the view query" is "independent of a structure of data in the relational database".
    • Receiving a "user query" against the structured document view.
    • "Forming an executable query" by composing the view query and the user query.
    • "Partitioning" the executable query into a "data extraction portion" and a "construction portion".
    • Receiving at least one "tuple stream" from the database based on the data extraction portion.
    • "Merging" the tuple stream and the construction portion to generate a structured document of "arbitrary nesting depth".

U.S. Patent No. 7,152,018 - "System And Method For Monitoring Usage Patterns," issued December 19, 2006

• The Invention Explained:
  • Problem Addressed: The patent addresses the challenge of monitoring user activity on websites for personalization. It notes that conventional methods relying on server-side processing of user histories can be computationally intensive and that using unique identifiers in cookies can raise anonymity concerns (Compl. ¶41; ’018 Patent, col. 2:5-19).
  • The Patented Solution: The invention describes a method where a "state object" (e.g., a cookie) containing a user's usage profile is stored on the client's machine. The key innovation is that this profile is modified by scripts sent from the server but executed on the client, which "preclud[es] manipulation of the profile by the server." This approach is described as more "computationally efficient" because it avoids the need for constant database lookups on the server side to retrieve and update user profiles (Compl. ¶¶ 39, 41; ’018 Patent, col. 4:1-6).
  • Technical Importance: This client-centric profiling method offered a way to achieve web personalization with potentially lower server load and greater efficiency compared to traditional server-side tracking systems (Compl. ¶42; ’018 Patent, col. 4:1-6).
• Key Claims at a Glance:
  • The complaint asserts at least independent Claim 1 (Compl. ¶45).
  • Essential elements of Claim 1 include:
    • Providing a "state object" containing a "profile representative of user usage".
    • "Storing the state object at a client location".
    • Passing the state object to a "central server" with each interaction.
    • Receiving the state object back from the server with the server's response.
    • Wherein the profile is "modified... by one of one or more scripts" provided by the server and executed "at the client location".
    • This modification scheme is for the purpose of "precluding manipulation of the profile by the server".

Multi-Patent Capsule: U.S. Patent No. 7,392,160

• Patent Identification: U.S. Patent No. 7,392,160, "System And Method For Monitoring Usage Patterns," issued June 24, 2008.
• Technology Synopsis: As a continuation of the application leading to the ’018 patent, this patent addresses the same technical domain of user profiling. The claimed method also involves a state object stored and modified at the client location, but adds a step wherein the central server "audits the state object/profile passed to it" and "performs analysis on the audited profile" to direct services or information back to the client (Compl. ¶¶ 53, 59).
• Asserted Claims: At least Claim 1 is asserted (Compl. ¶58).
• Accused Features: The complaint alleges that Defendant's use of website cookies to track user activity, which are then analyzed by its servers to personalize the user experience, infringes this patent (Compl. ¶¶ 57, 59).

Multi-Patent Capsule: U.S. Patent No. 7,657,531

• Patent Identification: U.S. Patent No. 7,657,531, "Systems And Methods For State-Less Authentication," issued February 2, 2010.
• Technology Synopsis: This patent addresses problems in distributed systems where users may need to re-authenticate for different processes, which can be complex and inefficient (Compl. ¶¶ 66-67). The invention describes a method for renewing an expired "security-context" (e.g., a session token). A user presents the expired context and a renewal request to an authorization component, which verifies the user's identity and generates an updated security-context, allowing the user to regain access without a full re-logon (Compl. ¶¶ 68-69).
• Asserted Claims: At least Claim 1 is asserted (Compl. ¶73).
• Accused Features: The complaint accuses the functionality for renewing user sessions after expiration, such as the "Reset Password" page, of infringing this patent (Compl. ¶¶ 72, 74). Figure 3 in the complaint is a screenshot of the "Reset Password" page, used to illustrate the accused functionality (Compl. p. 20).

Multi-Patent Capsule: U.S. Patent No. RE 46,513

• Patent Identification: U.S. Patent No. RE 46,513, "Systems And Methods For State-Less Authentication," issued August 15, 2017.
• Technology Synopsis: This patent, a reissue of a patent from the same family as the ’531 patent, focuses on the initial generation of a security context. It describes a method where, after a user logon, the system generates a security context comprising a "plaintext header" and an "encrypted body." This context is then provided to the user, who can send it back to the system with a request to access resources, thereby enabling "state-less" authentication that avoids repeated logons (Compl. ¶¶ 81-84).
• Asserted Claims: At least Claim 1 is asserted (Compl. ¶88).
• Accused Features: The complaint accuses the website's user login system, which establishes secure sessions and provides the user with a session token or cookie, of infringing this patent (Compl. ¶¶ 87, 89). The complaint's Figure 4, a screenshot of the "Log in or sign up" page, is provided as an example of the accused functionality (Compl. p. 24).

III. The Accused Instrumentality

• Product Identification: The accused instrumentality is the website https://www.getyourguide.com/ and its associated hardware, software, and functionality (the "Accused Products") (Compl. ¶15).
• Functionality and Market Context: The complaint describes the Accused Products as an online platform that allows users to search, view, save, and purchase travel-related activities. To support this, the platform allegedly tracks user activities and preferences via cookies and manages user identity and access through login processes and secure sessions (Compl. ¶15). The complaint provides a screenshot in Figure 1 of a product page for a "Plano Scavenger Hunt" to exemplify the type of content and functionality offered (Compl. p. 9).

IV. Analysis of Infringement Allegations

6,604,100 Infringement Allegations

• Identified Points of Contention:
  • Architectural Question: A central question will be evidentiary: does the complaint provide sufficient factual basis to allege that the Accused Products use the specific internal architecture claimed, namely the "composition" of queries and the subsequent "partitioning" and "merging" steps? The court may question whether observing a webpage generated from a database is enough to plausibly allege this specific back-end process.

7,152,018 Infringement Allegations

• Identified Points of Contention:
  • Technical Question: The claim requires that the user profile is modified by client-side scripts to "preclude" manipulation by the server. A key point of contention may be whether the Accused Products' use of cookies meets this limitation. The defense may argue that servers routinely set, modify, and overwrite cookie values directly, which would suggest server manipulation is not "precluded." The interpretation of this negative limitation may be central to the infringement analysis.

V. Key Claim Terms for Construction

For U.S. Patent No. 6,604,100

• The Term: "structure of the view query being independent of a structure of data in the relational database" (Claim 1)
• Context and Importance: This term is central to the patent's assertion of novelty over prior art, which allegedly offered only fixed, "canonical" mappings tied directly to the database schema. To prove infringement, the plaintiff must show that the accused system uses a view definition that is decoupled from the underlying table structure. Practitioners may focus on this term to determine if the accused system's data-to-webpage mapping is merely a direct translation or a more abstract, flexible transformation as the patent appears to require.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification repeatedly emphasizes the goal of mapping relational data into XML that conforms to "arbitrary public document type definitions (DTDs)" ('100 Patent, col. 2:32-35), suggesting a high degree of independence from the proprietary relational schema.
  • Evidence for a Narrower Interpretation: The patent's own examples of the "RXL" query language still explicitly name relations (tables) from the database (e.g., from Clothing $c). A party could argue that any view definition that must explicitly reference underlying database tables is not truly "independent" of the database's structure.

For U.S. Patent No. 7,152,018

• The Term: "precluding manipulation of the profile by the server" (Claim 1)
• Context and Importance: This limitation defines the core technical departure from conventional server-side user profiling. The dispute may turn on the strength of the word "precluding."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification explains that "it is possible to update and manipulate the contents of the cookie profile without requiring any server side manipulation" ('018 Patent, col. 6:20-21, emphasis added). This language suggests the invention's purpose is to make server-side manipulation unnecessary for routine updates, not to make it technically impossible under all circumstances.
  • Evidence for a Narrower Interpretation: The plain meaning of "preclude" suggests prevention. A defendant could argue that any system in which the server can and does directly write or overwrite the cookie profile does not meet this limitation, as manipulation is not prevented. The claim language "thus precluding" suggests that the use of client-side scripts is the mechanism that achieves this preclusion.

VI. Other Allegations

• Indirect Infringement: The complaint does not include separate counts for indirect infringement. However, it alleges that Defendant infringes "by virtue of Defendant's... direction and control of customers and/or affiliates' performance of any steps deemed to require activity at a client" (Compl. ¶¶ 46, 59, 74, 89). This language raises the possibility of an induced infringement theory, where Defendant is alleged to provide a system that instructs its users' browsers to perform the claimed methods.
• Willful Infringement: The complaint does not explicitly allege willful infringement. It does, however, request in its prayer for relief that the court declare the case "exceptional" and award attorneys' fees pursuant to 35 U.S.C. § 285 (Compl. ¶92.e). Such a finding is often predicated on a finding of willful infringement, but the complaint does not plead specific facts concerning Defendant's pre- or post-suit knowledge of the patents.

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

• An Evidentiary Question of Architecture: A core issue for the ’100 patent will be whether Plaintiff can produce evidence that the internal architecture of the GetYourGuide platform performs the specific "partitioning" and "merging" of a "composed query" as claimed. The case may hinge on whether allegations based on observing the website's external output are sufficient to plausibly infer this specific, complex backend process.
• A Definitional Question of Technical Operation: For the ’018 and ’160 patents, the dispute will likely focus on the scope of the phrase "precluding manipulation... by the server." The central question for the court will be whether standard web cookie functionality, where servers frequently set and overwrite cookie values, can infringe a claim that requires profile modification to occur at the client location for the purpose of preventing server-side manipulation.
• A Question of Functional Scope: For the ’531 and ’513 authentication patents, a key issue will be one of definitional scope. The court will need to determine whether the functions of modern, standard web session management—such as user logins, password resets, and session cookies—are merely new names for the specific, multi-element "security-context" generation and renewal methods described in the patents, or if there is a fundamental mismatch in their technical scope and operation.