DCT
2:25-cv-00034
Alto Dynamics LLC v. Coldwell Banker Real Estate LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Alto Dynamics, LLC (Georgia)
- Defendant: Coldwell Banker Real Estate LLC (California)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-00034, E.D. Tex., 01/15/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains regular and established places of business within the district, including offices in Plano, McKinney, Allen, and Frisco, and has committed the alleged acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s "coldwellbanker.com" website infringes five patents related to methods for converting relational database data to structured documents, monitoring user activity patterns via client-side objects, and providing stateless user authentication.
- Technical Context: The asserted patents address foundational technologies for web applications, including how servers efficiently present database information, track user behavior for personalization, and manage secure user sessions.
- 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. This indicates the original patent underwent a subsequent examination by the USPTO, which can affect the scope and interpretation of its claims.
Case Timeline
| Date | Event |
|---|---|
| 2000-02-09 | Priority Date for U.S. Patent No. 6,604,100 |
| 2001-04-19 | Priority Date for U.S. Patent Nos. 7,657,531 and RE 46,513 |
| 2002-12-18 | Priority Date for U.S. Patent Nos. 7,152,018 and 7,392,160 |
| 2003-08-05 | Issue Date for U.S. Patent No. 6,604,100 |
| 2006-12-19 | Issue Date for U.S. Patent No. 7,152,018 |
| 2007-01-01 | Defendant allegedly began doing business in Texas |
| 2008-06-24 | Issue Date for U.S. Patent No. 7,392,160 |
| 2010-02-02 | Issue Date for U.S. Patent No. 7,657,531 |
| 2017-08-15 | Issue Date for U.S. Patent No. RE 46,513 |
| 2025-01-15 | Complaint Filing Date |
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 addresses the technical challenge of converting data from traditional relational databases—which store information in flat, tabular formats—into structured, nested XML documents suitable for web applications. Prior methods were described as inefficient, not general enough to map to arbitrary XML formats, and not "dynamic," often requiring the entire database to be converted at once rather than just the portion a user requested. (Compl. ¶¶24-26; ’100 Patent, col. 1:41-2:24).
- The Patented Solution: The invention proposes a method where a "view query" defines a virtual, structured (XML) view of the relational data, independent of the database's actual schema. When a user makes a request, the system composes the user's query with the view query to form a new, "executable query." This executable query is then partitioned into a data extraction part (e.g., an SQL query) and a construction part (e.g., an XML template). Only the specific data needed is retrieved from the database and then merged with the template to dynamically generate the final structured document. (Compl. ¶¶27-28; ’100 Patent, Fig. 1).
- Technical Importance: This approach provided a more flexible and computationally efficient bridge between legacy relational database systems and the growing number of web services and applications designed to consume structured XML data. (Compl. ¶25).
Key Claims at a Glance
- The complaint asserts at least independent claim 1. (Compl. ¶32).
- Claim 1 requires a method comprising the elements of:
- storing a view query that defines a structured document view of the relational database, a structure of the view query being independent of a structure of data in the relational database;
- receiving a user query against the structured document view;
- forming an executable query by determining a composition of the view query and the user query;
- partitioning the executable query into a data extraction portion and a construction portion;
- transmitting the data extraction portion to the relational database;
- receiving at least one tuple stream from the relational database according to the data extraction portion; and
- merging the at least one tuple stream and the construction portion to generate a structured document, wherein the structured document view is capable of defining a 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 identifies a need for more computationally efficient ways to monitor user activity on websites. Traditional methods that relied heavily on server-side processing and database storage for user profiles were described as creating a significant computational burden. (Compl. ¶43; ’018 Patent, col. 4:1-6).
- The Patented Solution: The invention describes a method where a "state object" (e.g., a cookie) containing a user profile is stored on the client's machine. The profile is then modified directly on the client by scripts sent from the server. This client-side modification reflects the user's interactions (e.g., pages visited) "without requiring any server side manipulation," thereby offloading processing from the server to the client. (Compl. ¶¶41-42; ’018 Patent, col. 6:18-25).
- Technical Importance: This client-centric approach to profile management was aimed at improving the scalability and performance of high-traffic websites that rely on user tracking for personalization and analytics. (Compl. ¶44).
Key Claims at a Glance
- The complaint asserts at least independent claim 1. (Compl. ¶47).
- Claim 1 requires a method comprising the elements of:
- providing at least one state object, the object including a profile representative of user usage;
- storing the state object at a client location;
- passing, to a central server, the state object with each subsequent interaction initiation;
- receiving, from the central server, the state object along with the response of the central server;
- wherein the profile is modified, to reflect the interaction between the client location and the central server, by one of one or more scripts within or included in information/resources provided to the client location by the central server, and one or more programs executed at the client location, thus precluding manipulation of the profile by the server.
U.S. Patent No. 7,392,160, "System And Method For Monitoring Usage Patterns," issued June 24, 2008
- Technology Synopsis: This patent, related to the ’018 Patent, describes a method for monitoring user usage patterns. The method involves storing a "state object" with a user profile on the client machine, modifying that profile at the client location to reflect user-server interactions, and having the central server audit the returned profile to direct services or information back to the client. (Compl. ¶¶55-56, 61).
- Asserted Claims: At least independent claim 1. (Compl. ¶60).
- Accused Features: Defendant's deployment and use of cookies to track user activity. (Compl. ¶59).
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 authenticating users in distributed computing environments. It discloses a method using an "encrypted data element called a security context" that is built and accessed only by a trusted computing environment. This context allows a user to access resources without repeated logons, eliminating the security risks of interception or unauthorized use associated with less complex authentication schemes. (Compl. ¶¶68, 70).
- Asserted Claims: At least independent claim 1. (Compl. ¶75).
- Accused Features: The accused functionality is the "renewal of cookies after their expiration" as part of the website's user authentication system. (Compl. ¶74).
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, also relates to stateless authentication. The invention describes generating a "security context" from logon information. This security context comprises a "plaintext header" (containing a context ID, key handle, etc.) and an "encrypted body." The user sends this security context to a processing system to request access to a resource, enabling secure communication sessions. (Compl. ¶¶83, 86).
- Asserted Claims: At least independent claim 16. (Compl. ¶90).
- Accused Features: The accused functionality is the website's "employ of secure communication sessions" for user access and authentication. (Compl. ¶89).
III. The Accused Instrumentality
- Product Identification: The accused instrumentality is the website "https://www.coldwellbanker.com/" and its associated hardware, software, and functionality (collectively, the "Accused Products"). (Compl. ¶17).
- Functionality and Market Context: The complaint alleges that the Accused Products constitute an online real estate platform that provides several infringing functionalities. These include database searching and viewing capabilities that allow users to search, view, and save property listings. (Compl. ¶¶17, 33). The complaint also alleges the platform tracks user activities and preferences through the use of cookies and provides user authentication through login processes and secured sessions. (Compl. ¶¶17, 46, 74, 89). Figure 1 of the complaint provides a screenshot of the website's search interface, showing property listings on a map, which illustrates the alleged database viewing capabilities. (Compl. p. 5, Fig. 1).
IV. Analysis of Infringement Allegations
'100 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| storing a view query that defines a structured document view of the relational database, a structure of the view query being independent of a structure of data in the relational database | The Accused Products store a query that defines a structured view of the underlying real estate relational database. | ¶33 | col. 5:6-10 |
| receiving a user query against the structured document view | The Accused Products receive user queries, such as search criteria for properties, against the structured document view. | ¶33 | col. 5:14-16 |
| forming an executable query by determining a composition of the view query and the user query | The Accused Products form an executable query by composing the stored view query and the received user query. | ¶33 | col. 5:19-22 |
| partitioning the executable query into a data extraction portion and a construction portion | The Accused Products partition the executable query into a portion for data extraction (e.g., from a database) and a portion for construction (e.g., rendering the webpage). | ¶33 | col. 5:26-29 |
| transmitting the data extraction portion to the relational database | The Accused Products transmit the data extraction portion of the query to the relational database containing property information. | ¶33 | col. 5:36-37 |
| receiving at least one tuple stream from the relational database according to the data extraction portion | The Accused Products receive a stream of data (tuples) from the database in response to the query. | ¶33 | col. 5:38-40 |
| merging the at least one tuple stream and the construction portion to generate a structured document... | The Accused Products merge the received data stream with the construction portion to generate a structured document, such as the search results webpage. The complaint provides a screenshot with underlying code purporting to show this structure. (Compl. p. 10, Fig. 4). | ¶33 | col. 5:41-44 |
Identified Points of Contention
- Scope Questions: The analysis may focus on whether the standard architecture of a modern web application, which queries a database and renders a results page, practices the specific, ordered steps of the claim. A question for the court may be whether the defendant’s system uses a "view query" that is "independent of a structure of data in the relational database" and performs a "composition" step as those terms are defined by the patent, or if it uses more direct database queries that do not meet these limitations.
- Technical Questions: A factual question may be what evidence exists that the accused system specifically "partitions" a single "executable query" into distinct "data extraction" and "construction" portions that are later "merged," as opposed to employing a more integrated process of data retrieval and rendering.
'018 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing at least one state object, the object including a profile representative of user usage | The Accused Products provide a state object, such as a cookie, that includes a profile of the user's usage of the website. The complaint includes screenshots of cookie consent and preference dialogs. (Compl. p. 14, Figs. 6-7). | ¶48 | col. 2:21-24 |
| storing the state object at a client location | The Accused Products store this state object (cookie) on the user's client device (e.g., in the web browser). | ¶48 | col. 2:24-25 |
| passing, to a central server, the state object with each subsequent interaction initiation | The user's browser passes the state object back to the central server with each subsequent request. | ¶48 | col. 2:25-27 |
| receiving, from the central server, the state object along with the response of the central server | The client receives the state object back from the server along with the server's response (e.g., webpage content). | ¶48 | col. 2:27-29 |
| wherein the profile is modified...by one of one or more scripts within or included in information/resources provided to the client location...thus precluding manipulation of the profile by the server | The user profile within the state object is allegedly modified by scripts running on the client's device, which reflects the user's interaction with the site and precludes the server from manipulating the profile in this step. | ¶48 | col. 2:62-67 |
Identified Points of Contention
- Scope Questions: The central dispute may involve the negative limitation "thus precluding manipulation of the profile by the server." The court may need to determine if this requires that the server be architecturally incapable of modifying the cookie upon its return, or if it is sufficient that a specific modification step is performed on the client side without server involvement.
- Technical Questions: An evidentiary question will be whether the modification of user-profile cookies in the Accused Products is in fact performed exclusively by client-side scripts as required by the claim, or if the server also participates in or retains the ability to perform such modifications.
V. Key Claim Terms for Construction
For the ’100 Patent
- The Term: "view query"
- Context and Importance: This term is critical because the claim requires a specific two-query architecture: a persistent "view query" and a transient "user query" that are composed. Infringement depends on whether the defendant's system uses a construct that meets this definition. Practitioners may focus on this term because Defendant may argue its system uses a more conventional, single-query model (e.g., via an Object-Relational Mapper) that does not employ a separate, independent "view query" as contemplated by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the invention as providing a "general, dynamic, and efficient tool for viewing and querying relational data in XML," suggesting the concept is not limited to a single implementation. (’100 Patent, col. 2:30-33).
- Evidence for a Narrower Interpretation: The patent's detailed description heavily features a specific, novel language called RXL ("Relational to XML Transformation Language") as the means for defining the view query. This could support an interpretation that "view query" is limited to a query written in RXL or a language with similar declarative, transformational properties. (’100 Patent, col. 5:55-58).
For the ’018 Patent
- The Term: "precluding manipulation of the profile by the server"
- Context and Importance: This negative limitation is a cornerstone of the claimed invention's purported efficiency improvement. The entire infringement theory for this patent may turn on whether the accused system's architecture meets this "preclusion" requirement. Practitioners may focus on this term because it presents a high bar; if the defendant's server retains any ability to modify the profile cookie, it may argue it does not infringe.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification explains that through client-side scripts, "it is possible to update and manipulate the contents of the cookie profile without requiring any server side manipulation." (’018 Patent, col. 6:20-22). This language suggests that the "precluding" refers to the capability of the claimed method to operate without the server's involvement in the modification step, not necessarily that the server must be rendered permanently incapable of manipulation.
- Evidence for a Narrower Interpretation: The claim's use of "thus precluding" suggests a direct causal result. An interpretation could be that the use of client-side scripts must create a condition where the server is, in fact, prevented from manipulating the profile. The abstract states the profile is modified to "preclude manipulation... by the server," framing it as a definitive outcome of the invention. (’018 Patent, Abstract).
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant has indirectly infringed the asserted patents. For the '018 and '160 patents, this allegation is based on the "direction and control of customers and/or affiliates' performance of any steps deemed to require activity at a client." (Compl. ¶¶48, 61).
VII. Analyst’s Conclusion: Key Questions for the Case
This case presents several fundamental questions regarding the application of patents from the early 2000s to contemporary web technologies. The outcome will likely depend on the answers to these key questions:
- A core issue will be one of architectural equivalence: Does the data-handling architecture of the accused modern web platform, which dynamically generates content from a database in response to user input, practice the specific sequence of storing, receiving, composing, partitioning, and merging queries as recited in claim 1 of the ’100 patent?
- A second key question will be one of functional scope: What is the proper construction of the term "precluding manipulation... by the server" in the ’018 patent? Does this require an architecture where the server is rendered incapable of modifying the user profile, or is it sufficient that a particular modification step is performed on the client-side without the server's involvement?
- A third question will be one of technical specificity: Can Plaintiff demonstrate that the general use of cookies and secure sessions for user authentication on the accused website maps to the specific cryptographic structures and methods described in the stateless authentication patents, such as the generation and use of a "security context" with a defined plaintext header and encrypted body?