TG 2006 Holdings LLC v. Atlassian Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TG--2006 Holdings, LLC (Texas)
  • Defendant: Atlassian Corporation (Australia)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00249, E.D. Tex., 03/02/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the Eastern District of Texas and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s software products infringe a patent related to systems and methods for tracking business information using a hierarchical display that visually indicates status changes.
• Technical Context: The technology concerns graphical user interfaces for project and process management, a field central to enterprise software for monitoring complex workflows.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,583,514 - System and method for tracking information in a business environment

• Patent Identification: U.S. Patent No. 8,583,514, "System and method for tracking information in a business environment", issued November 12, 2013.

The Invention Explained

• Problem Addressed: The patent addresses the challenge that tracking business information can be "time consuming and confusing," and if not displayed in a "visually clear and meaningful way," the tracking system defeats its own purpose (ʼ514 Patent, col. 1:13-21).
• The Patented Solution: The invention is a software system that uses a hierarchical "folder tree view" to manage tasks and information. The core concept is that items within the hierarchy (e.g., tasks, documents, sub-folders) are "child elements" of "parent folders." These child elements are associated with "time triggers" or other event alerts. When a trigger is activated (e.g., a deadline is missed), the "visual attributes" of the parent folder—and potentially folders further up the hierarchy—are automatically altered to signal a status change, such as by changing color. This allows a user to identify problems at a high level without needing to expand every folder in the tree view (ʼ514 Patent, col. 1:24-34; col. 4:4-16).
• Technical Importance: The described approach provides a method for visually managing complex processes by cascading status alerts up a hierarchical structure, enabling users to quickly identify and locate issues in workflows like production, sales, or project management (’514 Patent, col. 1:35-40).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead referring to "Exemplary '514 Patent Claims" detailed in a non-proffered exhibit (Compl. ¶11). All thirteen claims of the patent depend from the single independent claim, Claim 1.
• Independent Claim 1 recites a method with the following essential elements:
  • Establishing a "parent folder" to contain other folders or documents.
  • Establishing a "child element" (e.g., a document or sub-folder) associated with the parent folder.
  • "Correlating the child element" with a time-critical task, inventory, or accounting activity.
  • "Associating a time trigger" with that task or activity.
  • Providing a means for "clearing the time trigger" upon completion of the task.
  • "Changing an attribute of the parent folder" based on the state of the child element when a time trigger is met before it can be cleared.

III. The Accused Instrumentality

Product Identification

• The complaint does not specifically name any of Defendant’s products. It refers generally to "Exemplary Defendant Products" that are identified in claim charts attached as Exhibit 2, which was not filed with the complaint (Compl. ¶11, ¶16).

Functionality and Market Context

• The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '514 Patent" (Compl. ¶16). Based on this allegation, the accused functionality would involve a hierarchical system for managing tasks or information where status alerts associated with lower-level items cause a visual change in higher-level containers. The complaint does not provide sufficient detail for analysis of the products' specific features or market position.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference its infringement allegations from claim charts in Exhibit 2, which was not provided (Compl. ¶17). Therefore, a claim chart summary cannot be constructed. The complaint’s narrative theory is that the accused products "satisfy all elements of the Exemplary '514 Patent Claims" (Compl. ¶16).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: The '514 Patent's specification heavily illustrates the invention using examples from manufacturing, physical inventory management, and parts production (e.g., ʼ514 Patent, col. 1:35-40; Fig. 2). A central issue may be whether the claim terms, when read in light of this disclosure, can be construed to cover the purely digital constructs within Atlassian's software development and project management tools. For example, the case may raise the question of whether a software task in a project management tool is equivalent to the "in house product" (IHP) described as a primary embodiment in the patent.
  • Technical Questions: The complaint lacks any detail on how the accused products allegedly meet the claim limitations. A key technical question will be what evidence demonstrates that the accused products perform the step of "changing an attribute of the parent folder" in response to a "time trigger" on a "child element." The court will need to determine if the functionality of the accused products (e.g., updating a numerical badge or icon) corresponds to the specific visual state changes (e.g., color, animation) described as the alerting mechanism in the patent's specification (ʼ514 Patent, col. 4:51-53).

V. Key Claim Terms for Construction

• The Term: "changing an attribute of the parent folder"

• Context and Importance: This term is the core of the invention's alerting mechanism. Its construction will define what type of notification or status update in the accused products can be considered infringing. Practitioners may focus on this term because the patent's examples of attribute changes (e.g., color) may be different from the notification systems in modern software.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself is broad, referring simply to "an attribute." This could arguably encompass any change, including a numerical counter, an icon modification, or a textual update.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the attribute change as a distinct visual transformation intended to signal a problem, such as a folder's color changing "from green to red" or through a change in "color, size, animation, or other visual attribute." An audible tone is also mentioned as a customizable attribute (ʼ514 Patent, col. 4:1-3, 51-53). A party could argue these specific embodiments limit the term to salient visual or audible state changes rather than more subtle updates.

• The Term: "child element"

• Context and Importance: The scope of this term determines what types of trackable items fall within the patent's claims. Its definition is crucial for determining if the patent, which is exemplified by manufacturing processes, can read on the digital artifacts managed by the accused software.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Claim 1 provides a definition: "comprising one or more child documents or one or more child folders containing one or more child documents, or any combination thereof" (ʼ514 Patent, col. 10:59-63). This language is facially broad and not explicitly tied to any particular technical field.
  • Evidence for a Narrower Interpretation: The detailed description almost exclusively uses examples from a business engaged in physical production, such as "production subassemblies or in-house products" (IHPs), sales and shipping of end-products, and inventory management (ʼ514 Patent, col. 1:35-40). A party may argue that the term "child element" should be construed in this context, limiting its scope to items related to physical or logistical business processes rather than abstract software development tasks.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '514 Patent" (Compl. ¶14).
• Willful Infringement: The complaint bases its allegation of knowledge on the service of the complaint itself (Compl. ¶13). It further alleges that Defendant's inducement has occurred "at least since being served by this Complaint and corresponding claim charts" (Compl. ¶15), suggesting the willfulness claim is based on alleged post-suit conduct.

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

1. A core issue will be one of definitional scope: Can the claim terms of the ’514 Patent, interpreted in light of a specification focused on manufacturing and physical inventory, be construed to cover the purely digital tasks, issues, and artifacts within a modern software project management environment?

2. A central evidentiary question will be one of functional operation: Assuming the claims are construed to cover the accused products, does the accused functionality—which is not detailed in the complaint—actually perform the method of "changing an attribute of the parent folder" in a way that maps onto the cascading visual alert system described and claimed in the patent?