TG 2006 Holdings LLC v. Mondaycom Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TG--2006 Holdings, LLC (Texas)
  • Defendant: Monday.com Ltd. (Delaware, with a place of business in Israel)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00250, E.D. Tex., 03/02/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has an established place of business in the District, has committed acts of patent infringement in the District, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s software products, which provide tools for business information tracking, infringe a patent related to systems for visually tracking tasks and information using a hierarchical display.
• Technical Context: The lawsuit concerns project and task management software, a market segment focused on helping teams organize, track, and manage their work.
• Key Procedural History: The patent-in-suit is a continuation of a chain of applications tracing back to 2004, suggesting a long history of development and prosecution for this technology. The complaint does not mention any prior litigation, licensing, or post-grant proceedings involving the patent.

Case Timeline

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

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

• Patent Identification: U.S. Patent No. 9,805,323, issued October 31, 2017.

The Invention Explained

• Problem Addressed: The patent identifies that tracking business information can be "time consuming and confusing," and that conventional methods may not display this information in a "visually clear and meaningful way." (’323 Patent, col. 1:17-26).
• The Patented Solution: The invention proposes a system that uses a "typical hierarchical folder tree view" to organize and monitor tasks, events, or other business conditions. (’323 Patent, col. 1:30-34). The core innovation is that "parent folders" in the hierarchy automatically change their visual attributes (e.g., color) in response to the status of items within their "child folders." (’323 Patent, col. 3:12-29). For example, if a time-critical task in a child folder exceeds a pre-set time limit, its folder might turn red, and the parent folder containing it would also turn red, providing an immediate, high-level visual alert. (’323 Patent, col. 4:6-11).
• Technical Importance: The technology aimed to provide an intuitive, at-a-glance status overview for complex projects by propagating alerts up a visual hierarchy, reducing the need for users to manually inspect individual sub-tasks to identify problems. (’323 Patent, col. 4:1-5).

Key Claims at a Glance

• The complaint asserts "one or more claims" and refers to "Exemplary '323 Patent Claims" but does not identify specific claims in the main body. (Compl. ¶11, 13). Independent claim 1 is representative of the method taught by the patent.
• Independent Claim 1: A method for tracking and displaying time critical information comprising the steps of:
  • establishing a parent folder;
  • establishing a child folder associated with the parent folder;
  • correlating the child folder with a time critical task;
  • associating a first alert interval with the time critical task;
  • starting a system clock and monitoring system time;
  • changing an attribute of the child folder when system time equals or exceeds the first alert interval; and
  • changing an attribute of the parent folder when the attribute of the child folder changes.
• The complaint does not explicitly reserve the right to assert dependent claims, but its general reference to "one or more claims" suggests this possibility. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not name specific products, referring only to "Exemplary Defendant Products" identified in an external exhibit. (Compl. ¶11). The defendant, TG 2006 Holdings LLC v. Mondaycom Ltd, is a known provider of a cloud-based work operating system that includes project management and task tracking functionalities.

Functionality and Market Context

• The complaint alleges that the accused products "practice the technology claimed by the '323 Patent." (Compl. ¶13). Based on the patent's subject matter, this implies the accused functionality involves software for organizing information in a hierarchy (e.g., projects, task lists, and sub-tasks) and providing visual notifications or status changes when certain conditions, such as deadlines, are met. The complaint makes no specific allegations regarding the products' commercial importance.

IV. Analysis of Infringement Allegations

The complaint alleges infringement via claim charts provided in Exhibit 2, which was not available for this analysis. The complaint asserts that these charts show the "Exemplary Defendant Products practice the technology claimed by the '323 Patent" and "satisfy all elements of the Exemplary '323 Patent Claims." (Compl. ¶13). No probative visual evidence provided in complaint.

• Identified Points of Contention: Lacking the specific claim charts, analysis must focus on the likely points of dispute between the patent's claims and the general nature of modern project management software.
  • Scope Questions: A central question may be whether the terms "parent folder" and "child folder," which are described in the patent in the context of a hierarchical tree view reminiscent of a desktop file system, can be interpreted to cover the data structures used in a modern, cloud-based platform like Monday.com. The court may need to determine if a project, a task list, or a Kanban board constitutes a "folder" within the meaning of the claims.
  • Technical Questions: Another point of contention could be whether the accused product's notification systems (e.g., changing a status label from "In Progress" to "Overdue") perform the function of "changing an attribute of the... folder" as required by the claim. The defense may argue that such status labels are attributes of the task data itself, not of the container or "folder" in which the task resides, potentially creating a mismatch with the claim language that requires the folder's attribute to change.

V. Key Claim Terms for Construction

• The Term: "parent folder" / "child folder"

  • Context and Importance: These terms are foundational to every independent claim. The infringement case hinges on whether the accused product's architecture for organizing information (e.g., workspaces, boards, groups, items) contains structures that meet the definition of "parent folder" and "child folder." Practitioners may focus on this term because the patent's specification appears to tie it to a specific visual metaphor.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent summary describes the invention in more general terms as providing "visual indications of the progress or status of any number of tasks, events or conditions," which could support an interpretation not strictly limited to a literal folder icon. (’323 Patent, col. 1:28-31).
    • Evidence for a Narrower Interpretation: The specification repeatedly refers to a "typical hierarchical folder tree view" and includes figures (e.g., Fig. 1, Fig. 3a) that explicitly depict a classic, collapsible tree structure with folder icons. (’323 Patent, col. 1:31-32). This could support a narrower construction limited to that specific type of user interface element.

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

  • Context and Importance: This term defines the core alerting mechanism of the invention. The dispute will likely center on what types of visual changes in the accused product qualify as a change to a "folder's" attribute, versus a change to an attribute of a data item within the folder.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not limit "attribute" to a single type of change. Claim 7 lists "visual, color, animation, textual, size and audible" attributes, suggesting the term was intended to be flexible. (’323 Patent, col. 12:7-14).
    • Evidence for a Narrower Interpretation: The primary embodiment described is a parent folder's icon changing color (e.g., from green to red) to reflect the status of a child element. (’323 Patent, col. 4:6-11). A defendant might argue that this implies the "attribute" must be a property of the container element itself, not merely the display of data contained within it.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain specific allegations of induced or contributory infringement.
• Willful Infringement: The complaint does not contain allegations of willful infringement.

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

This case appears to present fundamental questions of claim scope and the application of older patent language to modern software paradigms. The outcome will likely depend on the court's resolution of two key issues:

1. A core issue will be one of definitional scope: Can the terms "parent folder" and "child folder," which are rooted in the patent’s description of a 2004-era hierarchical tree view, be construed broadly enough to encompass the relational data structures and user interface components of a contemporary, web-based project management platform?

2. A key evidentiary question will be one of technical application: Assuming the "folder" structures are found to exist, does the accused product's method of displaying status updates (e.g., textual labels, color-coded tags on tasks) constitute "changing an attribute of the... folder" itself, as required by the claims, or is it merely changing an attribute of the data within the folder, creating a potential failure to meet a specific claim limitation?