Brian Moffat Private Data LLC v. Mega Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Brian Moffat Private Data LLC (Texas)
  • Defendant: Mega Limited (New Zealand)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:25-cv-315, E.D. Tex., 03/28/2025
• Venue Allegations: Venue is alleged to be proper because Defendant is not a resident of the United States but is subject to personal jurisdiction within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s Mega SHARE cloud storage platform infringes four patents related to secure, private data sharing systems where the service provider is architecturally prevented from accessing user data.
• Technical Context: The technology at issue involves methods and systems for encrypted data sharing, a domain central to cloud storage, secure collaboration, and online privacy services.
• Key Procedural History: The complaint does not allege any prior litigation, licensing history, or administrative patent challenges; it does allege that the asserted patents are "pioneering" and have been cited as relevant prior art in numerous subsequent U.S. patent applications.

Case Timeline

Date	Event
2010-10-08	Priority Date for ’281, ’983, ’347, and ’050 Patents
2015-04-21	U.S. Patent No. 9,015,281 Issued
2016-07-19	U.S. Patent No. 9,397,983 Issued
2019-01-22	U.S. Patent No. 10,187,347 Issued
2021-09-28	U.S. Patent No. 11,134,050 Issued
2025-03-28	Complaint Filed

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

U.S. Patent No. 9,015,281 - "Private data sharing system"

• Patent Identification: U.S. Patent No. 9,015,281, "Private data sharing system," issued April 21, 2015.

The Invention Explained

• Problem Addressed: The patent addresses the perceived lack of adequate security and privacy in contemporary social networks and general data sharing systems (DSSs) (Compl. ¶14). It notes that typical shared online archives also lack functionalities for direct content manipulation, user-to-user messaging, and commenting that are characteristic of social networks (Compl. ¶14; ’281 Patent, col. 5:15-35).
• The Patented Solution: The invention proposes a private DSS where a user's data is "obfuscated" and can be shared securely because designated contacts are provided with the unique means required to "de-obfuscate" it (Compl. ¶15). As shown in the patent’s Figure 1, the system involves a DSS Client communicating over a network with a DSS Server, architecturally separating the user-facing functions from the central data handling (Compl. ¶12). A client-side program stores the de-obfuscation tools, enabling convenient and secure access among approved users without exposing the underlying data to the network operator (Compl. ¶15; ’281 Patent, col. 5:35-55).
• Technical Importance: The complaint alleges the technology was "pioneering" and has been cited as relevant prior art in 188 subsequent U.S. patent applications from various technology companies (Compl. ¶16).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶49).
• Claim 1 of the ’281 Patent is a method claim directed to a DSS server, comprising the essential elements of:
  • Receiving a first obfuscated data packet (ODP) from a first client.
  • Transmitting the first ODP to a second client.
  • Receiving a second ODP from the second client.
  • Transmitting the second ODP to the first client.
  • Wherein the server lacks the means needed to de-obfuscate the first ODP.
  • Wherein the server lacks the means needed to de-obfuscate the second ODP.
• The complaint reserves the right to assert additional claims (Compl. ¶45).

U.S. Patent No. 9,397,983 - "Private data sharing system"

• Patent Identification: U.S. Patent No. 9,397,983, "Private data sharing system," issued July 19, 2016.

The Invention Explained

• Problem Addressed: Social networks at the time of the invention lacked adequate privacy and security, creating a need for systems where data access is limited to a user and their specified contacts (Compl. ¶23; ’983 Patent, col. 2:20-29).
• The Patented Solution: The patent describes a system where a user's information is stored and transmitted in an obfuscated (e.g., encrypted) form, and the only means to de-obfuscate it (e.g., a decryption key) remains in the "sole possession of the user and the user's contacts" (Compl. ¶24). This arrangement is intended to prevent the website or commercial provider hosting the DSS from examining or exploiting user data (Compl. ¶24; ’983 Patent, col. 6:25-40). The complaint references the patent's Figure 22, which illustrates a user interacting with a client that communicates through a network with a server that maintains a log of activities (Compl. ¶21).
• Technical Importance: The complaint alleges this patent is also "pioneering" and has been cited as prior art in 188 subsequent U.S. patent applications (Compl. ¶25).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶57).
• Claim 1 of the ’983 Patent is a system claim directed to a DSS client architecture, comprising the essential elements of:
  • A computing device with a DSS client initialized by a first user with a "data obfuscation value and/or program" (DOVP).
  • The DSS client is configured to obfuscate a data file and transmit the obfuscated data file (ODF) for receipt by at least second and third DSS clients.
  • The second and third DSS clients are similarly initialized by their respective users with their own DOVPs.
  • The second DSS client is configured to de-obfuscate the ODF from the first user using a "data de-obfuscation value and/or program" (DDVP) provided by the first user.
• The complaint reserves the right to assert additional claims (Compl. ¶45).

U.S. Patent No. 10,187,347 - "Data Sharing System Method"

• Patent Identification: U.S. Patent No. 10,187,347, "Data Sharing System Method," issued January 22, 2019.
• Technology Synopsis: The patent addresses a vulnerability in conventional encrypted cloud storage, where the service provider often possesses the encryption keys and can thus decrypt and examine user data (Compl. ¶32; ’347 Patent, col. 3:40-65). The patented solution is a DSS where user information is stored and transmitted in an obfuscated form, with the means for de-obfuscation remaining in the sole possession of the user and their contacts (Compl. ¶33).
• Asserted Claims: At least independent claim 1 (Compl. ¶65).
• Accused Features: The Mega SHARE platform and other data sharing products are alleged to utilize the patented methods (Compl. ¶¶44, 64).

U.S. Patent No. 11,134,050 - "Private Data Sharing System"

• Patent Identification: U.S. Patent No. 11,134,050, "Private Data Sharing System," issued September 28, 2021.
• Technology Synopsis: The patent addresses the failure of typical shared online archives to provide functionalities characteristic of social networks, such as tools to directly create and edit files, exchange messages, and generate comments (Compl. ¶41; ’050 Patent, col. 5:20-40). The solution is a secure data sharing network where access to a user's data is limited to the user and their designated contacts, which may also include a separate system for reviewing content for abuse without diminishing the privacy of non-abusive users (Compl. ¶42).
• Asserted Claims: At least independent claim 1 (Compl. ¶73).
• Accused Features: The Mega SHARE platform and other data sharing products are alleged to utilize the patented methods (Compl. ¶¶44, 72).

III. The Accused Instrumentality

• Product Identification: The accused instrumentalities are Defendant’s "Mega SHARE platform and other data sharing products" (Compl. ¶44).
• Functionality and Market Context: The complaint alleges that Defendant provides data sharing methods and systems that utilize the technologies of the Asserted Patents (Compl. ¶44). A provided screenshot depicts the Mega SHARE user interface, which is marketed for "Secure sharing with anyone, anywhere" and allows users to "Share folders and files with colleagues and friends to collaborate securely" (Compl. p. 14). The complaint does not provide further technical details on the operation of the accused products but makes a general allegation that they "include each and every limitation of at least, but not limited to, claim 1 of the Asserted Patents" (Compl. ¶45). No allegations regarding the accused products’ specific market positioning are included.

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Instrumentalities meet every limitation of at least Claim 1 of each of the four Asserted Patents (Compl. ¶¶45, 49, 57, 65, 73). However, the complaint does not provide an element-by-element mapping of accused product features to the claim language or cite to publicly available technical documentation for such a mapping. The infringement allegations are presented in a conclusory manner, precluding the creation of a detailed claim chart summary at this stage.

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the term "private data sharing system," as described in the patents to require that the server cannot access user data, can be read to cover the architecture of the Mega SHARE platform. Further, the construction of "obfuscated data packet" and "de-obfuscate" will be critical in determining whether standard end-to-end encryption methods fall within the scope of the claims.
  • Technical Questions: The primary technical question will concern the actual operation of the accused Mega SHARE platform. What evidence does the complaint provide that Defendant's server architecturally "lacks the needed key(s) to fully decrypt" user content, as required by Claim 1 of the ’281 Patent? The complaint does not specify the mechanism by which the accused products are alleged to perform the claimed data obfuscation and controlled de-obfuscation by designated contacts.

V. Key Claim Terms for Construction

• The Term: "obfuscated data packet (ODP)" / "de-obfuscate" (from Claim 1 of the ’281 Patent)

• Context and Importance: These terms are foundational to the patents' claimed novelty. The infringement case may depend on whether the encryption and decryption performed by the accused Mega SHARE platform constitutes the claimed "obfuscation" and "de-obfuscation," particularly with respect to the architectural limitation that the server itself cannot perform the "de-obfuscation."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification of the related ’983 Patent, which shares the same priority date and family, clarifies that obfuscation can mean encryption, stating "an obfuscated (e.g. an encrypted) form" and that data can be "de-obfuscated (e.g. decrypted)" (Compl. ¶24; ’983 Patent, col. 6:25-40). This may support an interpretation that covers conventional encryption techniques.
  • Evidence for a Narrower Interpretation: The claims consistently pair the concept of "obfuscation" with the limitation that the server or system operator cannot reverse it (e.g., ’281 Patent, Claim 1). An argument could be made that the term must be construed in the context of this specific system architecture, where the server is a passive conduit for data it cannot understand, potentially narrowing the term to exclude systems where an administrator or provider retains any form of access to decryption keys.

• The Term: "data sharing system (DSS) client architecture" (from Claim 1 of the ’983 Patent)

• Context and Importance: As a system claim, the definition of the claimed "architecture" will be crucial. Practitioners may focus on this term because the dispute may hinge on whether Defendant's software constitutes the specific client-side architecture required by the patent, which includes elements for managing and using obfuscation values and decryption keys.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent figures depict a very general architecture of a client, a network, and a server (Compl. ¶¶12, 21). This could support a broad construction covering any system with client-side software that interacts with a central server for data sharing.
  • Evidence for a Narrower Interpretation: The specification describes specific functions of the client, such as storing decryption keys for contacts in a "key locker" and using them to decrypt incoming data from the server (’347 Patent, col. 10:2f, which is a divisional of the '983 patent's parent application). A narrower construction might require the accused client to perform these specific key management functions to qualify as the claimed "architecture."

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all four patents. Inducement is alleged based on Defendant’s creation and distribution of "manuals, instructional documents, and/or similar materials with instructions on... implementing infringing products" (Compl. ¶¶51, 59, 67, 75). Contributory infringement is alleged based on Defendant providing material parts of the inventions that are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶¶52, 60, 68, 76).
• Willful Infringement: Willfulness is alleged for all four patents based on a theory of pre-suit willful blindness. The complaint asserts that Defendant "has a practice of not performing a review of the patent rights of others first for clearance or to assess infringement thereof prior to launching products and services" (Compl. ¶¶50, 58, 66, 74).

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

• A key evidentiary question will be one of technical operation: does the accused Mega SHARE platform function as alleged, specifically by using a client-server architecture where the server is cryptographically and architecturally prevented from accessing unencrypted user data? The complaint’s conclusory allegations will need to be substantiated with technical evidence showing a direct correspondence with the claimed systems and methods.
• A core issue will be one of architectural scope: can the "private DSS" described in the patents, which emphasizes the server's inability to decrypt content, be construed to cover a modern end-to-end encrypted cloud storage service? The outcome will likely depend on the court's construction of key terms like "obfuscated data packet" and "DSS client architecture" in the specific context of the patent specifications.