DataCloud Tech LLC v. Murata Mfg Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DataCloud Technologies, LLC (Georgia)
  • Defendant: Murata Manufacturing Co., Ltd (Japan), Murata Corporation (Pennsylvania), and Murata Electronics North America, Inc. (Texas/Georgia)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:25-cv-00684, E.D. Tex., 07/03/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has significant business ties to and presence in the district.
• Core Dispute: Plaintiff alleges that Defendant’s Internet of Things (IoT) hardware, website infrastructure, and associated cloud services infringe six patents related to data organization, anonymous network communication, remote file access, file synchronization, software deployment, and metadata-based content management.
• Technical Context: The patents-in-suit address foundational technologies for managing, delivering, and securing information and software over distributed networks, which are core to modern cloud computing and IoT ecosystems.
• Key Procedural History: The complaint states that Plaintiff notified Defendant of the asserted patents and its infringement allegations through a licensing letter and multiple follow-up emails between March 2023 and February 2024, establishing a basis for pre-suit knowledge.

Case Timeline

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

U.S. Patent No. 6,651,063 - “Data Organization And Management System And Method”

(Issued November 18, 2003)

The Invention Explained

• Problem Addressed: The patent describes prior art information storage systems (e.g., filing cabinets, early computer software) as being cumbersome and decentralized, requiring significant effort from the user to categorize and organize information such as product manuals or warranties (’063 Patent, col. 1:46-55).
• The Patented Solution: The invention proposes a system where providers send information in pre-categorized “information packs” to a user's data repository. A “category identifier” automatically places the information in a default location, and a “provider identifier” identifies the source (’063 Patent, Abstract). The system further allows a user to create a “custom category” and, via a “Feedback means,” can instruct the system or provider to automatically place subsequent information from that same provider into the user's custom location, automating future organization (’063 Patent, col. 4:13-43; Fig. 1).
• Technical Importance: The technology aimed to shift the burden of initial data categorization from the recipient to the provider, streamlining information management for consumers and businesses receiving increasing volumes of digital information (’063 Patent, col. 2:1-9).

Key Claims at a Glance

• The complaint asserts independent method claim 4 (Compl. ¶22).
• Essential elements of claim 4 include:
  • storing information in an “information pack”;
  • associating the pack with a user destination address, a category identifier, and a provider identifier;
  • communicating the pack over a network to a user data repository and placing it in a location corresponding to the category identifier;
  • creating a “custom location” in the repository and placing the information pack there;
  • sending a “custom category signal” to a processing station; and
  • the processing station using that signal to analyze subsequent information packs from the same provider and automatically place them in the user's custom location.
• The complaint asserts infringement of “one or more claims,” reserving the right to assert additional claims (Compl. ¶21).

U.S. Patent No. 7,209,959 - “Apparatus, System, And Method For Communicating To A Network Through A Virtual Domain Providing Anonymity To A Client Communicating On The Network”

(Issued April 24, 2007)

The Invention Explained

• Problem Addressed: The patent notes that standard internet protocols expose a client's IP address to web servers, creating privacy risks. It characterizes existing proxy servers as an incomplete solution that merely substitutes one persistent identity for another (’959 Patent, col. 1:56-2:9).
• The Patented Solution: The invention describes a system architecture with three distinct components: a “deceiver,” a “controller,” and a “forwarder.” A client's request to a destination website is intercepted by the deceiver, which passes it to the controller. The controller resolves the destination's true IP address, selects a forwarder, and provides the deceiver with the forwarder's IP address. The client then communicates with the forwarder, which relays communications to the destination website using its own IP address, thereby concealing the client's identity from the destination server for the duration of the session (’959 Patent, Abstract; Fig. 1).
• Technical Importance: The described method aims to provide session-specific anonymity by creating an ad-hoc virtual domain that isolates the client from the destination server, preventing the server from directly identifying or tracking the client (’959 Patent, col. 2:49-54).

Key Claims at a Glance

• The complaint asserts independent method claim 1 (Compl. ¶33).
• Essential elements of claim 1 include:
  • in response to a client request, setting up a “forwarding session” using a “forwarder” disposed between the client and destination server;
  • implementing the session such that neither the client nor the destination server is aware of the forwarder's employment;
  • employing a “controller” that queries a domain name server to resolve the destination website's name;
  • employing a “deceiver” that receives the client's initial request and initiates the controller to perform the query; and
  • initiating the forwarding session in response to the controller receiving the answer from the domain name server.
• The complaint asserts infringement of “one or more claims,” reserving the right to assert additional claims (Compl. ¶32).

U.S. Patent No. 7,398,298 - “Remote Access And Retrieval Of Electronic Files”

(Issued July 8, 2008)

Technology Synopsis

This patent describes a method for managing remote access to data directory structures. A computer server receives a request for remote management, consults a “profile store” to determine which directories are accessible to the user, and delivers the requested data and control to the user, later sending a notification of delivery (Compl. ¶44; ’298 Patent, Abstract).

Asserted Claims

The complaint asserts at least claim 13 (Compl. ¶44).

Accused Features

The complaint accuses Murata's services as an AWS Partner that provides pre-certified wireless connectivity modules for IoT hardware development (Compl. ¶45).

U.S. Patent No. 7,139,780 - “System And Method For Synchronizing Files In Multiple Nodes”

(Issued November 21, 2006)

Technology Synopsis

This patent discloses a method for synchronizing files between a central node and multiple local nodes. The system uses a first table in each local database to track local file information and a second table in the central database to record all update information. When a file is updated on a local node, the update information is added to the central table, and the updated file is uploaded to the central file server, from which other local nodes can download the latest version (Compl. ¶55; ’780 Patent, col. 2:40-64).

Asserted Claims

The complaint asserts at least claim 1 (Compl. ¶55).

Accused Features

The complaint accuses the firmware upgrade process for the Murata Manufacturing SCA11H sensor node (Compl. ¶56).

U.S. Patent No. 7,246,351 - “System And Method For Deploying And Implementing Software Applications Over A Distributed Network”

(Issued July 17, 2007)

Technology Synopsis

This patent describes a method for deploying software on a client device. The system provides text files containing embedded program logic to a software module on the user's device. The module assembles this logic into a functioning application that provides a graphical user interface (GUI) for user interaction (Compl. ¶66; ’351 Patent, Abstract).

Asserted Claims

The complaint asserts at least claim 14 (Compl. ¶66).

Accused Features

The complaint accuses Murata's system for allowing users to view video content on mobile devices, which allegedly fetches program logic and interface components as text-based files to assemble a video player on the device (Compl. ¶67).

U.S. Patent No. 8,607,139 - “System and process for managing content organized in a tag-delimited template using metadata”

(Issued December 10, 2013)

Technology Synopsis

This patent describes a system for generating web pages from a metadata template. The template defines an object based on a class, representing the structure of a web page. A graphical interface with input fields corresponding to the object is used to generate a data entry form, and a web page generator uses the template and user input to generate the final web page (Compl. ¶77; ’139 Patent, Abstract).

Asserted Claims

The complaint asserts at least claim 8 (Compl. ¶77).

Accused Features

The complaint accuses the Murata Manufacturing website infrastructure, specifically its “Contact Form,” which is allegedly configured with input fields defined by an object in a base template (Compl. ¶¶78-79).

III. The Accused Instrumentality

Product Identification

• The complaint accuses a range of Murata’s products and services, including:
  • The Murata Manufacturing SCA11H sensor node and its associated firmware upgrade process (Compl. ¶¶23, 56).
  • Murata’s AWS Partner services, which provide pre-certified wireless connectivity modules (e.g., Wi-Fi, Bluetooth, cellular, LoRa) for IoT hardware development (Compl. ¶45).
  • Murata’s public-facing website infrastructure, including solution.murata.com and its contact form page (Compl. ¶¶34, 78).
  • Murata’s systems for delivering video content to users’ mobile devices via its website (Compl. ¶67).

Functionality and Market Context

• The complaint alleges that the SCA11H sensor node can be configured and its firmware upgraded via an HTTP API on an Android device by accessing a configuration web page (Compl. ¶¶23, 56).
• It is alleged that Murata's website infrastructure hosts dynamic websites and uses a system of controllers and forwarders to respond to user requests while masking back-end server details (Compl. ¶34).
• The complaint alleges that Murata’s video player functionality on mobile devices involves a software module that connects to a Murata server to fetch program logic and interface components as text-based files, which are then assembled on the device to create a GUI (Compl. ¶67).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,651,063 Infringement Allegations

Identified Points of Contention

• Technical Questions: The complaint alleges infringement of claim 4 but provides no specific facts detailing how the accused firmware update process performs the claim's latter and more detailed steps. This raises the question: what evidence does the complaint provide that the accused process involves creating a “custom location” or sending a “custom category signal” to a “processing station” for the purpose of automating the categorization of subsequent information packs, as explicitly required by the claim?

U.S. Patent No. 7,209,959 Infringement Allegations

Identified Points of Contention

• Scope Questions: The infringement theory depends on mapping the claimed “deceiver,” “controller,” and “forwarder” onto Murata's website infrastructure. This raises a definitional question: do these terms, as defined and architected in the patent, read on the components of a conventional web hosting environment (such as a load balancer, reverse proxy, or DNS resolver), or does the patent require a specific, non-conventional architecture that is absent from the accused system?

V. Key Claim Terms for Construction

For the ’063 Patent

• The Term: “custom category signal”
• Context and Importance: This term is critical to distinguishing the claimed invention from a simple manual file organization system. The infringement theory requires showing not only that a user can create a custom folder, but that this action generates a specific “signal” that is sent to a “processing station” to automate the routing of future information packs. The existence and nature of this “signal” will likely be a central point of dispute.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification refers generally to “Feedback means” that can “relay back to the Provider...specifics as to the reassignment or additional categorization” (’063 Patent, col. 4:27-31), which might be argued to cover any data transmission indicating a user's preference.
  • Evidence for a Narrower Interpretation: The detailed description and figures show the custom categorization being communicated to a “Processing Station 30” which then analyzes “all subsequent information transmitted from the Providers” to automatically categorize them, suggesting a specific, automated, and persistent system-level change rather than a one-off communication (’063 Patent, col. 4:44-59; Fig. 1).

For the ’959 Patent

• The Term: “deceiver”
• Context and Importance: Practitioners may focus on this term because the patent’s three-part architecture (deceiver, controller, forwarder) is foundational to the claim. The defendant may argue that its standard network infrastructure does not contain a structurally or functionally distinct “deceiver” as required. The plaintiff's ability to identify a discrete component performing the claimed functions of the deceiver—receiving the initial client request and initiating the controller's query—will be crucial.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the deceiver's function as providing “name resolution for clients” and communicating with the controller (’959 Patent, col. 2:38-40), which could be argued to encompass functions performed by components in a modern web stack.
  • Evidence for a Narrower Interpretation: Figure 1 of the patent depicts the Deceiver (104) as a distinct architectural element with specific, separate communication paths to the Client (101) and the Controller (106), suggesting it is intended to be a structurally separate component, not merely a functional label for part of a monolithic proxy server (’959 Patent, Fig. 1).

VI. Other Allegations

• Indirect Infringement: The complaint includes a general allegation of inducement (Compl. ¶10), but does not plead specific facts to support it for any of the asserted patents, such as identifying specific instructions from Defendant that would encourage third parties to perform the claimed methods.
• Willful Infringement: The complaint alleges that Defendant had pre-suit knowledge of the asserted patents and its alleged infringement based on a licensing letter dated March 8, 2023, and several follow-up emails (Compl. ¶14). These allegations may serve as the basis for a claim of willful infringement from the date of first notice.

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

• A central issue across multiple patents will be one of factual sufficiency: do the complaint's allegations provide enough technical detail to plausibly map the specific, multi-step processes of the method claims onto the accused functionalities (e.g., the automated re-categorization based on a “custom category signal” in the '063 patent), or will the infringement theories be challenged as conclusory?
• A key question for the network-related patents will be one of architectural equivalence: does Murata’s accused website and cloud infrastructure employ the specific, discrete components claimed in the patents (such as the “deceiver, controller, and forwarder” of the '959 patent), or is there a fundamental mismatch between the patented architecture and the conventional technologies used by the defendant?