DCT

2:25-cv-01053

STT Webos Inc v. Verizon Communications Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01053, E.D. Tex., 10/20/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains 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 Verizon Cloud platform and services infringe nine patents related to web-based communication systems, multitasking, and information exchange.
  • Technical Context: The technology at issue concerns systems and methods for managing information exchange, user collaboration, and task processing in web-based, multi-user environments, which are foundational concepts in modern cloud computing and storage services.
  • Key Procedural History: The complaint notes that the patents-in-suit have been cited in in over 60 patents issued to various technology companies, which Plaintiff presents as an indication of the inventions' significance. No prior litigation or post-grant proceedings are mentioned.

Case Timeline

Date Event
2002-08-06 Earliest Priority Date Asserted for Patents-in-Suit
2014-08-19 U.S. Patent 8,812,682 Issues
2015-03-10 U.S. Patent 8,977,722 Issues
2015-04-21 U.S. Patent 9,015,321 Issues
2015-12-01 U.S. Patent 9,201,961 Issues
2016-09-20 U.S. Patent 9,448,697 Issues
2019-11-19 U.S. Patent 10,484,455 Issues
2020-06-16 U.S. Patent 10,686,797 Issues
2022-05-17 U.S. Patent 11,336,754 Issues
2022-10-04 U.S. Patent 11,463,442 Issues
2025-10-20 Complaint Filed

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

U.S. Patent No. 8,812,682 - "Concurrent web based multi-tasks support for computer system"

The Invention Explained

  • Problem Addressed: The patent describes a problem in traditional web-based systems where a user's web browser is "blocked or hanged" while waiting for a time-consuming task (e.g., creating a large file system) to complete, preventing the user from submitting any other tasks in the same browser window (’682 Patent, col. 1:17-25).
  • The Patented Solution: The invention proposes a "web-based computer user work environment" that processes tasks in the background. It uses a "user space task list" to manage submitted tasks, allowing the web browser's user interface to remain active and enabling the user to submit new tasks without waiting for prior ones to finish (’682 Patent, col. 2:48-51; FIG. 4). This allows for concurrent multitasking from a single web browser interface.
  • Technical Importance: This approach aimed to improve the efficiency and user experience of web-based system management tools, making them behave more like traditional desktop operating systems with multitasking capabilities (’682 Patent, col. 1:39-46).

Key Claims at a Glance

  • The complaint asserts infringement of Claim 1 (’682 Patent, col. 9:10-31; Compl. ¶19).
  • The essential elements of independent Claim 1, a computing device, include:
    • An operating system with a "web based user work environment" (WCUWE).
    • The WCUWE includes instructions for displaying information about resources in a web browser.
    • The WCUWE includes instructions for processing a first task for access to a first resource.
    • Processing the first task includes processing it "in the background" and causing the display of information in the web browser "without being blocked."
    • This allows the user to select a second resource and submit a second task "without waiting for completion of the processing of the first task."
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,336,754 - "Method and system for concurrent web based multitasking support"

The Invention Explained

  • Problem Addressed: Similar to the ’682 Patent, this patent addresses the problem of a web browser becoming unresponsive while waiting for a long task, like a large file transfer, to complete. This prevents the user from submitting other tasks from the same browser (’754 Patent, col. 1:33-46).
  • The Patented Solution: The invention proposes a method where a local web server on the user's device manages tasks. When a task is submitted, its information is stored in a "user space task list," and the task is processed in the background. The local web server can then immediately respond to the web browser, unblocking it and allowing the user to submit additional concurrent tasks (’754 Patent, col. 2:50-61; FIG. 2).
  • Technical Importance: This system architecture decouples the browser's user interface from the execution of back-end tasks, enhancing the efficiency and responsiveness of web-based control management systems (’754 Patent, col. 2:4-6).

Key Claims at a Glance

  • The complaint asserts infringement of Claim 1 (’754 Patent, col. 5:8-49; Compl. ¶35).
  • The essential elements of independent Claim 1, a method to prevent browser blocking, include:
    • Executing a local web browser and a local web server on a device.
    • Identifying a first task submitted by the user.
    • Storing information of the first task into a "user space task list," including invoking lock protection.
    • Processing the first task "in the background and without blocking the local web browser."
    • Responding to a second task "before completion of the first task," where the second task runs in parallel.
    • Removing the stored information of the first task from the task list after its completion.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 10,686,797 - "Method and apparatus for information exchange over a web based environment"

  • Technology Synopsis: This patent describes a system for a "dynamic work space" in a web-based environment where users can "post" or "un-post" messages, files, or folders. An "un-post" operation for a message is intended to remove it from the recipient's view to avoid embarrassment if the message was improper, enhancing then-existing message sharing technology (’797 Patent, Abstract).
  • Asserted Claims: Claim 1 (Compl. ¶51).
  • Accused Features: The Verizon Cloud platform and services are accused of infringement (Compl. ¶13).

U.S. Patent No. 11,463,442 - "Method and apparatus for information exchange over a web based environment"

  • Technology Synopsis: The patent discloses a method for information sharing where "posting" and "un-posting" (stop sharing) files and messages is managed by a "dynamic workspace technology." A key feature is that un-posting a file does not delete the actual file, allowing it to be re-shared later. The system also provides a "sharing control list" for the user to manage shared content (’442 Patent, Abstract).
  • Asserted Claims: Claim 1 (Compl. ¶67).
  • Accused Features: The Verizon Cloud platform and services are accused of infringement (Compl. ¶13).

U.S. Patent No. 8,977,722 - "Method and apparatus for information exchange over a web based environment"

  • Technology Synopsis: The invention relates to exchanging information via a "dynamic workspace technology." This technology is intended to allow people to exchange information "much efficiently and flexibly" in a global web environment (’722 Patent, Abstract). The specification describes systems for group-based and peer-to-peer sharing of messages and files (’722 Patent, col. 2:4-11).
  • Asserted Claims: Claim 1 (Compl. ¶83).
  • Accused Features: The Verizon Cloud platform and services are accused of infringement (Compl. ¶13).

U.S. Patent No. 9,015,321 - "Concurrent web based multitasking support for computing system"

  • Technology Synopsis: This patent describes a system supporting multiple concurrent tasks submitted from a single web browser. The invention is intended to improve efficiency for daily work by preventing the user interface from being blocked by long-running tasks, thereby creating a web-based multitasking environment (’321 Patent, Abstract).
  • Asserted Claims: Claim 1 (Compl. ¶99).
  • Accused Features: The Verizon Cloud platform and services are accused of infringement (Compl. ¶13).

U.S. Patent No. 9,201,961 - "Concurrent web based multi-task support for computer system"

  • Technology Synopsis: The invention discloses a method for web multitasking, particularly for small-sized devices where a displayed browser is a "precious resource." It aims to improve efficiency by allowing a user to handle multiple tasks concurrently (e.g., watch a streaming video while handling an email) from a single browser interface (’961 Patent, Abstract).
  • Asserted Claims: Claim 1 (Compl. ¶116).
  • Accused Features: The Verizon Cloud platform and services are accused of infringement (Compl. ¶13).

U.S. Patent No. 9,448,697 - "Method and apparatus for information exchange over a web based environment"

  • Technology Synopsis: This patent describes an "innovated dynamic workspace technology" that implements operations of "posting and un-posting" for resources like messages, files, and folders. This technology is intended to improve the efficiency and flexibility for users to exchange information across a global network (’697 Patent, Abstract).
  • Asserted Claims: Claim 1 (Compl. ¶132).
  • Accused Features: The Verizon Cloud platform and services are accused of infringement (Compl. ¶13).

U.S. Patent No. 10,484,455 - "Method and apparatus for information exchange over a web based environment"

  • Technology Synopsis: The invention provides a method for "posting and un-posting files and messages in a collaborative file sharing environment." A user is provided with the functionality to "instantly stop sharing files or folders without physically deleting the files or folder" (’455 Patent, Abstract). This is achieved via a "dynamic workspace" technology (’455 Patent, col. 2:4-14).
  • Asserted Claims: Claim 1 (Compl. ¶148).
  • Accused Features: The Verizon Cloud platform and services are accused of infringement (Compl. ¶13).

III. The Accused Instrumentality

Product Identification

  • The "Accused Instrumentalities" are identified as the "Verizon Cloud platform and services" (Compl. ¶13).

Functionality and Market Context

  • The complaint describes the accused instrumentality as an "apparatus and method for communication networks and web-based control management systems" (Compl. ¶13). Figure 1 of the complaint provides a screenshot of the Verizon Cloud marketing page, which describes features such as "Automatic Backup," "Unlimited Reliability," and the ability to "Sync content across devices, between your phone, tablet, & computer" (Compl. Fig. 1, p. 6). These descriptions suggest a consumer-facing cloud storage and synchronization service.

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for analysis in a claim chart format. For each asserted patent, it makes a conclusory allegation that "Claim 1 is infringed by making, using, importing, selling, and/or offering for sale the Accused Instrumentalities" (Compl. ¶¶ 19, 35, 51, 67, 83, 99, 116, 132, 148). The complaint does not map specific features or operations of the Verizon Cloud platform to the individual elements of any asserted claim.

  • Identified Points of Contention:
    • Scope Questions: A central question for the '754 Patent will be whether the architecture of the Verizon Cloud platform includes a "local web server on the device" that performs the functions required by Claim 1, or if its architecture is fundamentally different (e.g., a pure client-server model without a local server performing these specific task management functions).
    • Technical Questions: For the '682 Patent, a key factual question will be what evidence demonstrates that the Verizon Cloud's user interface, when performing a long-running task like uploading a large file, utilizes the specific "user space task list" and background processing method as claimed, rather than using other known web technologies for asynchronous operations. The complaint does not provide evidence to distinguish between these possibilities.

V. Key Claim Terms for Construction

U.S. Patent 8,812,682 (Claim 1)

  • The Term: "web based user work environment ('WCUWE')"
  • Context and Importance: This term appears to define the overall software architecture required by the claim. Its construction will be critical to determine if the Verizon Cloud platform, a modern cloud service, falls within the scope of the environment described in the 2002-priority-date patent family.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states the WCUWE provides a user with "a private web browser based operating environment, which is a private workspace including one or more assigned and permitted resources" (’682 Patent, col. 13:33-37). This could be argued to broadly cover any personalized, web-accessible user account.
    • Evidence for a Narrower Interpretation: The specification describes the WCUWE as part of a "centrally controlled distributed scalable virtual machine ('CCDSVM')" architecture (’682 Patent, col. 13:30-32; FIG. 1). This could support a narrower construction requiring the specific client-server architecture detailed in the patent, which may or may not map to the accused product.

U.S. Patent 11,336,754 (Claim 1)

  • The Term: "user space task list"
  • Context and Importance: This is the core mechanism by which the invention purports to manage concurrent tasks. Whether the Verizon Cloud platform uses a data structure that meets the definition and functional requirements of a "user space task list" will be central to the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes the task list as having entries that are marked "used" or "not used" and which hold "information of a task" (’754 Patent, col. 3:5-14). This could be argued to encompass any queue or data structure that tracks the status of asynchronous operations.
    • Evidence for a Narrower Interpretation: Figure 3 depicts the "Task List and Lock" mechanism, showing specific "slots" (S(1)...S(n)) and interactions between a "Web Interface thread" and a "Control Monitoring thread" (’754 Patent, FIG. 3). A defendant may argue this specific implementation limits the term to a data structure managed by distinct, interacting threads as shown, rather than any generic task queue.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement across all asserted patents. The basis for this allegation is that Verizon provides "product manuals that instruct its customers and end users how to use the Accused Instrumentalities" in an infringing manner (e.g., Compl. ¶¶ 28, 44, 60).
  • Willful Infringement: Willfulness is alleged based on two primary theories. First, the complaint alleges pre-suit "willful blindness" based on an asserted "policy or practice against investigating third party patent rights" (e.g., Compl. ¶¶ 23, 39, 55). Second, it alleges post-suit willfulness on the basis that Verizon has had "actual notice" of the patents since receiving service of the complaint in this litigation (e.g., Compl. ¶¶ 16, 32, 48).

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

  • A core issue will be one of evidentiary sufficiency: Given the complaint’s lack of technical detail, a primary question is what specific architectural and operational evidence Plaintiff will produce to demonstrate that the Verizon Cloud platform practices the particular methods of background processing, task management, and information sharing recited in the asserted claims, as opposed to using other non-infringing methods to achieve similar commercial outcomes.
  • A second central question will be one of claim scope and temporal context: Can the claims, which originate from a 2002 priority date and describe specific architectures like a "CCDSVM" and a "WCUWE," be construed to cover modern, consumer-facing cloud storage systems? The case will likely involve significant disputes over whether the terminology of the patents is limited to the specific embodiments described or can be read broadly onto present-day cloud technologies.