DCT
4:19-cv-00270
Akoloutheo LLC v. Thoughtspot Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Akoloutheo, LLC (Texas)
- Defendant: ThoughtSpot, Inc. (Delaware)
- Plaintiff’s Counsel: RWBurns & Co., PLLC
- Case Identification: 4:19-cv-00270, E.D. Tex., 04/10/2019
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in Plano, Texas, within the Eastern District of Texas, and has committed acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s business intelligence and data analytics software platform infringes a patent related to a generalized framework for processing transactions between disparate information services.
- Technical Context: The technology addresses the challenge of integrating data from multiple, distinct networked sources by using a centralized processing function to manage and execute user requests based on a standardized model.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2001-04-19 | Priority Date for U.S. Patent No. 7,426,730 |
| 2008-09-16 | Issue Date for U.S. Patent No. 7,426,730 |
| 2012-01-01 | ThoughtSpot raises Series A funding (earliest operational date cited) |
| 2019-04-10 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,426,730 - Method and System for Generalized and Adaptive Transaction Processing Between Uniform Information Services and Applications, issued September 16, 2008
The Invention Explained
- Problem Addressed: The patent’s background section describes the difficulty of integrating information from different online sources, such as providing driving directions that are automatically adapted to current traffic conditions (’730 Patent, col. 1:62-2:5). Existing solutions were often custom-built for a specific problem and lacked a generalized, scalable framework for dynamically coupling disparate information services (’730 Patent, col. 2:6-14).
- The Patented Solution: The invention discloses a system centered on a "Transaction Processing Function" (TPF) that acts as an intermediary between information consumers and providers (’730 Patent, Abstract). A user request is formalized as a "transaction definition" (TD), which the TPF uses to identify and orchestrate the necessary information services based on a standardized "Uniform Specification Model" (USM) and the current "Transaction Situation Context" (TSC), such as user location or preferences (’730 Patent, col. 5:11-25; Fig. 1). This allows services to be integrated dynamically without being explicitly hard-coded to work together.
- Technical Importance: The described framework sought to simplify the management of service transactions at a large scale, a key challenge for service-oriented architectures, by abstracting the integration logic away from the individual information services and applications (’730 Patent, col. 2:49-56).
Key Claims at a Glance
- The complaint asserts independent claims 1, 15, and 17 (Compl. ¶22).
- Independent Claim 1 is a system claim directed to a networked computer system comprising:
- a resource transaction processing module;
- a plurality of remote resource providers;
- a resource information registry for storing information about the resources;
- wherein the module responds to a transaction request by constructing a context, dynamically selecting a resource, determining operations, obtaining the resource, and processing it to generate a resultant resource.
- The complaint reserves the right to assert additional claims from the patent (Compl. ¶22).
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant’s "ThoughtSpot and SpotIQ software systems," collectively referred to as "ThoughtSpot Software" (Compl. ¶11).
Functionality and Market Context
- The ThoughtSpot Software is described as a business intelligence platform for "organizing, searching and analyzing business intelligence data across multiple networked resources" (Compl. ¶11). It is deployed on a cluster of nodes and can access data from sources including "on-premise, cloud, big data, or desktop" (Compl. ¶13).
- A core component is a "relational search engine" that processes user queries and delivers an answer "in the form of a best fit visualization" (Compl. ¶15). A diagram in the complaint illustrates the platform's architecture, including a "Search IQ & Relational Search Engine," "Spot IQ AI Engine," "In-Memory Calculation Engine," and a "Distributed Cluster Manager" (Compl. ¶17, Figure). The system maintains an "in-memory data cache" and indexes the "entire data model... including the raw data, metadata, and relationships" to facilitate fast query processing (Compl. ¶17).
- The complaint alleges the platform is an "AI-Driven analytics platform" that is "disrupting the BI industry" (Compl. ¶8).
IV. Analysis of Infringement Allegations
’730 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a networked computer system... comprising: a resource transaction processing module; | ThoughtSpot Systems are alleged to comprise "transaction processing module(s)," which are supported by components like the Search IQ Engine, Spot IQ AI Engine, and Distributed Cluster Manager. | ¶24, ¶17 | col. 4:49-52 |
| a plurality of resource providers, each resource provider being remotely located to the resource transaction processing module and communicatively coupled... | The ThoughtSpot Software is alleged to access data from a plurality of networked resources, including "on-premise, cloud, big data, or desktop" sources. | ¶13 | col. 4:18-20 |
| a resource information registry communicatively coupled... for storing information about the resources provided by the plurality of resource providers... | ThoughtSpot Systems are alleged to maintain a registry where the "entire data model is indexed, including the raw data, metadata, and relationships." | ¶17, ¶26 | col. 5:5-8 |
| wherein, in response to receiving a transaction request, the resource transaction processing module: constructs a transaction situation context... | The system is alleged to process transaction requests "utilizing contextual elements related to the request and/or the user entering the request." A provided visual shows the system filtering a query by a date range. | ¶27, ¶17 | col. 4:56-62 |
| dynamically selects at least one resource to process... | The system is alleged to "dynamically process user transaction requests (queries), selecting information resources and performing operations on those resources." | ¶18, ¶28 | col. 30:13-17 |
| determines one or more discrete operations to perform on the at least one selected resource to satisfy the transaction request; | The complaint alleges the system performs "one or more operations on those data resources to satisfy the transaction request." A process flow diagram shows steps including "Automated Data exploration" and "Sorting." | ¶28, ¶18 | col. 30:21-24 |
| obtains the at least one selected resource from the resource provider providing that resource; | ThoughtSpot Systems are alleged to "process the user query and retrieve data from a plurality of networked data sources." | ¶16 | col. 30:25-27 |
| and processes the at least one selected resource... to generate a resultant resource. | The system is alleged to "generate a resultant data resource responsive to the transaction request, and delivers that resultant data resource to the user via a user interface," such as a data visualization. The complaint provides a screenshot of a bar chart as an example of a resultant resource (Compl. ¶16, Figure). | ¶29, ¶15 | col. 30:28-31 |
- Identified Points of Contention:
- Scope Questions: A potential dispute may arise over whether the accused "business intelligence" platform, which appears to query structured and semi-structured data sources, constitutes the "generalized... transaction processing between uniform information services" framework described in the patent. The patent's examples often refer to integrating functionally distinct services like GIS and traffic reporting, raising the question of whether querying different databases within a single analytics platform falls within the patent’s scope.
- Technical Questions: The complaint alleges that ThoughtSpot's indexed data model is the claimed "resource information registry" (Compl. ¶17). A key technical question will be what evidence supports the allegation that this index functions like the patent’s registry, which is described as using a "Uniform Specification Model" (USM) with a "standard taxonomic structure" to classify services (’730 Patent, col. 5:43-46). The complaint does not specify how the accused system's indexing method aligns with the patent's USM concept.
V. Key Claim Terms for Construction
The Term: "resource information registry"
- Context and Importance: This term is critical because infringement depends on whether the accused system's method of indexing data sources qualifies as the claimed "registry." The defendant may argue its data indexing is a standard database practice, while the plaintiff will likely contend it performs the claimed function of classifying and storing information about available resources for dynamic selection.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent claims a registry "for storing information about the resources provided by the plurality of resource providers" (’730 Patent, col. 30:1-3). The complaint alleges the accused system indexes "raw data, metadata, and relationships," which could be argued to be "information about the resources" (Compl. ¶17).
- Evidence for a Narrower Interpretation: The specification states the TPF accesses a "Uniform Specification Repository (USR)" which stores information "in a format consistent with the USM" (Uniform Specification Model) (’730 Patent, col. 5:5-8). A party could argue that to be a "resource information registry," the accused feature must use a classification system analogous to the patent's detailed USM, which defines services via a "standard taxonomic structure" (’730 Patent, col. 5:43-46).
The Term: "resource transaction processing module"
- Context and Importance: This is the central engine of the claimed invention. Practitioners may focus on this term because its construction will determine whether the collection of components in the accused platform (e.g., search engine, cluster manager, AI engine) collectively meets this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent defines the "Transaction Processing Function" (TPF), which the module performs, broadly as a "software component that manages transactions between one or more information services" (’730 Patent, col. 4:49-52).
- Evidence for a Narrower Interpretation: The detailed description outlines a specific, multi-step process flow for the TPF, including TD processing, TSC construction, TD operation atomization, and service linking (’730 Patent, Fig. 12). An argument could be made that a "resource transaction processing module" must perform these specific, sequenced functions, not just generally manage data queries.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant infringes indirectly because it exercises "exclusive control and direction of the infringing instrumentalities and/or operations" and requires end users to operate the systems in a "prescribed and controlled" manner (Compl. ¶34, ¶36). This appears to be an argument for direct infringement under a theory of control or agency, though it is labeled in the alternative as indirect infringement.
- Willful Infringement: The complaint alleges willfulness based on notice provided by the filing of the lawsuit itself, seeking enhanced damages for post-filing conduct (Compl., Prayer for Relief ¶d). No facts are alleged to support pre-suit knowledge of the patent or infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the patent’s claims, which describe a framework for dynamically integrating disparate "information services" like mapping and traffic data, be construed to cover a business intelligence platform that queries and analyzes data from different databases and repositories under a unified analytics environment?
- A key evidentiary question will be one of technical alignment: does the accused system's indexing of "raw data, metadata, and relationships" (Compl. ¶17) constitute the claimed "resource information registry," which the patent specification ties to a "Uniform Specification Model" (’730 Patent, col. 5:5-8) for classifying services? The complaint's allegations are general on this point, suggesting that discovery into the specific mechanisms of the accused system will be critical.