DCT
4:21-cv-00093
R2 Solutions LLC v. Workday Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: R2 Solutions LLC (Texas)
- Defendant: Workday, Inc. (Delaware)
- Plaintiff’s Counsel: Nelson Bumgardner Albritton PC
- Case Identification: 4:21-cv-00093, E.D. Tex., 01/29/2021
- Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Defendant Workday, Inc. maintains a regular and established place of business in Frisco, Texas, and has allegedly committed acts of patent infringement within the district, including by selling its platform to customers located there.
- Core Dispute: Plaintiff alleges that Defendant’s Human Capital Management software platform, specifically its data analytics and talent acquisition features, infringes two patents related to distributed database processing and intent-driven search result presentation.
- Technical Context: The patents-in-suit address foundational technologies in large-scale data processing (MapReduce) and search engine result customization, which are relevant to modern cloud-based enterprise software platforms.
- Key Procedural History: The complaint states the patents-in-suit were originally filed by Yahoo! Inc. and are now owned by Plaintiff R2 Solutions LLC. No other significant procedural history, such as prior litigation or administrative proceedings, is mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2006-10-05 | '610 Patent Priority Date (Application Filing) |
| 2009-07-31 | '157 Patent Priority Date (Application Filing) |
| 2012-05-29 | '610 Patent Issue Date |
| 2012-12-25 | '157 Patent Issue Date |
| 2021-01-29 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,190,610 - MapReduce for Distributed Database Processing (Issued May 29, 2012)
The Invention Explained
- Problem Addressed: The patent asserts that conventional MapReduce programming methodologies were not well-suited for processing data from heterogeneous sources, making it "impractical to perform joins over two relational tables that have different schemas" (’610 Patent, col. 3:18-20; Compl. ¶17).
- The Patented Solution: The invention enhances the MapReduce framework by treating input data as distinct "groups," where each group can have a different data structure or schema (’610 Patent, col. 4:62-65). The system applies separate mapping functions to these heterogeneous data groups and then processes the intermediate results, which are linked by a common key, together in a single "reduce" function. This is accomplished by using different iterators for each data group within the reduce step, enabling the joining of disparate datasets (’610 Patent, Abstract; col. 8:52-58).
- Technical Importance: This approach extended the capabilities of MapReduce beyond handling uniform data, enabling it to perform complex operations analogous to relational database joins across large, distributed, and structurally different datasets (Compl. ¶19; ’610 Patent, col. 1:40-45).
Key Claims at a Glance
- The complaint asserts claims 1–5, 17–21, 33–34, and 40–41, with independent claim 1 being representative (Compl. ¶33).
- Independent Claim 1 recites a method of data processing comprising:
- Partitioning data from a plurality of "data groups" and providing the partitions to "user-configurable" mapping functions.
- The mapping functions independently output lists of values for a set of keys to form intermediate data for each group.
- Crucially, a first data group has a "different schema" than a second data group, and they are mapped differently.
- The intermediate data from the different groups has a "key in common."
- Reducing the intermediate data from the groups to merge it based on the common key, all performed on a distributed system (Compl. ¶18).
U.S. Patent No. 8,341,157 - System and Method for Intent-Driven Search Result Presentation (Issued December 25, 2012)
The Invention Explained
- Problem Addressed: The patent identifies a shortcoming in traditional search engines that treat a query as a simple "bag of words," which may yield results that do not align with the user's underlying purpose or "intent" (Compl. ¶23; ’157 Patent, col. 4:1-5).
- The Patented Solution: The invention proposes a method where the system first analyzes a user's query to determine a "plurality of intents" (e.g., intent to purchase, research, or find support) (’157 Patent, col. 3:46-57). After identifying data objects that match the query's keywords, the system assigns one of the determined intents to the results and then uses that assigned intent to "customize" the way each search result is displayed to the user (’157 Patent, Abstract; Compl. ¶25).
- Technical Importance: This technology aimed to improve search relevance by moving beyond keyword matching to a model where the presentation of results is actively tailored to the inferred goal of the user, potentially enhancing user experience and the utility of the results (Compl. ¶24; ’157 Patent, col. 4:16-19).
Key Claims at a Glance
- The complaint asserts claims 1-5 and 11, with independent claim 1 being representative (Compl. ¶42).
- Independent Claim 1 recites a method comprising:
- Receiving a query and identifying a query keyword.
- Determining a "plurality of intents" from the keyword.
- Classifying the query into at least one of the determined intents.
- Identifying data objects that match the keyword.
- Assigning at least one of the intents to some of the data objects.
- Ranking the data objects.
- Building a result with a plurality of display entries, where at least one display entry is "customized to a respective assigned intent" (Compl. ¶25).
III. The Accused Instrumentality
- Product Identification: The complaint identifies the accused instrumentalities as the "Workday data analytics system built on Apache Hadoop" and the "Workday Talent Acquisition platform" (Compl. ¶¶33, 42).
- Functionality and Market Context: The complaint describes the accused products as components of Workday's broader cloud-based Human Capital Management (HCM) platform, which provides financial and human capital management software to corporate customers (Compl. ¶3). The platform is marketed as a "single system with a single source for data" that replaces legacy on-premise systems (Compl. p. 2). The complaint alleges that the "Workday data analytics system" infringes the ’610 Patent and is built on Apache Hadoop, a known software framework that utilizes the MapReduce paradigm (Compl. ¶33). The "Workday Talent Acquisition" platform is accused of infringing the ’157 Patent (Compl. ¶42). To establish use within the judicial district, the complaint provides a screenshot from Workday's website identifying Collin College, an entity located within the district, as a customer (Compl. p. 5).
IV. Analysis of Infringement Allegations
'610 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of processing data...comprising: partitioning the data of each one of the data groups into a plurality of data partitions that each have a plurality of key-value pairs and providing each data partition to a selected one of a plurality of mapping functions that are each user-configurable to independently output a plurality of lists of values...to form corresponding intermediate data... | The complaint alleges that the "Workday data analytics system built on Apache Hadoop" performs the claimed method of data processing. | ¶¶18, 33 | col. 8:61-65 |
| wherein the data of a first data group has a different schema than the data of a second data group and the data of the first data group is mapped differently... | The system is alleged to process data from heterogeneous sources with different data structures. | ¶¶17, 18, 33 | col. 8:47-52 |
| wherein the different schema and corresponding different intermediate data have a key in common; | The system is alleged to process related datasets that are characterized by a common key. | ¶¶17, 18, 33 | col. 7:49-52 |
| and reducing the intermediate data for the data groups to at least one output data group, including processing the intermediate data...so as to result in a merging of the corresponding different intermediate data based on the key in common... | The system is alleged to use a reduce function to merge intermediate data from the different groups based on their common key. | ¶¶18, 33 | col. 8:52-58 |
- Identified Points of Contention:
- Technical Questions: A central evidentiary question will be whether the "Workday data analytics system" performs the specific, enhanced MapReduce process claimed. The complaint alleges the system is built on Apache Hadoop (Compl. ¶33), but it does not specify how it allegedly implements the novel claim elements, such as joining data from groups with "different schema" using a "key in common." The analysis will likely focus on whether Workday's implementation goes beyond a conventional MapReduce architecture.
'157 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| ...receiving, over a network, a query from a user...analyzing the query...to identify at least one query keyword; | The complaint alleges that the "Workday Talent Acquisition" platform performs the claimed method of processing user queries. | ¶¶25, 42 | col. 9:26-34 |
| determining...a plurality of intents from the at least one keyword...classifying the query...into at least one of the plurality of intents; | The platform is alleged to determine and classify user query "intents." | ¶¶25, 42 | col. 10:41-47 |
| identifying...a plurality of data objects available over the network that match the at least one query keyword; | The platform is alleged to identify matching data objects, such as job listings or candidate profiles. | ¶¶25, 42 | col. 10:1-4 |
| assigning...at least one of the plurality of intents to at least some of the plurality of data objects; | The platform is alleged to associate an inferred "intent" with the identified data objects. | ¶¶25, 42 | col. 10:5-9 |
| building a result...the result comprises a plurality of display entries, at least one display entry customized to a respective assigned intent is constructed for each of the ranked plurality of data objects; | The platform is alleged to build and display results where the presentation is customized based on the assigned intent. | ¶¶25, 42 | col. 10:27-38 |
- Identified Points of Contention:
- Scope Questions: The dispute may turn on the definition of key terms. It raises the question of whether the functionality of a specialized enterprise tool like "Workday Talent Acquisition" can be said to determine a "plurality of intents" and "customize" display entries in the manner contemplated by a patent originally directed at general-purpose web search.
V. Key Claim Terms for Construction
'610 Patent
- The Term: "user-configurable" (from Claim 1)
- Context and Importance: This term is critical because it defines the required nature of the mapping functions. The degree and type of configurability required will be a key point of dispute. Practitioners may focus on this term to determine if it requires end-user interaction, administrator-level setup, or developer-level programming, which could distinguish the claimed invention from a hard-coded or less flexible system.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers generally to "user-provided" map and reduce functions, which could suggest any form of configuration supplied by a user of the system (’610 Patent, col. 1:21-22).
- Evidence for a Narrower Interpretation: The specification's detailed pseudocode examples for map and reduce functions imply that the "user" is a software developer writing complex code, not an end-user adjusting settings in a graphical interface (’610 Patent, col. 5:25-6:65). This could support a narrower construction requiring developer-level programmability.
'157 Patent
- The Term: "a plurality of intents" (from Claim 1)
- Context and Importance: This term is the conceptual core of the ’157 Patent. The entire infringement case rests on whether Workday's platform determines "intents." Practitioners may focus on this term because its definition will determine whether the accused functionality meets this central limitation. A broad definition might cover any user goal, while a narrow one might require a specific, predefined taxonomy of goals.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes intent in general terms, such as the difference between a user who wishes to "browse web sites relating to 'rainforests'" versus one with a "more focused purpose" like purchasing merchandise or travel (’157 Patent, col. 3:49-57). This suggests "intent" could be a broad classification of user purpose.
- Evidence for a Narrower Interpretation: The illustrative example in the patent lists a specific, categorical taxonomy of intents for a product query: "Product, official-site, research, purchase, dealer, support, reviews" (’157 Patent, col. 13:13-17). This could support a narrower construction requiring a structured, predefined set of classifications.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain allegations of indirect infringement (induced or contributory infringement). The infringement counts are explicitly limited to direct infringement under 35 U.S.C. § 271(a) (Compl. ¶¶32, 41).
- Willful Infringement: The complaint does not include an allegation of willful infringement or facts to support a claim for enhanced damages. While the prayer for relief requests a finding that the case is "exceptional" for the purpose of attorneys' fees under 35 U.S.C. § 285, it does not plead willfulness (Compl. p. 15).
VII. Analyst’s Conclusion: Key Questions for the Case
This litigation will likely center on the following key questions:
A core issue will be one of definitional scope: Can the term "plurality of intents", which is rooted in the patent's context of general web search, be construed to read on the search and filtering mechanisms within Workday's specialized Talent Acquisition software? The patentability and infringement analyses will depend heavily on the construction of this term.
A key evidentiary question will be one of operational specifics: For the '610 patent, can the Plaintiff prove that Workday’s analytics system performs the specific claimed method of joining heterogeneous data groups using distinct iterators and a common key, or does it merely use a generic MapReduce architecture that falls outside the patent’s claims?
A threshold procedural question concerns pleading sufficiency: The complaint makes broad allegations of infringement without providing specific factual connections between the accused products' operations and the elements of the asserted claims. An initial focus of the litigation may be on whether these allegations meet the plausibility standard required to survive a motion to dismiss.