Web 20 Tech LLC v. Medical City Denton

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Web 2.0 Technologies, LLC (Texas) and Pennar Software Corporation (Virginia)
  • Defendant: Medical City Denton (Texas)
  • Plaintiff’s Counsel: Devlin Law Firm LLC
• Case Identification: 4:25-cv-00191, E.D. Tex., 02/27/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant having a regular and established place of business in the district where acts of infringement have purportedly occurred.
• Core Dispute: Plaintiffs allege that Defendant’s customized Electronic Health Record (EHR) systems, which comply with federal "Meaningful Use" standards, infringe a patent related to an online repository for personal information.
• Technical Context: The lawsuit concerns the management of electronic personal health records, a field heavily influenced by federal regulations designed to promote the interoperability and security of patient data.
• Key Procedural History: The complaint alleges that the accused systems are certified to comply with standards promulgated under the HITECH Act, which provides financial incentives for the "meaningful use" of certified EHR technology. This regulatory compliance is presented as the basis for infringement.

Case Timeline

Date	Event
2000-01-07	U.S. Patent No. 9,465,913 Priority Date
2016-10-11	U.S. Patent No. 9,465,913 Issued
~2018-01-01	Name of EHR incentive program changed to "Promoting Interoperability"
2025-02-27	Complaint Filed

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

U.S. Patent No. 9,465,913 - “Online Repository for Personal Information,” issued October 11, 2016

The Invention Explained

• Problem Addressed: The patent identifies the inefficiency and annoyance for users who must repeatedly enter personal information into forms on various websites (’913 Patent, col. 1:35-41). It also notes the lack of a method for a user to store personal information at a single location and selectively authorize its distribution, or to easily update that information across multiple entities ('913 Patent, col. 1:60-col. 2:3).
• The Patented Solution: The invention proposes a central online repository where a user can store their personal information, associate different security levels with different pieces of information, and authorize release to third-party "requesters" based on those levels ('913 Patent, Abstract; col. 2:42-55). The system is designed to verify a requester's authorization before disbursing the information and can automatically notify designated entities when a user updates their information ('913 Patent, col. 2:55-67).
• Technical Importance: The technology provides a framework for user-centric control over the dissemination of personal data online, a departure from entity-specific data collection methods ('913 Patent, col. 1:55-64).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 1 ('913 Patent, col. 15:1-35; Compl. ¶26).
• The essential elements of independent Claim 1 are:
  • A computer-implemented method for accessing a patient's personal health record (PHR) in an online repository.
  • Establishing an account for a patient with a server computer.
  • Receiving the patient's PHR via a first client computer.
  • Storing the PHR, thereby creating a record for the patient.
  • Associating "patient-established control settings" with the PHR to restrict access to designated requesters.
  • Receiving an access request from a "designated requester" via a second computer, which includes an identifier and authorization information.
  • Verifying the authorization information.
  • Selecting and sending a portion of the PHR to the second computer in accord with the "patient-established control settings."
  • Recording every access of the patient's PHR.
  • Enabling access in a medical emergency.
  • Receiving updates to the PHR and automatically notifying the patient of the change.
• The complaint does not explicitly reserve the right to assert dependent claims, but states infringement of "one or more claims" ('913 Patent, Compl. ¶26).

III. The Accused Instrumentality

Product Identification

The complaint does not name a specific commercial EHR product. It identifies the "Accused Instrumentalities" as "customized EHR systems, platforms, and/or services" that Defendant "designs, develops, uses and/or maintains" ('913 Patent, Compl. ¶8).

Functionality and Market Context

The core functionality alleged to be infringing is the systems' compliance with the "Meaningful Use" ("MU") and "Certified EHR Technology" ("CEHRT") standards ('913 Patent, Compl. ¶¶8-9). The complaint alleges that in order to receive federal financial incentives and avoid penalties, Defendant's EHR systems must be used for purposes like electronic prescribing and exchanging electronic health information, which purportedly infringes the '913 Patent ('913 Patent, Compl. ¶¶11-13, 26). The complaint does not describe the specific technical operation of Defendant's EHR systems beyond their compliance with these federal standards.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in its Exhibit 2, but this exhibit was not filed with the complaint document itself (Compl. ¶28). Therefore, a detailed element-by-element analysis cannot be performed from the provided documents.

The complaint’s narrative infringement theory posits that by using EHR systems that "comply with the Meaningful Use standards and CEHRT," Defendant directly infringes at least Claim 1 of the '913 Patent (Compl. ¶26). The central allegation is that meeting the requirements of these federal programs inherently practices the steps of the claimed method. No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A primary issue will be whether the general requirements of the MU/CEHRT government standards are coextensive with the specific limitations of Claim 1. The court may need to determine if mere compliance with a standard, without more, constitutes performance of each claimed step.
  • Technical Questions: The complaint lacks specific factual allegations detailing how Defendant’s EHR systems perform certain claim steps. For example, it does not explain how the systems implement "patient-established control settings" or how access is restricted to "designated requesters" in a manner that maps onto the patent's teachings. The case may turn on whether the control and access functions mandated by CEHRT standards are technically equivalent to those claimed in the '913 Patent.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a full analysis of potential claim construction disputes. However, based on the asserted claims and the nature of the allegations, certain terms will likely be critical.

• The Term: "patient-established control settings"

• Context and Importance: This term appears central to the patent's concept of user-centric control. The infringement case may depend on whether the access controls in Defendant's EHR system are "established" by the "patient," or if they are pre-determined by the system, the healthcare provider, or the CEHRT regulations themselves.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification is silent on who implements the security policy, which could suggest that as long as the settings reflect patient privacy choices, they are "patient-established" even if implemented by a provider.
  • Evidence for a Narrower Interpretation: The patent repeatedly emphasizes the user's role in providing information and setting preferences, suggesting the "patient" must be the party actively defining the rules ('913 Patent, col. 9:2-15; col. 9:48-54). The term may be construed to require direct configuration by the patient, not merely adherence to default privacy rules.

• The Term: "designated requester"

• Context and Importance: The claim requires that access be restricted to "one or more designated requesters." The dispute may focus on who performs the "designation." If the CEHRT framework defines classes of authorized users (e.g., all treating physicians, any participating pharmacy), it raises the question of whether this meets the claim limitation, which seems to imply a more specific designation by the patient.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not explicitly state that the patient must individually name every single requester. A party could argue that designating a category of requester (e.g., "my travel agent") is sufficient ('913 Patent, col. 11:5-8).
  • Evidence for a Narrower Interpretation: The overall context of the patent, which focuses on granular, user-specific control, may support a construction where the patient must affirmatively identify and approve specific entities to be "designated."

VI. Other Allegations

The complaint does not contain allegations for indirect or willful infringement. It asserts only direct infringement under 35 U.S.C. § 271(a) (Compl. ¶26).

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

This case appears to hinge on the link between federal regulatory compliance and patent infringement. The central questions for the court will likely be:

1. A core question of evidentiary sufficiency: Can Plaintiffs demonstrate, with specific evidence, that Defendant's use of a "CEHRT-compliant" EHR system performs each and every specific step of the method claimed in the '913 Patent, or is the allegation of "compliance" an insufficient proxy for infringement?

2. A key issue of claim scope: Can the patent's term "patient-established control settings" be construed to read on the access and privacy protocols mandated by the federal "Meaningful Use" and CEHRT framework, or do those standards impose a fundamentally different control scheme than what the patent describes?