Reigntek IP LLC v. Microsoft Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Reigntek IP LLC (Delaware)
  • Defendant: Microsoft Corporation (Washington)
  • Plaintiff’s Counsel: Corcoran IP Law PLLC
• Case Identification: 5:18-cv-00112, E.D. Tex., 09/13/2018
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Microsoft conducts business, a portion of the alleged infringements occurred, and Microsoft derives revenue from goods and services provided to individuals within the district.
• Core Dispute: Plaintiff alleges that Defendant’s Windows 10 Operating System infringes a patent related to a multi-route, client-server network architecture for optimizing data retrieval.
• Technical Context: The technology concerns methods for reducing network congestion by enabling peer-to-peer data sharing among client devices, thereby avoiding redundant requests to a central server.
• 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

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

U.S. Patent No. 6,633,901 - "Multi-Route Client-Server Architecture"

• Patent Identification: U.S. Patent No. 6,633,901, “Multi-Route Client-Server Architecture,” issued October 14, 2003 (’901 Patent). (Compl. ¶7).

The Invention Explained

• Problem Addressed: The patent identifies inefficiencies in conventional network topologies where multiple, geographically-close clients must each independently request the same information from a distant server, resulting in duplicated data transmission and increased bandwidth consumption. (’901 Patent, col. 1:18-35).
• The Patented Solution: The invention proposes a "flat" network architecture where "agent software" resides on participating client nodes. A central server maintains a database of which clients have cached which information. When one client requests data, the server can redirect it to retrieve the data directly from another client that already has it, rather than from the original source. (’901 Patent, Abstract; col. 2:10-25). The system is also designed to handle situations where information is fragmented across multiple clients. (Compl. ¶13).
• Technical Importance: This peer-to-peer retrieval method is presented as a way to make more efficient use of computer and network resources, particularly in environments with communication bottlenecks, such as between a corporate intranet and the Internet. (Compl. ¶11).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" without specifying which ones, but refers to a claim chart in an unattached exhibit. (Compl. ¶18, ¶20). Assuming the assertion of the primary independent claim, the elements of Claim 1 are:
  • designating a device on the network as a server, and a plurality of other devices as clients;
  • associating a database with the server to identify where desired information is stored on one or more of the other clients when a request is received from a requestor for the desired information;
  • if the database indicates that the information is available from one or more of the clients, providing the desired information to the requestor directly through the one or more of the clients such that the requestor is given a fastest possible access to the desired information while using minimum bandwidth of the network; and
  • wherein, when only fragments of the information are available from one or more of the clients, the one or more of the clients are negotiated to rebuild the information such that the requestor can receive the information completely from the one or more of the clients. (’901 Patent, col. 5:19-39).
• Plaintiff explicitly reserves the right to modify its infringement theories and assert other claims as discovery progresses. (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

• The accused product is Defendant's Windows 10 Operating System. (Compl. ¶16).

Functionality and Market Context

• The complaint does not describe the specific functionality of the Windows 10 Operating System alleged to infringe the ’901 Patent. The infringement allegations rely entirely on a reference to "Exhibit 2," which was not filed with the complaint. (Compl. ¶18, ¶20). The complaint also makes no specific allegations regarding the commercial importance or market positioning of the accused product. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint provides no narrative infringement theory in its body, stating that the theory of infringement is understandable from a plain reading of the complaint, the patent, and an unattached "Exhibit 2" claim chart. (Compl. ¶20). As this exhibit is not available, a detailed claim chart summary cannot be constructed.

• Identified Points of Contention: The lack of a specific infringement theory in the complaint makes it difficult to identify definitive points of contention. However, based on the patent's claims and the general nature of the accused product, several technical and legal questions are likely to arise.
  • Scope Questions: A central question may be whether any feature within the Windows 10 operating system, such as a P2P update service, qualifies as the general-purpose "method of accessing information on a network" as claimed, or if its functionality is too specific and distinct from the patented method.
  • Technical Questions: A key technical dispute will likely center on whether any accused Windows 10 feature performs the specific steps recited in the claims. For instance, what evidence demonstrates that Windows 10 utilizes a "server" with an associated "database" to identify information on other "clients" for peer-to-peer transfer, as required by Claim 1? Furthermore, what evidence shows that clients "are negotiated to rebuild the information" from fragments, as opposed to using a different technical method for assembling data from multiple peers?

V. Key Claim Terms for Construction

• The Term: "server" and "clients"

  • Context and Importance: The claims are founded on a "server-client" architecture. Practitioners may focus on these terms because their construction will determine whether Microsoft's network infrastructure (for features like software updates) can be mapped onto the patent's framework. The accused system's architecture may not align with the traditional or claimed definitions of these roles.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that "the client and server terminology is used only for the description of this architecture and does not require or imply a specific network functionality." (’901 Patent, col. 2:61-64). This language may support an argument that the terms should be construed broadly and functionally.
    • Evidence for a Narrower Interpretation: The claims assign specific roles and functions to the "server" (e.g., "associating a database with the server to identify where desired information is stored") and "clients." (’901 Patent, col. 5:23-26). This may support a narrower construction where the terms are limited to devices that perform these exact, recited functions.

• The Term: "the one or more of the clients are negotiated to rebuild the information"

  • Context and Importance: This active step of "negotiation" to "rebuild" fragmented information appears to be a critical element of the claimed process. The case may turn on whether the accused Windows 10 functionality performs this specific type of negotiation or uses a different, non-infringing method to assemble data from peers.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that any automated protocol for gathering data fragments from multiple peer sources constitutes a "negotiation" in a technical sense.
    • Evidence for a Narrower Interpretation: The specification describes a process where the "requester of information... knows the size and extent of the fragmentation and negotiates with the other client-agents to request the fragmented parts of the information and rebuild the information it needs." (’901 Patent, col. 3:28-32). This could support a narrower construction requiring a process where the requesting client actively manages the negotiation and reconstruction.

VI. Other Allegations

• Willful Infringement: The complaint does not contain a formal count for willful infringement. However, it alleges that Microsoft has known of its alleged infringement since at least the date it was served with the complaint, which could form a basis for seeking enhanced damages for any post-filing infringement. (Compl. ¶22). The prayer for relief also seeks a judgment that the case is "exceptional" under 35 U.S.C. § 285, which permits an award of attorneys' fees. (Compl. Prayer for Relief ¶D).

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

1. A central issue will be one of pleading sufficiency and evidentiary basis: As the complaint’s infringement theory relies entirely on an unattached exhibit, the initial phase of litigation will likely focus on compelling Plaintiff to identify the specific functionality within the vast Windows 10 operating system that is accused of infringement and the factual basis for that accusation.

2. The case will likely turn on a question of technical mapping: Can the patent’s specific architecture—requiring a designated "server" with a "database" that orchestrates direct P2P transfers where clients "negotiate to rebuild" fragmented data—be accurately mapped onto the actual operation of a modern, complex feature within Windows 10? Or will discovery reveal a fundamental mismatch between the claimed process and the accused system's technology?