DCT

6:10-cv-00671

Global Sessions LP v. Travelocitycom LP

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:10-cv-00671, E.D. Tex., 06/13/2011
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants conduct substantial business and make, use, sell, or offer for sale the accused products and services within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendants’ e-commerce websites, cloud computing platforms, and underlying server infrastructure infringe four patents related to managing web systems, maintaining user session state across multiple servers, and using historical user data to provide dynamic content.
  • Technical Context: The technology addresses foundational challenges in early, large-scale web architecture, specifically the stateless nature of the HTTP protocol, enabling stateful applications like shopping carts and personalized user experiences.
  • Key Procedural History: The complaint is a First Amended Complaint. It alleges that Global Session Holdings, SRL owns the patents-in-suit and has granted an exclusive license to co-plaintiff Global Sessions LP, including the right to sue for infringement.

Case Timeline

Date Event
1998-03-06 Priority Date for '108, '220, '249, and '894 Patents
2000-06-13 Issue Date for U.S. Patent No. 6,076,108
2000-07-04 Issue Date for U.S. Patent No. 6,085,220
2002-03-19 Issue Date for U.S. Patent No. 6,360,249
2002-11-12 Issue Date for U.S. Patent No. 6,480,894
2011-06-13 First Amended Complaint Filing Date

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

U.S. Patent No. 6,076,108

  • Patent Identification: U.S. Patent No. 6,076,108, "System And Method For Maintaining A State For A User Session Using A Web System Having A Global Session Server," issued June 13, 2000.

The Invention Explained

  • Problem Addressed: The patent's background section identifies a core problem with web-based communication: the underlying HTTP protocol is "connectionless and stateless," meaning the system inherently "forgets" information about a user between interactions. This complicates dynamic interactions, especially in large web systems where a user may interact with multiple different servers during a single session (e.g., when shopping online) (’108 Patent, col. 1:21-36).
  • The Patented Solution: The invention proposes a "global session server" to solve this problem. This server stores "session data" representing the state of a user's session in a centralized or distributed memory location. When a web engine receives a user request, it retrieves the relevant session data from the global server, processes the request, and then updates the data in the global server to reflect any changes, making the new state available for subsequent interactions (’108 Patent, Abstract; col. 2:45-56). This architecture, illustrated in Figure 4, allows a web system to maintain a persistent "memory" of a user's session across multiple page requests and servers (’108 Patent, Fig. 4).
  • Technical Importance: This approach provided a method for enabling stateful applications (e.g., shopping carts, multi-step wizards) that are fundamental to modern e-commerce but were difficult to implement reliably at scale under the web's original stateless architecture (’108 Patent, col. 2:61-64).

Key Claims at a Glance

  • The complaint asserts "one or more claims" without specification. Independent claims 1 (method) and 12 (system) appear to cover the core invention.
  • Essential elements of Independent Claim 1 include:
    • Receiving a request from a user that initiates a user session.
    • Storing a "single set of session data" representing the session's state in a "global session server" that is accessible by multiple web system engines.
    • For subsequent requests, retrieving the session data from the global session server.
    • Processing the request using the session data to provide a web page.
    • Changing and updating the session data in the global session server to reflect the processing.
  • The complaint's general assertion of "one or more claims" reserves the right to assert dependent claims (Compl. ¶20).

U.S. Patent No. 6,085,220

  • Patent Identification: U.S. Patent No. 6,085,220, "Enterprise Interaction Hub For Managing An Enterprise Web System," issued July 4, 2000.

The Invention Explained

  • Problem Addressed: The patent addresses the broader challenge of managing a complex "enterprise web system" where simple page delivery must be integrated with business logic and legacy data systems (’220 Patent, col. 1:19-23).
  • The Patented Solution: The invention discloses a modular "enterprise interaction hub" with a layered architecture. This architecture separates functions into an "interaction layer" (receives requests), a "presentation layer" (generates web pages), a "business layer" (provides logic), and an "integration layer" (connects to backend data) (’220 Patent, col. 2:50-56; Fig. 1). A central feature of this hub is a "trend collection layer" that monitors and accumulates "historical information" about user activity, storing it in a trend database. This data can be mined and stored in a "profile database" to provide "customized dynamic content" to users (’220 Patent, Abstract).
  • Technical Importance: This layered, hub-based architecture provided a scalable framework for separating technical concerns (e.g., user interface from business rules), which simplified development and enabled sophisticated, data-driven personalization on enterprise-level websites (’220 Patent, col. 2:5-12).

Key Claims at a Glance

  • The complaint asserts "one or more claims" without specification. Independent claims 1 (hub system) and 8 (web system) appear to be central.
  • Essential elements of Independent Claim 1 include:
    • An interaction layer, presentation layer, business layer, and integration layer.
    • A "trend collection layer" that monitors and accumulates historical information from the other layers and stores it in a "trend database."
    • A "profile database," accessible by the presentation and business layers, that stores profile data mined from the trend database.
    • The use of this profile data to provide "customized dynamic content" in the generated web pages.
  • The complaint reserves the right to assert dependent claims (Compl. ¶35).

Multi-Patent Capsule: U.S. Patent No. 6,360,249

  • Patent Identification: U.S. Patent No. 6,360,249, "Enterprise Interaction Hub For Managing An Enterprise Web System," issued March 19, 2002.
  • Technology Synopsis: As a continuation related to the ’220 Patent, this patent further details a method and system for managing a web system. The claims focus on the method of receiving user requests, using business logic and profile data to generate responsive web pages with customized content, and accumulating historical user data in a trend database for subsequent analysis and personalization (’249 Patent, Abstract; Claim 1).
  • Asserted Claims: The complaint does not specify claims. Independent claims include 1, 2, 9, and 12.
  • Accused Features: The complaint accuses Defendants' "interaction hub for managing a web system" that enables the presentation of web pages to users (Compl. ¶49).

Multi-Patent Capsule: U.S. Patent No. 6,480,894

  • Patent Identification: U.S. Patent No. 6,480,894, "System And Method For Maintaining A State For A User Session Using A Web System," issued November 12, 2002.
  • Technology Synopsis: As a continuation related to the ’108 Patent, this patent further refines the system for maintaining user session state across multiple interactions. It claims a method and system where session data, reflecting changes from previous user requests, is stored and made accessible to a plurality of web system engines to ensure a persistent and consistent user experience in a distributed environment (’894 Patent, Abstract; Claim 1).
  • Asserted Claims: The complaint does not specify claims. Independent claims include 1, 5, 6, 10, 11, and 12.
  • Accused Features: The complaint accuses Defendants' systems that present web pages to users "from multiple web engines while maintaining session state" (Compl. ¶64).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are the large-scale commercial websites and associated backend infrastructure operated by the Defendants, including "www.travelocity.com", "www.amazon.com", "aws.amazon.com", "www.cdw.com", "www.orbitz.com", "www.priceline.com", and others (Compl. ¶¶ 19, 21, 23, 25, 27). The allegations also cover the underlying software and computer equipment that store and serve content for these sites (Compl. ¶19(iii)).

Functionality and Market Context

  • The complaint alleges that these websites function by presenting content "from multiple web engines while maintaining session state," a functionality necessary for features like shopping carts and multi-step transaction processes (Compl. ¶19). The complaint further alleges these systems operate as an "interaction hub for managing a web system," enabling the dynamic presentation of web pages and services to users (Compl. ¶34). For certain defendants like Amazon, the allegations explicitly include "cloud computing services" that provide the infrastructure for such functionality (Compl. ¶21, ¶66). The defendants represent major entities in the e-commerce, online travel, and cloud computing markets, suggesting the accused functionalities are of high commercial importance.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

6,076,108 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving a request from a user that initiates a user session with the web system... Defendants' websites (e.g., travelocity.com) and the underlying servers receive HTTP requests from end-users initiating an interaction. ¶19 col. 9:16-19
storing a single set of session data representing a state of the user session in a global session server... accessible by the web system engines... Defendants' systems allegedly maintain "session state" for users across multiple interactions, using servers that are accessible by multiple web engines. ¶19 col. 9:20-27
for each subsequent request... retrieving the session data from the global session server using one of the web system engines... To maintain a continuous session (e.g., a shopping cart), Defendants' systems must retrieve the user's current state upon receiving a subsequent request. ¶19 col. 9:39-41
processing the subsequent request... using the session data to provide a web page to the user... Defendants' systems serve responsive web pages and content that depend on the user's session state (e.g., showing items in a cart). ¶19 col. 9:42-45
changing the session data to reflect the processing; and updating the single set of session data in the global session server... The act of "maintaining session state" across multiple user actions implies that the state data is modified and updated after each interaction. ¶19 col. 9:46-49
  • Identified Points of Contention:
    • Scope Questions: A primary question will concern the scope of "global session server." The court may need to determine if this term, as described in the patent (e.g., with "lock" and "unlock" features at col. 9:35-49), reads on the modern, highly distributed caching architectures (e.g., Redis, Memcached) likely used by Defendants, which may operate differently from the patent's specific embodiments.
    • Technical Questions: The complaint alleges infringement in a conclusory manner. A key factual question will be whether Plaintiff can produce evidence showing that Defendants' session management systems function as claimed, particularly whether they store a "single set" of session data that is "shared" among engines in the manner described by the patent, as opposed to using other state-management techniques.

6,085,220 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
an interaction layer that receives requests... a presentation layer... generating... web pages; a business layer... providing business logic; [etc.] The complaint alleges Defendants operate an "interaction hub for managing a web system," which implicitly asserts the existence of the claimed layered architecture for handling requests and generating dynamic web pages. ¶34 col. 3:4-64
a trend collection layer operating to monitor and accumulate historical information... and... store that historical information in a trend database... The complaint does not specifically allege a "trend collection layer." Infringement is premised on the allegation that Defendants operate an "interaction hub," which in the patent is defined to include this layer for tracking user history. ¶34 col. 4:20-37
a profile database... that stores profile data, including data mined from the trend database... the profile data used... to provide customized dynamic content... The provision of personalized recommendations and targeted advertising on Defendants' sites suggests the use of user profile data. The complaint's theory appears to be that this functionality is evidence of the claimed profile database. ¶34 col. 4:38-51
  • Identified Points of Contention:
    • Scope Questions: The infringement analysis may turn on whether the accused systems possess the distinct, functionally separate "layers" as claimed. Defendants may argue their web frameworks are not architected in the specific layered manner required by the claim, even if they perform similar overall functions.
    • Technical Questions: A significant evidentiary hurdle for the Plaintiff will be to demonstrate that Defendants' systems actually employ a "trend collection layer" to accumulate "historical information" for populating a "profile database." The court will have to consider what level of user activity logging and data analysis meets the specific requirements of these claim limitations, and whether Plaintiff can prove this functionality exists within the accused systems.

V. Key Claim Terms for Construction

  • Term: "global session server" ('108 Patent, Claim 1)

    • Context and Importance: This term is the central component of the '108 patent's invention. The outcome of the infringement analysis for the '108 and '894 patents will largely depend on whether the session management systems used by the Defendants fall within the construed scope of this term.
    • Intrinsic Evidence for a Broader Interpretation: The specification suggests the server can be "centralized or distributed" ('108 Patent, col. 7:10-12), and Claim 1 only requires that it be "accessible by the web system engines such that the web system engines can share the session data." This language could support a construction covering any shared data store used for session management.
    • Intrinsic Evidence for a Narrower Interpretation: The detailed description explains a specific process where a session cache "calls a 'lock' on that SID within global session server," downloads the data, and later performs an "unlock" ('108 Patent, col. 9:31-38). A defendant may argue that the term should be limited to a server that operates with this specific lock/unlock protocol.

  • Term: "trend collection layer" ('220 Patent, Claim 1)

    • Context and Importance: This element distinguishes the '220 patent from a generic web server architecture and moves it into the realm of data mining and personalization. Proving the existence of this "layer" is critical to proving infringement of the '220 and '249 patents. Practitioners may focus on this term because it requires proof of a specific data-gathering architecture, not just generic web logging.
    • Intrinsic Evidence for a Broader Interpretation: The specification describes this as a "transparent layer that monitors and accumulates historical information" ('220 Patent, col. 4:20-23). Plaintiff could argue this broadly covers any automated system for logging user interactions over time for purposes of analysis and personalization.
    • Intrinsic Evidence for a Narrower Interpretation: The patent describes the layer as generating "events" that can be "as granular as events generated by individual business rule objects detailing their specific interactions" ('220 Patent, col. 4:27-30). This could support a narrower construction requiring a specific, event-driven monitoring architecture, rather than conventional server access logs.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that by providing their websites, software, and computer equipment, Defendants actively induce and contribute to the direct infringement of the patents-in-suit by end-users (Compl. ¶¶ 20, 22, 24, etc.). The alleged inducement is based on Defendants providing the platforms and services that cause users to perform the steps of the claimed methods.
  • Willful Infringement: The complaint does not allege specific facts to support willfulness, such as pre-suit knowledge of the patents. However, the prayer for relief includes a request for enhanced damages and treble damages for willful infringement (Compl. p. 29, ¶G).

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

  • A core issue will be one of definitional scope: can the term "global session server", rooted in the patent's description of a "lock/unlock" mechanism, be construed to cover the modern, highly distributed, and architecturally distinct caching systems used to manage sessions on large-scale commercial websites?
  • A second central question will be one of architectural correspondence: does the plaintiff have evidence that the defendants' web platforms are structured with the specific, multi-part "interaction hub" architecture as claimed in the '220 patent, particularly the "trend collection layer", or is there a fundamental mismatch between the claimed modular architecture and the integrated nature of modern web application frameworks?
  • Finally, a key threshold question, particularly under modern pleading standards, will be one of plausibility: do the complaint's parallel, high-level allegations against a wide array of different defendants and systems provide sufficient factual specificity to state a plausible claim for infringement for each accused instrumentality, or do they merely recite the claim elements?