DCT

6:25-cv-00058

Web 20 Tech LLC v. Christus Good Shepherd Medical Center

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-00058, E.D. Tex., 07/29/2025
  • Venue Allegations: Venue is alleged to be proper based on Defendant having a regular and established place of business within the Eastern District of Texas where acts of infringement have allegedly occurred.
  • Core Dispute: Plaintiffs allege that Defendant’s Electronic Health Record (EHR) systems infringe two patents related to secure, online repositories for managing and selectively sharing personal information.
  • Technical Context: The technology at issue involves centralized, web-based systems for storing personal and health information, allowing users to set access controls for sharing that data with authorized third parties, a functionality central to modern EHR platforms.
  • Key Procedural History: The complaint does not reference prior litigation involving the asserted patents. The infringement allegations are predicated on the Defendant’s alleged compliance with federal standards for Certified EHR Technology (CEHRT) and "Meaningful Use" (later "Promoting Interoperability") promulgated under the HITECH Act of 2009.

Case Timeline

Date Event
2000-01-07 U.S. Patent 9,465,913 Priority Date
2000-01-07 U.S. Patent 9,886,594 Priority Date
2016-10-11 U.S. Patent 9,465,913 Issues
2018-02-06 U.S. Patent 9,886,594 Issues
c. 2018 Meaningful Use program name changed to Promoting Interoperability
2025-07-29 First Amended 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 (’913 Patent)

The Invention Explained

  • Problem Addressed: The patent's background describes the inefficiency and annoyance faced by internet users who must repeatedly fill out online forms with personal and demographic information for various services (’913 Patent, col. 1:29-44). It also notes the absence of a method for a user to store personal information in a single location and selectively authorize its distribution (’913 Patent, col. 1:60-64).
  • The Patented Solution: The invention proposes a centralized online repository where a user can establish an account to store various pieces of personal data, described as "information objects" (’913 Patent, col. 2:49-50). The user can assign a specific security classification level to each object, enabling the system to release only authorized portions of the information to third-party "requesters" based on the requester's status and the user's settings (’913 Patent, Abstract; Fig. 1).
  • Technical Importance: This approach aimed to give users centralized, granular control over the dissemination of their personal data, streamlining interactions with a growing number of online services that required such information (’913 Patent, col. 1:45-49).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶28).
  • The essential elements of claim 1 include:
    • A method for permitting access to a patient's personal health record (PHR) in an online repository.
    • Establishing a patient account on a server computer and receiving the patient's health information.
    • Storing the information to create a PHR.
    • Associating "patient-established control settings" with the PHR to restrict access to designated requesters.
    • Receiving and verifying an access request from a designated requester via a second computer.
    • Selecting and sending a portion of the PHR to the requester in accordance with the control settings.
    • Recording every access of the PHR.
    • Enabling access in a medical emergency.
    • Receiving and storing updates to the PHR from an authorized party.
    • Automatically notifying the patient via electronic message if the PHR is changed.
      (’913 Patent, col. 14:57-15:35).

U.S. Patent No. 9,886,594, “Online Electronic Health Record,” issued February 6, 2018 (’594 Patent)

The Invention Explained

  • Problem Addressed: The patent identifies issues with contemporary methods of saving online content, noting that printing pages becomes unmanageable, downloading files consumes significant local resources, and bookmarking is unreliable as links can become "stale" or broken over time (’594 Patent, col. 1:36-62).
  • The Patented Solution: The invention describes an "online personal library" for storing "digital items" such as web pages, documents, or images on a central server (’594 Patent, col. 2:21-24). This system allows a user to create an account, store information, and grant access to authorized requesters, thereby creating a persistent, shareable, and centrally managed repository of online content (’594 Patent, col. 2:45-54).
  • Technical Importance: The technology provided a framework for a cloud-based storage system that preserved online information and facilitated controlled sharing, representing a more robust solution than local bookmarking or downloading (’594 Patent, col. 1:63-65).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶36).
  • The essential elements of claim 1 include:
    • A method performed by a server system to establish accounts for users.
    • Receiving a first user's medical information and storing an indication of it in the user's account.
    • Receiving an update to the first user's medical information from an authorized second user.
    • Verifying the identity of the second user.
    • Receiving "approval or disapproval for the update from one or more users registered with the server computer system."
    • Storing identifying information of the users who approved or disapproved.
    • Storing the updated medical information.
    • Automatically sending the updated information to a designated requester.
      (’594 Patent, col. 26:48-27:1).

III. The Accused Instrumentality

Product Identification

Defendant's "customized EHR systems, platforms, and/or services" (’Accused Instrumentalities’) (Compl. ¶8).

Functionality and Market Context

The complaint alleges these are systems certified to comply with federal "Meaningful Use" (MU) and Certified EHR Technology (CEHRT) standards, as mandated by the HITECH Act (Compl. ¶8, ¶10). Their functionality is described as facilitating the interoperable exchange of electronic health information to improve care quality, efficiency, and patient engagement (Compl. ¶11). The complaint alleges that by complying with these standards, Defendant obtained federal financial incentives and avoided penalties, positioning the technology as a required component of its medical practice (Compl. ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theories. The following is a summary of the narrative allegations.

’913 Patent Infringement Allegations

The complaint alleges that Defendant’s EHR systems directly infringe claim 1 of the ’913 Patent (Compl. ¶30-31). The theory appears to equate a certified EHR system with the claimed "online repository." It suggests that such systems inherently perform the claimed steps: a patient's information is received and stored, creating a PHR; access controls required by regulations like HIPAA function as the "patient-established control settings"; and other authorized healthcare providers act as "designated requesters" who access portions of the PHR. The complaint states that a detailed element-by-element breakdown is provided in Exhibit 2, which was not filed with the public complaint (Compl. ¶30).

’594 Patent Infringement Allegations

For the ’594 Patent, the complaint alleges that the Accused Instrumentalities directly infringe claim 1 (Compl. ¶38-39). The infringement theory appears to map the functions of a collaborative healthcare environment onto the claim elements. For example, it suggests that the EHR system receives initial patient data (from a "first user") and then receives updates from other authorized clinicians (a "second user"). The complaint incorporates by reference a claim chart in Exhibit 4, which was not provided, to detail how each element is allegedly met by the accused systems (Compl. ¶38).

Identified Points of Contention

  • Scope Questions: A potential point of contention may be whether a hospital-operated EHR system, with access controls largely governed by institutional policies and federal regulations like HIPAA, can be considered equivalent to the "online repository" with "patient-established control settings" described in the ’913 Patent. The latter suggests a system with more direct, granular control by the individual user.
  • Technical Questions: The infringement allegation for the ’594 Patent hinges on whether the accused EHR system performs the step of receiving "approval or disapproval for the update from one or more users." This raises the question of what evidence the complaint provides that such a specific, multi-user consensus mechanism for updating a patient's medical record exists within the accused systems, as distinct from a standard clinical review or co-signing workflow.

V. Key Claim Terms for Construction

  • Term: "patient-established control settings" (from ’913 Patent, claim 1)

    • Context and Importance: The interpretation of this term may be dispositive. The dispute could center on whether this term requires active, granular configuration by the patient, or if it can be read to cover system-wide privacy and access rules that a patient agrees to upon intake.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification discusses assigning "security levels to each information object" and a "security classification" to fields, which might be argued to encompass general privacy elections or consents (’913 Patent, col. 2:51-53; col. 7:13-15).
      • Evidence for a Narrower Interpretation: The specification describes a user providing a "security classification for each information object," and payment plans that depend on "the number of security classifications the user 103 has chosen," language which may support an interpretation requiring direct and active choices by the patient (’913 Patent, col. 9:34-37; col. 10:50-52).

  • Term: "receive approval or disapproval for the update from one or more users registered with the server computer system" (from ’594 Patent, claim 1)

    • Context and Importance: Practitioners may focus on this term because its plain language suggests a formal, potentially collaborative review process that may not be standard in typical EHR workflows for patient data updates. Infringement could depend on whether this language can cover a general clinical verification or if it requires a specific approval/disapproval action by multiple users.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party seeking a broader reading might argue this language should be interpreted in the context of general data integrity and verification processes common in medical records systems.
      • Evidence for a Narrower Interpretation: The claim language explicitly recites receiving "approval or disapproval," which suggests a binary choice or voting mechanism. The patent does not appear to provide a specific definition or embodiment for this phrase, which could lead to a dispute centered on its plain and ordinary meaning.

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

  • A core issue will be one of definitional scope: can the patents' concept of a user-centric "online repository" or "personal library," where individuals actively manage granular security settings, be construed to cover a regulated, provider-centric EHR system where access controls are largely dictated by institutional policy and federal law?
  • A key evidentiary question will be one of technical and factual correspondence: do the accused EHR systems actually perform the specific methods recited in the claims? In particular, does the Defendant's system implement a workflow for receiving "approval or disapproval" from multiple users before storing an update to a patient's record, as required by claim 1 of the ’594 Patent, or is there a fundamental mismatch between the claim language and the accused clinical functionality?