DCT

6:25-cv-00059

Web 20 Tech LLC v. Longview Regional Medical Center

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-00059, E.D. Tex., 02/26/2025
  • Venue Allegations: Venue is alleged to be proper because the Defendant maintains a regular and established place of business within the district where at least some of the alleged acts of infringement have 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 managing and selectively disbursing personal information.
  • Technical Context: The technology concerns secure, centralized online platforms where individuals can store personal data (such as health records) and grant controlled access to third-party requesters, a foundational concept for modern patient portals and health information exchanges.
  • Key Procedural History: The asserted patent claims priority back to an application filed in 2000, potentially predating many of the modern EHR standards and technologies implicated in the complaint.

Case Timeline

Date Event
2000-01-07 ’913 Patent Earliest Priority Date
2016-10-11 ’913 Patent Issue Date
2025-02-26 Complaint Filing Date

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 describes the inefficiency and annoyance for users who must repeatedly provide personal information to various online entities. It also identifies a lack of a centralized method for users to store, manage, and selectively authorize the distribution of their personal information, or to automatically propagate updates to all relevant parties. (’913 Patent, col. 1:29-48, col. 2:1-4).
  • The Patented Solution: The invention proposes a method and system where a user can create an account with a service provider to store various pieces of personal information in a single online repository. The user can then assign different security classifications to different data objects and authorize specific requesters to access only the information they are permitted to see. The system is also designed to automatically notify designated entities of any changes or updates made by the user to their information. (’913 Patent, Abstract; col. 2:32-54).
  • Technical Importance: This centralized, user-permissioned approach to data management aimed to give individuals greater control and security over their personal data while streamlining access for authorized entities, addressing a growing need as more interactions moved online. (’913 Patent, col. 1:43-48).

Key Claims at a Glance

  • The complaint asserts independent Claim 1. (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 a patient account on a server computer.
    • Receiving and storing the patient's personal health information, thereby creating a PHR.
    • Associating "patient-established control settings" with the PHR, allowing the patient to configure and restrict access to "designated requesters."
    • Receiving an access request from a designated requester with a patient identifier and authorization information.
    • Verifying the authorization information.
    • Selecting and sending a portion of the PHR to the requester in accordance with the control settings.
    • Recording every access of the patient's PHR.
    • Enabling access to the PHR in a medical emergency.
    • Receiving and storing updates to the PHR from an authorized party.
    • Automatically notifying the patient via electronic message if their PHR is changed.
  • The complaint reserves the right to assert other claims of the ’913 Patent. (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

Functionality and Market Context

  • The complaint alleges these systems are used to manage electronic medical health records and are certified to comply with federal "Meaningful Use" (MU) and Certified EHR Technology (CEHRT) standards promulgated under the HITECH Act. (Compl. ¶8-10). These standards govern how patient health information is captured, shared, and used. The complaint alleges that by complying with these standards, the Defendant's systems improve care coordination and efficiency, and that the Defendant obtained federal financial incentives for this compliance. (Compl. ¶11-12). The complaint points to Defendant's "hospital-patient-portal" as an example of the accused systems. (Compl. ¶8).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit 2, but this exhibit was not provided. (Compl. ¶28). The infringement theory, based on the complaint's narrative, is that the Defendant's use of its EHR systems, by virtue of their compliance with MU and CEHRT standards, directly infringes the method steps of at least Claim 1 of the ’913 Patent. (Compl. ¶16, ¶26). The complaint alleges a broad correspondence between the functionalities required by the HITECH Act framework—such as providing patients with electronic access to their health information and ensuring its secure exchange—and the specific steps recited in the patent. (Compl. ¶10-13, ¶26).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A central question may be whether general compliance with the MU/CEHRT regulatory framework is sufficient to meet the specific limitations of Claim 1. For instance, do the accused systems feature "patient-established control settings" that allow a patient to "restrict access to...one or more designated requesters" with the granularity described in the patent, or do they operate on a more basic consent model?
    • Technical Questions: What evidence does the complaint provide that the accused EHR systems perform each specific step of the claim? For example, the claim requires "enabling access to the patient's PHR in case of a medical emergency involving the patient." The infringement analysis will turn on whether the accused systems have a specific technical feature for this purpose that maps to the claim, rather than relying on general hospital emergency procedures. The complaint's reliance on broad standards compliance rather than detailing the specific operation of the accused patient portal raises the question of how closely the accused technology matches the claimed method. (Compl. ¶8, ¶16).

V. Key Claim Terms for Construction

  • The Term: "patient-established control settings" (’913 Patent, col. 15:7)

  • Context and Importance: The definition of this term is critical for determining infringement. The dispute may focus on how much control a patient must have over access permissions. Practitioners may focus on this term because its construction will determine whether a standard patient portal consent agreement is sufficient to meet the limitation, or if more granular, user-configurable rules are required.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the user's ability to "authorize the release of such information to any person or entity" (’913 Patent, col. 1:46-48) and to "provide a list of entities that should be notified" of changes (’913 Patent, col. 9:20-22), which could suggest a general, user-driven authorization model.
    • Evidence for a Narrower Interpretation: The specification also describes a system for assigning a "security classification for each information object, at the tuple or at the field level" and providing "a predetermined number of security classifications." (’913 Patent, col. 9:50-55). This language may support a narrower construction requiring a more specific, fine-grained control mechanism.

  • The Term: "designated requester" (’913 Patent, col. 15:12)

  • Context and Importance: This term's construction is important for defining the parties to the infringing act. The key question is whether the "requester" must be a third party separate from the entity hosting the PHR system (the Defendant).

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification lists "doctor's/dentist's offices" among a long list of potential requesters, which could include the Defendant itself in its capacity as a healthcare provider. (’913 Patent, col. 1:55).
    • Evidence for a Narrower Interpretation: Claim 1 distinguishes between the "patient" operating a "first client computer" and the "designated requester" operating a "second computer," which may suggest the requester is an external entity. (’913 Patent, col. 15:4, 15:14). The specification also provides examples of requesters as third parties, such as a "travel agent or a tailor." (’913 Patent, col. 11:5-8).

VI. Other Allegations

  • Indirect Infringement: The complaint does not include a count for indirect or induced infringement.
  • Willful Infringement: The complaint does not contain a specific count for willful infringement. However, the prayer for relief seeks a judgment that this is an "exceptional case" and an award of attorneys' fees under 35 U.S.C. § 285. (Compl. p. 8, ¶C). The complaint does not allege any facts to support pre-suit knowledge by the Defendant of the ’913 Patent or the alleged infringement.

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

  • A core issue will be one of technical specificity: does the general operation of an EHR system compliant with federal "Meaningful Use" standards inherently practice the specific, multi-step method of Claim 1? The case may turn on whether the patent's requirements for "patient-established control settings" and a distinct "designated requester" process demand more granular functionality than is provided by the accused patient portal.
  • A key evidentiary question will be one of proof of infringement: beyond alleging compliance with broad federal regulations, what specific evidence will be presented to show that the Defendant’s particular EHR system and patient portal actually perform each and every step of the asserted claim, such as the clauses for handling medical emergencies and automatically notifying patients of changes to their records?