DCT

6:25-cv-00059

Web 20 Tech LLC v. Longview Regional Medical Center

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-00059, E.D. Tex., 07/29/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has a regular and established place of business in the district where acts of infringement have allegedly occurred.
  • Core Dispute: Plaintiffs allege that Defendant’s customized Electronic Health Record (EHR) systems infringe patents related to methods for securely storing, managing, and sharing personal information in an online repository.
  • Technical Context: The technology concerns centralized, user-controlled online databases for personal data, applied here to the field of electronic health records mandated and incentivized by federal healthcare regulations.
  • Key Procedural History: The complaint is a First Amended Complaint. No other significant procedural events are mentioned.

Case Timeline

Date Event
2000-08-05 ’594 Patent Priority Date
2004-11-12 ’913 Patent Priority Date
2009-01-01 HITECH Act / ARRA enacted
2016-10-11 U.S. Patent No. 9,465,913 Issues
2018-01-01 EHR incentive program name changed
2018-02-06 U.S. Patent No. 9,886,594 Issues
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 Oct. 11, 2016

The Invention Explained

  • Problem Addressed: The patent’s background describes the inefficiency and annoyance of users repeatedly filling out online forms with personal information for different entities and the lack of a centralized, user-controlled system for managing and selectively sharing this data (’913 Patent, col. 1:26-44). It also notes that existing methods, like credit reporting agencies, often provide incomplete or inaccurate information not verified by the user (’913 Patent, col. 2:15-24).
  • The Patented Solution: The invention proposes a central online repository where a user can store various types of personal information, assign different security classifications to each piece of data, and authorize third-party "requesters" to access only specific, approved portions of that information (’913 Patent, Abstract; col. 2:33-44). The system architecture, shown in Figure 1, comprises a server computer that manages user accounts, security, and a database, interacting with both users and requesters over a network (’913 Patent, Fig. 1).
  • Technical Importance: The claimed solution provides a method for individuals to maintain a single, authoritative source for their personal data while retaining granular control over its dissemination, addressing privacy and data accuracy concerns. (Compl. ¶11).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶28).
  • Claim 1 of the ’913 Patent recites a method with the essential elements of:
    • Establishing a patient account on a server computer.
    • Receiving and storing the patient's personal health information (PHR) in a data storage area associated with the account.
    • 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.
    • Verifying the requester's authorization information.
    • Selecting and sending a portion of the patient's PHR to the requester in accordance with the patient-established control settings.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,886,594 - "Online Electronic Health Record", Issued Feb. 6, 2018

The Invention Explained

  • Problem Addressed: The patent identifies problems with managing digital information, such as bookmarks to web pages becoming "stale" when the content is moved or deleted, and the difficulty of sharing information with others in a controlled, collaborative manner (’594 Patent, col. 1:46-67).
  • The Patented Solution: The invention describes a method for operating an online repository where a "first user" (e.g., a patient) can store medical information, and an authorized "second user" (e.g., a provider) can submit updates to that information (’594 Patent, claim 1). The method includes a step for receiving "approval or disapproval" for the update from other registered users and then storing and distributing the updated information (’594 Patent, claim 1).
  • Technical Importance: This technology outlines a collaborative workflow for maintaining the accuracy and integrity of a shared electronic record by incorporating an update, verification, and approval process among multiple authorized users. (Compl. ¶11).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶36).
  • Claim 1 of the ’594 Patent recites a method with the essential elements of:
    • Establishing accounts for users on a server computer system.
    • Receiving and storing a "first user's" medical information.
    • Receiving an update to that 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 the identifying information of the users who approved or disapproved.
    • Storing the updated medical information.
    • Automatically sending the updated information to a designated requester.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

  • Product Identification: The "Accused Instrumentalities" are identified as customized Electronic Health Record (EHR) systems, platforms, and services that Defendant "designs, develops, uses, and/or maintains" (Compl. ¶8). These systems are alleged to comply with the federal "Meaningful Use" ("MU") and Certified EHR Technology ("CEHRT") standards (Compl. ¶8).
  • Functionality and Market Context: The complaint alleges these EHR systems are used to create and manage electronic medical health records, facilitate electronic prescriptions, and enable the exchange of electronic health information to improve care quality and efficiency (Compl. ¶11). A "hospital-patient-portal" is cited as an example of the technology (Compl. ¶8). Plaintiffs allege that by complying with the MU standards, Defendant obtained federal financial incentives and avoided penalties (Compl. ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits (Exhibits 2 and 4) that purportedly detail the infringement of independent claim 1 of each asserted patent (Compl. ¶30, ¶38). The following analysis is based on the narrative infringement theory presented in the body of the complaint.

  • ’913 Patent Infringement Theory: Plaintiffs allege that Defendant’s EHR systems, including its patient portal, necessarily perform the steps of claim 1 (Compl. ¶28). The theory suggests that patients establish accounts, their personal health information is stored, and they are given some level of control over their records, while designated requesters (such as the patients themselves or their providers) can access this information through the system (Compl. ¶8, ¶11). The infringement allegation is tied to the functionalities required to achieve federal "Meaningful Use" certification (Compl. ¶9).
  • ’594 Patent Infringement Theory: Plaintiffs allege that the collaborative nature of EHR systems infringes claim 1 of the ’594 Patent (Compl. ¶36). The theory posits a workflow where a patient (the "first user") has a record that is updated by a healthcare provider (the "second user"). The complaint alleges, without specific factual support, that the Defendant's CEHRT-compliant systems perform the claimed steps of verifying the provider, storing the update, and notifying other parties, thereby infringing the patent (Compl. ¶8, ¶16, ¶36).
  • Identified Points of Contention:
    • Factual Support Questions: The complaint broadly alleges that compliance with "Meaningful Use" standards results in infringement. A primary question will be whether the specific, accused EHR systems used by Defendant actually perform the detailed steps required by the asserted claims. For instance, what evidence demonstrates that the accused systems feature the "patient-established control settings" of the ’913 Patent's claim 1, or the specific "approval or disapproval" workflow recited in the ’594 Patent's claim 1?
    • Scope Questions: Claim 1 of the ’594 Patent requires a step of receiving "approval or disapproval for the update from one or more users." A key legal and factual question will be whether any review or co-signing feature in a clinical EHR system meets this limitation, or if the claim requires a distinct, consensus-based validation function that may not be present in the accused systems.

V. Key Claim Terms for Construction

  • For the ’913 Patent:
    • The Term: "patient-established control settings"
    • Context and Importance: The infringement reading for the '913 Patent depends on the degree of control a patient has over access to their PHR. The construction of this term will determine whether a standard portal's binary access rules suffice, or if more granular, patient-configurable restrictions for third-party requesters are required.
    • Intrinsic Evidence for a Broader Interpretation: The patent abstract describes releasing information "based on the second party's status," which could suggest a system of pre-set roles rather than highly granular, user-defined rules (’913 Patent, Abstract).
    • Intrinsic Evidence for a Narrower Interpretation: The specification describes assigning a "security classification for each information object, at the tuple or at the field level" (’913 Patent, col. 10:49-52). This may support a construction requiring fine-grained, data-element-level control configured by the patient.
  • For the ’594 Patent:
    • The Term: "receive approval or disapproval for the update from one or more users"
    • Context and Importance: This term appears to describe a specific collaborative workflow. The infringement case for the '594 Patent may turn entirely on whether this limitation can be read onto the functionality of Defendant's EHR system. Practitioners may focus on this term because it is a highly specific step that may not be present in a standard clinical record-keeping process.
    • Intrinsic Evidence for a Broader Interpretation: The patent does not define "approval or disapproval," potentially allowing Plaintiffs to argue that it covers any form of supervisory review, co-signature, or quality check performed within the EHR system.
    • Intrinsic Evidence for a Narrower Interpretation: The plain language suggests a formal validation or voting mechanism by a plurality of "users." This could support a narrower construction that excludes a hierarchical review process (e.g., an attending physician signing off on a resident's note), which is not typically characterized as a peer "approval or disapproval" process.

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

This case will likely focus on the factual mapping of the accused EHR systems onto specific and detailed claim limitations. The central open questions are:

  • A key evidentiary question will be one of functional correspondence: Can Plaintiffs demonstrate that Defendant’s EHR system, as actually used, performs the specific workflow of receiving "approval or disapproval for the update from one or more users," as required by Claim 1 of the ’594 Patent, or is there a fundamental mismatch between the claimed collaborative method and standard clinical documentation practices?
  • A core issue will be one of definitional scope: Does the term "patient-established control settings" in Claim 1 of the ’913 Patent require a system of granular, field-level access rights configured by the patient for third parties, as suggested by the specification, or can it be construed more broadly to cover the general access permissions of a standard patient portal?
  • A foundational issue will be the link between regulatory compliance and infringement: The complaint's theory hinges on the assertion that "Meaningful Use" certification requires the performance of the patented methods. The case may depend on whether Plaintiffs can prove this assertion or if Defendant can show that its systems achieve compliance without practicing every element of the asserted claims.