DCT

9:25-cv-00087

Web 20 Tech LLC v. St Lukes Health Memorial Hospital

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 9:25-cv-00087, E.D. Tex., 07/29/2025
  • Venue Allegations: Plaintiff alleges venue is proper as Defendant maintains a regular and established place of business in the Lufkin Division of the Eastern District of Texas, where acts of infringement are alleged to have occurred.
  • Core Dispute: Plaintiffs allege that Defendant’s customized Electronic Health Record (EHR) systems, used to comply with federal healthcare regulations, infringe two patents related to secure online repositories for personal and health information.
  • Technical Context: The technology at issue involves centralized, network-accessible databases for storing, managing, and securely disseminating sensitive personal information, a foundational concept for modern Electronic Health Record systems.
  • Key Procedural History: The operative pleading is a First Amended Complaint. The complaint's infringement theory is predicated on the allegation that Defendant's compliance with federal standards for "Meaningful Use" (MU) and Certified EHR Technology (CEHRT), as mandated by the HITECH Act of 2009, necessitates the use of the patented technologies.

Case Timeline

Date Event
2000-01-07 Earliest Priority Date for ’913 and ’594 Patents
2016-10-11 U.S. Patent No. 9,465,913 Issues
2018-02-06 U.S. Patent No. 9,886,594 Issues
2025-07-29 First Amended Complaint for Patent Infringement 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 describes the inefficiency and annoyance of users repeatedly filling out online forms with personal information for various websites and services. It further notes the lack of a centralized method for users to store this data once and selectively authorize its release to different entities while maintaining security and control ('913 Patent, col. 1:31-58).
  • The Patented Solution: The invention proposes a system where a user stores their personal information in a single online repository. This system allows the user to assign different security classifications to individual pieces of information ("information objects"). When a third party requests data, the system verifies the requester's authorization against the user-defined security levels and releases only the permitted information, creating an audit trail of all accesses ('913 Patent, Abstract; col. 2:32-61).
  • Technical Importance: The technology aimed to provide users with granular, centralized control over the privacy and dissemination of their personal data, a significant concern with the proliferation of online services requiring user registration ('913 Patent, col. 1:59-64).

Key Claims at a Glance

  • The complaint asserts independent claim 1 ('Compl. ¶28).
  • The essential elements of independent claim 1 include:
    • A method for providing access to a patient's personal health record (PHR) stored in an online repository on a server computer.
    • Establishing a patient account and receiving the patient's health information from a first client computer.
    • 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 on a second computer.
    • Selecting and sending a portion of the PHR to the second computer in accordance with the control settings.
    • Recording every access of the PHR.
    • Enabling PHR access in a medical emergency.
    • Receiving and storing updates from an authorized party.
    • Automatically notifying the patient via electronic message if their PHR is changed.
  • 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 the problem of web bookmarks becoming "stale" (pointing to content that no longer exists) and the difficulty of sharing bookmarked information in a controlled, secure manner ('594 Patent, col. 1:59-68).
  • The Patented Solution: The invention describes an "online personal library" where a user can store actual digital items (e.g., documents, web pages, medical information) on a central server rather than just linking to them. This system allows the user to grant specific permissions to other "requesters" to access or modify the stored items, thereby creating a persistent, shareable, and secure repository ('594 Patent, Abstract; col. 2:45-68).
  • Technical Importance: This solution offered a method for persistent storage and controlled sharing of digital content, moving beyond simple bookmarking to create a user-managed online archive ('594 Patent, col. 2:45-50).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶36).
  • The essential elements of independent claim 1 include:
    • A method performed by a server system for managing user medical information.
    • Establishing accounts for a plurality of users.
    • Receiving a "first user's" medical information.
    • Storing an indication of the first user's medical information in their account.
    • Receiving, from a "second user" authorized by the first user, an update to the first user's medical information.
    • 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 approving/disapproving users.
    • Storing the updated medical information for the first user.
    • 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 the "customized EHR systems, platforms, and/or services" that Defendant St. Lukes Health Memorial Hospital "designs, develops, uses, and/or maintains" (Compl. ¶8).

Functionality and Market Context

  • The complaint alleges these EHR systems are configured to comply with federal "Meaningful Use" (MU) and Certified EHR Technology (CEHRT) standards promulgated under the HITECH Act (Compl. ¶8). Their functionality is alleged to include data capture and sharing, advancing clinical processes, and moving toward improved health outcomes (Compl. ¶15). By using these certified systems, the Defendant allegedly obtained federal financial incentives and avoided penalties, demonstrating the systems' commercial and regulatory importance (Compl. ¶12).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits 2 and 4) that were not provided with the filed document (Compl. ¶¶30, 38). The infringement allegations are therefore summarized below in narrative form based on the complaint's text.

  • '913 Patent Infringement Allegations: The complaint alleges that the Defendant's use of its MU- and CEHRT-compliant EHR systems directly infringes at least claim 1 of the ’913 Patent (Compl. ¶¶28, 31). The narrative infringement theory suggests that such EHR systems inherently perform the steps of the claimed method. This includes establishing accounts for patients, storing their personal health information (PHR), allowing patients to control access (e.g., through a patient portal), receiving and verifying requests from authorized providers, transmitting select portions of the PHR as needed for care, recording all data access for auditing purposes (e.g., HIPAA compliance), providing for emergency access, allowing authorized clinicians to update records, and notifying patients of changes to their record (Compl. ¶¶8-16, 28).

  • '594 Patent Infringement Allegations: The complaint alleges that the Defendant's EHR systems also directly infringe at least claim 1 of the ’594 Patent (Compl. ¶¶36, 39). The implicit theory is that the multi-user clinical environment in which EHRs operate maps onto the claimed method. This would involve the system establishing accounts for various users (e.g., a patient as a "first user" and a specialist as a "second user"), storing the patient's medical information, allowing the authorized specialist to update the record, verifying the specialist's identity, potentially involving an approval or co-signature workflow from other registered users (such as a primary care physician), storing the updated record, and automatically transmitting it to designated recipients (e.g., for continuity of care) (Compl. ¶¶8-16, 36).

V. Key Claim Terms for Construction

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

    • Context and Importance: The infringement analysis may hinge on whether the access controls within a commercial EHR system, which are often configured by the hospital or vendor according to system-wide policies like HIPAA, can be considered "patient-established." The degree of direct control a patient has over these settings will be a critical factual and legal question.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes a user providing a list of entities to be notified of changes, suggesting that designating recipients constitutes a form of control setting ('913 Patent, col. 9:21-23). This could support an interpretation where any patient-driven designation qualifies.
      • Evidence for a Narrower Interpretation: The specification repeatedly describes the user actively assigning a "security classification for each information object," suggesting a granular, field-level control that the patient directly establishes, which may be more specific than the general consent forms or portal settings in a standard EHR ('913 Patent, col. 10:49-54).

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

    • Context and Importance: This term appears to require a specific multi-user workflow for record updates. The viability of the infringement claim will depend on whether the accused EHR system includes a feature that can be characterized as a formal "approval or disapproval" step by other users, as opposed to merely logging an update made by a single authorized clinician.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not define or provide specific embodiments for this "approval or disapproval" step, potentially allowing for a broad reading that could cover functionalities like physician co-signature requirements or clinical peer review workflows common in hospital settings. The claim requires only that such feedback is "received" by the system.
      • Evidence for a Narrower Interpretation: The plain language "approval or disapproval" suggests an active, binary decision-making process by other registered users before an update is finalized. A defendant may argue this requires a specific feature, like a voting or formal sign-off queue, that is absent from its EHR system, which might instead allow direct updates by authorized personnel with only a subsequent audit trail.

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

  • A core issue will be one of agency and control: Are the functionalities of a hospital-administered EHR system, configured to comply with institutional and federal policies, equivalent to the "patient-established control settings" envisioned by the ’913 Patent? The case may turn on the distinction between a system where the patient is the primary administrator of their data versus one where a healthcare institution is the administrator acting on the patient's behalf.
  • A key evidentiary question will be one of functional specificity: Does the accused EHR system's workflow for updating patient records include a step that meets the ’594 Patent's requirement to "receive approval or disapproval... from one or more [other] users"? The dispute will likely focus on whether standard clinical features, such as co-signature requirements or audit logs, perform the specific function required by the claim, or if the claim demands a distinct, formal consensus-gathering mechanism that is absent in the accused system.