DCT

3:18-cv-02702

Akoloutheo LLC v. Citrix Systems Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:18-cv-02702, N.D. Tex., 10/11/2018
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a "regular and established place of business" in Dallas, Texas, specifically a sales, marketing, and business development office, and has committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s suite of network management, application delivery, and analytics products infringes a patent related to a generalized framework for processing transactions between disparate information services and applications.
  • Technical Context: The technology concerns service-oriented architecture, specifically methods for a central system to dynamically discover, integrate, and manage transactions with various independent network resources without requiring pre-configured, point-to-point integration.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2001-04-19 Priority Date, U.S. Patent No. 7,426,730
2008-09-16 Issue Date, U.S. Patent No. 7,426,730
2018-10-11 Complaint Filing Date

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

U.S. Patent No. 7,426,730 - Method and System for Generalized and Adaptive Transaction Processing Between Uniform Information Services and Applications

Issued September 16, 2008

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of integrating information from multiple, disparate online services in a flexible and scalable way. It notes that custom, hard-coded integrations are inefficient and limited, citing the example of combining driving directions with real-time traffic data, which were typically presented as separate, non-integrated services. (’970 Patent, col. 1:59-2:5).
  • The Patented Solution: The invention describes a "Transaction Processing Function" (TPF) that acts as an intelligent intermediary between service "consumers" (RSCs) and service "providers" (RSPs). (’970 Patent, Fig. 1). An RSC submits a generalized "Transaction Definition" (TD) describing a desired outcome. The TPF analyzes the TD, consults a repository of classified services (a "Uniform Specification Repository" or USR), dynamically selects and binds to the appropriate RSPs, and orchestrates the transaction to produce a result, adapting the process based on "context" data such as user location or session history. (’970 Patent, Abstract; col. 5:11-24). This framework allows for the dynamic composition of services without requiring the services to be explicitly aware of each other.
  • Technical Importance: The described architecture provides a generalized model for a service-oriented architecture (SOA) that enables loose coupling between services, aiming to simplify the integration and management of complex, distributed systems. (’970 Patent, col. 3:5-14).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 15, and 17. (Compl. ¶37).
  • Independent Claim 1 (System Claim):
    • A networked computer system with servers for providing a resultant resource.
    • A "resource transaction processing module."
    • A plurality of remotely located "resource providers."
    • A "resource information registry" storing information about the providers' resources.
    • The module is configured to: construct a "transaction situation context," dynamically select a resource, determine operations to perform, obtain the resource, and process it to generate a "resultant resource."
  • Independent Claim 17 (Method Claim):
    • Obtaining a "transaction request" identifying an output.
    • Constructing a "transaction situation context."
    • Analyzing the request to: dynamically create a set of input resources, determine operations, obtain the resources, and execute the operations to generate the output.
  • The complaint reserves the right to assert additional claims. (Compl. ¶37).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses a broad suite of integrated products, collectively referred to as "Citrix Systems," including "Citrix Software" and "Citrix Network Devices." (Compl. ¶¶11, 12, 14). Key accused products include Citrix ADC, Application Delivery Management, Citrix Gateway, Workspace App, Virtual Apps & Desktops, and Citrix Analytics. (Compl. ¶11).

Functionality and Market Context

  • The complaint alleges these products form "unified systems" that manage and provide access to a variety of network resources from a centralized point. (Compl. ¶14). The "Citrix Analytics" software is central to the allegations, described as a service that "aggregates and correlates information across network traffic, users, files and endpoints to monitor user activity, application performance and operational usage." (Compl. ¶15). The complaint includes a diagram from Citrix marketing material showing how Citrix Analytics collects data from various sources (e.g., "Citrix Virtual Apps and Desktops," "Citrix Networking offerings") to "Generate insights" and "Take actions." (Compl. p. 7). This system allegedly provides a web-based dashboard for users to "manage and interrogate data" and "request data-driven operations." (Compl. ¶20).

IV. Analysis of Infringement Allegations

’730 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a resource transaction processing module Citrix Software, particularly Citrix Analytics, which allegedly performs centralized monitoring, interrogation, and configuration for network resources. ¶¶25, 38 col. 4:51-54
a plurality of resource providers, each resource provider being remotely located... Various Citrix products and services (e.g., Citrix ADC, Virtual Apps, Citrix Gateway) that are communicatively coupled to the Citrix Software and provide data to it. ¶¶18, 23, 41 col. 4:18-20
a resource information registry for storing information about the resources... The system allegedly "generates a registry of Citrix Network Resources and information about each" and stores this in a "resource information registry." ¶¶28, 43 col. 5:5-8
constructs a transaction situation context... Citrix Software is alleged to process "context specific data," and Citrix Workspace is described as using "user context and IT-designed policies" to deliver experiences. ¶¶32, 45; p. 6 col. 4:56-62
dynamically selects at least one resource to process... according to information stored in the resource information registry The software allegedly "dynamically selects at least one Citrix Network Resource to process" based on "information stored in the resource information registry." ¶46 col. 12:47-51
determines one or more discrete operations to perform on the at least one selected resource... The software is alleged to determine "one or more operations to perform on the Citrix Network Resource to obtain a result satisfying the requested transaction." ¶47 col. 12:35-38
obtains the at least one selected resource... and processes the at least one selected resource... to generate a resultant resource Citrix Analytics allegedly "aggregates and correlates information" and "obtains the result from the selected Citrix Network Resource and processes that result to generate a desired output." ¶¶15, 48 col. 12:40-45
  • Identified Points of Contention:
    • Scope Questions: A primary question may be whether the accused "Citrix Analytics" system, which is described as a tool for monitoring, security, and performance analysis, performs "transaction processing" as contemplated by the patent. The defense may argue that the patent is directed at executing discrete, user-initiated functional tasks (e.g., retrieving map data), not performing continuous, system-level data aggregation and analytics. Plaintiff may counter by pointing to the broad definition of "transaction" in the patent.
    • Technical Questions: The complaint alleges the existence of a "resource information registry" (Compl. ¶43), but the factual basis for how this registry is implemented and used will be a key issue. The court will need to determine whether the dynamic discovery of data sources by Citrix Analytics, as depicted in a screenshot showing the enabling of virtual servers (Compl. p. 8), meets the structural and functional requirements of the claimed "registry."

V. Key Claim Terms for Construction

  • The Term: "resource transaction processing module"

    • Context and Importance: This term defines the central engine of the claimed system. Its construction will be critical, as the dispute may turn on whether Citrix's analytics and management software qualifies as a "transaction processing module." Practitioners may focus on this term because it distinguishes between a general-purpose service orchestrator and a more specific-purpose monitoring tool.
    • Intrinsic Evidence for a Broader Interpretation: The patent defines "Transaction" as potentially being a "programmatic event, signal, or information exchange," which could be argued to encompass the data collection events in an analytics system. (’970 Patent, col. 3:1-3).
    • Intrinsic Evidence for a Narrower Interpretation: The specification consistently uses the acronym "TPF" (Transaction Processing Function) and provides examples involving explicit user requests for a functional result (e.g., a map), which may suggest a more active, request-driven process than passive data monitoring. (’970 Patent, col. 11:13-11:41).

  • The Term: "transaction request"

    • Context and Importance: The nature of the "transaction request" will be pivotal for both system and method claims. The defense may argue that the automated data flows in its analytics platform are not initiated by a "request" in the claimed sense.
    • Intrinsic Evidence for a Broader Interpretation: The patent states a transaction is "initiated by a request from a client," but does not strictly limit the form of that client or request. (’970 Patent, col. 4:51-52). A user logging into a dashboard to view analytics could be framed as the client initiating a request for processed data.
    • Intrinsic Evidence for a Narrower Interpretation: The patent's detailed example of a Transaction Definition (TD) shows a structured, programmatic request for a specific action ("FindNearby"). (’970 Patent, Fig. 11). This may support an argument that the term requires a specific, structured command to initiate a process, rather than a general user interaction with a UI.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Citrix requires end users to operate the accused systems in an infringing manner and "exercises control and/or direction over the performance of every action." (Compl. ¶53). The basis appears to be Citrix's control over its platform and documentation instructing users on its operation. (Compl. ¶¶53, 55).
  • Willful Infringement: Willfulness is alleged based on notice provided by the filing of the complaint itself. No pre-suit knowledge is alleged. (Compl., Prayer for Relief ¶d).

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

  • A core issue will be one of definitional scope: can the patent's framework for "generalized and adaptive transaction processing," which is exemplified by executing discrete, user-initiated functional tasks like mapping, be construed to cover the accused Citrix platform, whose primary described function is system-level monitoring, data aggregation, and security analytics?
  • A key evidentiary question will be one of functional mapping: does the accused system's dynamic discovery and aggregation of data from various network sources, as depicted in the complaint's diagrams (Compl. pp. 7-8), perform the specific sequence of functions—including the use of a "resource information registry" and the processing of a "transaction request"—in the manner required by the asserted claims, or is there a fundamental mismatch in the operational paradigm?