DCT

3:25-cv-01491

Patent Armory Inc v. Wrike Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-01491, N.D. Tex., 06/11/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Northern District of Texas and has committed acts of patent infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s products infringe two patents related to intelligent call routing and automated, auction-based systems for matching entities.
  • Technical Context: The patents address technologies for optimizing resource allocation in communications systems, such as call centers, by moving beyond simple queuing to sophisticated, multi-factor decision-making.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history involving the patents-in-suit.

Case Timeline

Date Event
2002-03-07 ’979 Patent Priority Date
2003-03-07 ’086 Patent Priority Date
2003-03-07 ’979 Patent Application Filing Date
2006-04-04 ’979 Patent Issue Date
2010-03-08 ’086 Patent Application Filing Date
2016-09-27 ’086 Patent Issue Date
2025-06-11 Complaint Filing Date

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

U.S. Patent No. 7,023,979 - "Telephony Control System With Intelligent Call Routing"

  • Patent Identification: U.S. Patent No. 7,023,979, "Telephony Control System With Intelligent Call Routing," issued April 4, 2006. (Compl. ¶9).

The Invention Explained

  • Problem Addressed: The patent describes the inefficiency of traditional Automatic Call Distribution (ACD) systems in call centers, which typically route calls based on simple rules like first-come-first-served or longest-idle-agent. (ʼ979 Patent, col. 3:5-13). These methods are inadequate when agents possess varying skills, leading to potential mismatches such as under-skilled agents receiving complex calls or over-skilled agents being assigned simple tasks, reducing overall efficiency. (ʼ979 Patent, col. 4:26-39).
  • The Patented Solution: The invention proposes a communications management system that integrates intelligent decision-making directly into the low-level call switching architecture. (’979 Patent, col. 59:6-14). The system receives a "communications classification" for an incoming call and uses a processor to compute an "optimum agent selection" by comparing the call's needs against a database of agent skills and skill weights, as illustrated in the flowchart of Figure 1. (ʼ979 Patent, Abstract; Fig. 1).
  • Technical Importance: This approach enabled a more dynamic and optimized allocation of call center resources by moving beyond rigid queuing rules to a system that could evaluate multiple variables in real-time to make a more effective match between a caller and an agent. (ʼ979 Patent, col. 66:13-23).

Key Claims at a Glance

The complaint does not identify specific claims, instead referencing an unattached exhibit. (Compl. ¶17). Independent claim 1 is representative of the technology.

  • Independent Claim 1:
    • A communications control system within a common operating environment.
    • An input for receiving call classification information.
    • A data structure representing agent characteristics.
    • A processor that determines an optimum agent for a call based on a multivariate cost function comparing at least three agents.
    • The processor also controls the call routing, with the determination and routing performed within the common operating environment.
  • The complaint alleges infringement of "one or more claims" of the patent, reserving the right to assert additional claims, including dependent claims. (Compl. ¶12).

U.S. Patent No. 9,456,086 - "Method and system for matching entities in an auction"

  • Patent Identification: U.S. Patent No. 9,456,086, "Method and system for matching entities in an auction," issued September 27, 2016. (Compl. ¶10).

The Invention Explained

  • Problem Addressed: The patent addresses limitations in systems that match entities based solely on skill profiles. It introduces a more advanced model for situations where multiple qualified entities exist and a more economically efficient allocation is desired, extending beyond simple technical matching. (’086 Patent, col. 37:5-14).
  • The Patented Solution: The invention describes a method for matching entities using an automated, auction-style optimization. The system defines entities using "multivalued scalar data" (e.g., skill profiles, cost, availability) and performs an optimization that considers not only the quality of a potential match but also the "economic surplus" and the "opportunity cost"—the value lost by making one particular match versus another potential match. (’086 Patent, Abstract; col. 63:45-64:17). The process is depicted in Figure 3, where incoming "Call Classification Vectors" are processed against "Agent Characteristics" using a "Cost Function" to determine the optimal routing. (’086 Patent, Fig. 3).
  • Technical Importance: This technology advances resource allocation by applying principles of auction theory and economic optimization, allowing a system to maximize the overall utility of a pool of resources rather than just optimizing individual transactions in isolation. (’086 Patent, col. 73:6-15).

Key Claims at a Glance

The complaint does not identify specific claims, instead referencing an unattached exhibit. (Compl. ¶26). Independent claim 1 is representative of the technology.

  • Independent Claim 1:
    • A method for matching a first subset of entities with a second subset of entities.
    • Storing multivalued scalar data for the first subset (e.g., callers with specific needs).
    • Storing multivalued scalar data for the second subset (e.g., agents with specific skills).
    • Performing an optimization using an automated processor that considers the "economic surplus" of a match and the "opportunity cost" of making that entity unavailable for other potential matches.
    • Outputting a signal based on the optimization.
  • The complaint alleges infringement of "one or more claims" of the patent, reserving the right to assert additional claims. (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

  • The complaint does not name any specific accused products in its main body, referring to them generally as the "Exemplary Defendant Products" identified in unattached exhibits. (Compl. ¶¶12, 21).

Functionality and Market Context

  • The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. It makes only the conclusory statement that the products "practice the technology claimed" by the patents-in-suit. (Compl. ¶¶17, 26).
    No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim chart Exhibits 3 and 4, which were not provided with the pleading. (Compl. ¶¶18, 27). The complaint’s narrative theory alleges that Defendant’s "Exemplary Defendant Products" directly infringe because they "satisfy all elements of the Exemplary... Patent Claims." (Compl. ¶¶17, 26). It further alleges that Defendant’s internal testing and use by its employees also constitutes direct infringement. (Compl. ¶¶13, 22).

  • Identified Points of Contention:
    • Evidentiary Questions: A primary question for the court will be whether the factual record supports the complaint’s conclusory allegations. The complaint does not specify what features of the accused products allegedly perform the functions of a "communications control system" (’979 Patent) or an "auction" system that calculates "economic surplus" and "opportunity cost" (’086 Patent).
    • Scope Questions: A potential point of contention may be whether the claims, which are described in the context of telephony call centers, can be construed to cover the functionality of Defendant’s products. The analysis will raise the question of whether the accused system’s functionality is analogous to the "call routing" and "entity matching" described in the patents.

V. Key Claim Terms for Construction

  • Term: "multivariate cost function" (from ’979 Patent, Claim 1)

    • Context and Importance: This term is central to the inventive concept of the ’979 Patent. Its construction will determine the level of algorithmic sophistication required for a system to infringe. Practitioners may focus on this term because it distinguishes the claimed invention from simpler, rule-based routing systems.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests the term is flexible, stating that disparate factors can be "normalized into a common metric, 'cost'," and can include variables such as "customer satisfaction" and "training cost." (ʼ979 Patent, col. 65:21-25; col. 65:14-16).
      • Evidence for a Narrower Interpretation: The patent discloses specific mathematical formulas for the cost function, such as "An=Max[Acn1∑(rsian,s)+Acn2]". (ʼ979 Patent, col. 65:5-6). This specific embodiment could be cited to argue for a narrower construction limited to similar quantitative models.

  • Term: "economic surplus" and "opportunity cost" (from ’086 Patent, Claim 1)

    • Context and Importance: These terms are foundational to the economic optimization model claimed in the ’086 Patent. The infringement analysis will depend on whether the accused system can be shown to calculate or approximate these specific economic values.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's abstract describes the optimization in general terms as being with respect to "at least an economic surplus... and an opportunity cost," suggesting a conceptual rather than a rigidly defined formula. (’086 Patent, Abstract).
      • Evidence for a Narrower Interpretation: These are established terms of art in economics. Their use in the claim may be argued to require a specific type of calculation that considers the value of foregone alternatives, not just the value of the immediate match. Claim 6, for example, refers to maximizing a "predicted aggregate economic surplus value," which implies a concrete, calculable figure. (’086 Patent, col. 76:59-62).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for both patents. It asserts that Defendant provides "product literature and website materials" that instruct and encourage end users to use the accused products in a manner that infringes the patents. (Compl. ¶¶15-16, 24-25).
  • Willful Infringement: The complaint does not contain a formal allegation of willful infringement based on pre-suit knowledge. It does allege that service of the complaint itself provides "Actual Knowledge of Infringement," which may form a basis for seeking enhanced damages for any post-filing infringement. (Compl. ¶¶14, 23).

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

  • A core issue will be one of evidentiary sufficiency: Given the complaint’s lack of specific factual allegations mapping product features to claim elements, a central question is what evidence Plaintiff will present to demonstrate that the accused products perform the specific "multivariate cost function" (’979 Patent) and "economic surplus/opportunity cost" optimization (’086 Patent) required by the claims.
  • A key legal question will be one of technological scope: Can the patent claims, rooted in the technical context of telephony and call center agent routing, be construed to read on the functionalities of a collaborative work management platform? The case will likely turn on whether assigning tasks or resources within a software application is legally and technically analogous to the claimed methods of routing communications and conducting auctions.