Complaint

Complaint Analysis

Prosecution History analysis

Examiner Search analysis

Invalidity Framework analysis

## I. Executive Summary and Procedural Information

*   **Case Name:** *DatRec, LLC v. UKG, Inc.*
*   **Parties & Counsel:**
    *   **Plaintiff:** [DatRec, LLC](https://ai-lab.exparte.com/party/datrec-llc) (Texas)
    *   **Defendant:** [UKG, Inc.](https://ai-lab.exparte.com/party/ukg-inc) (Delaware)
    *   **Plaintiff’s Counsel:** [Ramey LLP](https://ai-lab.exparte.com/law-firm/103247)
*   **Case Identification:** [3:25-cv-01886](https://ai-lab.exparte.com/case/dct/txnd/3:25-cv-01886), N.D. Tex., 07/18/2025
*   **Venue Allegations:** Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the Northern District of Texas and has committed the alleged acts of infringement within the district.
*   **Core Dispute:** Plaintiff alleges that Defendant’s "OrangeHRM Mobile App" infringes a patent related to methods for verifying user identity to enable secure communication over a public network.
*   **Technical Context:** The technology addresses the problem of unverified or falsely-identified parties in online communications by creating a system to authenticate user identities based on crowd-sourced data.
*   **Key Procedural History:** Plaintiff states it is a non-practicing entity that has never sold a product practicing the patent. The complaint notes that Plaintiff and its predecessors have entered into settlement licenses with other entities, but alleges none of these licenses were for the production of a patented article, a fact relevant to potential defenses based on patent marking requirements.

#### Case Timeline

| **Date** | **Event** |
| :--- | :--- |
| 2006-12-07 | [’309](https://ai-lab.exparte.com/patent/8381309) Patent Priority Date |
| 2013-02-19 | ’309 Patent Issue Date |
| 2025-07-18 | Complaint Filing Date |

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

### U.S. Patent No. 8,381,309 - *“Method and System for Secure Communication Over a Public Network”*
*   **Issued:** February 19, 2013

#### The Invention Explained
*   **Problem Addressed:** The patent identifies a need for greater security in online communications, where individuals are often "exposed to non-secure connections and to communications from unreliable or falsely-identified senders" (’309 Patent, col. 1:21-25).
*   **The Patented Solution:** The invention describes a method to improve confidence in a user's identity by creating a database of verified information. The system permits multiple users to input "individual-associated data bits" (IDBs), which include personal details and "relationship data" for themselves and others. By comparing the data entered by different users about the same individual, the system determines a "level of reliability" for that individual's identity and uses this verification to define permitted levels of communication over the network. (’309 Patent, Abstract; col. 2:26-40). The core concept relies on cross-referencing information from multiple sources to authenticate an identity (’309 Patent, Fig. 3A).
*   **Technical Importance:** This approach seeks to solve the foundational challenge of establishing trust online by creating a system to improve "confidence in the identity of a party to an electronic communication" (’309 Patent, col. 1:63-65).

#### Key Claims at a Glance
*   The complaint asserts independent claim 1 and dependent claims 2-17 (Compl. ¶9).
*   The essential elements of independent claim 1 include:
    *   (a) providing a database with verified data to authenticate an individual's identity, which is constructed by:
        *   permitting multiple individuals related to the subject individual to enter data, where the data is an "individual-associated data bit" (IDB) comprising a personal identifier and "relationship data indicative of a family tree";
        *   generating an "individual-associated data set" (IDS) from the IDB;
        *   verifying the IDS by "determining the level of reliability based on a degree of similarity between data on the individual entered by different individuals"; and
    *   (b) compiling the IDSs to build the database and defining permitted communication levels based on the verification.

## III. The Accused Instrumentality

### Product Identification
*   Defendant’s "OrangeHRM Mobile App" product (Compl. ¶10).

### Functionality and Market Context
*   The complaint alleges the accused product is a "system and method for secure communication over a public network" (Compl. ¶9). It is marketed via Defendant's websites, which suggest its use for people management within an organization (Compl. ¶12). The complaint does not provide sufficient detail for analysis of the specific technical operations of the app beyond these general characterizations.

No probative visual evidence provided in complaint.

## IV. Analysis of Infringement Allegations

The complaint references a preliminary claim chart in "Exhibit B" but does not include the exhibit in the filing (Compl. ¶10). The infringement theory is therefore based on the narrative allegations in the complaint. Plaintiff alleges that Defendant's "OrangeHRM Mobile App" constitutes a "system and method for secure communication over a public network" that directly infringes one or more of claims 1-17 of the ’309 patent (Compl. ¶9). The complaint does not, however, map specific features of the accused app to the discrete limitations of the asserted claims.

### Identified Points of Contention
*   **Scope Questions:** The patent's claims and specification repeatedly use the term "family tree" to describe the relationship data used for verification. A central question may be whether the organizational hierarchies and employee relationships managed within an HR application like the accused "OrangeHRM Mobile App" fall within the scope of "relationship data indicative of a family tree" as recited in the claim.
*   **Technical Questions:** Claim 1 requires a specific verification mechanism: "determining the level of reliability based on a degree of similarity between data on the individual entered by different individuals." A key factual question for the court will be whether the "OrangeHRM Mobile App" performs this type of crowd-sourced, comparison-based identity verification, or if it uses a more conventional security architecture (e.g., administrator-provisioned credentials) that does not meet this claim limitation.

## V. Key Claim Terms for Construction

### The Term: "relationship data indicative of a family tree"
*   **Context and Importance:** The definition of this term is critical, as it may determine whether the patent's verification method applies to the corporate environment of the accused product. Practitioners may focus on this term because the infringement theory appears to depend on extending a concept rooted in social and familial connections to a business context.
*   **Intrinsic Evidence for Interpretation:**
    *   **Evidence for a Broader Interpretation:** The specification defines "relationship data" to potentially include "friends, acquaintances, neighbors, business colleagues or associates," suggesting the concept is not strictly limited to genealogy (’309 Patent, col. 5:48-53).
    *   **Evidence for a Narrower Interpretation:** The patent’s primary examples focus on "first degree family members (parents, brothers and sisters, spouse, children)" and other relatives, and the term "family tree" itself has a strong connotation of kinship that could support a more limited definition (’309 Patent, col. 5:41-48).

### The Term: "determining the level of reliability based on a degree of similarity between data... entered by different individuals"
*   **Context and Importance:** This phrase describes the core technical step of the claimed invention. The dispute will likely turn on whether the accused product’s security model performs this specific function.
*   **Intrinsic Evidence for Interpretation:**
    *   **Evidence for a Broader Interpretation:** The specification describes the concept generally as determining authenticity based on "correspondence between data on the individual entered by different users," which could be argued to cover any system that cross-references data from multiple sources (’309 Patent, col. 4:4-6).
    *   **Evidence for a Narrower Interpretation:** The patent discloses specific methods for this determination, including calculating a "relative reliability R of more than 8 out of 10" and assigning numerical scores to data fields, which could support a narrower construction requiring a quantitative, comparison-based scoring algorithm (’309 Patent, col. 10:55-58; Fig. 5B).

## VI. Other Allegations

### Indirect Infringement
*   The complaint alleges inducement by asserting that Defendant instructs its customers on how to use the accused app for secure communication through its "website and product instruction manuals" (Compl. ¶¶11-12). It alleges contributory infringement by claiming the product is not a staple commercial good and its only reasonable use is an infringing one (Compl. ¶12).

### Willful Infringement
*   Willfulness is alleged based on Defendant’s knowledge of the ’309 patent from "at least the filing date of the lawsuit" (Compl. ¶11, 12). Plaintiff reserves the right to amend the complaint if pre-suit knowledge is found in discovery (Compl. ¶11 n.1).

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

*   A core issue will be one of **definitional scope:** can the term "relationship data indicative of a family tree," which is described in the patent with examples of familial and social connections, be construed to cover the organizational and reporting structures within a corporate human resources application?
*   A key evidentiary question will be one of **technical mechanism:** what evidence will show that the accused "OrangeHRM Mobile App" performs the specific verification method of Claim 1—namely, determining reliability by comparing data on a person entered by different individuals—as opposed to employing a conventional, non-infringing security model?

Technical scope clash: UKG's OrangeHRM Mobile App faces suit over whether its org chart is a `relationship data indicative of a family tree` for ID verification.

3:25-cv-01886

DatRec LLC v. UKG Inc