DCT
4:25-cv-05364
Veridoc Systems LLC v. Asite LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: VeriDoc Systems LLC (Wyoming)
- Defendant: Asite LLC (New York)
- Plaintiff’s Counsel: DNL Zito
- Case Identification: 4:25-cv-05364, S.D. Tex., 11/10/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Southern District of Texas because Defendant maintains a "regular and established place of business" in Houston and has allegedly committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Asite workspace platform, a document management and collaboration tool, infringes a patent related to methods for digitally verifying the authenticity of physical documents using a unique symbology linked to a central repository.
- Technical Context: The technology addresses version control and document fraud by linking a physical paper document to its authoritative digital counterpart via a scannable code, a critical function in industries like construction and legal services that rely on document integrity.
- Key Procedural History: The complaint notes that during the patent’s prosecution, the invention was distinguished from prior art that allegedly lacked the generation of a location-specific "symbology" to identify a document's unique location within a repository, suggesting this concept may be a focal point in claim construction.
Case Timeline
| Date | Event |
|---|---|
| 2016-12-07 | ’661 Patent Priority Date |
| 2020-10-27 | ’661 Patent Issue Date |
| 2025-11-10 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,814,661 - METHOD AND SYSTEM FOR VERIFYING AUTHENTICITY OF A DOCUMENT
- Patent Identification: U.S. Patent No. 10,814,661, "METHOD AND SYSTEM FOR VERIFYING AUTHENTICITY OF A DOCUMENT," issued October 27, 2020. (Compl. ¶9).
The Invention Explained
- Problem Addressed: The patent’s background section identifies the technical challenge of verifying the genuineness of important documents—such as medical prescriptions, legal contracts, or educational certificates—which are susceptible to being forged or tampered with before they can be processed. (’661 Patent, col. 1:27-49).
- The Patented Solution: The invention proposes a method where a document is first registered in a digital repository along with its key details. A unique "symbology" (e.g., a QR code) is generated that acts as an identifier for the document's specific location within that repository. This symbology is then associated with a physical copy of the document. To verify the physical copy, a user scans it, which uses the symbology to access the original document in the repository and allows for a comparison to determine its authenticity. (’661 Patent, Abstract; Fig. 3).
- Technical Importance: This method creates a verifiable link between a static physical document and its dynamic, authoritative digital version, addressing critical needs for version control and fraud prevention. (Compl. ¶11).
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶14).
- Claim 1 of the ’661 Patent recites the following essential elements for a method of verifying a document's authenticity:
- Registering a document in a repository by storing details (e.g., name, creator e-mail, creation date, image, signature).
- Generating a "symbology" for the document that serves as an identifier of its location in the repository.
- Associating the symbology with a physical copy of the document.
- Scanning the physical copy to generate a scanned image.
- Accessing the stored document and its details from the repository using the symbology present on the scanned image.
- Comparing the scanned image with the document stored in the repository to determine the authenticity of the physical copy.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant's "Asite workspace platform," which includes a "Document Manager" system. (Compl. ¶¶14-15).
Functionality and Market Context
- The Asite platform is alleged to be a document management system that provides a central repository for storing files and their attributes. (Compl. ¶16). It includes functionality for version control and allows users to generate and embed a unique QR code onto documents before they are printed. (Compl. ¶15, ¶17). When a user scans the QR code on a printed document with a mobile device, the system retrieves the corresponding online document to allow for verification of whether the physical copy is the "latest or superseded" version. (Compl. ¶15, ¶21). The complaint includes a visual depicting a user scanning a document with a QR code using a smartphone. (Compl. p. 6).
- The complaint alleges the platform creates a "comprehensive audit trail" and allows users to "publish Documents to a central repository," positioning it as a collaborative tool for managing document revisions and integrity. (Compl. p. 5, p. 14).
IV. Analysis of Infringement Allegations
10,814,661 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| registering, by a processor, a document in a repository by storing details related to the document... | The Asite platform provides a "central repository" where users can store documents and their associated attributes ("details"). | ¶16 | col. 10:22-29 |
| wherein the details comprise at least one of a name of the document, an e-mail of a creator..., date and time of creation..., an image of the document..., and a signature of the creator | The platform allegedly stores details including file name ("name of the document"), publish date ("date and time of creation"), and publisher name. A screenshot shows selectable attributes like "Doc Ref" and "Publish Date." | ¶16 | col. 10:25-29 |
| generating, by the processor, a symbology for the document, wherein the symbology is an identifier of the location of the repository... | The platform’s "Include QR code" feature allegedly generates a unique QR code ("a symbology") for a document, which is used to retrieve version details from storage and thus acts as an "identifier of the location of the repository." | ¶17 | col. 10:29-33 |
| associating, by the processor, the symbology with a physical copy of the document | Users can allegedly position the generated QR code on the document, then download and print it, thereby creating a physical copy with the associated symbology. A screenshot shows a user interface for positioning the QR code. | ¶18 | col. 10:33-35 |
| scanning, by the processor, the physical copy of the document to generate a scanned image | The system allegedly allows a user to scan the QR code on the printed document with a mobile device's camera, which the complaint asserts creates a "digital representation of the printed document." | ¶19 | col. 10:35-38 |
| accessing, by the processor, the document and the details... wherein the document is accessed using the symbology present on the scanned image | After scanning, the platform allegedly decodes the QR code to retrieve the corresponding document and its attributes from the repository for display to the user. | ¶20 | col. 10:35-40 |
| and comparing, by the processor, the scanned image with the document stored in the repository to determine the authenticity of the physical copy of the document... | The platform’s "version control" functionality allows users to verify if a printed document is the "latest or superseded," which the complaint alleges fulfills the "comparing" step to "determine authenticity." A screenshot highlights a "Compare versions" feature. | ¶21 | col. 10:40-44 |
- Identified Points of Contention:
- Scope Questions: The case may turn on whether the accused system's function of checking if a document is the "latest or superseded" version meets the claim requirement to "determine the authenticity of the physical copy." A dispute may arise over whether "authenticity" in the patent's context implies merely a version check or requires a more substantive verification against tampering or forgery.
- Technical Questions: A central question is whether the accused system performs the claimed step of "comparing... the scanned image with the document stored in the repository." The complaint alleges that the version control check fulfills this step, but also notes that the "comparison logic may be based on metadata." (Compl. ¶21). This raises the question of whether a metadata check triggered by a QR code scan constitutes the image-based comparison described in the patent.
V. Key Claim Terms for Construction
The Term: "comparing... the scanned image with the document stored in the repository"
- Context and Importance: This term is critical because it defines the mechanism for verification. The infringement dispute will likely focus on whether the accused system’s metadata-driven version check satisfies this limitation, or if a more direct, image-to-image comparison is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that the claim's purpose is to "determine the authenticity," and in a version-control context, comparing version numbers linked via a QR code achieves this purpose. The claim does not specify the method of comparison, leaving room for functional interpretations.
- Evidence for a Narrower Interpretation: The claim language explicitly recites comparing the "scanned image." The patent specification further supports a narrower reading by disclosing specific image-based comparison techniques, such as "pixel to pixel comparison, Optical Character Recognition (OCR), [and] keypoint matching." (’661 Patent, col. 6:10-12). Defendant may argue that a simple QR code lookup and metadata check does not involve a comparison of the "scanned image" itself.
The Term: "symbology"
- Context and Importance: The definition of this term is fundamental to the scope of the invention. Practitioners may focus on this term because the complaint highlights its importance during prosecution history, suggesting it was key to overcoming prior art. (Compl. ¶13).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification provides an explicit, broad definition, stating the symbology may be "at least one of an alphanumeric code, Quick Response (QR) code, barcode, and a hologram." (’661 Patent, col. 9:45-46; Claim 2).
- Evidence for a Narrower Interpretation: While the specification is broad, the primary embodiment and figures focus on a QR code. (’661 Patent, Fig. 2; col. 7:1-9). A party seeking a narrower construction might point to the repeated emphasis on QR codes in the detailed description as limiting the term's practical scope.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides the Asite workspace platform along with "online manuals describing how the Asite workspace platform can be operated" and instructs its customers to use the platform in a manner that allegedly infringes claim 1. (Compl. ¶22).
- Willful Infringement: The complaint does not include a formal count for willful infringement. However, it alleges that Defendant has had knowledge of the ’661 Patent and its alleged infringement "at least as of the filing of this lawsuit and service of the Complaint," which could form a basis for seeking enhanced damages for post-filing conduct. (Compl. ¶22).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical mechanism: Does the accused platform's process—which uses a scanned QR code to look up a document's version status in a database—satisfy the claim requirement of "comparing the scanned image with the document stored in the repository"? The case may depend on whether this metadata-level check is equivalent to the image-level comparison described in the patent.
- A second key question will be one of definitional scope: Can the claim term "determine the authenticity," as used in the patent, be construed to cover a version control check (i.e., confirming a document is the latest revision), or does it require a more stringent verification against alteration or forgery?