DCT

1:24-cv-00233

Emerald Lake Hills LLC v. Amazon Web Services Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-00233, W.D. Tex., 03/04/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because AWS maintains a regular and established place of business in the district, including offices in Austin, and employs over 3,000 people there.
  • Core Dispute: Plaintiff alleges that Defendant’s Amazon Web Services Marketplace infringes a patent related to methods for managing and synchronizing business activity data across networked domains.
  • Technical Context: The technology concerns distributed data management systems, specifically those designed to create a unified, real-time view of business activities (e.g., sales, inventory) among multiple, distinct commercial partners.
  • Key Procedural History: The asserted patent has a long prosecution history, originating from a provisional application filed in 2003. This extensive history, spanning multiple continuations and divisional applications, may be relevant for claim construction and prosecution history estoppel arguments.

Case Timeline

Date Event
2003-06-23 '413 Patent Priority Date
2012-04-19 AWS Marketplace Launch Date (Accused Product)
2023-04-25 U.S. Patent No. 11,636,413 Issues
2024-03-04 Complaint Filed

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

U.S. Patent No. 11,636,413 - "Autonomic Discrete Business Activity Management Method"

  • Patent Identification: U.S. Patent No. 11,636,413, "Autonomic Discrete Business Activity Management Method", issued April 25, 2023.

The Invention Explained

  • Problem Addressed: The patent describes a business environment where specialization and division of labor have fragmented critical business intelligence across different companies and systems ('413 Patent, col. 1:24-34). This fragmentation creates inefficiencies and a problem termed "data parallax," where different entities have incongruent views of the same business attribute (e.g., product inventory) because their data is not synchronized in time ('413 Patent, col. 7:12-17).
  • The Patented Solution: The invention proposes a system built on a "Grid" framework featuring a central "Discrete Business Activity Management (DBAM) engine" ('413 Patent, col. 3:35-43). This engine synchronously extracts, translates, and harmonizes business data from multiple "partner business networked domains" to create a single, unified "universal business activity mosaic" ('413 Patent, Abstract; Fig. 1). This mosaic provides a real-time, shared view of business activities, eliminating data parallax and enabling automated, or "autonomic," management functions across the entire network ('413 Patent, col. 12:12-24, Fig. 16).
  • Technical Importance: The technology purports to enable unprecedented levels of integration and automation in supply chain and partnership management, allowing for more efficient operations and the creation of new service paradigms like "Buy on Demand" and "Zero Cash Cycle" ('413 Patent, col. 4:5-8).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and reserves the right to assert additional claims (Compl. ¶38).
  • Independent Claim 1 recites a system for managing attribute data across partner domains, comprising:
    • A DBAM processing node.
    • A plurality of networked domains.
    • A Web Service Network.
    • Computer systems coupling the foregoing elements.
    • A requirement that the Web Service Network is configured by a stateful and/or stateless method.
    • A requirement that the networked domains translate transient attribute data between domains under the direction of the DBAM node.
    • A requirement that each Web Service Network node is harmonized by assembling data in near real-time to establish a "collective state" and then translating that harmonized data back to the context of each node.

III. The Accused Instrumentality

Product Identification

  • The Amazon Web Services Marketplace (the "AWS Marketplace") (Compl. ¶37).

Functionality and Market Context

  • The complaint describes the AWS Marketplace as an "online store" and a "platform for buying and selling software and services configured for cloud operation" (Compl. ¶37). It functions as an intermediary connecting third-party software vendors with AWS customers.
  • The complaint does not provide sufficient detail for analysis of the specific data handling, translation, or synchronization mechanisms employed by the AWS Marketplace.

IV. Analysis of Infringement Allegations

The complaint references an "Exhibit 2" containing an exemplary infringement analysis for claim 1, but this exhibit was not attached to the publicly filed document (Compl. ¶38). The complaint's narrative allegations are conclusory, stating only that the AWS Marketplace infringes one or more claims (Compl. ¶37). Without the specific mappings from the exhibit, a detailed element-by-element analysis is not possible based on the provided documents. No probative visual evidence provided in complaint.

  • Identified Points of Contention: Based on the claim language and the nature of the accused product, the infringement dispute may center on several key technical and legal questions:
    • Scope Questions: A primary issue will concern whether the relationship between AWS (as the platform operator), third-party software vendors, and end customers constitutes the "partner business networked domains" as that term is used in the patent. The defense may argue that the patent's specification, which provides examples like manufacturing and finance partners ('413 Patent, Fig. 18), implies a scope limited to operational supply chains, thereby excluding a transactional software marketplace.
    • Technical Questions: The analysis will likely turn on what evidence is produced regarding the AWS Marketplace's internal data architecture. A key factual question is whether the platform performs the specific function of harmonizing data from all participants in "near real time" to establish a "collective state," as required by Claim 1. The court will need to determine if the standard functions of a marketplace (e.g., displaying listings, processing payments) meet this specific technical requirement for deep-level data synchronization aimed at solving "data parallax" ('413 Patent, col. 7:12-17).

V. Key Claim Terms for Construction

  • The Term: "partner business networked domains"

    • Context and Importance: This term is foundational to the claim's scope and central to the dispute. Its construction will determine whether the patent's claims can read on a cloud marketplace architecture or are confined to more traditional, integrated supply chains. Practitioners may focus on this term because the applicability of the patent to the accused AWS Marketplace hinges almost entirely on its definition.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself is broad. Plaintiff may argue that any network of commercially transacting entities (like AWS, its vendors, and their customers) falls within the plain meaning of "partner business networked domains."
      • Evidence for a Narrower Interpretation: The specification repeatedly provides examples related to operational management, such as manufacturing, finance, logistics, and trading partners ('413 Patent, Fig. 18; col. 1:12-23). The defense may argue these embodiments limit the term to entities engaged in a collaborative production or supply process, not just a sales platform.

  • The Term: "harmonized by assembling a harmonized attribute data ... to establish a collective state"

    • Context and Importance: This term defines the core technical function of the invention. The infringement question will depend on whether the data processing within the AWS Marketplace rises to the level of creating a "harmonized" and "collective state."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Plaintiff could argue that any system that gathers data from multiple sources and presents it in a unified interface (like a marketplace storefront) is "harmonizing" data to create a "collective state" for the user.
      • Evidence for a Narrower Interpretation: The patent defines the purpose of harmonization as solving "data parallax"—the "incongruence between two or more entities' translated attribute states for the same attribute at different time indexes" ('413 Patent, col. 7:12-17). The defense may argue this requires a specific, active process of synchronizing and translating underlying proprietary datasets between partners, not merely aggregating and displaying public-facing information like product prices and descriptions.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that AWS is "causing to be used" the accused products, which suggests a theory of induced infringement (Compl. ¶37). This is likely premised on AWS providing the Marketplace platform and encouraging or instructing vendors and customers to use it in a way that allegedly infringes. However, the complaint does not plead the specific elements of knowledge and intent required for an inducement claim.
  • Willful Infringement: The complaint makes no allegations of pre-suit knowledge of the '413 patent. The prayer for relief seeks a finding of an exceptional case and treble damages, remedies associated with willfulness, but the complaint body does not currently provide a factual basis to support such a finding beyond the notice provided by the lawsuit itself (Compl. p. 11).

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

  • A core issue will be one of definitional scope: can the term "partner business networked domains," which is described in the patent with examples from operational supply chains, be construed to cover the transactional relationships between a platform operator (AWS), third-party vendors, and customers in a cloud software marketplace?
  • A key evidentiary question will be one of technical function: what level of data synchronization and translation does the AWS Marketplace actually perform? Does its operation meet the specific claim requirement of creating a "harmonized... collective state" in real-time to solve "data parallax," or is there a fundamental mismatch between the platform's function and the patent's claimed solution?
  • A third question will be one of timing and relevance: given that the patent’s priority date is 2003 and the accused marketplace launched in 2012, the case may explore whether the patent, rooted in the "Grid computing" paradigm of the early 2000s, is truly directed to the type of cloud marketplace architecture that emerged nearly a decade later.