Emerald Lake Hills LLC v. Arista Networks Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Emerald Lake Hills, LLC (California)
  • Defendant: Arista Networks, Inc. (Delaware)
  • Plaintiff’s Counsel: Devlin Law Firm LLC
• Case Identification: 1:24-cv-00517, W.D. Tex., 05/15/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Arista maintains a regular and established place of business in the district, specifically a Research and Development office in Austin.
• Core Dispute: Plaintiff alleges that Defendant’s network operating systems and cloud management platforms infringe a patent related to methods for managing and synchronizing business activity data across different networked entities.
• Technical Context: The technology addresses the challenge of creating a unified, real-time view of business operations that span multiple, independent commercial partners by harmonizing data across their disparate systems.
• Key Procedural History: The complaint indicates that Plaintiff is the assignee of the patent-in-suit. No other significant procedural events, such as prior litigation or post-grant proceedings involving the patent, are mentioned in the complaint.

Case Timeline

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, titled “Autonomic Discrete Business Activity Management Method,” issued on April 25, 2023 (the “'413 Patent”).

The Invention Explained

• Problem Addressed: The patent describes a key limitation in modern business: as processes become specialized across different companies, critical business intelligence becomes "splintered" and firewalled within each entity, making it difficult to achieve greater operating efficiencies (Compl. ¶15; ’413 Patent, col. 1:23-39). This can lead to "data parallax," where different entities have incongruent views of the same business attribute because their data is not synchronized in time (Compl. ¶16).
• The Patented Solution: The invention proposes a system built on a "Grid" or similar network architecture to create a "universal business activity mosaic" (’413 Patent, Abstract). This is achieved by a central "DBAM engine" that synchronously extracts, translates, and harmonizes business data from multiple partner domains. This process creates a unified, time-indexed, and universally viewable representation of business activities, eliminating data parallax and enabling more efficient, autonomic management of business processes (Compl. ¶9; ’413 Patent, col. 5:7-34). Figure 1 of the patent illustrates the core logic of this engine, showing the cycle of data extraction, synchronization, and translation across subscribers (’413 Patent, Fig. 1).
• Technical Importance: The technology aimed to overcome the fragmentation of business data in complex, multi-enterprise environments (e.g., supply chains) by providing a method for creating a single, trusted, real-time view of operations across all partners (Compl. ¶10-11).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶39).
• The essential elements of independent claim 1 include:
  • A system with a DBAM processing node, a plurality of networked domains, and a Web Service Network.
  • The DBAM processing node directs each networked domain to translate transient attribute data from a first domain to a second domain.
  • Each Web Service Network node is harmonized by assembling harmonized attribute data between nodes in near real time or real time to establish a collective state.
  • The system translates the harmonized attribute data back to the context of each Web Service Network node.
• The complaint does not explicitly reserve the right to assert dependent claims, but focuses its exemplary allegations on claim 1 (Compl. ¶38).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Accused Instrumentalities" as the Arista Extensible Operating System (“EOS”), Arista CloudEOS, Arista CloudVision, Arista NetDB, and Arista NDR (Compl. ¶37). It is also alleged that these are offered as services through Amazon Web Services (“AWS”) (Compl. ¶37).

Functionality and Market Context

• The complaint does not provide a detailed technical description of how the Accused Instrumentalities operate. It broadly characterizes them as products and services for network operations and management (Compl. ¶37).
• The complaint alleges that these products and services are used in a manner that performs the functions claimed in the ’413 Patent, such as managing and synchronizing data across networked systems (Compl. ¶37).
• The complaint asserts that the patented invention provides significant commercial value for companies like Arista, suggesting the accused functionalities are important to Arista’s business, but provides no specific market data (Compl. ¶21). The complaint references the patent’s Figure 16, which depicts a multi-layered ‘Universal Business Activity Mosaic’ being synchronously created from underlying subscriber and source data frames, to allege that the invention supports autonomic business functions (Compl. ¶20).

IV. Analysis of Infringement Allegations

The complaint references an Exhibit 2 containing exemplary infringement analyses for claim 1; however, this exhibit was not attached to the publicly filed complaint (Compl. ¶38). The complaint's narrative infringement theory alleges that Arista's products and services, including its network operating systems and cloud management platforms, perform the steps of the claimed method for managing and synchronizing data across networked domains (Compl. ¶37). Without the claim chart exhibit, the specific mapping of product features to claim elements is not detailed in the provided document. The core of the allegation is that the Accused Instrumentalities are used to create a harmonized view of data across a network, thereby infringing the patented method.

Identified Points of Contention

• Scope Questions: A primary question may be whether the operations of Arista's network infrastructure products (e.g., EOS, CloudVision) constitute the "autonomic discrete business activity management" described and claimed in the patent. The defense may argue that the patent is directed to a specific business process management method in a commercial or supply-chain context, while the accused products are general-purpose networking tools that do not perform the claimed "business activity" management (’413 Patent, col. 1:8-12).
• Technical Questions: The infringement analysis will turn on whether the accused systems perform the specific steps of claim 1. This raises the question of whether Arista's architecture includes a "DBAM processing node" that "translates" data to establish a "collective state" and then translates it "back to a context of each Web Service Network node" as claimed (’413 Patent, col. 49:17-30). Evidence will be needed to show not just data transfer, but the specific harmonization, state establishment, and reverse-contextualization process recited in the claim.

V. Key Claim Terms for Construction

• Term: "DBAM processing node"

  • Context and Importance: This term appears to define the central architectural component of the claimed system. Its construction will be critical to determining whether Arista's potentially distributed network architecture includes a structure that meets this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests a functional definition, referring to a "DBAM engine or a functionally equivalent agent," which could support an argument that the "node" is a logical role rather than a single physical device (’413 Patent, col. 3:26-28).
    • Evidence for a Narrower Interpretation: Figures in the patent, such as Figure 14, depict a distinct "DBAM Grid Svcs Host and Admin Domain," which could be argued to support a more centralized and structurally defined "node" as opposed to a purely functional, distributed concept (’413 Patent, Fig. 14).

• Term: "harmonized attribute data"

  • Context and Importance: This term defines the output of the core process of the invention. Whether Arista's products create "harmonized attribute data" will be a central point of the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue this term simply means data that has been synchronized in time and put into a common format, without regard to its specific content.
    • Evidence for a Narrower Interpretation: The patent's glossary defines "Translate" as a process where attributes from different domains are converted to "have consistent meaning" (’413 Patent, col. 6:62-col. 7:2). This suggests harmonization requires more than just technical synchronization; it may require a semantic reconciliation of business-level data to resolve contextual differences between partner domains.

VI. Other Allegations

Indirect Infringement

• The complaint alleges that Arista is "providing and causing to be used" the accused products, which is language associated with induced infringement (Compl. ¶37). However, the complaint does not plead specific facts to support the requisite knowledge and intent for an indirect infringement claim, such as citing user manuals or marketing materials that instruct customers to perform the infringing acts.

Willful Infringement

• The complaint does not contain a specific count for willful infringement or allege any facts related to pre-suit knowledge of the patent by Arista. However, the prayer for relief seeks a declaration that the case is exceptional and an award of treble damages, which are remedies associated with a finding of willfulness (Compl. p. 11, ¶C).

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

• A central issue will be one of definitional scope: can the patent's claims, which are rooted in the language of "business activity management" and commercial data harmonization, be construed to cover the technical functions of general-purpose network operating systems and cloud management platforms?
• A key evidentiary question will be one of technical mapping: what proof will be offered to demonstrate that the accused Arista products perform the specific, multi-step data transformation process of claim 1, particularly the creation of a "collective state" through data harmonization and the subsequent "translation" of that data back into the context of individual network nodes?
• The outcome will likely depend heavily on claim construction: the dispute may turn on whether key terms like "DBAM processing node" are interpreted functionally or as specific architectural components, and whether "harmonized attribute data" requires semantic business-level reconciliation or merely technical data synchronization.