Emerald Lake Hills LLC v. Cloudera Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Emerald Lake Hills, LLC (California)
  • Defendant: Cloudera, Inc. (Delaware)
  • Plaintiff’s Counsel: Devlin Law Firm LLC
• Case Identification: 1:24-cv-00518, W.D. Tex., 05/15/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Cloudera has a regular and established place of business in Austin, along with significant customers in the district.
• Core Dispute: Plaintiff alleges that Defendant’s data platform products and services infringe a patent related to autonomic management of business activity data across networked domains.
• Technical Context: The technology concerns methods for synchronizing and integrating business intelligence data from disparate, distributed systems to provide a unified, real-time view for analysis and decision-making.
• Key Procedural History: The asserted patent claims priority back to a 2003 provisional application and is the result of a long prosecution history involving at least one parent patent and a continuation application.

Case Timeline

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

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

• Issued: April 25, 2023

The Invention Explained

• Problem Addressed: The patent addresses the problem of fragmented business intelligence, where data critical to understanding performance is scattered across multiple, specialized business entities and systems (’413 Patent, col. 1:22-38). This "splintering" makes it difficult to get a synchronized, real-time view of business activities, leading to a problem the patent terms "data parallax"—the incongruence of data from different sources viewed at different time indexes (’413 Patent, col. 7:13-17). The background also notes that prior "Grid" infrastructures were not well-suited to handle the interoperability and security challenges of integrating these disparate domains (Compl. ¶23-24).
• The Patented Solution: The invention proposes a system and method for "autonomic discrete business activity management" (DBAM) that uses a "Grid framework" to create a "universal business activity mosaic" (’413 Patent, Abstract; col. 3:35-4:18). This is achieved by a central engine that synchronously extracts, translates, and harmonizes business attribute data from multiple networked partner domains, creating a unified and time-synchronized view of business activities that is accessible to all participants (’413 Patent, col. 12:20-35; Fig. 16).
• Technical Importance: This approach aimed to overcome the limitations of scattered data by providing a mechanism for real-time, synchronized access to business intelligence, thereby enabling more effective management and "unprecedented gains in business productivity" (Compl. ¶9).

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, a Web Service Network, and one or more computer systems.
  • The Web Service Network is configured by a stateful and/or stateless method.
  • The networked domains are configured 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 in near real time or real time to establish a collective state.
  • The harmonized data is translated back to the context of each registered node reference.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are identified as the Cloudera Data Platform (including CDP Private Cloud and CDP Public Cloud) and a suite of related products and services such as Cloudera SDX, Cloudera Enterprise, Cloudera Data Engineering, Cloudera DataFlow, Cloudera Data Hub, Cloudera Unified Data Fabric, Cloudera Management Console, and Cloudera Data Mesh (Compl. ¶37). The complaint also notes that these products are offered through Amazon Web Services ("AWS") (Compl. ¶37).

Functionality and Market Context

The complaint alleges that the Accused Instrumentalities are used for large-scale data management, analytics, and machine learning, allowing organizations to manage and derive insights from data across hybrid, multi-cloud, and on-premises environments (Compl. ¶37, fns. 5-15). The core accused functionality appears to be the integration and processing of data from disparate sources to provide a unified data fabric or platform for business use (Compl. ¶37, fn. 11). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an "Exhibit 2" containing an exemplary infringement analysis of claim 1, but this exhibit was not filed with the complaint (Compl. ¶38). The following analysis is constructed from the narrative allegations.

’413 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The asserted claim requires a "Web Service Network." A central dispute may be whether Cloudera’s modern, hybrid cloud architecture, which integrates various data sources and services, constitutes a "Web Service Network" as that term is used in the patent, which describes the concept in the context of early 2000s technologies like the Globus Toolkit and Open Grid Service Architecture (OGSA) (’413 Patent, col. 1:48-62).
  • Technical Questions: A key technical question will be whether the Accused Instrumentalities perform the specific two-part harmonization process required by the claim: first, "assembling a harmonized attribute data...to establish a collective state," and second, "translating the harmonized attribute data back to a context of each Web Service Network node." The complaint provides general allegations about creating a unified view but lacks specific factual detail on this reverse-translation element.

V. Key Claim Terms for Construction

• The Term: "Web Service Network"

• Context and Importance: This term appears in the preamble and body of claim 1. Its construction is critical because it defines the environment in which the invention operates. Defendant may argue for a narrow construction tied to the specific "Grid" and "Web Services-Management Standard" technologies disclosed in the patent, while Plaintiff may argue for a broader meaning that covers modern cloud and data platform architectures.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims themselves do not explicitly limit the term to a specific standard. The glossary defines "Grid Technologies" broadly as resources that "support the sharing and coordinated use of diverse resources in dynamic, virtual organizations" (’413 Patent, col. 7:26-32), a description that could plausibly cover modern cloud environments.
  • Evidence for a Narrower Interpretation: The specification repeatedly and specifically links the invention to the "Grid" paradigm, the Open Grid Service Architecture (OGSA), and the Globus Toolkit (’413 Patent, col. 1:39-62; 46:31-47:11). Claim 11 explicitly recites that the network protocols are "based on the Web Services-Management Standard," which could be used to argue the general term "Web Service Network" in claim 1 should be interpreted in light of these specific disclosures.

• The Term: "harmonized by assembling a harmonized attribute data"

• Context and Importance: This phrase describes the core technical function of creating a unified data state. The dispute will likely focus on what level of synchronization, translation, and combination is required to meet this limitation. Practitioners may focus on this term because the specific method of "harmonizing" is what allegedly solves the "data parallax" problem.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes the goal as creating a "universal business activity mosaic" that is "viewable without data parallax by each participant" (’413 Patent, col. 3:53-56), suggesting any process that achieves this end result could suffice.
  • Evidence for a Narrower Interpretation: The detailed description outlines a specific multi-step process for synchronization, including setting an identical time index, extracting data, concatenating, integrating, and conditioning it using mathematical algorithms (’413 Patent, col. 13:58-14:65). A defendant may argue that "harmonized" requires these specific steps.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Cloudera infringes by "causing to be used" the Accused Instrumentalities, which suggests a claim for induced infringement (Compl. ¶37). The complaint also mentions that Cloudera offers its products through third-party resellers and on the AWS platform, which could be part of an inducement theory (Compl. ¶37, fns. 14, 16). However, the complaint does not plead specific facts showing that Cloudera possessed the requisite knowledge and specific intent for inducement.
• Willful Infringement: The prayer for relief requests treble damages and attorneys' fees, which are remedies for willful or exceptional cases (Compl., Prayer for Relief ¶C). The complaint, however, does not allege any facts supporting pre-suit knowledge of the ’413 patent, such as prior correspondence or knowledge of the patent family. The willfulness allegation appears to be based on post-suit conduct.

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

• A core issue will be one of definitional scope and technological evolution: Can the term "Web Service Network," which the patent specification grounds in early 2000s "Grid" computing standards like OGSA, be construed to read on the Defendant's modern, hybrid-cloud data platform architecture? The outcome of this question will likely determine whether the patent is relevant to the accused technology.
• A key evidentiary question will be one of functional mapping: What specific evidence can Plaintiff produce to demonstrate that the Accused Instrumentalities perform the full, two-step process recited in claim 1, particularly the final step of "translating the harmonized attribute data back to a context of each Web Service Network node"? The complaint's high-level allegations do not detail how the accused platform executes this specific reverse-translation function.