Web 20 Tech LLC v. Methodist Hospital Hill Country

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Web 2.0 Technologies, LLC (Texas) and Pennar Software Corporation (Virginia)
  • Defendant: Methodist Hospital Hill Country (Texas)
  • Plaintiff’s Counsel: DEVLIN LAW FIRM LLC
• Case Identification: 1:25-cv-00292, W.D. Tex., 02/26/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant having a regular and established place of business in the Western District of Texas where acts of infringement have purportedly occurred.
• Core Dispute: Plaintiffs allege that Defendant’s Electronic Health Record (EHR) systems, implemented to comply with federal "Meaningful Use" standards, infringe a patent related to an online repository for securely storing and disbursing personal information.
• Technical Context: The technology resides in the field of electronic health records and data management, where secure, interoperable, and user-controlled access to sensitive personal information is a key market and regulatory requirement.
• Key Procedural History: The asserted patent claims a priority date tracing back to an application filed in 2000, predating the HITECH Act of 2009, which established the "Meaningful Use" standards at the center of the infringement allegations. The complaint does not mention any prior litigation or post-grant proceedings involving the patent.

Case Timeline

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

U.S. Patent No. 9,465,913 - Online Repository for Personal Information

The Invention Explained

• Problem Addressed: The patent’s background section describes the inefficiency and annoyance for users who must repeatedly provide personal information to various online entities (e.g., news sites, software providers, e-commerce stores) via lengthy forms. It also notes the lack of a centralized method for a user to store this information once and selectively authorize its distribution. (’913 Patent, col. 1:29-47).
• The Patented Solution: The invention proposes a method and system where a central server computer acts as a trusted repository for a user's personal information. This information is broken down into discrete "information objects," each of which can be assigned a different security level by the user. When a third party requests information, the system verifies the requester's authorization and releases only the specific information objects permitted by the user's settings. The architecture involves a user, a requester, and a central server communicating over a network. (’913 Patent, Abstract; Fig. 1).
• Technical Importance: The technology addresses the foundational challenge of managing digital identity and personal data by providing a framework for user-centric, granular control over the dissemination of private information to third parties. (’913 Patent, col. 2:4-12).

Key Claims at a Glance

• The complaint asserts independent Claim 1. (Compl. ¶26).
• The essential elements of independent Claim 1 are:
  • A computer-implemented method for accessing a patient's personal health record (PHR) in an online repository.
  • Establishing an account for a patient on a server computer with an associated data storage area.
  • Receiving and storing the patient's personal health information, thereby creating a PHR.
  • Associating "patient-established control settings" with the PHR, where the settings are "configurable by the patient" to "restrict access" to "one or more designated requesters."
  • Receiving an access request from a "designated requester" via a second computer.
  • Verifying authorization information from the requester.
  • Selecting and sending a portion of the PHR to the requester in accord with the control settings.
  • Recording every access of the patient's PHR.
  • Enabling access in a medical emergency.
  • Receiving and storing updates to the PHR from an authorized party.
  • Automatically notifying the patient via an electronic message if the PHR is changed.
• The complaint reserves the right to assert additional claims. (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are identified as "customized EHR systems, platforms, and/or services" used by Defendant that "comply with the Meaningful Use ('MU') standards and CEHRT as prescribed in the HITECH Act." (Compl. ¶8).

Functionality and Market Context

• The complaint alleges these EHR systems are used for core healthcare functions like "issuing electronic prescriptions and for the exchange of electronic health information to improve quality of care." (Compl. ¶11). The central allegation is that the act of complying with federal MU and Certified EHR Technology (CEHRT) standards constitutes use of the infringing technology. (Compl. ¶9, ¶16).
• The complaint alleges that by using these systems to comply with federal mandates, the Defendant obtained financial incentives and avoided penalties, establishing the commercial importance of the accused functionality. (Compl. ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit 2, but the exhibit was not attached to the publicly filed document. (Compl. ¶28). The narrative infringement theory is summarized below.

The complaint’s infringement theory asserts that Defendant’s use of EHR systems that are certified to comply with federal "Meaningful Use" (MU) and Certified EHR Technology (CEHRT) standards directly infringes, either literally or under the doctrine of equivalents, at least Claim 1 of the ’913 Patent. (Compl. ¶9, ¶26). The core of the allegation is that the functionalities mandated by the HITECH Act—such as capturing, sharing, and using electronic health information to improve care—inherently practice the patented method of storing and selectively disbursing personal health information from a central repository under a set of access controls. (Compl. ¶11, ¶16). The complaint states that each element of Claim 1 is present in the Accused Instrumentalities but provides no specific factual allegations tying the operation of Defendant's systems to the claim limitations, other than the general allegation of standards-compliance. (Compl. ¶28-29).

Identified Points of Contention

• Technical Questions: What specific components or processes within Defendant's EHR systems correspond to the "patient-established control settings" of Claim 1? The complaint does not specify how a patient directly configures access restrictions on the hospital's system, a key requirement of the claim.
• Scope Questions: Can the act of "complying with the MU standards" serve as a wholesale substitute for a limitation-by-limitation analysis of infringement? A central dispute may be whether the Defendant's specific implementation of its EHR system, even if certified, actually meets every element of the claim, particularly the requirement for controls to be "patient-established" and "configurable by the patient."

V. Key Claim Terms for Construction

The Term: "patient-established control settings"

Context and Importance

This term appears central to the dispute. The infringement case may depend on whether the access rules for Defendant's EHR system are "established" and "configurable" by the patient, as the claim requires, or if they are primarily controlled by the healthcare provider (the Defendant) in accordance with internal policies and external regulations like HIPAA. Practitioners may focus on this term because the complaint accuses a hospital's system, where provider-centric controls are common, of infringing a claim that appears to describe a patient-centric control model.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification discusses a user choosing the "number of security classifications" and "the nature of the information objects stored," which could be argued to encompass any system where patient preferences are taken into account, even if indirectly. (’913 Patent, col. 10:33-38).
• Evidence for a Narrower Interpretation: The claim language "configurable by the patient via the first client computer" suggests direct, interactive control by the patient. (’913 Patent, col. 15:11-12). The specification reinforces this by describing a user directly accessing a website to set up an account and enter information, supporting a narrower construction requiring direct patient interaction with the configuration interface. (’913 Patent, col. 8:41-56; Fig. 3).

The Term: "designated requester"

Context and Importance

The claim requires that an access request come from a "designated requester" and that the "patient-established control settings" restrict access to such requesters. The meaning of "designated" will be critical in determining what type of authorization satisfies this limitation.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification mentions notifying a "list of authorized recipients automatically," which might support a flexible definition of who is "designated." (’913 Patent, col. 9:25-27).
• Evidence for a Narrower Interpretation: The claim links the "designated requester" directly to the "patient-established control settings." This suggests that a requester must be affirmatively identified within the control settings established by the patient, rather than being an entity that receives ad-hoc authorization at the time of a request. (’913 Patent, col. 15:14-16).

VI. Other Allegations

Indirect Infringement

The complaint does not plead a count for indirect infringement (inducement or contributory infringement) or allege facts to support the requisite knowledge and intent. The sole count is for direct infringement under 35 U.S.C. § 271(a). (Compl. ¶26).

Willful Infringement

The complaint does not allege willful infringement or plead facts indicating that Defendant had pre- or post-suit knowledge of the patent and infringed despite a risk of infringement. The Prayer for Relief includes a request for a finding that the case is "exceptional" to recover attorneys' fees under 35 U.S.C. § 285, which is a related but distinct legal standard. (Compl., Prayer for Relief ¶C).

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

• A core issue will be one of factual and technical correspondence: can Plaintiffs prove that the Defendant's hospital-operated EHR system, which functions within the provider-controlled and HIPAA-regulated healthcare environment, actually practices the specific, patient-centric method of Claim 1? The case may turn on whether the system’s access controls can be fairly characterized as "patient-established" and "configurable by the patient."
• A key evidentiary question will be whether the general allegation of "compliance with Meaningful Use standards" is sufficient to demonstrate infringement. The court will likely require Plaintiffs to produce specific evidence from the accused system's architecture and operation that maps directly to each limitation of the asserted claim, moving beyond the high-level theory presented in the complaint.