DCT
1:26-cv-00010
Atomic IP LLC v. Sumo Logic Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Atomic IP LLC (Texas)
- Defendant: Sumo Logic, Inc. (Delaware)
- Plaintiff’s Counsel: BRADFORD BLACK P.C.
- Case Identification: 1:26-cv-00010, W.D. Tex., 01/05/2026
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the Western District of Texas, specifically an office in Austin.
- Core Dispute: Plaintiff alleges that Defendant’s cloud-native monitoring and observability platform, specifically its web-based dashboarding features, infringes a patent related to the server-side generation and delivery of customizable display "widgets."
- Technical Context: The dispute centers on the architecture for creating and displaying dynamic data visualizations within a web browser, a core technology for modern business intelligence, analytics, and IT monitoring platforms.
- Key Procedural History: The complaint alleges that Defendant has been on notice of the patent-in-suit since at least October 6, 2025, via a letter from Plaintiff, a fact which forms the basis for the willfulness allegation.
Case Timeline
| Date | Event |
|---|---|
| 2005-08-12 | ’869 Patent Priority Date |
| 2014-12-30 | ’869 Patent Issue Date |
| 2025-10-06 | Alleged pre-suit notice of infringement via letter |
| 2026-01-05 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,924,869 - "Service for Generation of Customizable Display Widgets"
- Patent Identification: U.S. Patent No. 8,924,869, "Service for Generation of Customizable Display Widgets," issued December 30, 2014 (the "’869 Patent").
The Invention Explained
- Problem Addressed: The patent addresses the challenge of presenting an increasing volume of computer-accessible data in a "visually compelling manner," noting that purely text-based or numerical information was becoming less effective in an "image-focused society" (Compl. ¶13; ’869 Patent, col. 1:43-62).
- The Patented Solution: The invention describes a server-based system for defining and delivering customizable visual elements, or "widgets," to a client device like a web browser. The system stores defining data for a widget, which includes a "base image component," user-defined alphanumeric data, and real-time data. A server-side "generation module" combines these data sources to generate the final visual element, which is then sent to the client in response to a request. This architecture is designed to avoid the need to install specialized software on the client device (’869 Patent, Abstract; col. 3:29-39).
- Technical Importance: The described web-services model for delivering dynamic, data-driven content was a key enabler for the development of rich internet applications that could provide sophisticated visualizations without relying on client-side plugins or installations (Compl. ¶8; ’869 Patent, col. 3:13-24).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2, 9, and 25 (Compl. ¶31).
- Independent Claim 1 of the ’869 Patent recites the following essential elements for a "widget service system":
- A data storage system configured to store visual element defining data, which comprises (i) image data with a base image component, (ii) user-defined alphanumeric data, and (iii) real-time data.
- A client definition interface for receiving user selections of the data to be associated with the visual element.
- A generation module configured to generate the visual element based on the user-selected data.
- A network interface module to receive requests and send the generated visual element to the client.
- The system must be operative to deliver the visual element independent of the client device's operating system.
- The complaint reserves the right to assert additional claims (Compl. ¶31).
III. The Accused Instrumentality
Product Identification
- The "Sumo Logic cloud-native monitoring and observability platform," and specifically its "web-based dashboards and dashboard panels/visualizations" and related functionalities (the "Sumo Logic Platform") (Compl. ¶17).
Functionality and Market Context
- The complaint alleges the Sumo Logic Platform allows users to create, configure, and view dashboards composed of various "panels" or visualizations (Compl. ¶18). These panels are described as user-modifiable visual elements delivered through a web browser interface.
- The platform allegedly stores the definitions for these dashboards and panels, which can be exported in a JSON format (Compl. ¶19). A screenshot from Sumo Logic's documentation shows a "Library" where users' saved dashboards are stored (Compl. p. 7).
- Functionality is alleged to include combining different data types, such as using a base map image and overlaying it with graphical data points in "Map Charts" (Compl. ¶20), allowing user-entered text in "Text Panels" (Compl. ¶21), and displaying "real-time" or "live" telemetry data that can be automatically refreshed (Compl. ¶22).
IV. Analysis of Infringement Allegations
’869 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a data storage system comprising a computer processor configured to store visual element defining data... the data comprising: image data including a base image component... user-defined data including alphanumeric data... and real-time data... | The Sumo Logic Platform allegedly stores dashboard and panel definition data, which can be exported as JSON. This data is alleged to include base images (e.g., world maps for Map Charts), user-defined text (for Text Panels), and real-time telemetry data (for dashboards in "live mode"). | ¶19-22 | col. 2:5-12 |
| a client definition interface configured to receive input from a client computing device indicative of a user selection of at least some of the image data, the user-defined data, and the real-time data to be associated with the visual element; | The complaint alleges that Sumo Logic's dashboard editor provides a browser-based interface for users to select visualization types, specify text, and choose data sources and time ranges, thereby defining the panel. A screenshot shows the "Modify a Chart" interface where a user can edit panel settings (Compl. p. 12). | ¶23 | col. 6:50-54 |
| a generation module configured to generate the visual element based on the user-selected visual element defining data; | It is alleged that when a user views a dashboard, the Sumo Logic Platform retrieves the stored definition data and current telemetry data and uses that information to generate the requested visualization for display in the browser. | ¶24 | col. 6:29-44 |
| a network interface module configured to receive requests from the client computing device related to the generated visual element, and send the generated visual element that is responsive to the request, | The platform is alleged to provide shareable URLs which, when accessed, cause the server to transmit the dashboard for display. It also allegedly responds to export requests by generating and delivering downloadable PDF or PNG files. A screenshot depicts the "Exporting Dashboards" feature (Compl. p. 15). | ¶25 | col. 2:15-17 |
| wherein the system is operative to define and deliver to the client computing device independent of the operating system of the client computing device making the requests. | The complaint alleges the Sumo Logic Platform provides its dashboards via standard web browsers, making access independent of the client's underlying operating system (e.g., Windows, macOS). A screenshot from Defendant's documentation lists supported browsers such as Chrome and Firefox (Compl. p. 18). | ¶26 | col. 4:28-33 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the accused system's practice of sending dashboard definition data (e.g., JSON) to a client browser for rendering falls within the scope of the claim language "send the generated visual element." The patent's specification frequently describes a process where the server generates "image data" and sends that resulting image to the client (’869 Patent, col. 6:40-46), raising the question of whether sending rendering instructions rather than a rendered image constitutes infringement.
- Technical Questions: The complaint's strongest example for a "base image component" is the world map in a Map Chart (Compl. ¶20, p. 9). It is an open question what evidence will show that other accused visualizations, such as time-series charts or single value panels, also use a "base image component" as required by the claim.
V. Key Claim Terms for Construction
The Term: "generate the visual element"
- Context and Importance: The construction of this term is critical to the infringement analysis. The dispute may turn on whether this "generation" must occur entirely on the server, resulting in a finished image file (e.g., a PNG) that is sent to the client, or if it can refer to the server's assembly of a data package (e.g., JSON) that instructs the client's browser on how to render the element.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of "generate the visual element" does not explicitly forbid client-side processing. An argument could be made that by creating the definitive set of instructions and data, the server has "generated" the element in a legally sufficient sense.
- Evidence for a Narrower Interpretation: The patent specification, particularly in its description of FIG. 4A, details a process where the server receives inputs, "(re)generates image data based on received data," and then "send[s] image data to [the] requesting process or device" (’869 Patent, col. 6:40-46). This language may support a narrower construction requiring the server to perform the image rendering itself.
The Term: "visual element"
- Context and Importance: This term is directly linked to the "generation" term above. Practitioners may focus on whether the claimed "visual element" is the final array of pixels viewed by the user, or if it can be the underlying data structure that defines it.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is general. An argument could be made that the data structure (JSON) and the final visualization are two forms of the same "visual element," one encoded and one rendered.
- Evidence for a Narrower Interpretation: The patent consistently discusses the visual element in the context of "image data," "base image component," and "sub-images," suggesting a graphical, pixel-based entity rather than an abstract data structure (’869 Patent, col. 5:1-9).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), asserting that Sumo Logic publishes documentation, tutorials, and training materials that instruct and encourage its customers to use the Sumo Logic Platform in an infringing manner (Compl. ¶32, ¶34).
- Willful Infringement: Willfulness is alleged based on Sumo Logic's continued infringement after having received a notice letter identifying the ’869 Patent and its infringement on October 6, 2025 (Compl. ¶33, ¶35-36).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical implementation: does the patent’s server-centric model, which describes the server performing the final "generation" of "image data" to be sent to a client, read on the accused system's apparent architecture, where the server sends definition data (JSON) to the client's browser, which then performs the final rendering of the visualization?
- The case will likely hinge on a question of definitional scope during claim construction: can the term "visual element" be construed to mean a data structure that defines a visualization, or is it limited by the specification to a rendered graphical image? Similarly, does "generate" require the server to render the final pixels, or merely to assemble the data that enables that rendering?