Lone Star Document Management LLC v. Oracle Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lone Star Document Management, LLC (Delaware)
  • Defendant: Oracle Corporation (Delaware)
  • Plaintiff’s Counsel: DEVLIN LAW FIRM LLC
• Case Identification: 1:26-cv-17, W.D. Tex., 01/05/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Oracle maintains a regular and established place of business in Austin, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s content management products and services infringe a patent related to a networked system for collaborative electronic document proofing.
• Technical Context: The technology addresses methods for managing, reviewing, and tracking multiple versions of electronic documents among different users over a computer network, a foundational capability in enterprise collaboration software.
• Key Procedural History: The complaint alleges that Plaintiff put Defendant on notice of the patent-in-suit via a letter offering a license, delivered on June 12, 2020. This alleged pre-suit knowledge may form the basis for a future claim of willful infringement.

Case Timeline

Date	Event
1998-12-17	’082 Patent Priority Date
2005-07-12	’082 Patent Issue Date
2020-06-12	Defendant allegedly received notice of the ’082 Patent
2026-01-05	Complaint Filing Date

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

U.S. Patent No. 6,918,082 - "ELECTRONIC DOCUMENT PROOFING SYSTEM"

The Invention Explained

• Problem Addressed: At the time of the invention, collaboratively proofing electronic documents over a network was difficult because parties often used incompatible software, operating systems, or proprietary file formats, which hindered version tracking and comment consolidation (’082 Patent, col. 1:32-36). Existing systems for delivering portable format documents allegedly failed to provide ways to automatically track multiple versions, manage a history of comments, or simultaneously display a document version with its associated commentary (’082 Patent, col. 2:49-59).
• The Patented Solution: The invention describes a centralized, network-accessible system for managing the document proofing lifecycle (’082 Patent, Abstract). The system stores multiple versions of portable format documents in a database, associates them with authorized "proofer identifiers," and links comments to specific document versions. A key aspect is the system's ability to receive a request from a proofer, retrieve the corresponding document and its comments, and format them for simultaneous display. The patent also describes a "unique methodology for storing files" where a hierarchical directory structure is used to generate a URL that points to a specific document version (’082 Patent, col. 5:10-22).
• Technical Importance: The technology aimed to solve platform and software dependency issues in collaborative workflows by centralizing document management and providing a unified interface for version control and review over networks like the internet (Compl. ¶¶16, 21).

Key Claims at a Glance

• The complaint asserts independent claim 16 (Compl. ¶37).
• The essential elements of independent claim 16 are:
  • A system comprising a database of portable format electronic documents stored with at least one proofer identifier; a computer for receiving comments concerning the documents; and a program for associating and storing the comments with the documents.
  • The computer is for receiving a request from a proofer, who presents the identifier, to review a particular document.
  • The program is for retrieving a record corresponding to the requested document.
  • The program "assembles a URL pointing toward the document from data in the record."
  • The program retrieves and formats the requested document together with the associated comments "for simultaneous display to permit review."
• The complaint states that its infringement analysis is preliminary and reserves the right to amend its contentions (Compl. ¶38).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Oracle systems, including one or more hardware and software products for content management and related services" (Compl. ¶37). It refers to non-included Exhibits 2 and 4 for specific product identification.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality. It alleges in general terms that Oracle implemented the patented invention to provide "convenience and efficiency for its customers" and enhance "customer engagement" (Compl. ¶14). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an infringement analysis in an exhibit that was not provided with the pleading (Compl. ¶38). The narrative infringement theory alleges that Oracle’s systems directly infringe at least claim 16 of the ’082 Patent (Compl. ¶37). The complaint asserts that the patented system solves prior art problems by performing the functions recited in claim 16, such as storing documents with identifiers, associating comments, receiving requests, assembling a URL, and formatting the document and comments for simultaneous display (Compl. ¶23). However, the pleading does not contain specific factual allegations detailing how any particular Oracle product performs these claimed functions.

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over the meaning of "assembles a URL pointing toward the document from data in the record." The infringement analysis will likely turn on whether the accused systems generate URLs using a method analogous to the one described in the patent’s specification, which involves concatenating client, project, and version data into a URL string (’082 Patent, col. 5:55-67), or if they use a fundamentally different architecture.
  • Technical Questions: The complaint alleges that the accused systems provide for "simultaneous display" of a document and its comments (Compl. ¶23). A technical question will be what evidence demonstrates that the accused products perform this specific formatting and display function as required by the claim, rather than simply making documents and comments accessible in separate interface elements.

V. Key Claim Terms for Construction

• The Term: "assembles a URL pointing toward the document from data in the record"

• Context and Importance: The method by which the system generates a link to the document is a specific technical step in the claim. The viability of the infringement allegation may depend on whether this term is construed broadly to cover any method of link generation or narrowly to the specific method disclosed.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not specify the exact method of assembly. A party could argue that any system that dynamically generates a unique locator for a document based on record data meets this limitation.
  • Evidence for a Narrower Interpretation: The specification describes a detailed implementation where the system "pastes together as a string the , , , and from the tag and record to assemble on the fly a URLpath" (’082 Patent, col. 6:25-30). This explicit description of assembling a hierarchical URL from constituent parts could be used to argue for a narrower construction limited to that methodology.

• The Term: "for simultaneous display"

• Context and Importance: This term defines the output of the claimed system. The dispute may focus on whether "simultaneous display" requires a single, integrated view where the document and comments are presented together, or if it is met by any user interface where both are visible on a screen at the same time.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue that the plain and ordinary meaning of "simultaneous" simply requires the document and comments to be available for viewing at the same time, for example in adjacent panes or windows.
  • Evidence for a Narrower Interpretation: The patent’s background criticizes prior art systems for their failure "to simultaneously-display a particular document version and its current history," suggesting the invention provides a novel, combined presentation (’082 Patent, col. 2:54-57). This contrast with the prior art may support an interpretation that requires a more integrated or unified format.

VI. Other Allegations

• Willful Infringement: The complaint does not include a formal count for willful infringement. However, it alleges that Defendant has had knowledge of the ’082 Patent since at least June 12, 2020, as a result of a letter from Plaintiff offering to license the patent (Compl. ¶13). This allegation of pre-suit notice could be used to support a future claim of willfulness for any infringement occurring after that date. The prayer for relief also requests a finding that the case is "exceptional" under 35 U.S.C. § 285 (Compl., p. 13, ¶C).

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

• A core issue will be one of claim scope: can the phrase "assembles a URL," which is detailed in the specification as a specific string-concatenation process, be construed to cover the methods potentially used in modern, database-driven content management systems for generating resource locators?
• A key evidentiary question will be one of technical operation: does the complaint’s bare allegation of infringement provide a plausible basis to believe that Oracle’s accused products perform the specific function of retrieving and formatting a document together with its associated comments for "simultaneous display" in the manner required by the claim? The lack of factual detail in the pleading suggests this will be a central point of contention during discovery and claim construction.