Lone Star Document Management LLC v. IBM Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lone Star Document Management, LLC (Delaware)
  • Defendant: International Business Machines Corporation (New York)
  • Plaintiff’s Counsel: DEVLIN LAW FIRM LLC
• Case Identification: 1:26-cv-18, W.D. Tex., 01/05/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant IBM maintains a "regular and established place of business" in the district, specifically citing an office at 11501 Burnet Road, Austin, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s content management products and services infringe a patent related to systems for the collaborative proofing and version management of electronic documents over a network.
• Technical Context: The technology addresses network-based systems for managing collaborative review of digital documents, a critical function in corporate environments that rely on complex, multi-party digital workflows.
• Key Procedural History: The complaint notes that Plaintiff sent a letter to IBM on June 11, 2020, offering to license the patent-in-suit. This correspondence, which allegedly establishes pre-suit knowledge of the patent, may be relevant to potential future claims for enhanced damages.

Case Timeline

Date	Event
1998-12-17	’082 Patent Priority Date
2005-07-12	’082 Patent Issue Date
2020-06-12	Plaintiff's license offer delivered to Defendant
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"

• Patent Identification: U.S. Patent No. 6,918,082, "Electronic Document Proofing System," issued July 12, 2005 (’082 Patent).

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulties in the 1990s of collaboratively reviewing electronic documents. These problems included the need for all collaborators to use the same software and operating system, the use of proprietary file formats, and the lack of systems to track multiple document versions or manage comment histories effectively (’082 Patent, col. 1:32-36, 1:50-54). Existing solutions for delivering portable documents over networks allegedly failed to "provide features for collaborative production and review of documents" (’082 Patent, col. 2:47-48, 2:49-59).
• The Patented Solution: The invention is a networked system that centralizes document proofing (’082 Patent, Abstract). A central computer stores multiple versions of portable format documents in a database, receives comments from authorized users ("proofers"), and associates those comments with the corresponding document versions (’082 Patent, col. 3:10-23). The system allows a proofer to request a document and its associated comments for "simultaneous display," facilitating review and comparison of different versions (’082 Patent, col. 3:23-31). Figure 1 depicts the overall architecture, showing a central computer (60) managing documents, versions, and comments between a creator computer (56) and a proofer computer (52).
• Technical Importance: The claimed system represents a move away from ad-hoc file sharing via email or FTP toward a structured, server-managed environment for collaborative document workflows, which was a significant step in online collaboration technology (’082 Patent, col. 6:60-64).

Key Claims at a Glance

• The complaint asserts independent claim 10 and dependent claim 16 (Compl. ¶37).
• Independent Claim 10 requires 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;
  • A program for associating and storing the comments with the documents;
  • The computer receiving a request from a proofer to review a document; and
  • The program retrieving and formatting the document and its associated comments for "simultaneous display to permit review."
• Dependent Claim 16 adds the further limitations that the program:
  • Retrieves a record corresponding to the requested document; and
  • "assembles a URL pointing toward the document from data in the record."
• The complaint reserves the right to amend its infringement analysis, suggesting other claims may be asserted later (Compl. ¶38).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "IBM 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 names.

Functionality and Market Context

The complaint does not describe the specific technical functionality of the accused IBM products. It alleges at a high level that IBM implemented features that "utilized the patented invention" to provide "convenience and efficiency for its customers" and enhance "customer engagement" (Compl. ¶14). The complaint's technical arguments frequently cite an expert declaration (Exhibit 3) that was not included with the complaint, and as such, the public filing provides insufficient detail for analysis of the accused product's operation (Compl. ¶¶15, 17, 18).

IV. Analysis of Infringement Allegations

The complaint states that a claim chart analyzing infringement of claim 16 is provided in Exhibit 2, which is not included in the provided document (Compl. ¶38). The narrative infringement theory alleges that IBM's content management systems meet the limitations of claim 16 by providing a networked architecture for document management and review (Compl. ¶14). The complaint repeatedly paraphrases the elements of claim 10 and 16, asserting that they solve technical problems and were unconventional at the time of the invention, and then concludes that IBM's systems infringe (Compl. ¶¶23, 25, 28, 37). No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central dispute may concern the scope of "assembles a URL pointing toward the document from data in the record" (Claim 16). The question will be whether this language, as described in the patent, can be read to cover the linking mechanisms used in the accused IBM products.
• Technical Questions: The complaint's infringement theory rests on assertions in a non-public expert declaration. A key factual question will be what evidence demonstrates that the accused IBM systems perform the specific function of retrieving and formatting a document "together with the associated plurality of comments for simultaneous display" as required by Claim 10. The complaint does not provide this evidence.

V. Key Claim Terms for Construction

Term: "assembles a URL pointing toward the document from data in the record" (from Claim 16)

• Context and Importance: This limitation is the core of asserted dependent claim 16 and distinguishes it from the base claim. Its construction will be critical to determining infringement, as it addresses how the system generates a link to a specific document version.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Parties may argue that this phrase should be given its plain and ordinary meaning, covering any programmatic generation of a hyperlink to a document based on metadata stored in a database record.
  • Evidence for a Narrower Interpretation: The specification describes a "unique methodology" where the URL is formulated from a specific directory tree structure: <protocol>://<host>/<client>/<project>/<version>/<name>/ (’082 Patent, col. 6:57-61). A defendant may argue this detailed embodiment limits the claim's scope to systems that construct URLs embedding this type of hierarchical information.

Term: "simultaneous display" (from Claim 10)

• Context and Importance: This term describes the user-facing output of the system and is presented as a key feature overcoming prior art deficiencies (’082 Patent, col. 2:54-57). Its meaning will define what kind of user interface infringes.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff may argue this term covers any presentation where the document and its associated comments are visible to the user at the same time, for example in different frames or panels of a single web page.
  • Evidence for a Narrower Interpretation: The patent describes viewing comments "in the same window as the proof commented on," which could support a narrower construction requiring a more integrated display rather than merely co-located but separate content blocks (’082 Patent, col. 8:23-25).

VI. Other Allegations

Willful Infringement

The complaint does not use the word "willful" but alleges facts that could support a future claim for enhanced damages. It alleges that IBM gained knowledge of the ’082 Patent no later than June 12, 2020, upon receiving Plaintiff's license offer (Compl. ¶13). The prayer for relief requests a declaration that the case is "exceptional" under 35 U.S.C. § 285, a finding often associated with willful infringement (Compl., Prayer for Relief ¶C).

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

• A core issue will be one of claim scope: can the term "assembles a URL," which is described with a specific hierarchical structure in the patent’s detailed description, be construed broadly enough to read on the modern hyperlinking technology used in Defendant’s accused content management systems?
• A second key issue will be one of evidentiary proof: as the complaint's technical assertions rely on a non-public expert report, a central question will be what evidence Plaintiff can produce during discovery to show that Defendant’s products actually perform the claimed functions, particularly the "simultaneous display" of documents with comments and the specific URL assembly method of Claim 16.