Lone Star Document Management LLC v. Atlassian US Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lone Star Document Management, LLC (Delaware)
  • Defendant: Atlassian US, Inc. (Delaware)
  • Plaintiff’s Counsel: Devlin Law Firm LLC
• Case Identification: 1:26-cv-00019, W.D. Tex., 01/05/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant 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 electronic document proofing system.
• Technical Context: The technology concerns network-based systems for managing the collaborative review, annotation, and versioning of electronic documents among multiple users.
• Key Procedural History: The complaint alleges that Plaintiff contacted Defendant with an offer to license the patent-in-suit via a letter delivered on September 4, 2018, establishing a date of alleged pre-suit knowledge of the patent.

Case Timeline

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 (the "’082 Patent").

The Invention Explained

• Problem Addressed: At the time of the invention, collaboratively reviewing electronic documents over a network was inefficient. It often required all parties to use the exact same software version on the same operating system, and existing systems using "portable document formats" lacked features for managing the review process, such as tracking multiple document versions or consolidating comment histories from different reviewers (’082 Patent, col. 1:32-36, col. 2:49-59).
• The Patented Solution: The patent describes a centralized, network-based system designed to solve these problems. A central computer stores multiple versions of portable format documents in a database, receives comments from authorized reviewers ("proofers"), and associates those comments with the corresponding document versions (’082 Patent, col. 3:10-23). To facilitate access, the system employs a "unique methodology" where it generates a hierarchical directory structure based on document metadata (e.g., client, project) and uses this structure to formulate a URL for displaying the document to the user (’082 Patent, col. 5:10-22).
• Technical Importance: The system was intended to facilitate "electronic document distribution, proofing and communication between a document creator and a person or people responsible for approving the document," streamlining the collaborative workflow by centralizing version and comment management (’082 Patent, col. 6:60-64).

Key Claims at a Glance

• The complaint asserts independent claim 16 (Compl. ¶37).
• The essential elements of claim 16 are:
  • 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 receives a request from a proofer (presenting the identifier) to review a document.
  • The program retrieves a record corresponding to the document and "assembles a URL pointing toward the document from data in the record."
• The complaint states its infringement analysis is preliminary and reserves the right to amend or supplement it (Compl. ¶38).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Atlassian systems, including one or more hardware and software products for content management and related services" (Compl. ¶37). Specific products are allegedly identified in Exhibits 2 and 4, which were not included with the complaint document (Compl. ¶37).

Functionality and Market Context

The complaint alleges that Atlassian's products incorporate features that utilize the patented invention to provide "convenience and efficiency for its customers" and enhance customer engagement (Compl. ¶14). The complaint does not provide sufficient detail for analysis of the specific technical functionality of the accused products, as this information is contained in external exhibits.

IV. Analysis of Infringement Allegations

The complaint states that an exemplary infringement analysis is provided in an external document, Exhibit 2, which was not available for review (Compl. ¶38). The complaint’s narrative alleges that Atlassian’s content management systems directly infringe at least claim 16 of the ’082 Patent (Compl. ¶37). The core of the infringement theory appears to be that the accused systems provide a networked environment for managing and collaborating on documents, where users are identified, comments are associated with documents, and documents are accessed via system-generated links, thereby practicing the elements of claim 16 (Compl. ¶14, ¶28).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question may be whether the term "proofer identifier," as described in the patent in the context of being "stored together with" the documents, can be read to cover modern user authentication systems where user data may be managed separately from the document data itself.
• Technical Questions: The infringement analysis may turn on whether the accused products "assemble a URL... from data in the record" in the manner required by the claim. The patent describes a specific methodology based on a directory tree structure (’082 Patent, col. 5:10-22). A key factual question will be whether the architecture used by the accused products to generate links to content aligns with the method described and claimed in the patent.

V. Key Claim Terms for Construction

The Term: "proofer identifier"

• Context and Importance: This term is fundamental to the user access and management element of the claim. Its construction will determine whether modern, complex user account and permissioning systems fall within the claim's scope. Practitioners may focus on this term to dispute whether a general user login satisfies the claim's requirement that the identifier be "stored together with" the documents.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes "proofer identifiers" as indicating "who is authorized to view the document version for review and comment" and provides an example of a user logging in with a "username and password," suggesting the term could encompass general user authentication credentials (’082 Patent, col. 3:61-63, col. 6:40-41).
  • Evidence for a Narrower Interpretation: The claim requires the database to have documents "stored together with at least one proofer identifier" (’082 Patent, col. 10:12-13). This language could support an argument that the identifier must be part of the same data record as the document, not merely linked through a separate user authentication database.

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

• Context and Importance: This term defines the core technical mechanism for retrieving a document. The dispute will likely focus on the specific actions connoted by "assembles."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify a particular method of assembly, which could support an interpretation covering any programmatic generation of a link to a stored document based on its corresponding data record.
  • Evidence for a Narrower Interpretation: The specification characterizes its method as a "unique methodology" that "relies on the dynamic interaction between... a relational database, a directory tree file storage system, and URL strings" to formulate a URL with a specific hierarchical structure (e.g., <host>/<client>/<project>/...) (’082 Patent, col. 5:10-22, col. 5:59-61). This detailed description may be used to argue that the claim is limited to this specific directory-based assembly method.

VI. Other Allegations

Willful Infringement

The complaint does not explicitly allege "willful" infringement. However, it alleges that Defendant has had knowledge of the ’082 Patent since at least September 4, 2018, based on a license offer letter Plaintiff sent to Defendant (Compl. ¶13). This allegation of pre-suit knowledge could form the basis for a later claim of willfulness. The prayer for relief also seeks a declaration that the case is "exceptional" under 35 U.S.C. § 285, which is often associated with findings of willful infringement or other litigation misconduct (Compl. ¶C, p. 13).

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

• A core issue will be one of technological translation: can the specific architectural elements recited in claim 16, which reflects a 1998-era client-server file system paradigm (e.g., a "proofer identifier" stored with a document, a URL assembled from a directory-like path), be construed to read on the potentially different architecture of Defendant's modern, cloud-native content management platforms?
• A key infringement question will be one of methodological scope: does the claim limitation "assembles a URL" cover any programmatic generation of a hyperlink to a resource, or is its scope narrowed by the specification's disclosure of a "unique methodology" for formulating a URL from a hierarchical directory structure? The resolution of this question will be critical in determining whether there is a mismatch in technical operation between the claimed invention and the accused systems.