DCT

1:26-cv-00021

Lone Star Document Management LLC v. Document Logistix LLC

Key Events
Complaint
complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-00021, W.D. Tex., 01/05/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district and maintains a regular and established place of business within the Western District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s content management products and services infringe a patent related to systems for the collaborative proofing of electronic documents over a network.
  • Technical Context: The technology concerns networked systems that allow multiple users to store, track, comment on, and review different versions of electronic documents, a foundational capability for modern collaborative software platforms.
  • Key Procedural History: The complaint alleges that Plaintiff sent Defendant a letter on March 23, 2015, offering to license the patent-in-suit, thereby providing Defendant with knowledge of the patent more than a decade before the complaint was filed.

Case Timeline

Date Event
1998-12-17 ’082 Patent Priority Date
2005-07-12 U.S. Patent No. 6,918,082 Issues
2015-03-24 Plaintiff's counsel delivers letter offering to license the ’082 patent to Defendant
2026-01-05 Complaint Filed

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 difficult. Prior art systems often required all parties to use the same software and operating system, struggled with managing multiple document versions, and lacked features for tracking comment history or displaying a document alongside its associated comments ( Compl. ¶16; ’082 Patent, col. 1:32-36, col. 2:49-59). Even with the advent of "portable document formats," problems persisted in managing and tracking versions distributed to multiple parties for asynchronous review (Compl. ¶21; ’082 Patent, col. 2:13-17).
  • The Patented Solution: The patent describes a centralized, networked system to solve these problems. A central computer stores multiple versions of portable format documents, receives comments from various "proofers," and stores those comments in a database associated with the specific document version (’082 Patent, Abstract). When a proofer requests a document, the system retrieves the document and its associated comment history and formats them for "simultaneous display" (’082 Patent, col. 3:10-23). The system also describes a specific method for storing files in a hierarchical directory structure and using that structure to formulate a URL for displaying the document (’082 Patent, col. 5:10-22).
  • Technical Importance: The invention purported to provide a unified system for document distribution, version control, and collaborative proofing that was platform-independent and could manage reviews by multiple parties across different projects (Compl. ¶22; ’082 Patent, col. 6:60-64).

Key Claims at a Glance

  • The complaint asserts independent claim 16 (Compl. ¶37).
  • The essential elements of independent claim 16 include:
    • A database of portable format electronic documents stored with at least one proofer identifier.
    • A computer for receiving a plurality of comments concerning the documents.
    • A program for associating and storing the comments with the particular documents.
    • The computer receiving a request from a proofer to review a particular document.
    • The program retrieving a record corresponding to the requested document.
    • The program assembling a URL pointing toward the document from data in the record.
    • The program retrieving and formatting the requested document with the associated comments for simultaneous display to permit review.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Doc Logistix systems, including one or more hardware and software products for content management and related services" (Compl. ¶37).

Functionality and Market Context

The complaint does not provide specific details on the functionality of the accused products. It alleges in general terms that Defendant "implemented their products and services in network architectures having features which utilized the patented invention" to provide convenience and efficiency for its customers (Compl. ¶14). The complaint references an "Exhibit 2" and "Exhibit 4" that purportedly identify the accused products and provide an infringement analysis, but these exhibits were not included with the complaint filing (Compl. ¶¶37-38). The complaint does not provide sufficient detail for a technical analysis of the accused instrumentality's operation.

IV. Analysis of Infringement Allegations

The complaint references an infringement analysis chart in an exhibit that was not provided (Compl. ¶38). The narrative of the complaint alleges that the Accused Instrumentalities meet each limitation of claim 16 by providing a networked system for collaborative document review (Compl. ¶¶23, 25-26, 28). The complaint highlights that the patented invention overcomes prior art deficiencies by, among other things, storing documents with proofer identifiers, associating comments with documents, retrieving records, assembling a URL, and formatting the document and comments for simultaneous display (Compl. ¶23). The complaint does not, however, map these functions to specific features or operations of the named Doc Logistix products.

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." The question will be whether this limitation requires the specific directory-tree-based URL formulation described in the specification (’082 Patent, col. 5:10-22) or if it can be read more broadly to cover other methods of dynamically generating links to stored documents.
  • Technical Questions: A key factual question will be whether the accused Doc Logistix system performs the specific function of retrieving and formatting a document together with its associated comments for "simultaneous display," as required by the claim. The complaint alleges this functionality but provides no evidence demonstrating how the accused products actually achieve it (Compl. ¶28).

V. Key Claim Terms for Construction

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

Context and Importance

This term describes a specific technical step for locating and presenting the requested document. The complaint emphasizes this feature, citing the patent's description of it as a "unique methodology" (Compl. ¶29). The defendant will likely argue for a narrow construction tied to the patent's specific embodiment, while the plaintiff will likely argue for a broader one covering any functionally equivalent process.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The claim language itself does not specify how the URL is assembled, only that it is assembled "from data in the record." This may support an argument that any method of using record data (e.g., a database ID) to generate a unique link falls within the claim's scope.
  • Evidence for a Narrower Interpretation: The specification describes a detailed and "unique methodology" where the URL is formulated directly from a "directory tree file storage system" that mirrors database information like client, project, and version number (’082 Patent, col. 5:10-22, col. 6:25-34). This detailed description of a single embodiment may be used to argue that the claim is limited to this specific URL-generation architecture.

The Term: "simultaneous display"

Context and Importance

This term defines how the document and its associated comments are presented to the user. Its construction will be critical for determining whether the accused system's user interface infringes.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The term itself is not explicitly defined. It could be argued to encompass any user interface where the document and comments are available on the same screen or within the same parent window at the same time, even if in separate frames or panes.
  • Evidence for a Narrower Interpretation: The patent’s objective is to solve the problem of prior art systems that "fail to provide a way to... simultaneously-display a particular document version and its current history" (’082 Patent, col. 2:54-57). This suggests an integrated view. Embodiments described in the specification imply a close association, where comments are displayed directly "with the document version" (’082 Patent, col. 4:10-12). This could support a narrower construction requiring a more integrated or unified presentation.

VI. Other Allegations

Willful Infringement

The complaint does not explicitly allege "willful infringement." However, it alleges that Defendant had knowledge of the ’082 Patent as of March 24, 2015, due to a letter offering a license (Compl. ¶13). This allegation of pre-suit knowledge could form the basis for a later claim of willfulness and enhanced damages. The complaint also seeks a declaration that the case is "exceptional" under 35 U.S.C. § 285 (Compl., Prayer for Relief ¶C).

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

  • A core issue will be one of definitional scope: can the claim limitation "assembles a URL pointing toward the document from data in the record" be construed broadly to cover modern methods of dynamic link generation, or is it confined to the specific directory-tree-to-URL architecture detailed in the ’082 Patent's specification?
  • A key evidentiary question will be one of factual proof: absent the referenced exhibits, the complaint lacks specific allegations mapping the features of the accused Doc Logistix products to the elements of claim 16. The case will depend on whether discovery uncovers evidence that the accused systems perform the precise functions required by the claim, particularly the "simultaneous display" of a document with its associated comment history.