Decapolis Systems LLC v. Central Texas Community Health Centers doing Business As CommUnityCare Health Centers

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Decapolis Systems, LLC (Florida)
  • Defendant: Central Texas Community Health Centers, d/b/a CommUnityCare Health Centers (Texas)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 6:21-cv-01262, W.D. Tex., 12/03/2021
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains its headquarters and numerous physical business locations within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s electronic health records (EHR) systems infringe patents related to the automated processing of healthcare data, including insurance claim generation and controlled access to patient records.
• Technical Context: The technology concerns centralized systems for managing electronic health records, a domain critical to the efficiency, accuracy, and privacy of modern healthcare delivery and administration.
• Key Procedural History: The complaint notes that the patents-in-suit have been cited as prior art in patents issued to numerous technology and healthcare industry leaders, which the Plaintiff asserts as evidence of the patents' significance. The patents are expired, and the complaint seeks damages for past infringement.

Case Timeline

Date	Event
1999-12-18	Priority Date for U.S. Patent No. 7,464,040
2001-04-25	Priority Date for U.S. Patent No. 7,490,048
2008-12-09	Issue Date for U.S. Patent No. 7,464,040
2009-02-10	Issue Date for U.S. Patent No. 7,490,048
2021-12-03	Complaint Filing Date

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

U.S. Patent No. 7,490,048 - Apparatus and Method for Processing and/or for Providing Healthcare Information and/or Healthcare-Related Information

• Patent Identification: U.S. Patent No. 7,490,048, issued February 10, 2009.

The Invention Explained

• Problem Addressed: The patent's background section describes the need to maintain the privacy of patient healthcare records while also providing notification to patients and other individuals when third parties have accessed or modified those records (’048 Patent, col. 2:21-29).
• The Patented Solution: The invention describes a computer-implemented method for managing access to electronic health records. When a person or entity requests to access or modify a patient's record, the system processes the request, determines if it is authorized, and generates a "notification report" detailing the request or action. Crucially, this report is transmitted to the patient's communication device during, concurrently with, or even prior to the completion of the data access, creating a real-time or near-real-time audit trail for the patient (’048 Patent, Abstract; Fig. 16A-16B).
• Technical Importance: The invention provides a framework for auditable, controllable, and transparent access to sensitive electronic health records, directly addressing patient privacy concerns in a networked environment (’048 Patent, col. 7:31-36).

Key Claims at a Glance

• The complaint asserts claims 1, 2, 10, 20, and 22-40, with claim 20 (dependent) cited as exemplary (Compl. ¶36). Independent claim 1 is the basis for the asserted dependent claims.
• Independent Claim 1 requires:
  • A processor that processes a request to access, obtain, change, alter, or modify information in a patient's healthcare record.
  • The processor determines if the requesting individual or entity is authorized.
  • The processor generates a notification report containing details about the requestor and the actual or sought-after change.
  • A transmitter that transmits the notification report to the patient's communication device over a network.
  • The transmission occurs "at least one of during, concurrently with, at a same time as, and prior to a completion of" the access, modification, or processing of the request.
• The complaint reserves the right to assert additional claims (Compl. ¶36).

U.S. Patent No. 7,464,040 - Apparatus and Method for Processing and/or for Providing Healthcare Information and/or Healthcare-Related Information

• Patent Identification: U.S. Patent No. 7,464,040, issued December 9, 2008.

The Invention Explained

• Problem Addressed: The patent background identifies inefficiencies and rising costs in the healthcare system stemming from paper-based, slow, and potentially fraudulent insurance claims processing (’040 Patent, col. 2:4-15). It also notes that patient information collected on paper forms just before an appointment can be inaccurate or incomplete (’040 Patent, col. 1:50-60).
• The Patented Solution: The invention discloses a centralized system where a provider transmits a patient's clinical information (e.g., diagnosis, treatment) to a remote processing computer. The system uses this information to update the patient's record in a central database. In response to this clinical update, the system automatically generates a corresponding insurance claim and transmits it to the appropriate insurer's computer system, thereby directly linking the clinical and billing workflows (’040 Patent, Abstract; Fig. 14B).
• Technical Importance: This invention describes a method to automate and integrate the generation of insurance claims with the entry of clinical data, aiming to improve the speed, efficiency, and accuracy of the healthcare billing cycle (’040 Patent, col. 2:49-56).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 46 (Compl. ¶56).
• Independent Claim 1 requires:
  • A receiver that receives clinical information about an individual from a healthcare provider's computer over the Internet or World Wide Web.
  • A remote database that stores records for a plurality of individuals, providers, and payers.
  • A processing device that stores the received information in the database or updates the individual's healthcare record.
  • The processing device "automatically generates an insurance claim in response to the storing of the information... or the updating of the healthcare record."
  • The processing device transmits the generated insurance claim to a second computer associated with the healthcare insurer or payer.

III. The Accused Instrumentality

Product Identification

• The "Accused Instrumentalities" are Defendant's "plurality of electronic healthcare systems, platforms and services," including a cloud-based electronic health records ("EHR") and practice management system (Compl. ¶31). Specific platforms identified are "MyChart" and "EpicCare Link" (Compl. Figures 2-3).

Functionality and Market Context

• The accused systems provide a framework to manage patient care, including receiving and sending data, managing referrals, scheduling, billing, accounting, and collections (Compl. ¶31). The complaint includes a screenshot of the "MyChart" patient portal, which allows patients to communicate with doctors and access test results (Compl. Figure 2, p. 9). It also provides a screenshot describing "EpicCare Link" as a tool providing real-time web access to patient clinical data for providers (Compl. Figure 3, p. 9). The complaint alleges that Defendant owns, directs, and controls the operation of these systems (Compl. ¶35, ¶55). The complaint also presents a map from Defendant's website showing its numerous physical locations within the judicial district (Compl. Figure 1, p. 3).

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,490,048 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a processor, wherein the processor processes a request to at least one of access, obtain, change, alter, and modify, information contained in a patient’s healthcare record...	The Accused Instrumentalities receive and process requests regarding restrictions on the ability of a person or entity to access or modify information in a patient's healthcare record.	¶38	col. 45:19-25
wherein the processor determines whether an individual or entity is authorized...	The system determines, using stored restriction information, whether the person or entity is allowed or authorized to access or modify the patient's healthcare information.	¶41	col. 45:26-31
and further wherein the processor generates a notification report containing at least one of information regarding the individual or entity making the request... and... an actual change, alteration, or modification...	The system generates a message containing information about the entity making the request and the actual change, alteration, or modification made to the healthcare record.	¶41	col. 45:32-38
a transmitter, wherein the transmitter transmits the notification report to a patient communication device of the patient via, on, or over, a communication network...	The system transmits the message to a communication device of the individual or patient over a communication network.	¶41	col. 45:39-43
and further wherein the notification report is transmitted... at least one of during, concurrently with, at a same time as, and prior to a completion of... an accessing, an obtaining, a changing...	The message is transmitted to the patient's device at least one of during, concurrently with, at a same time as, and prior to a completion of the accessing or processing of the request to modify the information.	¶42	col. 45:44-49

Identified Points of Contention

• Technical Question: The complaint alleges in a conclusory manner that a notification is sent to the patient's device "concurrently with" or "prior to" the completion of access (Compl. ¶42). A central point of contention may be whether the plaintiff can produce evidence that the accused systems perform this real-time or pre-emptive notification function, as distinguished from creating a standard audit log that records access after the event has occurred.
• Scope Question: A question may arise as to whether the functionality of the accused patient and provider portals, such as MyChart and EpicCare Link (Compl. Figures 2-3), constitutes the specific method of receiving, processing, and acting upon "information regarding a restriction or limitation" as required by the claims.

U.S. Patent No. 7,464,040 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a receiver, wherein the receiver receives information regarding an individual... transmitted from a first computer... associated with a healthcare provider... via, on, or over, at least one of the Internet and the World Wide Web...	The Accused Instrumentalities receive information regarding an individual, transmitted from a first computer associated with a healthcare provider over the Internet.	¶58	col. 18:58-64
a database or a memory device... stores information regarding a plurality of individuals, a plurality of healthcare providers, and a plurality of healthcare insurers or healthcare payers...	The system includes a database that stores information regarding multiple individuals, providers, and payers, consistent with a centralized EHR platform.	¶58, ¶59	col. 19:56-62
a processing device, wherein the processing device processes information for at least one of storing the information regarding an individual in the database... and updating the healthcare record...	The system includes a processing device that processes information by storing it in the database and updating the healthcare record of the individual.	¶60	col. 29:6-10
and further wherein the processing device automatically generates an insurance claim in response to the storing of the information... or the updating of the healthcare record...	The processing device automatically generates an insurance claim as a direct result of the storing of information in the database or the updating of the individual's healthcare record.	¶60	col. 6:55-59
and further wherein the processing device transmits the insurance claim to the second computer...	The processing device transmits the generated insurance claim to a second computer associated with the healthcare insurer or payer.	¶60	col. 40:29-34

Identified Points of Contention

• Technical Question: The complaint alleges that the system "automatically generates an insurance claim in response to" the updating of a clinical record (Compl. ¶60). A key technical dispute may be whether the accused systems create such a direct, triggered causal link between a clinical data entry event and a billing event, or whether claim generation is part of a separate, and potentially manually initiated, billing cycle that is not "in response to" the clinical update in the manner required by the claim.

V. Key Claim Terms for Construction

For the ’048 Patent

• The Term: "transmitting the... report... at least one of during, concurrently with, at a same time as, and prior to a completion of... an accessing..." (Claim 1)
• Context and Importance: This temporal limitation appears to be a core inventive concept, distinguishing the claimed method from conventional post-event logging or auditing. The viability of the infringement allegation will likely depend on whether the accused system's notifications occur within this narrow time window relative to the completion of data access.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The disjunctive "at least one of" phrasing provides several alternative timings, which may support a broader reading that does not require a purely pre-emptive notification.
  • Evidence for a Narrower Interpretation: The specification discusses providing "notification to patients and other individuals when others have accessed, obtained, and/or made changes" (’048 Patent, col. 2:24-27), language which could be argued to describe a post-facto notification rather than one that is strictly concurrent with or prior to the completion of the act.

For the ’040 Patent

• The Term: "automatically generates an insurance claim in response to the storing... or the updating..." (Claim 1)
• Context and Importance: This phrase establishes the causal and automated link between a clinical event (updating a record) and a billing event (generating a claim). The infringement analysis will turn on how directly and immediately the accused system's claim generation function is triggered by a clinical data update.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The abstract's use of "in response to" suggests a strong causal connection. The specification also describes "automatic claim submission... once a final diagnosis and treatment has been prescribed" (’040 Patent, col. 6:55-59), which supports the idea that the clinical event is the trigger.
  • Evidence for a Narrower Interpretation: The patent's flowchart in Figure 14B depicts "UPDATE PATIENT'S RECORDS" (step 1408) as a distinct step preceding "GENERATE CLAIM FORM" (step 1409). A defendant might argue this illustrates a sequential, but not necessarily directly triggered, process, suggesting that "in response to" requires a more immediate, programmatic trigger than simply being the next step in a workflow.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement for both patents, asserting that Defendant encourages infringement by advertising and providing the Accused Instrumentalities for use by others (Compl. ¶44, ¶47, ¶63).
• Willful Infringement: Willfulness is alleged based on two theories. First, the complaint asserts that infringement will become willful upon Defendant's receipt of the complaint, establishing post-suit knowledge (Compl. ¶43, ¶62). Second, it alleges a pre-suit theory of willful blindness, contending that Defendant has a practice of not reviewing the patent rights of others before launching its services (Compl. ¶48, ¶67).

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

The resolution of this case may depend on the answers to several key technical and legal questions:

• A central issue of causation and automation for the ’040 patent: Does the evidence show that the accused EHR systems automatically generate an insurance claim as a direct, programmatic response to the updating of a clinical record, or is claims generation a separate function initiated by a different process or at a later time?
• A key evidentiary question of notification timing for the ’048 patent: Can the plaintiff demonstrate that the accused systems transmit a notification to a patient's device "concurrently with" or "prior to" the completion of a third party's access to their health record, or do the systems only provide for conventional after-the-fact audit logs that fall outside the patent's temporal requirements?
• A question of functional scope for the ’048 patent: Do the standard access control and user authentication features of the accused EHR portals perform the specific claimed functions of processing "information regarding a restriction" and generating a detailed "notification report" containing the content required by the claims?