Ak Meeting IP LLC v. Zoho Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: AK Meeting IP LLC (Texas)
  • Defendant: Zoho Corporation (Florida)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 6:22-cv-00250, W.D. Tex., 03/08/2022
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established place of business in the district and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s products and services for multi-party communication and content sharing infringe two patents related to collaborative computer networking technology.
• Technical Context: The patents relate to client-server architectures for enabling real-time collaboration, where user inputs on one computer are efficiently shared and displayed across multiple participant computers.
• Key Procedural History: Post-filing, an Inter Partes Review (IPR) was instituted against U.S. Patent No. 10,963,124. The proceeding, IPR2022-01142, resulted in the cancellation of all asserted claims (1-14) of the patent. This development suggests that the infringement allegations concerning the ’124 patent may be rendered moot.

Case Timeline

Date	Event
2007-03-30	Earliest Priority Date for ’124 and ’211 Patents
2014-01-07	’211 Patent Issued
2021-03-30	’124 Patent Issued
2022-03-08	Complaint Filed
2022-06-22	IPR Filed Against ’124 Patent
2024-03-20	IPR Certificate Issued Cancelling Claims 1-14 of ’124 Patent

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

U.S. Patent No. 10,963,124 - "Sharing Content Produced By A Plurality Of Client Computers In Communication With A Server"

• Patent Identification: U.S. Patent No. 10,963,124, "Sharing Content Produced By A Plurality Of Client Computers In Communication With A Server," issued March 30, 2021.

The Invention Explained

• Problem Addressed: The patent’s background section identifies a common problem in online collaboration systems: "delays in transmitting posted comments and other information between the parties," which can "reduce the usefulness of an online communication since the parties do not feel a presence of other participants." (’124 Patent, col. 2:1-6).
• The Patented Solution: The invention describes a client-server method to improve real-time collaboration. In this system, multiple client computers display "common content." When a user at one client provides input (e.g., drawing, typing), that client generates messages defining the "content to be shared." These messages are sent to a central server, which in turn relays corresponding output messages to all participating clients. The clients then display this new "shared content" overlaid on the original "common content," synchronizing the view for all users. (’124 Patent, Abstract; col. 13:35-14:23).
• Technical Importance: This client-server relay architecture provides a method for managing and synchronizing user-generated content across multiple devices in a collaborative session. (’124 Patent, col. 12:4-12).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-14 (Compl. ¶8).
• Independent Claim 1 recites a method with the following essential elements:
  • Generating messages at one client computer representing user input that defines content to be shared.
  • Causing that client computer to transmit the messages to a server.
  • The server, in response, transmits output messages to all participating client computers.
  • Each client computer, upon receiving the output messages, displays the shared content over the common content.
• As noted, all asserted claims of the ’124 Patent were subsequently cancelled in an IPR proceeding.

U.S. Patent No. 8,627,211 - "Method, Apparatus, System, Medium, and Signals for Supporting Pointer Display In A Multi-Party Communication"

• Patent Identification: U.S. Patent No. 8,627,211, "Method, Apparatus, System, Medium, and Signals for Supporting Pointer Display In A Multi-Party Communication," issued January 7, 2014.

The Invention Explained

• Problem Addressed: The patent addresses the same technical problem as the ’124 Patent: network delays in collaborative systems that diminish the sense of a shared, real-time presence among users. (’211 Patent, col. 1:44-50).
• The Patented Solution: The invention creates a distinction between a user's local "cursor" and a shared "pointer." A client computer tracks its user's local cursor movements in real-time. It sends a "cursor message" to the server representing this movement. The server then transmits a "pointer message" to all participating clients, causing a corresponding "pointer" to be displayed on each user's screen. This architecture allows a user to see their own cursor respond instantly while also seeing pointers representing the slightly delayed cursor positions of all other participants, thereby enhancing the sense of collaborative presence. (’211 Patent, Abstract; col. 2:51-67).
• Technical Importance: This technique of separating the local cursor from a server-relayed shared pointer provides a way to give users immediate local feedback while still making them aware of the actions of other participants in the session. (’211 Patent, col. 12:1-12).

Key Claims at a Glance

• The complaint asserts claims 1-150, with claim 1 asserted as exemplary (Compl. ¶15-16).
• Independent Claim 1 recites a method with the following essential elements:
  • Transmitting a first "cursor message" to a server, representing a change in the position of a local "first cursor."
  • Receiving a first "pointer message" from the server in response.
  • Causing a corresponding change in the position of a "first pointer" displayed on the user's screen in response to the pointer message.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific Zoho product or service by name. It broadly accuses Defendant’s "products and services," "methods for sharing content," and "systems, apparatus, and methods for multi-party communications." (Compl. ¶¶8, 15).

Functionality and Market Context

• The complaint alleges that Defendant "maintains, operates, and administers" systems that allow for sharing content produced by multiple client computers over a network and for supporting multi-party communications between those computers. (Compl. ¶¶8, 15). The complaint does not provide further technical details regarding the functionality or market context of the accused instrumentalities. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references preliminary claim charts in Exhibits A and B but does not include them in the filing (Compl. ¶¶9, 16). The narrative infringement theory is summarized below.

’124 Patent Infringement Allegations

• The complaint alleges that Defendant's systems and methods for sharing content infringe claims 1-14 of the ’124 Patent. The theory appears to be that when users of Zoho’s services collaborate, their inputs are transmitted to Zoho's servers, which then relay that information to other users for display, thereby practicing the patented method. (Compl. ¶¶7-8). As the asserted claims have been cancelled, these allegations are likely moot.

’211 Patent Infringement Allegations

• The complaint alleges that Defendant's multi-party communication systems infringe claims 1-150 of the ’211 Patent. The infringement theory suggests that Zoho's services, which support multi-party communications, necessarily practice the patented method of transmitting cursor information to a server and receiving back pointer information for display to participants. (Compl. ¶¶14-15).

Identified Points of Contention

• Evidentiary Questions: A central question will be what specific Zoho products (e.g., Zoho Meeting, Zoho Projects) Plaintiff intends to accuse. The complaint’s lack of specificity raises the question of what evidence will be used to map the broad allegations onto concrete product functionalities.
• Technical Questions (’211 Patent): What is the precise mechanism by which Zoho's products display the cursor movements of remote users? Does the accused functionality rely on the specific "cursor message" to "pointer message" architecture required by the claims, or does it use a different technical approach for sharing cursor/pointer data?

V. Key Claim Terms for Construction

The Term

• "cursor" versus "pointer" (’211 Patent, Claim 1)

Context and Importance

• The entirety of Claim 1 of the ’211 Patent rests on the distinction between a "cursor" (whose movement generates a message sent to the server) and a "pointer" (whose movement is caused by a message received from the server). The viability of the infringement claim will depend on whether this specific two-part display architecture is present in the accused products. Practitioners may focus on this distinction as it is the inventive concept.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The parties may argue that the terms should be given their plain and ordinary meaning, where any on-screen indicator of a user's position could be considered a "cursor" or "pointer," potentially broadening the claim scope to cover various forms of shared pointers.
• Evidence for a Narrower Interpretation: The specification explicitly distinguishes the terms, stating, "the word 'cursor' is used to refer to the client computer cursor" while "the word 'pointer' is used to refer to a secondary pointer, which is also displayed." (’211 Patent, col. 12:22-27). This language suggests a specific architecture with two distinct visual elements, one for local feedback and one for shared feedback, which could support a narrower construction.

VI. Other Allegations

Indirect Infringement

• The complaint alleges both induced and contributory infringement. It claims Defendant actively encourages infringement by instructing customers on how to use its collaborative services and asserts there are "no substantial noninfringing uses" for these features. (Compl. ¶¶10-11, 17-18).

Willful Infringement

• Willfulness is alleged based on Defendant’s knowledge of the patents "from at least the filing date of the lawsuit." (Compl. ¶¶10, 17). This frames the allegation as one of post-suit willfulness.

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

1. Impact of IPR: A threshold issue is the legal effect of the IPR certificate cancelling all asserted claims of the ’124 Patent. This development will likely lead to the dismissal of all infringement counts related to that patent, narrowing the case significantly.
2. Definitional Scope: For the remaining ’211 Patent, the central dispute may be one of technical definition: does Zoho's method for displaying remote user cursors implement the claimed two-tiered "cursor" and "pointer" system, or does it use a technically distinct method that falls outside the claim scope?
3. Specificity and Proof: A key evidentiary question will be one of identification: which specific products within Zoho's extensive software suite are accused of infringement, and what technical evidence will Plaintiff provide to demonstrate that these products operate in the precise manner claimed by the ’211 Patent?