DCT
6:22-cv-00291
DatRec LLC v. Ge Healthcare Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: DatRec, LLC (Texas)
- Defendant: Ge Healthcare, Inc. (Delaware)
- Plaintiff’s Counsel: Ramey & Schwaller, LLP
- Case Identification: 6:22-cv-00291, W.D. Tex., 03/18/2022
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has a "regular and established place of business" in the Western District of Texas and has committed alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Edison Datalogue Connect system, used for managing electronic health records, infringes a patent related to secure communication and user authentication over a public network.
- Technical Context: The technology concerns methods for verifying a user's identity by cross-referencing information provided by multiple related parties, thereby aiming to enhance security and confidence in online communications and data exchange platforms.
- Key Procedural History: The complaint states that DatRec, LLC owns the patent-in-suit by assignment. No other procedural history, such as prior litigation or administrative proceedings, is mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2006-12-07 | U.S. Patent No. 8,381,309 Earliest Priority Date |
| 2013-02-19 | U.S. Patent No. 8,381,309 Issues |
| 2019-10-01 | Accused Product Datasheet Published (approx.) |
| 2022-03-18 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,381,309 - Method and System for Ecure [sic] Communiocation [sic] Over a Public Network
- Patent Identification: U.S. Patent No. 8,381,309, "Method and System for Ecure [sic] Communiocation [sic] Over a Public Network," issued February 19, 2013.
The Invention Explained
- Problem Addressed: The patent identifies a need for communication channels over public networks, like the internet, that have a high level of security, noting that users are often "exposed to non-secure connections and to communications from unreliable or falsely-identified senders" (’309 Patent, col. 1:21-25, 47-49).
- The Patented Solution: The invention provides a system for verifying a user's identity to enable secure, permissioned communication (’309 Patent, Abstract). The system constructs a database of user information by permitting a "plurality of users to enter user-associated data" (’309 Patent, col. 2:26-29). The core of the solution is that the system determines a "level of reliability (confidence) in the authenticity" of a user's identity "based on correspondence between data on the individual entered by different users" (’309 Patent, col. 4:3-6). Based on this verification, different levels of communication are permitted between users (’309 Patent, Abstract).
- Technical Importance: The described approach seeks to improve confidence in the identity of a party in an electronic communication by using a relational web of data, where information from multiple sources is compared to establish authenticity (’309 Patent, col. 1:63-65).
Key Claims at a Glance
- The complaint asserts infringement of one or more of claims 1-17, but provides a preliminary infringement analysis only for system claim 9 (Compl. ¶8, pp. 4-6).
- Independent Claim 9 recites:
- A system for enabling communication between users over a communication network;
- comprising a server system associated with a database with verified data for an individual, where the server authenticates the individual's identity;
- the system determines a level of reliability in authenticity based on correspondence between data entered by a plurality of related individuals; and
- the system is configured to define one or more levels of permitted communication based on that verification.
- The complaint does not explicitly reserve the right to assert other dependent claims, but the general allegation covers claims 1-17 (Compl. ¶8).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is GE Healthcare's "Edison Datalogue Connect" system and associated services for managing electronic health records ("EHR") (Compl. ¶8, p. 4).
Functionality and Market Context
The complaint describes the Edison Datalogue Connect as a system that enables "Case Exchange, Multi-Disciplinary Team Physician Access, and Patient Access" (Compl. p. 4). Its functions include allowing users to "Dynamically share and collaborate on sensitive patient data such as imaging, notes and reports across the clinical community" and to conduct "secure communication with unaffiliated partners" (Compl. p. 5). The system is also alleged to feature "Active directory integration for Single Sign On username and password experience" and user management settings for groups and connections (Compl. p. 5). The complaint includes a product datasheet for the accused system, which highlights its role in "patient centric collaboration and advanced care coordination" (Compl. p. 4). The product datasheet cover, dated October 2019, is presented as visual evidence of the accused system's function (Compl. p. 4).
IV. Analysis of Infringement Allegations
The complaint provides a preliminary claim chart for claim 9, which is summarized below (Compl. ¶9, pp. 4-6).
’309 Patent Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system for enabling communication between users over a communication network, the system comprising; | The Edison Datalogue Connect system is alleged to be a "system for enabling communication between users over a communication network." This is supported by marketing materials describing collaboration and data exchange. | ¶9 (p. 4) | col. 4:21-23 |
| a server system associated with a database comprising verified data relating an individual, said server system being configured and operable to verify at least some of the data so as to authenticate an identity of the individual; | The system is alleged to be a "server system associated with a database" that authenticates users. This is mapped to product features like "Active directory integration for Single Sign On username and password experience" and user management functions. A list of product applications is offered as visual evidence for this element (Compl. p. 5). | ¶9 (p. 5) | col. 4:23-28 |
| determining a level of reliability in authenticity based on correspondence between data on said individual entered by a plurality of related individuals; and | The complaint alleges the system performs this function, mapping it to features that "Enable diverse care use cases like care team coordination, patient referrals and secure communication with unaffiliated partners." | ¶9 (p. 5) | col. 4:3-6 |
| the system being configured to define one or more levels of permitted communication between individuals in the database and the verified individual on the basis of said verification. | The system is alleged to define permitted communication levels, mapped to features that enable "care team coordination, patient referrals and secure communication with unaffiliated partners." A screenshot of these features is provided as evidence (Compl. p. 6). | ¶9 (p. 6) | col. 4:28-32 |
Identified Points of Contention
- Technical Questions: The complaint’s primary point of contention may revolve around the third element: "determining a level of reliability... based on correspondence between data... entered by a plurality of related individuals." The complaint alleges this function is met by features enabling "care team coordination" and "patient referrals" (Compl. p. 5). A key question for the court will be what evidence demonstrates that the accused system actually compares data inputs from multiple distinct individuals to derive a "level of reliability," as opposed to employing standard enterprise authentication (like the alleged "Active directory integration") and role-based access controls.
- Scope Questions: The case may turn on the scope of the phrase "plurality of related individuals." The patent specification provides examples rooted in familial and social relationships (e.g., family trees) (’309 Patent, col. 5:40-54). A central question is whether this language can be construed to read on a group of healthcare professionals in a "care team," as the complaint's theory suggests.
V. Key Claim Terms for Construction
- The Term: "determining a level of reliability in authenticity based on correspondence between data on said individual entered by a plurality of related individuals"
- Context and Importance: This limitation appears to be the central inventive concept. The infringement analysis will depend heavily on whether the accused product's user authentication and access control methods fall within the scope of this term. Practitioners may focus on this term because the complaint’s evidence appears to equate general collaborative functionality with the specific verification method claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plaintiff might argue that the term does not require a specific algorithm. Language in the patent states the goal is to "improve confidence in the identity of a party" (’309 Patent, col. 1:63-65), which could be argued to encompass any system where a group of "related" professionals (the care team) are vetted for secure collaboration.
- Evidence for a Narrower Interpretation: The defendant may argue that the specification provides a much more specific meaning. The detailed description and figures describe a process of comparing data bits (IDBs) from different sources, resolving inconsistencies, and ascribing a reliability score, a process that may not be present in the accused system (’309 Patent, FIG. 3A; col. 9:17-col. 11:34). The repeated use of "family tree" and social relationships could be used to argue the term requires a social or familial, not merely professional, relationship among the "plurality of related individuals" (’309 Patent, col. 5:40-54, col. 8:16-20).
VI. Other Allegations
- Indirect Infringement: The complaint alleges that GE Healthcare induces infringement by "actively encourag[ing] or instruct[ing] others (e.g., its customers...)" on how to use its EHR products in a way that infringes (Compl. ¶10). A claim for contributory infringement is also made on similar grounds (Compl. ¶11). The factual support for these claims in the complaint is based on the general provision and operation of the accused system.
- Willful Infringement: Willfulness is alleged based on knowledge of the ’309 patent "from at least the filing of this lawsuit" (Compl. ¶¶10-11). The complaint does not allege any pre-suit knowledge of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of functional operation: Does GE Healthcare's Edison Datalogue Connect platform, which the complaint alleges uses standard "Active directory integration," actually perform the specific technical function of "determining a level of reliability... based on correspondence between data... entered by a plurality of related individuals," as required by the patent? Or is there a fundamental mismatch between the accused system’s enterprise authentication and the patent's social-web verification model?
- The case will also present a key question of definitional scope: Can the term "plurality of related individuals," which the patent specification describes in the context of family trees and social connections, be construed broadly enough to cover a "multi-disciplinary team" of healthcare professionals collaborating through an enterprise software platform? The outcome of this construction could be determinative for infringement.