DCT
6:22-cv-01254
Vilox Tech LLC v. Oracle Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Vilox Technologies, LLC and Vilox, LLC (Texas)
- Defendant: Oracle Corporation (Delaware)
- Plaintiff’s Counsel: Ramey LLP
- Case Identification: 6:22-cv-01254, W.D. Tex., 12/05/2022
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement and maintains a regular and established place of business in the district, including a principal place of business in Austin, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s Oracle Database and Oracle ATG Platform products infringe patents related to methods for conducting "on-the-fly" database searches and generating reports from the results.
- Technical Context: The technology concerns user-friendly database search interfaces that simplify data retrieval for users unfamiliar with a database's underlying structure and manage the display of large result sets.
- Key Procedural History: The complaint alleges Defendant has known of the patents-in-suit since at least the filing date of a prior lawsuit against Costco Wholesale Corporation, an alleged user of Defendant’s products, and also references knowledge from at least 2017. This history is cited to support allegations of indirect and willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2000-02-25 | Earliest Priority Date (’720, ’100 Patents) |
| 2004-07-06 | U.S. Patent No. 6,760,720 Issues |
| 2007-03-06 | U.S. Patent No. 7,188,100 Issues |
| 2017-01-01 | Alleged Knowledge Date (approx.) |
| 2022-12-05 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,760,720 - "Search-on-the-Fly/Sort-on-the-Fly Search Engine for Searching Databases," issued July 6, 2004
The Invention Explained
- Problem Addressed: The patent describes the difficulty for users who lack detailed knowledge of a database's structure (its "schema") to formulate effective search queries. It also notes that conventional searches can return unmanageably large sets of data that are difficult to review on a display screen. (’720 Patent, col. 2:1-28).
- The Patented Solution: The invention is a "search-on-the-fly" engine that provides an "intuitive means for searching databases" without requiring schema knowledge (’720 Patent, col. 2:32-36). A user iteratively selects search terms from dynamically generated menus. If a search would return too much data to be "conveniently displayed," the system executes a "truncation routine" to reduce the result set to a manageable size, for example by showing only the first few characters of entries to allow for further filtering (’720 Patent, Abstract; col. 5:61-col. 6:11).
- Technical Importance: The technology aimed to make complex databases more accessible to non-technical users and manage information overload in an era of growing online data repositories. (’720 Patent, col. 2:19-22).
Key Claims at a Glance
- The complaint asserts claims 1-39 (Compl. ¶9). Independent claim 1 is a method claim.
- Claim 1 Essential Elements:
- determining a database schema for a database
- providing a list of the database fields
- receiving a search selection for a database field
- determining a quantity of entries in the selected database field
- if the quantity exceeds a specified amount, truncating data, wherein the truncating reduces characters in one or more entries
- displaying the truncated data
- if the quantity does not exceed the specified amount, displaying contents of the database field
- The complaint reserves the right to assert other claims, which would include dependent claims. (Compl. ¶9).
U.S. Patent No. 7,188,100 - "Search-on-the-Fly Report Generator," issued March 6, 2007
The Invention Explained
- Problem Addressed: After conducting a search, users need a way to format the retrieved information into a structured, reusable report. The '100 patent builds on the search technology of the '720 patent to address this report generation need. ('100 Patent, col. 3:45-54).
- The Patented Solution: The invention is a method and apparatus for taking the results of an "on-the-fly" search and creating a "report template." This template is not just a static document but one that "includes a link or path to one or more fields in one or more databases," allowing for the dynamic generation of subsequent reports that reflect updated database content. (’100 Patent, Abstract; col. 4:5-10).
- Technical Importance: This technology facilitates the creation of dynamic, repeatable reports from complex databases, a function critical for business intelligence and data analysis applications. ('100 Patent, col. 3:45-54).
Key Claims at a Glance
- The complaint asserts claims 1-38 (Compl. ¶19). Independent claim 1 is a method claim.
- Claim 1 Essential Elements:
- receiving a database query
- searching a database on-the-fly based on the query using a search-on-the-fly search engine
- tweaking the received query to generate a defined query
- accessing the database using the defined query
- generating a search result that includes descriptors of data categories
- creating a template that includes a link or path to one or more fields in one or more databases
- The complaint reserves the right to assert other claims, which would include dependent claims. (Compl. ¶19).
III. The Accused Instrumentality
Product Identification
- The complaint identifies "Oracle Database products and Oracle ATG Platform products" as the Accused Instrumentalities (Compl. ¶10, ¶20).
Functionality and Market Context
- The complaint alleges these products perform functions related to "retrieval, search, generation of results, and truncation of displayed characters" (’720 Patent infringement) and utilize "search features and report features" (’100 Patent infringement) (Compl. ¶10, ¶20, ¶24).
- The complaint frames these as core functionalities of Oracle's database and e-commerce platform products, suggesting they are commercially significant features. (Compl. ¶9, ¶19).
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
As the complaint references but does not attach its claim chart exhibits (Exhibits B, C, E, and F), this analysis is based on the narrative infringement allegations contained within the body of the complaint.
U.S. Patent No. 6,760,720 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| determining a database schema for a database... | The complaint does not provide sufficient detail for analysis of this element. | col. 5:4-14 | |
| providing a list of the database fields, wherein the list includes a descriptor indicating a data category; | Allegedly generating a list of data fields that include a descriptor indicating a data category. | ¶9 | col. 5:44-53 |
| receiving a search selection for a database field on the provided list of the database fields; | Allegedly receiving a search selection for a data field from the list of data fields. | ¶9 | col. 5:58-60 |
| determining a quantity of entries in the selected database field; | Allegedly determining a quantity of entries in the selected database field. | ¶9 | col. 7:1-4 |
| if the quantity exceed a specified amount, truncating data...wherein the truncating reduces characters in one or more entries... | Allegedly determining if the number of entries in the database field exceeds a specified amount, and if in excess, reducing the number of characters displayed to the user. | ¶9 | col. 7:15-22 |
| displaying the truncated data... | Allegedly displaying the result of the character reduction. | ¶9 | col. 7:38-42 |
| if the quantity does not exceed the specified amount, displaying contents of the database field. | Allegedly determining if the number of entries is equal to or less than a specified number and displaying the full contents. | ¶9 | col. 7:1-14 |
Identified Points of Contention
- Technical Question: The core of the dispute for the ’720 patent may be whether Oracle's method for handling large result sets constitutes "truncating data" where the truncation "reduces characters in one or more entries" as specifically required by the claim. The case may turn on evidence showing how Oracle's products technically manage and display large data sets to users.
- Scope Question: A question may arise as to how broadly the term "reduces characters" can be interpreted. Does it cover any form of summarization or abbreviation, or is it limited to the specific iterative, character-by-character reduction methods described as embodiments in the patent?
U.S. Patent No. 7,188,100 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving a database query; | Allegedly receiving a database query. | ¶19 | col. 46:60-61 |
| searching a database on-the-fly based on the query using a search-on-the-fly search engine; | Allegedly searching a database on-the-fly based on the query using a search-on-the-fly search engine (or other search engine). | ¶19 | col. 46:61-63 |
| tweaking the received query to generate a defined query of the database; | Allegedly tweaking the received query to generate a defined query of the database. | ¶19 | col. 56:16-24 |
| accessing the database using the defined query; | Allegedly accessing the database using the defined query. | ¶19 | col. 56:20-22 |
| generating a search result that includes descriptors of data categories; | Allegedly generating a search result that includes descriptors of data categories. | ¶19 | col. 55:35-40 |
| and creating a template that includes a link or path to one or more fields in one or more databases. | Allegedly creating a template that includes a link or path to one or more fields in one or more databases. | ¶19 | col. 4:5-10 |
Identified Points of Contention
- Scope Question: A central dispute for the ’100 patent will likely be the definition of "template." The question for the court will be whether Oracle's report generation features create a "template" that includes the claimed "link or path" to database fields, enabling dynamic report regeneration, or if they simply create static report layouts.
- Technical Question: What evidence does the complaint provide that Oracle’s products perform the step of "tweaking the received query to generate a defined query"? The specific technical mechanism for this "tweaking" in the accused products will be a key factual issue.
V. Key Claim Terms for Construction
’720 Patent: "truncating data...wherein the truncating reduces characters in one or more entries" (Claim 1)
- Context and Importance: The definition of this phrase is fundamental to the infringement allegation for the '720 patent. The dispute will likely center on whether the accused functionality of managing large result sets in Oracle's products meets this specific definition of truncation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent Summary states that if returned data is too large, "the search engine executes a truncation routine so that the returned data is easily displayed" (’720 Patent, Abstract), which could be argued to encompass any method that shortens data for display.
- Evidence for a Narrower Interpretation: The Detailed Description provides a specific example where truncation involves iteratively reducing the number of characters checked against the database (e.g., from full city names to 7 characters, then 5, then 3) until a displayable list is achieved (’720 Patent, col. 7:15-42). This suggests the term may be limited to this specific character-reduction mechanism.
’100 Patent: "template that includes a link or path to one or more fields" (Claim 1)
- Context and Importance: This term is the core of the '100 patent's invention. Infringement will depend on whether Oracle's reporting tools create what can be legally defined as a "template" with this specific structural characteristic. Practitioners may focus on this term because it distinguishes the invention from a mere static report.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "template" in general software parlance can refer to any pre-formatted layout. A party might argue for this plain meaning.
- Evidence for a Narrower Interpretation: The claim language explicitly requires the template to include a "link or path." The specification explains this allows for the creation of "dynamic search-on-the-fly report[s]" that can be re-run against changing database content (’100 Patent, col. 4:46-54). This suggests the term requires a functional structure for dynamic data retrieval, not just a visual layout.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Oracle "actively encouraged or instructed others (e.g., its customers...)" on how to use the infringing features of its products (Compl. ¶14, ¶24). Contributory infringement is based on the allegation that "there are no substantial noninfringing uses for Defendant's products and services" that perform the claimed methods (Compl. ¶15, ¶25).
- Willful Infringement: The complaint alleges that Oracle has known of the patents and the underlying technology since "at least the filing date of the lawsuit against Costco," an Oracle customer, and also "from at least 2017" (Compl. ¶14, ¶15, ¶24, ¶25). This alleged pre-suit knowledge is the basis for the willfulness claim and the request for enhanced damages.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of definitional scope: does the term "truncating data...[that] reduces characters," as used in the ’720 patent, cover any form of data summarization for display, or is it limited to the specific iterative character-reduction process described in the patent's embodiments? The answer will determine if Oracle's method for managing large result sets infringes.
- Another key question will be one of structural equivalence: do the report generation features in Oracle’s products create a "template" that includes the specific "link or path" structure required by the ’100 patent for dynamic data retrieval, or do they merely generate static report formats?
- A significant factual question will concern scienter: what evidence will emerge in discovery to substantiate the allegation that Oracle knew of the patents-in-suit and their alleged infringement via prior litigation involving its customer, Costco, and how will that knowledge bear on the claims for indirect and willful infringement?