DCT

6:22-cv-01286

Alto Dynamics LLC v. Vacasa LLC

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Alto Dynamics, LLC (Georgia)
- Defendant: Vacasa LLC, and Vacasa Real Estate LLC (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
Case Identification: 6:22-cv-01286, W.D. Tex., 12/16/2022
Venue Allegations: Plaintiff alleges venue is proper because Defendants maintain established and regular places of business in the district, including physical office locations in Fredericksburg and Austin, Texas.
Core Dispute: Plaintiff alleges that Defendant’s online vacation rental platform, including its website and mobile applications, infringes eight patents related to database searching, relational data conversion, user activity monitoring, state-less authentication, and automatic data extraction.
Technical Context: The case involves technologies central to modern e-commerce and online service platforms, specifically in the competitive vacation and property rental market, which relies on efficient database management, user authentication, and personalized user experiences.
Key Procedural History: The complaint notes that U.S. Patent No. RE46,513 is a reissue of U.S. Patent No. 7,020,645, a fact that may be relevant to the patent's prosecution history and potential intervening rights defenses. No other significant procedural events are mentioned in the complaint.

Case Timeline

Date	Event
2000-02-09	Priority Date for U.S. Patent No. 6,604,100
2001-03-20	Priority Date for U.S. Patent No. 6,662,190
2001-04-19	Priority Date for U.S. Patent No. RE46,513
2002-04-02	Priority Date for U.S. Patent No. 6,691,103
2002-12-18	Priority Date for U.S. Patent No. 7,152,018
2003-08-05	Issue Date for U.S. Patent No. 6,604,100
2003-12-09	Issue Date for U.S. Patent No. 6,662,190
2004-02-10	Issue Date for U.S. Patent No. 6,691,103
2006-01-05	Priority Date for U.S. Patent No. 7,657,531
2006-11-07	Priority Date for U.S. Patent No. 7,392,160
2006-12-19	Issue Date for U.S. Patent No. 7,152,018
2008-06-24	Issue Date for U.S. Patent No. 7,392,160
2010-01-21	Priority Date for U.S. Patent No. 8,051,098
2010-02-02	Issue Date for U.S. Patent No. 7,657,531
2011-11-01	Issue Date for U.S. Patent No. 8,051,098
2017-08-15	Issue Date for U.S. Patent No. RE46,513
2022-12-16	Complaint Filing Date

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

U.S. Patent No. 6,691,103 - "Method For Searching A Database, Search Engine System For Searching A Database, And Method Of Providing A Key Table For Use By A Search Engine For A Database," Issued February 10, 2004

The Invention Explained

Problem Addressed: When a user searches a database with multiple criteria (e.g., name and city), some criteria are far more restrictive than others. Executing a broad search first can be computationally inefficient, as it returns a large, intermediate dataset that must then be filtered by the more restrictive criteria (’103 Patent, col. 1:10-50).
The Patented Solution: The invention proposes a method to improve search efficiency by first ordering the search elements based on the "expected size of the corresponding search results." The system then executes the search using the element expected to return the smallest result set first, thereby narrowing the search space for subsequent, less restrictive search elements (’103 Patent, Abstract; col. 2:40-56).
Technical Importance: This method describes a fundamental query optimization technique designed to reduce computational load and improve response time in database systems, a critical factor for user-facing applications.

Key Claims at a Glance

The complaint asserts at least independent claim 1 (Compl. ¶29).
Claim 1 breaks down into the following essential elements:
- A method for searching a database containing records with record fields and elements.
- Receiving a search criteria with multiple search elements corresponding to record elements.
- Ordering the search elements based upon an expected size of their corresponding search results.
- Searching the database with a first search element (expected to provide a first, smaller group of results) before searching with a second search element (expected to provide a second, larger group of results).
The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 6,604,100 - "Method For Converting Relational Data Into A Structured Document," Issued August 5, 2003

The Invention Explained

Problem Addressed: The patent addresses the technical challenge of converting data from traditional relational databases (which are flat and tabular) into structured, nested formats like XML, which became a standard for data exchange between web applications. The patent notes that existing conversion tools lacked generality, dynamism, and efficiency (’100 Patent, col. 1:12-45).
The Patented Solution: The invention provides a middleware system, referred to in the specification as "SilkRoute," for viewing and querying relational data as if it were in a structured XML format. It uses a transformation language to define a virtual XML view of the relational data, receives a user query against that view, and composes an efficient executable query (e.g., SQL) to retrieve only the necessary data from the underlying database, which is then formatted into a structured document (’100 Patent, Abstract; col. 2:26-42).
Technical Importance: This technology enabled legacy systems with relational databases to interoperate with modern web applications that consume structured data, without requiring costly and complex data migration projects.

Key Claims at a Glance

The complaint asserts at least independent claim 1 (Compl. ¶39).
Claim 1 breaks down into the following essential elements:
- Storing a view query defining a structured document view of a relational database.
- Receiving a user query against the structured document view.
- Forming an executable query by composing the view query and the user query.
- Partitioning the executable query into a data extraction portion and a construction portion.
- Transmitting the data extraction portion to the relational database.
- Receiving a tuple stream from the database.
- Merging the tuple stream and the construction portion to generate a structured document.
The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,392,160 - "System And Method For Monitoring Usage Patterns," Issued June 24, 2008

Technology Synopsis: This patent describes a method for monitoring user activity on a system by using a "state object" (such as a cookie) that contains a profile of the user's usage. The state object is stored on the client's machine, passed to a central server with each interaction, and modified by the server to reflect the interaction, allowing for analysis and the delivery of services suited to the user's profile (Compl. ¶50).
Asserted Claims: At least independent claim 1 (Compl. ¶49).
Accused Features: The accused functionality is Defendant's use of technology like cookies to track user activities and preferences on its platform to provide personalized content and analytics (Compl. ¶¶18, 50).

U.S. Patent No. 8,051,098 - "Systems And Methods For State-Less Authentication," Issued November 1, 2011

Technology Synopsis: This patent discloses a method for user authentication in a distributed computing environment. A user establishes a secure session with a logon component, which verifies the user's information and generates a "security context." This security context is then employed by the user's device to access various resources without requiring follow-on authorization communications between the accessed resource and the original logon component (Compl. ¶67).
Asserted Claims: At least independent claim 1 (Compl. ¶66).
Accused Features: The accused functionality is Defendant's user login processes and use of secured sessions for user authentication on its website and mobile apps (Compl. ¶¶18, 67).

U.S. Patent No. RE46,513 - "Systems And Methods For State-Less Authentication," Issued August 15, 2017

Technology Synopsis: This patent, a reissue of U.S. Patent No. 7,020,645, describes a processing system for providing users with selective access to resources. A logon component receives logon information during a secure session, verifies it against a database, and generates a security context. The user then provides this security context back to the system to request access to a resource, enabling state-less authentication (Compl. ¶77).
Asserted Claims: At least independent claim 16 (Compl. ¶76).
Accused Features: The accused functionality is Defendant's system for user authentication, including its logon processes and the use of secured sessions (Compl. ¶¶18, 77).

U.S. Patent No. 7,657,531 - "Systems And Methods For State-Less Authentication," Issued February 2, 2010

Technology Synopsis: This patent describes a method for renewing a user's access to a resource in a distributed system. A user provides a valid but expiring "security-context" along with a renewal request to an authorization component. The system verifies the request against stored identity information and generates an updated security-context, which is then sent back to the user to maintain access (Compl. ¶88).
Asserted Claims: At least independent claim 1 (Compl. ¶87).
Accused Features: The accused functionality is Defendant's management of user sessions, including what is alleged to be the renewal of cookies after their expiration (Compl. ¶¶86, 88).

U.S. Patent No. 7,152,018 - "System And Method For Monitoring Usage Patterns," Issued December 19, 2006

Technology Synopsis: This patent discloses a method for monitoring user usage patterns where a "state object" containing a user profile is stored at a client location. This object is passed to a central server with each interaction. The profile is modified by scripts or programs at the client location, which precludes manipulation by the server, and reflects the interaction between the client and server (Compl. ¶98).
Asserted Claims: At least independent claim 1 (Compl. ¶97).
Accused Features: The accused functionality includes Defendant's use of cookies and "Secure Flag" functionality to monitor user usage on its platform (Compl. ¶¶18, 96, 98).

U.S. Patent No. 6,662,190 - "Learning Automatic Data Extraction System," Issued December 9, 2003

Technology Synopsis: This patent describes a method for extracting data from a text file into a record file. The method involves identifying an area of interest, parsing it to find values that match a known vocabulary, forming a record with those values, and then "gleaning" a second set of values from the list that do not match the vocabulary, adding this second set to the record. This allows the system to learn new values not previously in its vocabulary (Compl. ¶114).
Asserted Claims: At least independent claim 1 (Compl. ¶113).
Accused Features: The accused functionality is Defendant's resume uploading feature, which allegedly employs text mining to extract data from resumes (Compl. ¶114).

III. The Accused Instrumentality

Product Identification

The Accused Instrumentalities are the website "https://www.vacasa.com/" and its associated mobile applications, along with the underlying hardware and software that operate them (Compl. ¶¶18-19).

Functionality and Market Context

The complaint alleges the Accused Instrumentalities constitute an online platform that allows users to view, search, and book vacation rentals (Compl. ¶18). The platform is alleged to employ various technologies, including user tracking via cookies to monitor activities and preferences, user authentication through login processes, and internal analytics (Compl. ¶18). The complaint highlights marketing materials stating that the platform uses "in-house automation tools" to provide personalized content, such as showing "guests vacation homes within driving distance of their address, or a last-minute weekend getaway idea that’s near where they’ve stayed before" (Compl. ¶20). A screenshot provided in the complaint illustrates a description of this personalized email marketing functionality (Compl. p. 5). A separate feature for processing job application resumes is also identified as an accused functionality (Compl. ¶18, 114).

IV. Analysis of Infringement Allegations

6,691,103 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method for searching a database including a plurality of records...	Defendant's platform provides a searchable database of vacation rental properties.	¶30	col. 2:40-42
receiving a search criteria including a plurality of search elements...	Users can input search criteria (e.g., location, dates, number of guests) to search the database.	¶30	col. 2:43-45
ordering the search elements of said search criteria based upon an expected size of the corresponding search results from said database...	The platform allegedly orders the user's search criteria based on the anticipated size of the results for each criterion.	¶30	col. 2:46-49
and searching said database with one of said search elements, which is expected to provide a first group of said search results, before searching said database with another one of said search elements, which is expected to provide a second group of said search results, said second group being larger in size than said first group.	The platform allegedly executes the search query by first applying the criterion expected to yield the smallest result set, before applying broader criteria.	¶30	col. 2:50-56

Identified Points of Contention:
- Evidentiary Question: The complaint's allegation that the accused system "order[s] the search elements...based upon an expected size" is a statement about the internal workings of Defendant's software (Compl. ¶30). A central question will be what, if any, evidence Plaintiff can obtain and present to demonstrate that the accused search functionality operates in this specific manner, as opposed to using other known query optimization techniques. The complaint itself does not provide such evidence.

6,604,100 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
storing a view query that defines a structured document view of the relational database...	The platform allegedly uses a predefined view to present its underlying relational data as a structured document to other parts of the system or to users.	¶40	col. 2:33-36
receiving a user query against the structured document view...	The system receives queries from users or applications that interact with this structured view.	¶40	col. 2:36-37
forming an executable query by determining a composition of the view query and the user query...	The system allegedly combines the user query with the predefined view query to create an executable query.	¶40	col. 2:47-52
partitioning the executable query into a data extraction portion and a construction portion...	The executable query is allegedly split into a part for retrieving raw data from the database and a part for assembling the final structured document.	¶40	col. 6:26-30
receiving at least one tuple stream from the relational database... and merging the at least one tuple stream and the construction portion to generate a structured document...	The system retrieves data from the database and uses the construction portion to assemble it into a structured document for the user.	¶40	col. 6:39-44

Identified Points of Contention:
- Technical Question: The patent describes a specific "middleware" architecture for converting data from relational databases to XML (’100 Patent, FIG. 1). A primary question will be whether Defendant’s modern web platform, which may use different data storage and transfer technologies (e.g., NoSQL databases, JSON APIs), performs a method that is technically equivalent to the specific steps of partitioning and merging queries as claimed. The complaint does not offer technical details on how the accused system actually functions.

V. Key Claim Terms for Construction

For the ’103 Patent:

The Term: "ordering the search elements...based upon an expected size of the corresponding search results"
Context and Importance: This phrase recites the central logic of the claimed method. The definition of how "expected size" is determined and what constitutes "ordering" based on it will be critical to the infringement analysis. Practitioners may focus on whether this requires a specific pre-calculation or estimation step, or if it can be read more broadly to cover any query execution plan that happens to process more restrictive criteria first.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify the mechanism for determining the "expected size," which may support an interpretation covering any method of estimating result set size to inform query order.
- Evidence for a Narrower Interpretation: The specification discusses employing a "search priority array" and calculating a "search priority field" for records, which could be cited to argue that the "expected size" must be determined through a specific, pre-calculated priority system rather than a dynamic, on-the-fly estimation by a query optimizer (’103 Patent, col. 2:56-61).

For the ’100 Patent:

The Term: "structured document"
Context and Importance: The definition of this term is key to determining whether the patent, filed in 2001, applies to modern web technologies. The dispute will likely center on whether this term is limited to the XML documents heavily discussed in the patent, or if it can encompass other nested data formats like JSON, which are common today.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is not explicitly limited to XML in the claim language. Plaintiff may argue it should be given its plain and ordinary meaning, covering any data document with a nested, hierarchical structure.
- Evidence for a Narrower Interpretation: The patent’s abstract and background are heavily focused on XML as the target format, referring to it as the "standard format for data exchange" (’100 Patent, Abstract; col. 1:12-25). This context may be used to argue that a person of ordinary skill in the art at the time would have understood "structured document" to mean XML or a functionally identical markup language.

VI. Other Allegations

Indirect Infringement: The complaint alleges induced and contributory infringement for U.S. Patent Nos. 7,392,160 and 7,152,018. The allegations are based on Defendants taking active steps to cause infringement by "advising or directing personnel, contractors, or end-users," "advertising and promoting the use" of the accused platform, and "distributing instructions" for its use (Compl. ¶¶51, 99).
Willful Infringement: The complaint alleges willful infringement for the ’160 and ’018 patents. The basis for willfulness is alleged knowledge of the patents "at least as of the date when it was notified of the filing of this action" (Compl. ¶¶53, 101). The complaint further alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others" (Compl. ¶¶54, 102).

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

A core issue will be one of evidentiary proof: What evidence can the plaintiff discover and present to demonstrate that the internal, server-side mechanisms of the modern Vacasa platform perform the specific, multi-step methods recited in claims drafted nearly two decades ago for different technological contexts, particularly for the '103 patent's query ordering and the '100 patent's data conversion methods?
A second key question will be one of technological scope: Can claim terms rooted in the context of early-2000s web technology (e.g., "structured document" in a patent focused on XML) be construed to cover the data formats and architectures (e.g., JSON, microservices) potentially used in a contemporary cloud-based platform?
A final central question will involve damages and apportionment: Given the assertion of eight patents covering a wide array of distinct platform functionalities—from core search features to ancillary HR functions like resume processing—a significant challenge will be to apportion the alleged value of the accused platform among the distinct technologies claimed by each patent.