TG 2006 Holdings LLC v. Box Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TG--2006 Holdings, LLC (Texas)
  • Defendant: Box, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 6:24-cv-00060, W.D. Tex., 01/31/2024
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s cloud storage and file management services infringe two patents related to systems for tracking information in a business environment using a hierarchical folder structure with status-indicating visual alerts.
• Technical Context: The technology at issue involves user interfaces for project and document management systems, where visual cues, such as changes in folder color, are automatically triggered to reflect the status or timeliness of underlying tasks or items.
• Key Procedural History: The complaint notes that U.S. Patent No. 9,454,741 is a continuation of the application that resulted in U.S. Patent No. 8,583,514. The continuation was filed on the same day the parent patent issued, a fact which may inform future arguments regarding claim scope and prosecution history.

Case Timeline

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

U.S. Patent No. 8,583,514 - System and method for tracking information in a business environment

• Patent Identification: U.S. Patent No. 8,583,514, issued November 12, 2013.

The Invention Explained

• Problem Addressed: The patent identifies that tracking business information can be "time consuming and confusing," and if not displayed in a "visually clear and meaningful way," the tracking system defeats its own purpose (ʼ514 Patent, col. 1:11-20).
• The Patented Solution: The invention is a software system that uses a hierarchical tree-view of folders to track the status of business activities. The core concept is that "parent folders" can change their visual attributes (e.g., color) in response to status changes of the "child" documents or folders they contain (ʼ514 Patent, col. 1:21-34). This change is driven by "time triggers" and "event alerts," creating a "child driven" system where an event in a child element sends a notification that alters the parent's appearance to alert a user to a status change, such as a missed deadline (ʼ514 Patent, col. 3:20-23).
• Technical Importance: This approach sought to provide an at-a-glance, intuitive visual dashboard for complex project management, allowing users to identify problems in a nested hierarchy without needing to inspect every individual item.

Key Claims at a Glance

• The complaint asserts "exemplary claims" without specifying them (Compl. ¶12). Independent claim 1 is a method claim.
• Claim 1 recites a method comprising the key steps of:
  • Establishing a "parent folder" and an associated "child element" (e.g., another folder or a document).
  • Correlating the "child element" with a "time critical task, critical inventory or accounting activities".
  • Associating a "time trigger" with that task.
  • Providing a means for an operator to clear the "time trigger" upon completion of the task.
  • "changing an attribute of the parent folder" based on the state of the child element when the "time trigger" is met before being cleared. (ʼ514 Patent, col. 13:51-col. 14:9).
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,454,741 - System and method for tracking information in a business environment

• Patent Identification: U.S. Patent No. 9,454,741, issued September 27, 2016.

The Invention Explained

• Problem Addressed: As a continuation of the '514 patent's application, the '741 Patent addresses the same problem of providing a more visually intuitive system for tracking business information (ʼ741 Patent, col. 1:13-22).
• The Patented Solution: The solution is substantively the same as in the parent '514 Patent, utilizing a hierarchical folder structure where visual attributes of parent and child folders change to reflect the status of underlying tasks based on time-based triggers (ʼ741 Patent, Abstract; col. 4:12-24). The '741 patent's single claim, however, is more narrowly focused on a manufacturing embodiment involving an "in-house product."
• Technical Importance: This patent refines the broader concept of the '514 Patent into a more specific application for production-line and manufacturing process management.

Key Claims at a Glance

• The complaint asserts "exemplary claims" from the patent (Compl. ¶21). The patent contains only one claim, independent method claim 1.
• Claim 1 recites a method with the key steps of:
  • Establishing "parent" and "child" folders.
  • Establishing an "in-house product" and associating it with at least one "task", "products", and "labor codes".
  • Associating a "first alert interval" and a "time trigger" with the task and product.
  • Monitoring a system clock and "changing the color of the child folder" when the time exceeds the alert interval.
  • "changing the color of the parent folder" when the child folder's color changes. (ʼ741 Patent, col. 11:5-col. 12:21).
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not name specific Box, Inc. products, referring to them generally as "Exemplary Defendant Products" (Compl. ¶¶12, 21). Given the defendant and the nature of the patents, the accused instrumentalities are presumably Box's cloud storage, file sharing, and collaboration services.

Functionality and Market Context

• The complaint alleges that the accused products "practice the technology claimed" by the patents-in-suit (Compl. ¶¶17, 26). However, it does not describe the specific functionality of the accused products, instead incorporating by reference claim chart exhibits that were not attached to the publicly filed complaint (Compl. ¶¶18, 27). The complaint does not provide sufficient detail for analysis of the accused product's specific features or market context.
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement but incorporates its substantive analysis into Exhibits 3 and 4, which were not included with the filed document (Compl. ¶¶ 18, 27). Without these exhibits, a detailed, element-by-element analysis is not possible based on the complaint alone. The narrative theory is that Defendant's products provide a hierarchical file structure where visual indicators change based on the status of underlying files or tasks, thereby satisfying the elements of the asserted claims (Compl. ¶¶ 17, 26).

Based on the patent claims and the general nature of the accused services, the following points of contention may arise.

• Identified Points of Contention:
  • Scope Questions ('514 Patent): A central question may be whether the general-purpose file management in a cloud storage service constitutes the "tracking and displaying [of] critical operational parameters including time critical tasks, mission critical inventories, [or] significant accounting activities" as contemplated by the patent (ʼ514 Patent, col. 13:51-54).
  • Scope Questions ('741 Patent): An issue for the '741 Patent will be one of definitional scope: whether a digital file or project within the accused service can be construed as an "in-house product" that is associated with "labor codes" and "tasks" in the manufacturing sense required by the claim (ʼ741 Patent, col. 11:9-13).
  • Technical Questions (Both Patents): The infringement case may depend on whether Plaintiff can produce evidence that the accused products contain the specific "time trigger" mechanism recited in the claims. This raises the question of whether the Defendant's system automatically changes a folder's visual "attribute" (for the '514 patent) or "color" (for the '741 patent) based on a predefined, elapsed "alert interval," or if it relies on more general, user-initiated status indicators or notifications that differ from the claimed invention.

V. Key Claim Terms for Construction

'514 Patent: "time trigger"

• The Term: "time trigger"
• Context and Importance: This term is the core mechanism of the invention. Its construction will be critical to determine whether the accused products, which may have general notification or deadline features, practice the specific automated alert system claimed by the patent. Practitioners may focus on whether this term requires a user-defined, fixed time interval that, upon elapsing, automatically causes a visual change, or if it can cover broader event-based notifications.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes attributes including "time triggers and deadlines, event alerts, and the like," which could suggest "time trigger" is one of several types of alerts (ʼ514 Patent, col. 1:30-32).
  • Evidence for a Narrower Interpretation: The detailed description provides specific examples of time triggers set for discrete time periods, such as "[step1 10 min], [step 2, 5 min], [step 3, 1 hour]," suggesting a specific, programmed time interval for a task (ʼ514 Patent, col. 6:41-43). The claim requires the trigger to be "met prior to clearance by an operator," implying an automatic event upon time expiration, not a user-prompted one (ʼ514 Patent, col. 14:7-9).

'741 Patent: "in-house product"

• The Term: "in-house product"
• Context and Importance: This term appears central to Claim 1 of the '741 Patent and seems to root the invention in a physical manufacturing context. The viability of the infringement claim against a software service may hinge on whether this term can be construed to cover digital assets like files, folders, or software projects.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's title, System and method for tracking information in a business environment, suggests a broad applicability beyond any single field (ʼ741 Patent, Title).
  • Evidence for a Narrower Interpretation: The specification consistently uses the term "in house product" (or "IHP") to refer to "production subassemblies" and items in a manufacturing process that involve physical products and inventory, distinguishing them from simple documents ('741 Patent, col. 1:41-43, col. 3:25-29). Claim 1 further links the "in-house product" to "labor codes", reinforcing a connection to manufacturing or service environments where labor is tracked against a specific output.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents. The factual basis for inducement is that Defendant allegedly distributes "product literature and website materials" that instruct customers on how to use the accused products in an infringing manner (Compl. ¶¶ 15, 24). Knowledge and intent are alleged to exist at least from the date of service of the complaint (Compl. ¶¶ 16, 25).
• Willful Infringement: The complaint does not contain a separate count for willfulness. However, it alleges that Defendant gained "Actual Knowledge of Infringement" upon service of the complaint and continued to infringe thereafter (Compl. ¶¶ 14-15, 23-24). The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285, which is often associated with findings of willful infringement or litigation misconduct (Compl. p. 7).

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

1. A central issue will be one of definitional scope: can claim terms rooted in a specific manufacturing and task-management context, such as "time critical task" ('514 Patent) and "in-house product" associated with "labor codes" ('741 Patent), be construed broadly enough to encompass the files, folders, and collaborative features of a general-purpose cloud storage service?

2. A key evidentiary and technical question will be whether Plaintiff can demonstrate that the accused services implement the specific "time trigger" mechanism required by the claims. The case may turn on evidence showing that a folder's visual attribute (specifically "color" for the '741 Patent) is automatically changed based on a pre-set, elapsed time interval, as opposed to relying on more general notification systems or user-driven status updates that may fall outside the claim scope.