DCT

6:25-cv-00069

Web 20 Tech LLC v. Advent Health Central Texas

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-00069, W.D. Tex., 02/26/2025
  • Venue Allegations: Venue is alleged to be proper based on Defendant having a regular and established place of business in the district where acts of infringement have occurred.
  • Core Dispute: Plaintiffs allege that Defendant’s customized Electronic Health Record (EHR) systems, which are used to comply with federal healthcare IT standards, infringe a patent related to an online repository for securely storing and disbursing personal information.
  • Technical Context: The technology concerns centralized, secure management of personal data, specifically applied to personal health records (PHRs) within the framework of U.S. healthcare interoperability and "Meaningful Use" regulations.
  • Key Procedural History: The complaint frames the alleged infringement in the context of federal legislation, including the HITECH Act and the American Recovery and Reinvestment Act (ARRA) of 2009, which created incentives for healthcare providers to adopt certified EHR technology. The "Meaningful Use" program, later renamed "Promoting Interoperability," is central to Plaintiffs' theory that Defendant's compliance with these standards results in infringement.

Case Timeline

Date Event
2000-01-07 U.S. Patent No. 9,465,913 Earliest Priority Date
2009-01-01 American Recovery and Reinvestment Act (ARRA) enacted (approx.)
2016-10-11 U.S. Patent No. 9,465,913 Issued
2018-01-01 "Meaningful Use" program name changed to "Promoting Interoperability" (approx.)
2025-02-26 Complaint Filed

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

U.S. Patent No. 9,465,913 - "Online Repository for Personal Information," issued October 11, 2016

The Invention Explained

  • Problem Addressed: The patent describes the inconvenience and inefficiency of users repeatedly entering personal information into forms on various websites. It also notes the lack of a method for a user to store personal data in a single location, control its release to different entities based on authorization levels, and automatically propagate updates to that data (’913 Patent, col. 1:29-55).
  • The Patented Solution: The invention proposes a system and method for a central "Personal Information Repository." A user establishes an account, enters personal information, and assigns security classifications to different data objects. When a third party requests information, the system verifies the requester's authorization and releases only the corresponding data. The system is also designed to automatically notify designated entities when a user's information is updated ('913 Patent, Abstract; col. 2:31-68).
  • Technical Importance: The invention provides a framework for user-centric data control, aiming to enhance privacy and efficiency in online data exchange by centralizing information and its dissemination rules under the user's authority ('913 Patent, col. 2:3-13).

Key Claims at a Glance

  • The complaint asserts infringement of independent Claim 1 (Compl. ¶26).
  • The essential elements of independent claim 1 include:
    • A computer-implemented method for accessing a patient's personal health record (PHR) in an online repository.
    • Establishing an account for a patient on a server computer.
    • Receiving and storing the patient's PHR information, thereby creating the PHR.
    • Associating "patient-established control settings" with the PHR, where these settings are "configurable by the patient" to restrict access to designated requesters.
    • Receiving an access request from a designated requester with patient identification and authorization information.
    • Verifying the authorization information.
    • Selecting and sending a portion of the PHR to the requester in accordance with the patient-established control settings.
    • Recording every access of the patient's PHR.
    • Enabling access in a medical emergency.
    • Receiving and storing updates to the PHR from an authorized party.
    • Automatically notifying the patient via an electronic message if their PHR is changed.
  • Plaintiffs reserve the right to assert other claims as discovery progresses (Compl. ¶32).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's "customized electronic medical health records ('EHR') systems, platforms, and/or services" (Compl. ¶8).

Functionality and Market Context

The complaint alleges these EHR systems are designed, used, and maintained by Defendant to comply with the "Meaningful Use" ('MU') standards and Certified EHR Technology (CEHRT) requirements prescribed by the HITECH Act (Compl. ¶8). The purpose of these systems is to manage patient health information electronically, improve care coordination, ensure privacy, and qualify for federal financial incentives (Compl. ¶¶11, 12). The complaint alleges that compliance with these federal standards gives assurance to users and government agencies that the systems have the necessary technological capabilities (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in its Exhibit 2 detailing the alleged infringement of Claim 1; however, this exhibit was not attached to the publicly filed document (Compl. ¶28). The core of the infringement theory presented in the complaint's text is that by designing and using EHR systems that are certified to comply with the federal MU and CEHRT standards, Defendant necessarily and inherently practices the method claimed in the '913 Patent (Compl. ¶¶9, 16, 26).

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Evidentiary Question: The complaint's theory hinges on the assertion that compliance with a set of federal regulations (MU/CEHRT) is coextensive with the performance of every specific step recited in Claim 1. A primary point of contention will be whether Plaintiffs can provide sufficient factual evidence to show that the accused EHR systems perform each of the dozen distinct method steps of Claim 1, such as the requirements to "automatically notify[] the patient" of changes and to associate "patient-established control settings" that are "configurable by the patient."
  • Scope Question: The case may raise the question of whether an EHR system, which operates within a healthcare provider's enterprise and is subject to institutional and HIPAA-based controls, constitutes an "online repository" with "patient-established control settings" as contemplated by the patent.

V. Key Claim Terms for Construction

"patient-established control settings"

  • Context and Importance: This term is central to the claimed invention's focus on user-centric control. The infringement analysis will likely turn on whether the access controls in Defendant's EHR system, which are likely designed primarily for institutional and regulatory compliance (e.g., HIPAA), can be considered "established" by the patient. Practitioners may focus on this term because the degree of control it requires—whether direct patient configuration or mere patient consent to system-defined rules—is critical to the infringement question.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses assigning security classifications to information objects in general terms, which could support an interpretation where any form of patient input or consent suffices ('913 Patent, col. 12:49-61).
    • Evidence for a Narrower Interpretation: The claim language requires the settings to be "configurable by the patient via the first client computer" ('913 Patent, col. 15:10-12). An embodiment describes a user setting security "by selecting a radio button or a check box for each information object," suggesting a granular, direct-action-by-the-patient requirement ('913 Patent, col. 12:50-54).

"online repository"

  • Context and Importance: The definition of this term establishes the environment in which the claimed method operates. Its construction will determine whether the architecture of Defendant's EHR system, which may be a complex, distributed, or federated system, falls within the scope of the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification acknowledges that the underlying database can be a "distributed database" located at "several nodes," not necessarily a single monolithic system ('913 Patent, col. 5:22-30).
    • Evidence for a Narrower Interpretation: The patent's background section repeatedly frames the problem as a lack of a "single location" for a user to store personal information, which could be argued to support a more centralized architectural model ('913 Patent, col. 1:46-48).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges direct infringement under 35 U.S.C. § 271(a) (Compl. ¶26). It does not contain specific factual allegations to support claims of induced or contributory infringement.
  • Willful Infringement: The complaint does not explicitly allege willful infringement or request enhanced damages. It does, however, request in its prayer for relief a finding that the case is "exceptional" for the purpose of awarding attorneys' fees under 35 U.S.C. § 285 (Compl., Prayer for Relief ¶C).

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

  • A key evidentiary question will be one of infringement-by-standard: can Plaintiffs prove that mere compliance with the broad MU/CEHRT regulatory framework, as alleged, is sufficient to establish that Defendant's systems perform each specific, granular step of the asserted method claim, or is there a factual mismatch between the regulatory requirements and the claim limitations?
  • A core issue will be one of definitional scope: can the term "patient-established control settings," which is rooted in the patent's context of direct user-centric data management, be construed to read on the access controls of an enterprise EHR system, which are likely governed by institutional policies and HIPAA regulations rather than direct, granular patient configuration?