DCT

6:25-cv-00072

Web 20 Tech LLC v. Seton Medical Center Harker Heights

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-00072, W.D. Tex., 02/26/2025
  • Venue Allegations: Venue is alleged to be proper as Defendant has a regular and established place of business in the district, specifically the hospital located at 850 W. Central Texas Expressway, Harker Heights, TX.
  • Core Dispute: Plaintiffs allege that Defendant’s use of customized Electronic Health Record (EHR) systems, which comply with federal "Meaningful Use" standards, infringes a patent related to an online repository for personal information.
  • Technical Context: The technology concerns secure, centralized online databases where users can store personal information and grant selective access to third parties, here applied to the field of electronic health records.
  • Key Procedural History: The complaint alleges that infringement arises from the Defendant's compliance with federal standards promulgated under the HITECH Act and ARRA of 2009, which incentivize the "Meaningful Use" of certified EHR technology. The asserted patent claims priority to an application filed in 2000.

Case Timeline

Date Event
2000-01-07 ’913 Patent Priority Date
2009 HITECH Act / ARRA enacted, establishing "Meaningful Use" standards
2016-10-11 ’913 Patent Issue Date
c. 2018 "Meaningful Use" program name changed to "Promoting Interoperability"
2025-02-26 Complaint Filing Date

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

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

  • Patent Identification: 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 inefficiency and annoyance for internet users who are repeatedly required to fill out lengthy online forms with personal information for various websites and services (’913 Patent, col. 1:29-45). It notes the lack of a central, user-controlled system for managing this data and authorizing its release to different entities (’913 Patent, col. 2:1-4).
  • The Patented Solution: The invention proposes a system where a user can store various types of personal information in a single online repository, managed by a service provider (’913 Patent, Abstract). The user can assign different security classifications to different pieces of information and then grant authorized "requesters" access to specific, pre-defined portions of that data, thereby maintaining control over its dissemination (’913 Patent, col. 2:32-44, 2:50-54). The system architecture involves a user computer, a requester computer, and a central server computer connected over a network (’913 Patent, Fig. 1).
  • Technical Importance: This approach sought to give users centralized control over their digital identity and streamline online transactions by creating a trusted, single source for personal data that could be selectively shared.

Key Claims at a Glance

  • The complaint asserts independent Claim 1 (’913 Patent, Compl. ¶26, ¶28).
  • Independent Claim 1 of the ’913 Patent recites a computer-implemented method with the following key steps:
    • establishing an account for a patient with a server computer, the account being associated with a data storage area;
    • receiving, from a first client computer operated by the patient, one or more pieces of the patient's personal health information;
    • storing the received health information in the data storage area, thereby creating a personal health record (PHR);
    • associating patient-established control settings with the PHR, where the settings enable the patient to restrict access to the PHR to one or more designated requesters;
    • receiving an access request from a designated requester via a second computer, the request including a patient identifier and authorization information;
    • verifying the authorization information;
    • selecting a portion of the patient's PHR in accordance with the patient-established control settings; and
    • sending the selected portion of the PHR to the second computer.
  • Plaintiffs reserve the right to assert infringement of other claims as discovery progresses (Compl. ¶27).

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are identified as "customized EHR systems, platforms, and/or services" that Defendant designs, develops, uses, and/or maintains (Compl. ¶8).

Functionality and Market Context

The complaint alleges these EHR systems are designed and used to comply with federal "Meaningful Use" ("MU") and Certified EHR Technology ("CEHRT") standards, as prescribed by the HITECH Act (Compl. ¶8, ¶10). The relevant functionality includes data capture and sharing, issuing electronic prescriptions, and exchanging electronic health information to improve care quality and efficiency (Compl. ¶11, ¶15). The complaint alleges that by complying with these standards, Defendant obtained financial incentives and avoided penalties from the federal government (Compl. ¶12).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that a claim chart detailing the infringement of independent Claim 1 is attached as Exhibit 2 (Compl. ¶28). However, this exhibit was not included with the complaint provided for analysis.

The narrative infringement theory presented in the complaint is that the Defendant’s use of its EHR systems, which are certified to comply with the federal MU and CEHRT standards, inherently infringes the ’913 Patent (Compl. ¶9, ¶26). The complaint alleges that in order to qualify for federal funds and meet the program objectives, Defendant implemented and used infringing technologies that practice the patented method for managing and disbursing personal health information (Compl. ¶13, ¶16). The infringement allegation is not based on a detailed breakdown of a specific product's features, but rather on the functionalities mandated by the governmental standards with which the Accused Instrumentalities allegedly comply (Compl. ¶16).

  • Identified Points of Contention:
    • Scope Questions: The complaint's theory appears to equate compliance with the CEHRT standard with infringement of Claim 1. This raises the question of whether every system certified to the standard necessarily performs every step recited in the claim, as claimed. A central dispute may be whether the general-purpose "online repository" described in the patent can be read to cover the specific, highly regulated architecture of a hospital's EHR system.
    • Technical Questions: A key evidentiary question will be what proof Plaintiffs can offer that the Defendant's specific EHR system performs the claimed steps of "associating patient-established control settings" and "verifying the authorization information" in the manner required by the claim. The court may need to distinguish between the general requirements of the CEHRT standard and the actual technical implementation and operation of the Defendant's particular system.

V. Key Claim Terms for Construction

  • The Term: "patient-established control settings"

  • Context and Importance: The infringement theory depends on whether the access controls in the accused EHR systems qualify as "patient-established." The definition of this term—specifically, how directly a patient must set the controls and what level of granularity is required—is critical to determining if the accused systems meet this limitation.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent specification describes a user authorizing the release of information to an entity, which could support an argument that general patient consent forms or high-level privacy choices meet the "patient-established" requirement (e.g., ’913 Patent, col. 2:45-49).
    • Evidence for a Narrower Interpretation: The specification also describes assigning security levels to individual "information objects" and providing specific authorization keys for specific data types, suggesting a more active and granular role for the user in setting the controls (’913 Patent, col. 2:50-54; col. 10:11-25). This could support a narrower construction requiring direct, technical configuration by the patient.

  • The Term: "designated requester"

  • Context and Importance: Claim 1 requires restricting access to "one or more designated requesters." Whether this term requires a patient to name a specific individual or entity, or if it can cover a pre-approved class of users (e.g., "all treating physicians at this hospital"), will be significant.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term is used broadly in the patent, which may support a construction that includes categories of requesters that a patient agrees to, rather than just individually named ones.
    • Evidence for a Narrower Interpretation: The specification provides examples where a user gives specific authorization to a particular entity, such as a doctor's office or a travel agent (’913 Patent, col. 11:5-20). This could support an interpretation requiring the patient to explicitly identify each "designated requester."

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

  • A central issue for the court will be the validity of the complaint's infringement-by-standards theory: can Plaintiffs demonstrate that compliance with the federal CEHRT/Meaningful Use standard necessarily results in the practice of every limitation of Claim 1, or will the analysis require a specific, feature-by-feature comparison of the Defendant's actual EHR system against the claim language?
  • The case will also likely turn on a question of definitional scope: can the claim term "patient-established control settings," as described in a patent for a general-purpose data repository, be construed to cover the access and consent mechanisms within a modern, provider-managed Electronic Health Record system, where a patient's control may be more indirect or constrained by the system's architecture and regulatory requirements?