Web 20 Tech LLC v. Baylor Scott & White Medical Center Hillcrest

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Web 2.0 Technologies, LLC (Texas) and Pennar Software Corporation (Virginia)
  • Defendant: Baylor Scott & White Medical Center - Hillcrest (Texas)
  • Plaintiff’s Counsel: Devlin Law Firm LLC
• Case Identification: 6:25-cv-00325, W.D. Tex., 07/30/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district where acts of infringement have allegedly occurred.
• Core Dispute: Plaintiffs allege that Defendant’s use of customized Electronic Health Record (EHR) systems infringes a patent related to methods for securely managing and sharing information in an online repository.
• Technical Context: The case concerns secure, multi-user electronic health record systems, a technology domain heavily influenced by federal regulations such as the HITECH Act, which incentivized the adoption of interoperable digital medical records.
• Key Procedural History: The patent-in-suit is a continuation-in-part of an application filed in August 2000, which itself is a continuation-in-part of an application filed in January 2000, giving it a priority date that significantly predates modern cloud computing and the widespread adoption of EHRs mandated by later federal initiatives.

Case Timeline

Date	Event
2000-01-07	U.S. Patent No. 9,886,594 Priority Date
2018-02-06	U.S. Patent No. 9,886,594 Issued
2018	EHR incentive program name changed to "Promoting Interoperability"
2025-07-30	Complaint Filed

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

• Patent Identification: U.S. Patent No. 9886594, "Online Electronic Health Record," issued February 6, 2018 (’594 Patent).

The Invention Explained

• Problem Addressed: The patent's background section describes the limitations of early internet-era information management, such as web page bookmarks that become "stale" or point to nonexistent data, and highlights a growing need for sharing information with others "in a controlled manner" (’594 Patent, col. 1:56-65).
• The Patented Solution: The invention proposes a centralized, secure online "personal library" where a primary "user" can store digital information objects (e.g., medical records). This user can then grant authorization to "requesters" (e.g., doctors, other providers) to access or update specific pieces of information based on assigned security levels, with the system managing and tracking these interactions (’594 Patent, Abstract; col. 2:30-44). The system is designed to create a verifiable audit trail for all access and modifications (’594 Patent, col. 12:44-49).
• Technical Importance: This architecture provides a method for patient-centric control over digital health information, allowing a patient to grant different levels of access to different healthcare entities from a single, secure repository (’594 Patent, col. 2:45-48).

Key Claims at a Glance

• The complaint asserts independent Claim 1 (Compl. ¶26).
• Essential elements of independent Claim 1 include:
  • A method performed by a server computer system.
  • Establishing accounts for a plurality of users.
  • Receiving a first user's medical information.
  • Receiving an update to that information from an authorized "second user."
  • Verifying the identity of the second user.
  • Receiving "approval or disapproval for the update from one or more users registered with the server computer system."
  • Storing identifying information of the users who approved or disapproved.
  • Storing the updated medical information.
  • "Automatically" sending the updated information to a "designated requester."
• The complaint does not explicitly reserve the right to assert dependent claims but notes infringement of "one or more claims" (Compl. ¶26).

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 systems are designed to comply with federal "Meaningful Use" ("MU") and Certified EHR Technology ("CEHRT") standards promulgated under the HITECH Act (Compl. ¶8, ¶10). Their alleged function is to manage electronic medical records in a way that improves care coordination, enhances efficiency, and ensures privacy, thereby allowing the Defendant to qualify for federal financial incentives and avoid penalties (Compl. ¶11-12). The complaint asserts these systems operate across all three stages of MU/CEHRT compliance (Compl. ¶15-16).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit 2, which was not filed with the complaint (Compl. ¶28). The following is a summary of the infringement theory presented in the body of the complaint.

Plaintiffs allege that Defendant's use of its EHR systems, which are certified to comply with federal MU and CEHRT standards, directly infringes at least Claim 1 of the ’594 Patent (Compl. ¶16, ¶26). The core of the infringement theory is that by implementing and using a certified EHR system to meet the objectives of the federal Promoting Interoperability program (formerly Meaningful Use), Defendant necessarily practices the patented method for managing and sharing electronic health records (Compl. ¶9, ¶13, ¶26). The complaint does not, however, map specific functions of the accused EHR systems to the individual limitations of Claim 1, instead relying on the allegation that compliance with the federal standards results in infringement (Compl. ¶16).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question will be whether merely using a CEHRT-compliant system to meet federal standards is sufficient to practice every element of Claim 1. The claim recites specific steps, such as receiving "approval or disapproval for the update from one or more users" and "automatically" sending the update to a "designated requester." The infringement analysis will likely turn on whether these specific actions are inherent to CEHRT compliance or represent distinct, optional functionalities not necessarily present in Defendant's systems.
  • Technical Questions: What evidence demonstrates that Defendant's EHR systems perform the specific, multi-party approval/disapproval workflow recited in Claim 1? The claim appears to describe a process where a "second user" (e.g., a specialist) submits an update, which is then subject to "approval or disapproval" by other registered users before being finalized and sent to a "designated requester." It is an open question whether this specific sequence of events occurs in Defendant's standard clinical workflows.

V. Key Claim Terms for Construction

• The Term: "receive approval or disapproval for the update from one or more users registered with the server computer system"

  • Context and Importance: This limitation appears to require a distinct validation step performed by a separate group of users after an initial update is submitted by a "second user." The construction of this term is critical because it may differentiate the claimed method from a simpler two-party (e.g., patient and doctor) record update. Practitioners may focus on this term to determine if it requires a specific, formal consensus or review mechanism that may not be present in a standard EHR system.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language uses the general term "users registered with the server computer system," which could be argued to encompass any authenticated user, potentially including the primary patient ("first user") or the provider making the update ("second user") acting in a different capacity (’594 Patent, col. 24:59-62).
    • Evidence for a Narrower Interpretation: Claim 1 presents this as a sequential step following the "second user" providing an update. This suggests the "one or more users" providing approval are distinct from the "second user" who submitted the update, implying a more complex, multi-actor workflow that may be limited to specific embodiments involving collaborative review (’594 Patent, col. 24:59-62).

• The Term: "automatically send the updated first user's medical information to a designated requester"

  • Context and Importance: The meaning of "automatically" and "designated requester" will be crucial. This limitation requires the system to perform an action without further user intervention directed to a pre-defined recipient. Infringement may depend on whether the accused systems have a configurable, trigger-based distribution feature or if they merely make information available for others to pull on demand.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes that "any modifications, updates, or changes are automatically notified to any authorized requesters," which could support a broad reading where any system-generated notification of a record change satisfies this element (’594 Patent, col. 3:3-5).
    • Evidence for a Narrower Interpretation: The claim requires sending the information itself, not just a notification. The specification also discusses users providing a "list of entities that should be notified for each change," suggesting the "designated requester" must be part of a specific, pre-configured distribution list for a particular information object, rather than any user with general access rights (’594 Patent, col. 12:61-63).

VI. Other Allegations

The complaint does not contain sufficient detail for analysis of indirect or willful infringement.

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

1. Evidentiary Sufficiency: A primary issue will be whether Plaintiffs can produce evidence showing that Defendant's EHR systems, as used in its daily operations, practice the highly specific, multi-step workflow of Claim 1. The complaint's reliance on general compliance with federal CEHRT standards may face challenges if those standards do not explicitly mandate the claimed sequence of receiving an update, seeking separate user approval/disapproval, and then automatically pushing the finalized information to a designated recipient.

2. Definitional Scope: The case will likely hinge on the construction of key claim terms. Can the claim limitation requiring "approval or disapproval for the update" be met by routine clinical chart review and sign-off, or does it require a distinct, formal voting or consensus mechanism as suggested by the claim's structure? Similarly, does the "automatically send" step read on general interoperability functions, or does it require a specific, pre-configured "push" notification system that transmits the actual medical data?

3. The Role of the "First User": A key technical question will be how the patient (the "first user") "authorizes" the "second user" in the accused system and whether the patient has the granular control over "designated requesters" as contemplated by the patent. The analysis will need to determine if Defendant's system architecture reflects the patent's user-centric authorization model or a more conventional provider-centric access control system.