DCT

7:25-cv-00020

FrameTech LLC v. Oracle Corp

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Key Events
Complaint
complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00020, W.D. Tex., 01/21/2025
  • Venue Allegations: Venue is asserted based on Defendant Oracle Corporation maintaining an established place of business in the Western District of Texas.
  • Core Dispute: Plaintiff alleges that unspecified products and services of the Defendant infringe a patent related to methods for automating the installation and configuration of mainframe computer operating systems.
  • Technical Context: The technology concerns automating complex, time-consuming mainframe computer setup procedures, a task traditionally requiring highly-skilled systems programmers.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2002-10-02 Priority Date, U.S. Patent No. 7,194,737
2007-03-20 Issue Date, U.S. Patent No. 7,194,737
2025-01-21 Complaint Filed

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

U.S. Patent No. 7,194,737 - "SYSTEM AND METHOD FOR EXPEDITING AND AUTOMATING MAINFRAME COMPUTER SETUP"

  • Patent Identification: U.S. Patent No. 7,194,737, issued March 20, 2007.

The Invention Explained

  • Problem Addressed: The patent describes the installation and configuration of mainframe operating systems as an "arduous task" that is "considerably complex and time-consuming," typically requiring several days of work by a "skilled mainframe computer systems programmer" (’737 Patent, col. 1:30-44). It notes that the pool of such programmers is aging and shrinking, making it difficult to efficiently install new technologies (’737 Patent, col. 2:1-17).
  • The Patented Solution: The invention automates this process using a client computer, such as a PC, connected to a mainframe. The system first performs a "discovery" to gather "profile information" about the target mainframe's existing hardware and software configuration (’737 Patent, col. 2:27-35). It then uses this information to generate a new "base operating system," transfer it to the mainframe, and automatically customize it to replicate the prior environment, preparing the mainframe for an Initial Program Load (IPL), or "boot-up" (’737 Patent, Abstract; Fig. 2).
  • Technical Importance: The stated purpose of this automation is to decrease the time and operator skill level required for mainframe operating system upgrades (’737 Patent, Abstract).

Key Claims at a Glance

  • The complaint alleges infringement of "one or more claims" but does not specify them in the body of the document, instead referring to an external exhibit (Compl. ¶11). Independent claim 1 is representative of the asserted technology.
  • Independent Claim 1: A method for upgrading a mainframe operating system, comprising the steps of:
    • Automatically receiving source profile information representing an existing hardware and software configuration on the mainframe.
    • Using a client computer system to generate a base operating system comprising operating system software components.
    • Transferring the base operating system from the client computer system to the mainframe computer.
    • Using the client computer system to automatically customize the base operating system on the mainframe to incorporate elements from the source profile information.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused product, method, or service by name (Compl. ¶11). It refers generally to "Defendant Products" and "Exemplary Defendant Products" identified in charts within an "Exhibit 2," which was not included with the filed complaint (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It makes only the conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '737 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are contained entirely within an external document, "Exhibit 2," which is incorporated by reference but was not filed with the court (Compl. ¶17). As such, a detailed claim chart comparison is not possible based on the provided documents. The complaint alleges that Defendant directly infringes by making, using, selling, and offering for sale the accused products, and also by having its employees internally test and use them (Compl. ¶11-12).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

  • The Term: "base operating system"

    • Context and Importance: This term defines the core object being installed and customized. Its construction is critical to determining whether the patent's scope is limited to traditional, full-featured mainframe operating systems (e.g., z/OS) or could be read more broadly to cover other foundational software platforms or environments that Defendant might offer for mainframe computers.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent claims do not explicitly define the term, referring generally to a "configuration of operating system software components" (’737 Patent, col. 12:58-60). This could support an argument that it covers any fundamental software layer, not just a specific commercial OS.
      • Evidence for a Narrower Interpretation: The specification repeatedly uses IBM's OS/390 and z/OS as the primary examples of the operating system being upgraded (’737 Patent, col. 3:36-37; col. 8:13). The detailed description is replete with terminology specific to this environment, such as "Initial Program Load ('IPL')," "SYS1.LINKLIB," and "JES2," suggesting the invention was conceived for and is directed to this specific class of traditional mainframe operating systems (’737 Patent, col. 1:36, col. 7:36-37, col. 8:45-46).

  • The Term: "using a client computer system to generate a base operating system"

    • Context and Importance: This limitation defines both the location (client computer) and the action (generate). The infringement analysis may turn on whether an accused Oracle process performs this generation step on a client system, as opposed to a process that is performed entirely on the mainframe or involves downloading a pre-generated image from a central server. Practitioners may focus on this term because it establishes a specific client-server architecture for the inventive method.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The term "generate" is not explicitly defined, which could allow for arguments that it encompasses a wide range of activities, including the client computer merely orchestrating the assembly of components that reside elsewhere.
      • Evidence for a Narrower Interpretation: The patent’s process flowcharts consistently depict a "Desktop PC" performing discrete steps that precede actions on the "Mainframe" (’737 Patent, Figs. 4A-4D). For instance, the client system "supplies" information to the mainframe to create new system volumes and files, and later "uploads" images to the mainframe, implying the client is the source of the generation and transfer process (’737 Patent, col. 8:6-8; col. 10:1-3). This supports a reading where the client actively creates or packages the base OS before transfer.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant sells its products with "product literature and website materials" that instruct and encourage end users to use the products in an infringing manner (Compl. ¶14-15).
  • Willful Infringement: Willfulness allegations are based on post-suit conduct. The complaint asserts that the filing and service of the complaint itself provides Defendant with "actual knowledge of infringement" and that any continued infringing activity thereafter is willful (Compl. ¶13-14). No facts suggesting pre-suit knowledge are alleged.

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

  1. Evidentiary Sufficiency: The central threshold issue is evidentiary: given the complaint’s failure to identify any accused product or provide the "Exhibit 2" claim charts, the first question for the court will be whether the plaintiff can substantiate its claims with specific facts showing what Oracle products are accused and how they allegedly function.
  2. Definitional Scope: A core legal issue will be one of definitional scope: can the term "base operating system," which is described in the patent in the context of traditional mainframe systems like z/OS, be construed to cover the specific software environments or platforms provided by Oracle for mainframe hardware?
  3. Architectural Equivalence: A key technical question will concern architectural equivalence: do the accused Oracle products, once identified, practice the specific client-centric architecture required by the claims, particularly the step of "using a client computer system to generate" the operating system before its transfer to the mainframe, or do they employ a fundamentally different technical process?