Optimnet LLC v. Amazon.com Services LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: OptimNet LLC (Texas)
  • Defendant: Amazon.com Services LLC (Delaware) and Amazon Web Services, Inc. (Delaware)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 7:25-cv-00532, W.D. Tex., 11/17/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendants maintain regular and established places of business in the district, including data centers, corporate offices, and fulfillment centers, and have purposefully directed infringing activities at the district.
• Core Dispute: Plaintiff alleges that Defendant’s suite of cloud computing and content delivery services, including Amazon EC2, S3, CloudFront, and CloudWatch, infringes four patents related to distributed data recovery, secure cloud computing, remote fault tracing, and content delivery network configuration.
• Technical Context: The technologies at issue concern foundational elements of large-scale, distributed cloud infrastructure, a market in which the accused AWS platform is a significant participant.
• Key Procedural History: The complaint states that the Asserted Patents originated from the Electronics and Telecommunications Research Institute (ETRI) in Korea and that Plaintiff OptimNet is the exclusive licensee. No other significant procedural events are mentioned in the complaint.

Case Timeline

Date	Event
2009-12-18	U.S. Patent No. 8,543,864 Priority Date
2011-11-03	U.S. Patent No. 8,788,846 Priority Date
2011-12-29	U.S. Patent No. 9,104,565 Priority Date
2012-04-05	U.S. Patent No. 9,112,934 Priority Date
2013-09-24	U.S. Patent No. 8,543,864 Issues
2014-07-22	U.S. Patent No. 8,788,846 Issues
2015-08-11	U.S. Patent No. 9,104,565 Issues
2015-08-18	U.S. Patent No. 9,112,934 Issues
2025-11-17	Complaint Filing Date

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

U.S. Patent No. 8,543,864 - “Apparatus and Method of Performing Error Recovering Process in Asymmetric Clustering File System”

Issued: September 24, 2013 (’864 Patent)

The Invention Explained

• Problem Addressed: The patent describes the problem of inefficient data recovery in large-scale storage systems where a central metadata server, upon detecting a failure on a data server, is solely responsible for recovering the lost data, creating a performance bottleneck (Compl. ¶52; ’864 Patent, col. 1:56-59).
• The Patented Solution: The invention proposes a method to "distributively process[] the recovery of a data error" (Compl. ¶52). Instead of relying on the central metadata server, the system offloads the recovery task to other data servers within the cluster. The metadata server identifies the failed data chunks and instructs other, operational data servers to collectively reconstruct the lost data using parity and other existing data chunks (’864 Patent, Abstract; col. 2:5-18).
• Technical Importance: This distributed recovery architecture is intended to enhance the speed, efficiency, and scalability of data restoration in large, fault-tolerant storage systems, which is crucial for maintaining high availability (’864 Patent, col. 1:62-66).

Key Claims at a Glance

• The complaint asserts infringement of the ’864 Patent’s claims generally, referencing an external exhibit for specifics (Compl. ¶55). Independent claim 1 is representative and recites:
  • A method of dividing a plurality of data servers into a plurality of data server groups.
  • Receiving a list of data chunks requiring recovery by one or more data servers in groups other than the one containing a failed server.
  • Requesting the necessary data for recovery from other data servers.
  • Recovering the erroneous chunk using the received data by the other data servers.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,788,846 - “Cloud Computing System and Cloud Server Managing Method Thereof”

Issued: July 22, 2014 (’846 Patent)

The Invention Explained

• Problem Addressed: The patent addresses the need for a "cloud computing system which protects privacy" (Compl. ¶67). Conventional cloud systems present challenges when users need to process sensitive or private data, as the infrastructure is shared and managed by a third party (’846 Patent, col. 1:28-32).
• The Patented Solution: The invention describes a cloud system with servers classified into two types: a "general server type" and a "secure server type." A client can submit a program where sensitive portions of the code are encrypted. The system's management server ensures that only a "secure server," which possesses the necessary decryption key, can decrypt and execute the sensitive code. The "general server" can only execute the non-encrypted parts of the program (’846 Patent, Abstract; col. 2:54-63).
• Technical Importance: This architecture provides a framework for confidential computing, enabling users to run workloads with sensitive components in a shared cloud environment with greater assurance that the code's privacy is maintained by restricting its execution to trusted, secure hardware or software environments.

Key Claims at a Glance

• The complaint asserts infringement of the ’846 Patent’s claims generally, referencing an external exhibit (Compl. ¶70). Independent claim 1 is representative and recites:
  • A cloud computing system with a management server and a plurality of servers, where each server is either a "secure server type" or a "general server type."
  • The "secure server type" decrypts an encrypted code portion of a program from a client.
  • The secret code is executed by the secure servers, while the general code is executed by the general servers.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,104,565 - “Fault Tracing System and Method for Remote Maintenance”

Issued: August 11, 2015 (’565 Patent)

Technology Synopsis

The patent describes a system for remote maintenance capable of "accurately and effectively tracing a fault that has occurred in a home network" by using resource and relationship information (Compl. ¶82). The method involves detecting faults, generating transactions for them, and tracing the faults through a map of resource relationships to identify the root cause (’565 Patent, col. 2:7-12).

Asserted Claims

The complaint does not identify specific asserted claims in its text, instead referencing Exhibit 6 (Compl. ¶85).

Accused Features

The complaint accuses Amazon CloudWatch and AWS X-Ray, which are monitoring, observability, and distributed tracing services used to identify performance bottlenecks and root causes of issues in customer applications (Compl. ¶¶24, 26, 84-85).

U.S. Patent No. 9,112,934 - “Apparatus and Method for Configuring On-Demand Content Delivering Overlay Network”

Issued: August 18, 2015 (’934 Patent)

Technology Synopsis

The patent discloses an apparatus for managing and configuring a content delivery network (CDN). The apparatus receives configuration requests and information from a service provider, manages information on available network resources, and based on both, configures a content delivery overlay network (Compl. ¶97).

Asserted Claims

The complaint does not identify specific asserted claims in its text, instead referencing Exhibit 8 (Compl. ¶100).

Accused Features

The complaint accuses Amazon CloudFront, which is described as a managed CDN service that accelerates content delivery by routing user requests to a global network of edge locations based on factors like latency (Compl. ¶¶13, 99).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are a suite of Amazon Web Services ("AWS") cloud products: Amazon Simple Storage Service (“S3”), Amazon Elastic Compute Cloud (“EC2”), the AWS Nitro System, Amazon CloudFront, Amazon CloudWatch, and Amazon CloudWatch Xray (Compl. ¶3).

Functionality and Market Context

The complaint describes these services as core to Amazon's cloud offerings and foundational infrastructure for many internet businesses (Compl. ¶¶10-12, 16-18).

• EC2 and Nitro System: EC2 provides resizable virtual computing capacity. The Nitro System is the underlying platform for modern EC2 instances that offloads virtualization functions to dedicated hardware, which is alleged to enhance performance and security (Compl. ¶¶4, 6-7).
• S3: A cloud object storage service designed for high durability, storing data redundantly across multiple "Availability Zones" (Compl. ¶¶19-20).
• CloudFront: A content delivery network (CDN) that delivers static and dynamic content by routing requests to a worldwide network of "edge locations" to minimize latency (Compl. ¶¶13-14).
• CloudWatch and X-Ray: Monitoring, observability, and distributed tracing services that collect metrics, logs, and traces to help customers debug applications and identify performance bottlenecks (Compl. ¶¶24, 26).

The complaint alleges that the AWS segment, which includes these services, is a key contributor to Amazon's profitability, with reported sales of $107.6 billion in 2024 (Compl. ¶9).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, external exhibits containing claim charts that detail its infringement theories (Compl. ¶¶55, 70, 85, 100). The narrative allegations suggest the following infringement rationales.

No probative visual evidence provided in complaint.

’864 Patent Infringement Allegations (Error Recovery)

The complaint alleges that Amazon's cloud services, particularly S3, infringe the ’864 Patent. The basis for this allegation appears to be S3's architecture, which stores data redundantly across physically separate locations (Availability Zones) to ensure durability (Compl. ¶20). The infringement theory may suggest that when a hardware failure occurs in one location, S3's process for automatically reconstructing or failing over to a redundant copy of the data constitutes the claimed "distributive[] processing" of error recovery performed by peer "data servers" rather than a central controller.

’846 Patent Infringement Allegations (Secure Computing)

The infringement allegations against EC2 and the AWS Nitro System appear to center on the Nitro System's security architecture. The complaint describes the Nitro System as an enhanced security model that offloads virtualization to dedicated hardware (Compl. ¶¶6-8). The infringement theory may posit that certain EC2 instances built on the Nitro System function as the claimed "secure server type," capable of executing encrypted, sensitive code provided by a customer, while other standard instances function as the "general server type."

V. Key Claim Terms for Construction

Term: "data server group" (from the ’864 Patent)

• Context and Importance: The definition of this term is critical for determining if the architecture of Amazon S3 maps onto the claimed invention. The dispute may turn on whether an AWS "Availability Zone" or another logical data grouping within S3 constitutes a "data server group" as contemplated by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 recites "dividing a plurality of data servers into a plurality of data server groups," which could be interpreted as covering any logical or physical partitioning of servers for redundancy or management.
  • Evidence for a Narrower Interpretation: The specification suggests a more specific structure, stating that a group’s server count may be "equal to a summed value of the number of file data divided in the unit of chunk... and the number of parities" for that data (’864 Patent, col. 2:19-24). This could be used to argue for a narrower construction tied to a specific RAID-like or erasure coding scheme.

Term: "secure server type" (from the ’846 Patent)

• Context and Importance: Infringement of the ’846 Patent hinges on whether the AWS Nitro System, or EC2 instances built upon it, fall within the definition of a "secure server type." Practitioners may focus on whether the technical operation of Nitro's security features matches the patent's description.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 defines the term functionally: a server that "decrypts an encrypted code of a program provided from a client." Plaintiff may argue that any AWS environment (such as a Nitro Enclave) that performs this function meets the claim limitation.
  • Evidence for a Narrower Interpretation: The specification describes a system where a client uses a public key to encrypt code and the secure server uses a corresponding private key to decrypt it (’846 Patent, Fig. 7). Defendant may argue that this specific public-key infrastructure (PKI) based decryption flow is a required element and that its Nitro security model, which may rely on different mechanisms like hardware roots of trust and attestation, operates differently.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for all four patents. The allegations are based on Defendants providing instructions, documentation, and marketing materials that allegedly "instruct and encourage their customers to use the Accused Instrumentalities in an infringing manner" (e.g., Compl. ¶¶56, 71, 86, 101).

Willful Infringement

The complaint alleges that Defendants have had knowledge of the patents and their infringement "through at least the filing and service of this Complaint" and have been "willfully blind" to the infringing nature of their products (e.g., Compl. ¶¶58, 73, 88, 103). The allegations primarily support a claim for post-suit willfulness.

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

This case presents several technical and legal questions concerning the application of patent claims to complex, modern cloud infrastructure. The outcome may turn on the court’s resolution of the following issues:

• A core issue will be one of definitional scope: can the term "secure server type", as defined in the ’846 Patent, be construed to cover the security architecture of the AWS Nitro System, or does the patent’s specification limit the term to a more specific cryptographic implementation that AWS does not practice?

• A second central question will be one of technical equivalence: does the automated data redundancy and recovery mechanism within Amazon S3 operate in a manner that meets the specific limitations of the "data server group" and distributed recovery process claimed in the ’864 Patent, or is there a fundamental mismatch in architectural design?

• A third question will be one of contextual application: can the claims of the ’565 Patent, which are described in the context of a "home/building network environment," be read to cover fault tracing in a distributed, enterprise-scale cloud computing environment like that monitored by Amazon CloudWatch and X-Ray?