TG 2006 Holdings LLC v. Siber Systems Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TG--2006 Holdings, LLC (Texas)
  • Defendant: Siber Systems Inc. (Virginia)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:24-cv-00174, E.D. Va., 02/02/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Virginia corporation with an established place of business in the district, where it has allegedly committed acts of patent infringement.
• Core Dispute: Plaintiff alleges that Defendant’s software products infringe two patents related to systems and methods for visually tracking information, such as tasks or projects, in a business environment.
• Technical Context: The technology at issue involves using a hierarchical folder-based graphical user interface to visually represent the status of tasks, where alerts or time-based triggers cause the visual attributes of folders to change, providing an at-a-glance project status.
• Key Procedural History: The patents-in-suit are continuations of an earlier patent application filed in 2004. The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patents.

Case Timeline

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

U.S. Patent No. 9,454,741 - System and method for tracking information in a business environment, issued Sep. 27, 2016

The Invention Explained

• Problem Addressed: The patent describes the process of tracking business information as potentially "time consuming and confusing," noting that if information is "confusingly displayed, it accomplishes nothing or defeats it own purpose" (’741 Patent, col. 1:17-23).
• The Patented Solution: The invention is a method for visually tracking information using a hierarchical folder structure (a "tree view") on a computer. In this system, "parent folders" can contain "child folders" or documents representing tasks. These folders have user-definable time triggers and deadlines. When a time-based event occurs (e.g., a deadline is missed), the "visual attributes of the parent folders are altered in response to conditions of the items contained within," providing an immediate visual cue about the status of the underlying task (’741 Patent, Abstract; col. 1:26-38).
• Technical Importance: The claimed method provides a way to visually manage complex, time-sensitive business processes by directly linking the status of individual tasks to a high-level, hierarchical visual display (’741 Patent, col. 1:45-48).

Key Claims at a Glance

• The complaint asserts infringement of one or more "Exemplary '741 Patent Claims" without specifying them; however, the patent contains only one claim (Compl. ¶12). The asserted claim is therefore Independent Claim 1.
• Independent Claim 1 recites a method with the following key steps:
  • establishing a parent folder and an associated child folder;
  • establishing an "in-house product" and associating it with at least one task, products, and labor codes;
  • associating a "first alert interval" and a "time trigger" with the task and product;
  • starting and monitoring a system clock;
  • changing the color of the child folder when the system time meets or exceeds the alert interval; and
  • changing the color of the parent folder when the child folder changes color.
• The complaint reserves the right to assert other claims, though none exist in the patent (Compl. ¶12).

U.S. Patent No. 9,805,323 - System and method for tracking information in a business environment, issued Oct. 31, 2017

The Invention Explained

• Problem Addressed: Similar to its parent patent, the '323 Patent addresses the need for a "visually clear and meaningful way" to track business information to avoid confusion and inefficiency (’323 Patent, col. 1:16-24).
• The Patented Solution: The invention describes a method for visually displaying the status of a "time critical task" using a parent-child folder hierarchy. A child folder is correlated with the task and has an associated "alert interval." When a system clock determines this interval has been exceeded, a visual "attribute" of the child folder changes. Critically, this change then triggers a corresponding change to an attribute of the parent folder, creating a cascading visual alert that propagates up the hierarchy (’323 Patent, Abstract; Claim 1).
• Technical Importance: This approach provides a dynamic, at-a-glance status update system for complex projects by visually propagating the status of low-level tasks up to high-level project folders, allowing a user to see high-level problems without needing to inspect every individual task (’323 Patent, col. 4:5-9).

Key Claims at a Glance

• The complaint asserts infringement of unspecified "Exemplary '323 Patent Claims" (Compl. ¶21). The patent contains two independent claims, Claim 1 and Claim 8.
• Independent Claim 1 recites a method with the following key steps:
  • establishing a parent folder and an associated child folder;
  • correlating the child folder with a "time critical task";
  • associating a "first alert interval" with the task;
  • starting and monitoring a system clock;
  • changing an "attribute" of the child folder when the system time meets or exceeds the alert interval; and
  • changing an "attribute" of the parent folder when the attribute of the child folder changes.
• Independent Claim 8 is substantively similar to Claim 1, but specifically recites "changing the color" of the folders rather than the more general "changing an attribute."
• The complaint reserves the right to assert dependent claims (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products or services. It refers to them generally as the "Exemplary Defendant Products" that are identified in claim charts attached as Exhibits 3 and 4, which were not filed on the public docket (Compl. ¶¶12, 21).

Functionality and Market Context

• The complaint does not provide any description of the accused products' functionality, features, or operation. It also makes no allegations regarding the products' commercial importance or market position (Compl. ¶¶12, 15, 21, 24).

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts (Exhibits 3 and 4) that were not publicly filed and provides no factual allegations in the body of the complaint detailing how the accused products infringe (Compl. ¶¶18, 27). The infringement theory is stated in a conclusory manner, asserting that the "Exemplary Defendant Products practice the technology claimed" by the patents-in-suit and "satisfy all elements" of the asserted claims (Compl. ¶¶17, 26).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Technical Questions: The central technical question will be evidentiary: what proof will Plaintiff offer to show that the unnamed accused products perform the specific steps of the asserted method claims? For example, what evidence demonstrates that the accused software performs the "cascading" change, where an attribute change in a parent folder is caused by an attribute change in a child folder, as required by the claims? A further question for the '741 Patent is whether the accused system uses concepts analogous to "in-house product" and "labor codes."
  • Scope Questions: The infringement analysis may raise a significant claim scope question regarding the term "in-house product" in Claim 1 of the ’741 Patent. The court may need to determine if this term is limited to the manufacturing context emphasized in the patent's specification or if it can be interpreted more broadly to cover any user-defined project in a general-purpose software application.

V. Key Claim Terms for Construction

• The Term: "in-house product" (’741 Patent, Claim 1)

  • Context and Importance: This term is a central element of the only claim in the ’741 Patent. Its construction will likely be critical in defining the scope of the patent. Practitioners may focus on this term because its interpretation could determine whether the patent is narrowly applicable to manufacturing-specific software or broadly applicable to general project management tools.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term is not explicitly defined with limiting language. The specification describes the invention in the general context of tracking "any number of tasks, events or conditions in a business enterprise" (’741 Patent, col. 1:27-29), which could support a reading beyond physical manufacturing.
    • Evidence for a Narrower Interpretation: The specification strongly implies a manufacturing context. It defines an "'in house product' (hereinafter IHP) is a product that a company manufactures that has specific tasks that lead to its completion" (’741 Patent, col. 3:31-34). The summary also illustrates the system in an environment of "production subassemblies or in-house products" and "purchasing of inventory and supplies" (’741 Patent, col. 1:38-44).

• The Term: "changing an attribute of the parent folder when the attribute of the child folder changes" (’323 Patent, Claim 1)

  • Context and Importance: This limitation describes the core "cascading alert" feature of the invention. The dispute will likely center on the nature of the causal link between the child folder's change and the parent folder's change.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain language suggests a dependency. A party could argue that any system where a parent folder's visual state reflects the aggregated status of its children (e.g., a project folder turning red because a sub-task becomes overdue) meets this element. The specification supports this, stating that a "parent folder's visual... representation is dependant upon the state of the child folders and their contents" (’323 Patent, col. 4:13-15).
    • Evidence for a Narrower Interpretation: A defendant might argue that the term requires a direct, event-driven causal mechanism. The specification states that "the tree view control sends notification messages to the parent folder when events occur within the child folder" (’323 Patent, col. 3:28-30). This language could be used to argue for a narrower construction requiring a specific inter-folder messaging protocol that is not present in all hierarchical status-display systems.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct and encourage end users to operate the accused products in a manner that infringes the patents-in-suit (Compl. ¶¶15-16, 24-25).
• Willful Infringement: The complaint alleges willful infringement based on knowledge of the patents obtained upon service of the complaint. It asserts that despite this actual knowledge, Defendant has continued its allegedly infringing activities (Compl. ¶¶14-15, 23-24).

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

• Evidentiary Sufficiency: As the complaint lacks specific factual allegations of infringement, a central issue will be whether Plaintiff can produce sufficient evidence to show that Defendant's unnamed products practice every element of the asserted method claims. The viability of the case will depend on the contents of the non-public infringement charts and subsequent discovery.
• Definitional Scope: The outcome may hinge on claim construction, particularly for the ’741 Patent. A key question for the court will be one of definitional scope: can the term "in-house product," which the specification defines in the context of a "product that a company manufactures," be construed to cover abstract projects or tasks in general-purpose management software?
• Causation: A key technical question for the infringement analysis will be one of causation: does the accused software's parent folder change its visual attribute because the child folder's attribute changed, as the claims require, or do the folders' attributes change independently in response to a common underlying data event, potentially breaking the causal link recited in the claims?