DCT

3:24-cv-00030

Synkloud Tech LLC v. Epic Systems Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:24-cv-00030, W.D. Wis., 01/17/2024
  • Venue Allegations: Venue is based on Defendant's alleged "regular and established place of business" in the Western District of Wisconsin, where it also allegedly commits acts of infringement.
  • Core Dispute: Plaintiff alleges that Defendant’s MyChart patient portal infringes a patent related to methods for a central server to update information across a user's communication devices, particularly when initiated by an authorized third party such as a caregiver.
  • Technical Context: The technology concerns centralized management and synchronization of user data across multiple devices, a foundational concept for modern cloud-based services in consumer and enterprise sectors, including healthcare.
  • Key Procedural History: The complaint notes that Plaintiff acquired the patent-in-suit by assignment on May 3, 2019. No other significant procedural history, such as prior litigation or administrative proceedings involving the patent, is mentioned in the complaint.

Case Timeline

Date Event
2004-05-20 ’383 Patent Priority Date
2014-10-07 ’383 Patent Issue Date
2019-05-03 Plaintiff acquires ’383 Patent by assignment
2024-01-17 Complaint Filing Date

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

U.S. Patent No. 8,856,383 - Systems And Methods For Controlling Information And Use Of Communications Devices Through A Central Server, issued October 7, 2014

The Invention Explained

  • Problem Addressed: The patent's background section describes the difficulty and time-consuming nature of individually updating information, such as contacts and calendar items, on multiple communication devices (e.g., cell phones, PDAs). It further identifies a need for a system that allows a third party, such as a caregiver, to program this information on behalf of a user who may lack technical expertise (’383 Patent, col. 1:25-44).
  • The Patented Solution: The invention proposes a system centered on a "call-processing center" with a server that links a user's various communication devices ('383 Patent, col. 1:45-56). An authorized party, such as a "caregiver" or "health care provider," can access a user's account—for instance, through a website—to program information like appointment reminders. The server then transmits this information to the user's devices, which can then provide alerts ('383 Patent, col. 4:46-65). The system is framed as facilitating communication for users like seniors by enabling remote management by trusted parties ('383 Patent, col. 3:18-24).
  • Technical Importance: The described technical approach sought to simplify device management by centralizing control and enabling remote administration, particularly for user groups like seniors who might benefit from assistance from family or healthcare providers ('383 Patent, col. 1:35-44).

Key Claims at a Glance

  • The complaint asserts independent claim 1 of the ’383 Patent (Compl. ¶¶ 14, 15).
  • The essential elements of independent claim 1 include:
    • A method of updating information on a first party's plurality of communication devices.
    • Establishing a user account for the first party on a call-processing system with a central server.
    • Granting a second party, who is a "caregiver," restricted access to the first party's account.
    • Receiving information, comprising "device configuration parameters," from the second party at the central server.
    • Transmitting this information from the server to the first party's communication devices to update them.
    • The central server initiating an alert on the first party's devices to notify them of the update.
    • A specified list of communication devices, including cellular phones and desktop computers.
    • A specified list of device configuration parameters, including contacts, calendar events, and reminders.
  • The complaint does not explicitly reserve the right to assert other claims but focuses its allegations on "at least claim 1" (Compl. ¶15, 19, 22).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is Defendant’s MyChart product (Compl. ¶15).

Functionality and Market Context

  • MyChart is described as an "online portal that connects patients with their physicians and their health records, including appointments, test results, prescriptions, and more" (Compl. ¶10). The complaint alleges that infringement occurs when Defendant tests its products or provides "cloud-based hosting to healthcare provider entities," suggesting the infringement theory centers on the backend operation of the MyChart system (Compl. ¶15).
  • The complaint alleges that in 2022, hospitals using Defendant's software held medical records for 78% of patients in the United States (Compl. ¶9).

IV. Analysis of Infringement Allegations

’383 Patent Infringement Allegations

The complaint references a claim chart in an "Exhibit B" to detail its infringement allegations; however, this exhibit was not provided with the complaint (Compl. ¶17, 26). The infringement theory, inferred from the complaint's text and the patent's claims, appears to be that the MyChart system performs the method of Claim 1. This theory suggests that a patient ("first party") has a MyChart account and can grant proxy access to a family member or other individual ("second party" or "caregiver"). This caregiver can then access the account to manage health information (e.g., appointments), which the system then communicates to the patient's devices (e.g., a smartphone with the MyChart app) along with associated notifications.

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions: A central dispute may concern whether the data managed by the MyChart system (e.g., medical appointments, test results) falls within the scope of "device configuration parameters" as recited in the claim. The claim defines this term with a specific list including "contacts, calendar events, reminders, alerts, ring or alert tones, volumes, snooze parameters, speed dial keys, and outgoing answering messages" (’383 Patent, col. 11:35-41). The analysis may turn on whether managing health information is analogous to managing these enumerated device-level settings.
  • Technical Questions: A question may arise regarding the claim limitation requiring the "central server [to initiate] an alert... to notify the first party of the updated information made at the central server." It remains to be seen what evidence will show that a general notification from the MyChart system (e.g., "You have a new message") performs the specific function of notifying the user about an update made by the second party, as required by the claim.

V. Key Claim Terms for Construction

The Term: "caregiver"

  • Context and Importance: Claim 1 requires that the "second party" granted access to the account be a "caregiver" (’383 Patent, col. 11:14-15). The MyChart system allows for proxy access to be granted to various individuals. Practitioners may focus on this term because the applicability of the claim to the accused system depends on whether any user with proxy access qualifies as a "caregiver" as the patent contemplates.
  • Evidence for a Broader Interpretation: The term is not explicitly defined in the patent, which could support a plain and ordinary meaning encompassing any individual providing assistance or care, a role that a MyChart proxy may fulfill.
  • Evidence for a Narrower Interpretation: The specification frequently contextualizes the invention with examples of an "adult child caregiver to a senior parent" (’383 Patent, Abstract; col. 3:18-20). This consistent framing could be used to argue for a narrower construction limited to informal, familial caregiving relationships.

The Term: "device configuration parameters"

  • Context and Importance: The infringement theory rests on mapping the health data managed in MyChart to this claim term. Its construction will therefore be critical to determining infringement.
  • Evidence for a Broader Interpretation: The claim includes "information regarding contacts, calendar events, reminders, alerts" in its definition of the term (’383 Patent, col. 11:36-37). Plaintiff may argue that appointment information in MyChart constitutes "calendar events" and "reminders," bringing it within the claim's scope.
  • Evidence for a Narrower Interpretation: The claim defines the term using a Markush group that also lists parameters such as "ring or alert tones, volumes, snooze parameters, speed dial keys, and outgoing answering messages" (’383 Patent, col. 11:35-41). A party could argue that this list as a whole characterizes the term as relating to the operational settings of a communication device itself, rather than the substantive application-level data (like medical records) that MyChart manages.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges both contributory and induced infringement under 35 U.S.C. § 271(c) and § 271(b), respectively. The inducement theory is based on allegations that Defendant advises, encourages, and provides "instructions or manuals" to its customers (healthcare providers and patients) that lead them to use the MyChart product in a manner that directly infringes Claim 1 (Compl. ¶¶ 22-23). The complaint also alleges the accused products are "designed specifically for use" in an infringing manner (Compl. ¶21).

Willful Infringement

  • The allegation of willfulness is based on Defendant’s alleged knowledge of the ’383 Patent "since at least the filing of this complaint" (Compl. ¶24). The complaint does not allege any pre-suit knowledge.

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

  • A core issue will be one of definitional scope: can the term "device configuration parameters," which the patent defines with a list of examples dominated by device-level settings like ring tones and volumes, be construed to cover the management of application-level patient health data, such as appointments and test results, within the accused MyChart system?
  • A second central question will be one of functional mapping: does the MyChart system, which facilitates proxy access to a patient’s health records, meet the claim's specific requirement that a "caregiver" provides information that is then transmitted to the patient's devices with a corresponding alert notifying the patient of the update made by that specific party?
  • Finally, the dispute may raise questions of technological evolution: how will claim limitations drafted in the context of early 2000s technology, such as the enumerated list of "communication devices," be applied to the architecture of a modern, integrated, cloud-based healthcare platform and its associated smartphone applications?