Inquisient Inc

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Entered
Case
Description
07/31/24
[SEALED] Letter to The Honorable Christopher J. Burke from Jennifer Ying regarding Opposition to Plaintiff InQuisient, Inc.'s Motion to Strike (D.I. 294) - re 294 MOTION to Strike Portions of Defendant's Expert Reports and Opinions, 295 Letter,. (Attachments: # 1 Exhibits 1-23)(Ying, Jennifer) (Entered: 07/31/2024)
07/31/24
STIPULATION TO EXTEND TIME for Plaintiff to file a redacted version of its opening letter in support of its motion to strike (D.I. 295) to August 2, 2024 - filed by ServiceNow, Inc.. (Ying, Jennifer) (Entered: 07/31/2024)
07/31/24
[SEALED] EXHIBIT re 326 Answering Brief in Opposition, Exhibit 2 by InQuisient Inc.. (Attachments: # 1 Exhibit 2)(Reeves, Taylor) (Entered: 07/31/2024)
07/31/24
ANSWERING BRIEF in Opposition re 285 MOTION for Reconsideration of the July 3, 2024 Order (D.I. 278) re 278 Oral Order,,,,,,,,, filed by InQuisient Inc..Reply Brief due date per Local Rules is 8/7/2024. (Attachments: # 1 Exhibit 1, # 2 Exhibit 3)(Reeves, Taylor) (Entered: 07/31/2024)
07/31/24
ORAL ORDER: With regard to the parties' motions for claim construction, (D.I. 102 ; D.I. 104 ), the Court now addresses the additional disputes as to and the construction of the term “element attribute module.” Defendant argues only that the term is indefinite because of Plaintiff’s disavowal of standard object-oriented structures. (D.I. 100 at 74-75; D.I. 101 at JA0000346, at paras. 60-62) As the Court has previously explained, however, (D.I. 320 ), it does not agree with Defendant’s position regarding the prosecution history. It therefore concludes that the term should be afforded its plain and ordinary meaning. Ordered by Judge Christopher J. Burke on 7/31/2024. (smg) (Entered: 07/31/2024)
07/31/24
ORAL ORDER: With regard to the parties' motions for claim construction, (D.I. 102 ; D.I. 104 ), the Court now addresses the additional disputes as to and the construction of the term “element attribute module.” Defendant argues only that the term is indefinite because of Plaintiff’s disavowal of standard object-oriented structures. (D.I. 100 at 74-75; D.I. 101 at JA0000346, at paras. 60-62) As the Court has previously explained, however, (D.I. 320 ), it does not agree with Defendant’s position regarding the prosecution history. It therefore concludes that the term should be afforded its plain and ordinary meaning. Ordered by Judge Christopher J. Burke on 7/31/2024. (smg) (Entered: 07/31/2024)
07/31/24
ORAL ORDER: With regard to the parties' motions for claim construction, (D.I. 102 ; D.I. 104 ), the Court now addresses the additional disputes as to and the construction of the term “tuple module.” Here, the parties dispute whether the term should be construed to mean “[a] module that defines and stores relationships between data according to the type of data[,]” as Defendant proposes. (D.I. 100 at 63-66) In support of its proposal, Defendant points to a portion of the specification that explains that the “tuple table has been separated to store information about the system schema” and the “relationship is created according to a type[.]” (Id. at 65 (citing 468 patent, col. 10:30-35)) The Court rejects Defendant’s proposal because: (a) the claim language already tells us “the necessary contents and functions of the respective tuple modules” and (b) Defendant provides no support for limiting the tuple module to an embodiment discussed in the specification. (Id. at 66; see also 468 patent, col. 10:24-30 (describing “[e]mbodiments of the present invention” that “include a tuple table 144” that has the characteristics called out in Defendant’s proposed construction) (emphasis added); 468 patent, col. 16:51-54) Having resolved the disputes between the parties, and because Plaintiff’s proposed construction is redundant of the claim language itself, the Court concludes that the term should simply be afforded its plain and ordinary meaning. Ordered by Judge Christopher J. Burke on 7/31/2024. (smg) (Entered: 07/31/2024)
07/31/24
ORAL ORDER: With regard to the parties' motions for claim construction, (D.I. 102 ; D.I. 104 ), the Court now addresses the additional disputes as to and the construction of the term “tuple module.” Here, the parties dispute whether the term should be construed to mean “[a] module that defines and stores relationships between data according to the type of data[,]” as Defendant proposes. (D.I. 100 at 63-66) In support of its proposal, Defendant points to a portion of the specification that explains that the “tuple table has been separated to store information about the system schema” and the “relationship is created according to a type[.]” (Id. at 65 (citing 468 patent, col. 10:30-35)) The Court rejects Defendant’s proposal because: (a) the claim language already tells us “the necessary contents and functions of the respective tuple modules” and (b) Defendant provides no support for limiting the tuple module to an embodiment discussed in the specification. (Id. at 66; see also 468 patent, col. 10:24-30 (describing “[e]mbodiments of the present invention” that “include a tuple table 144” that has the characteristics called out in Defendant’s proposed construction) (emphasis added); 468 patent, col. 16:51-54) Having resolved the disputes between the parties, and because Plaintiff’s proposed construction is redundant of the claim language itself, the Court concludes that the term should simply be afforded its plain and ordinary meaning. Ordered by Judge Christopher J. Burke on 7/31/2024. (smg) (Entered: 07/31/2024)
07/31/24
ORAL ORDER: With regard to the parties' motions for claim construction, (D.I. 102 ; D.I. 104 ), the Court now addresses the additional disputes as to and the construction of the term “element relation module.” Defendant asserts that the term is indefinite because Plaintiff accuses the same table and columns for both the “element relation module” and the “tuple module.” (D.I. 100 at 62-63) But as discussed above with respect to “class attribute module,” this argument (about what aspects of Defendant’s accused products are alleged to read on certain claim limitations) is premature. Thus, the Court will not consider it at the claim construction stage. The parties also dispute whether the “element relation module” must “define[]... relationships between elements[,]” as Defendant includes in its proposed construction. (Id. at 61-62) There is no basis to impose this requirement. Defendant makes no specific argument in support of the requirement in its briefing. And while claim 1 of the 468 patent does flatly state that other claimed modules “define” certain things, the claim includes no such requirement for the “element relation module.” (Id.; 468 patent, col. 16:24-41) Having resolved the disputes between the parties, and because Plaintiff’s proposed construction is redundant of the claim language itself, the Court concludes that the term should simply be afforded its plain and ordinary meaning. Ordered by Judge Christopher J. Burke on 7/31/2024. (smg) (Entered: 07/31/2024)
07/31/24
ORAL ORDER: With regard to the parties' motions for claim construction, (D.I. 102 ; D.I. 104 ), the Court now addresses the additional disputes as to and the construction of the term “element relation module.” Defendant asserts that the term is indefinite because Plaintiff accuses the same table and columns for both the “element relation module” and the “tuple module.” (D.I. 100 at 62-63) But as discussed above with respect to “class attribute module,” this argument (about what aspects of Defendant’s accused products are alleged to read on certain claim limitations) is premature. Thus, the Court will not consider it at the claim construction stage. The parties also dispute whether the “element relation module” must “define[]... relationships between elements[,]” as Defendant includes in its proposed construction. (Id. at 61-62) There is no basis to impose this requirement. Defendant makes no specific argument in support of the requirement in its briefing. And while claim 1 of the 468 patent does flatly state that other claimed modules “define” certain things, the claim includes no such requirement for the “element relation module.” (Id.; 468 patent, col. 16:24-41) Having resolved the disputes between the parties, and because Plaintiff’s proposed construction is redundant of the claim language itself, the Court concludes that the term should simply be afforded its plain and ordinary meaning. Ordered by Judge Christopher J. Burke on 7/31/2024. (smg) (Entered: 07/31/2024)