DataCloud Tech LLC v. Staples Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DataCloud Technologies, LLC (Georgia)
  • Defendant: Staples, Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt, LLC; Rozier Hardt McDonough PLLC
• Case Identification: 1:25-cv-00914, D. Del., 10/14/2025
• Venue Allegations: Venue is based on Defendant being a Delaware corporation and its alleged business activities, including the acts of infringement, within the District of Delaware.
• Core Dispute: Plaintiff alleges that Defendant’s e-commerce platforms, specifically the Staples Advantage Mobile App and the Staples.com website infrastructure, infringe three patents related to data organization, anonymous network communication, and remote file access.
• Technical Context: The patents relate to foundational methods for managing the flow and organization of digital information between providers and users in networked computer systems.
• Key Procedural History: The complaint states that Plaintiff sent a series of eight notice letters and emails to Defendant's Chief Legal Counsel regarding the patent portfolio beginning on December 15, 2022, which may be used to support allegations of willful infringement.

Case Timeline

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

U.S. Patent No. 6,651,063 - “Data Organization And Management System And Method”

The Invention Explained

• Problem Addressed: The patent's background describes a society "inundated with information" and notes that individuals lack a "reliable, easy-to-use, centralized information storage system" (’063 Patent, col. 1:42-44). Existing computer systems were described as "cumbersome," requiring users to manually create categories and place information into them ’063 Patent, col. 1:53-60
• The Patented Solution: The invention proposes a system where the provider of information pre-categorizes it before sending it. This information, contained in an "information pack," is sent to a recipient's "User Data Repository" and is automatically filed into a location corresponding to the provider-specified category ’063 Patent, col. 2:37-43 The complaint references a schematic diagram from the patent illustrating the data flow between a Provider, a Recipient, and a processing station Compl. ¶24 ’063 Patent, Fig. 1 The recipient can then manage the information, create custom categories, or block information from specific providers ’063 Patent, col. 4:7-22
• Technical Importance: This approach shifted the primary burden of data categorization from the end-user to the information provider, aiming to streamline information management for the recipient ’063 Patent, col. 2:2-6

Key Claims at a Glance

• The complaint focuses its infringement analysis on independent claim 4 but notes that all five claims, each of which is independent, are asserted Compl. ¶39
• Independent Claim 4 recites a method with essential elements including:
  • storing information in an "information pack";
  • associating the pack with a "user destination address" and a "category identifier";
  • associating the pack with a "provider identifier";
  • communicating the pack over a network to a user data repository;
  • locating the pack in a repository location corresponding to the "category identifier";
  • creating a "custom location" in the repository;
  • placing the pack in the "custom location";
  • associating a "custom category identifier" with the pack; and
  • "sending a custom category signal" to a "processing station" to analyze subsequent information packs from that provider and place them in the custom location.

U.S. Patent No. 7,209,959 - “Apparatus, System, And Method For Communicating To A Network Through A Virtual Domain Providing Anonymity To A Client Communicating On The Network”

The Invention Explained

• Problem Addressed: The patent describes how standard internet protocols like HTTP can expose a user's identity and activity, leading to privacy threats such as unwanted emails and tracking cookies (’959 Patent, col. 1:57-67). Existing solutions like proxy servers were deemed insufficient, as they merely substitute one identity for another that is "ultimately assigned back to the same client" ’959 Patent, col. 2:20-23
• The Patented Solution: The patent discloses a "DNS Misdirection" system composed of three distinct algorithmic components: a "deceiver," a "controller," and a "forwarder" ’959 Patent, col. 2:32-36 As depicted in a system architecture diagram referenced in the complaint, a client's request is intercepted by the deceiver, which coordinates with the controller to resolve the destination address Compl. ¶70 ’959 Patent, Fig. 1 The controller then establishes a session with a forwarder and returns the forwarder's IP address to the client, masquerading as the destination. This creates a virtual domain where neither the client nor the destination server is aware of the other's true identity or the intermediary's role ’959 Patent, col. 4:20-52
• Technical Importance: The invention proposed a multi-component architecture to create a more robust anonymous browsing environment than a simple proxy, by isolating client and server activity within a temporary, virtual session ’959 Patent, col. 2:46-51

Key Claims at a Glance

• The complaint focuses on independent claim 1 and also identifies independent claim 16, reserving the right to assert other claims Compl. ¶83-84
• Independent Claim 1 recites a method with essential elements including:
  • setting up a "forwarding session" using a "forwarder" disposed between the client and destination server;
  • the session is set up such that "neither the client or the destination server is aware of the employment of the forwarder";
  • employing a "controller" that queries a domain name server and initiates communication with the "forwarder";
  • employing a "deceiver" that receives the client's request and initiates the "controller" to query the domain name server; and
  • initiating the "forwarding session" in response to the "controller" receiving the answer from the domain name server.

U.S. Patent No. 7,398,298 - “Remote Access And Retrieval Of Electronic Files”

• Technology Synopsis: The patent addresses shortcomings in existing systems where users lacked remote control over their data's directory structure and could not confirm data delivery (Compl. ¶106, ¶108; ’298 Patent, col. 2:6-31). The patented solution provides a system where a remote computing application, operating on a server, allows authenticated users to access and manage data and directory structures and receive notifications confirming data delivery to intended targets Compl. ¶109 ’298 Patent, col. 4:28-34 The complaint references a figure illustrating the operation of this computing application Compl. ¶110 ’298 Patent, Fig. 3
• Asserted Claims: The complaint focuses on independent claim 13, and also identifies independent claims 1 and 18 Compl. ¶118-119
• Accused Features: The complaint alleges that the Staples Advantage app provides remote management capabilities, allowing administrators to control user access and permissions, manage profiles and data directories, and receive notifications about account activity Compl. ¶129

III. The Accused Instrumentality

Product Identification

The Staples Advantage Mobile App and the Staples' website infrastructure (www.staples.com) (Compl. ¶50, ¶93).

Functionality and Market Context

• The complaint describes the Staples Advantage Mobile App as an application accessible via the Google Play Store for Android phones Compl. ¶51 It is alleged to provide "remote management capabilities," allowing administrators to control user access and permissions across devices, manage user profiles and data directories in real time, and receive instant notifications of account activity Compl. ¶129
• The Staples' website infrastructure is alleged to operate by creating a direct TCP connection where neither the client nor the destination server is aware of an intermediary forwarder Compl. ¶94 The complaint alleges this system resolves domain names by querying a controller to find a private IP address for a destination server, particularly when multiple subdomains share a public IP address Compl. ¶94
• The complaint does not provide sufficient detail for analysis of the products' commercial importance or market positioning.

IV. Analysis of Infringement Allegations

’063 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The infringement theory raises several questions of claim scope. Can the term "information pack", described in the patent with examples like manuals and receipts, be construed to read on an executable "APK file"? Does a cryptographic "digital signature" function as a "custom category identifier" in the manner contemplated by the patent, which provides examples like user-named folders (e.g., "My Medicine")?
• Technical Questions: What evidence demonstrates that the process of "updating the app" performs the specific function of "sending a custom category signal to a processing station" for the purpose of analyzing subsequent provider identifiers and automatically routing future information packs? The complaint's allegation appears to be a high-level analogy rather than a direct technical mapping.

’959 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: Do standard, off-the-shelf web hosting components like load balancers or reverse proxies constitute the specific, coordinated, and functionally distinct "deceiver", "controller", and "forwarder" architecture claimed by the patent?
• Technical Questions: The patent describes a specific sequence of communications between the three claimed components. A key question for the court will be whether the accused Staples infrastructure actually performs this sequence or operates under a different, more conventional architectural logic. The complaint's allegations are based on high-level observations from developer tools, which may not reveal the full backend process.

V. Key Claim Terms for Construction

U.S. Patent No. 6,651,063

• The Term: "information pack"
• Context and Importance: The infringement theory for the ’063 patent hinges on equating an Android application package ("APK file") with an "information pack". The construction of this term is therefore central, as a narrow definition focused on documents and data, rather than executable code, could undermine the entire infringement allegation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is broad, referring to "storing information to be provided in an information pack" without express limitation on the type of information col. 23:29-30
  • Evidence for a Narrower Interpretation: The specification's examples of what an "information pack" contains are consistently data- or document-based, such as a "manual, maintenance schedule, receipt, DMV registration forms, warranty, etc." ’063 Patent, Fig. 5 and information about prescription drugs ’063 Patent, Fig. 2 This may support an interpretation limited to user-consumable data rather than executable software.

U.S. Patent No. 7,209,959

• The Term: "deceiver", "controller", "forwarder"
• Context and Importance: These three terms define the core architecture of the invention. Practitioners may focus on these terms because the infringement case depends on functionally mapping them onto what may be a standard web hosting environment. Whether these terms are construed as requiring three structurally distinct software components or merely a set of functions that can be performed by a more integrated system will be critical.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states the invention is "algorithmic" col. 6:41 and that the three components "can all be on a single computer, or on separate computers" col. 5:40-41, which may support a more functional interpretation not tied to a specific hardware or software structure.
  • Evidence for a Narrower Interpretation: The claims and the detailed description recite a specific, ordered sequence of operations between these three named entities (e.g., the deceiver initiates the controller, the controller initiates the forwarder). This step-by-step interaction, illustrated in Figure 1 and described in the specification, may support a narrower construction requiring a system that operates according to this specific tripartite logic ’959 Patent, col. 3:46-4:24

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating Defendant contributes to and induces infringement by third parties, including customers Compl. ¶9 For the '063 and '298 patents, this is premised on Staples providing the Staples Advantage Mobile App, which allegedly causes administrators and users to perform the infringing methods (Compl. ¶50, ¶128). For the '959 patent, this would relate to customers using the allegedly infringing website infrastructure Compl. ¶93
• Willful Infringement: The complaint alleges that Defendant had pre-suit knowledge of the Asserted Patents and its infringement. This allegation is based on a series of eight specific communications, beginning with a letter sent via email on December 15, 2022, to Defendant's Chief Legal Counsel, nearly three years before the complaint was filed Compl. ¶13

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

• A core issue will be one of definitional scope: can terms from the ’063 patent like "information pack" and "custom category identifier", which are described in the context of organizing user data and documents, be construed broadly enough to cover fundamentally different technical constructs like an executable "APK file" and its "digital signature"?
• A central dispute for the ’959 patent will be one of architectural mapping: do the components of a modern, standard e-commerce website perform the specific, coordinated functions of the claimed "deceiver", "controller", and "forwarder", or is the complaint's infringement theory an over-generalization that attempts to fit a conventional architecture into the patent's unique tripartite model?
• An overarching evidentiary question will be one of functional equivalence: does the accused functionality in the Staples app and website—such as app updates, user account management, and web request handling—in fact perform the specific, multi-step logical processes required by the asserted claims, or is there a fundamental mismatch in the technical operation that the complaint's high-level allegations obscure?