DCT
1:26-cv-00661
Uribe v. Aminochain Inc
Key Events
Amended Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Daniel Francisco Uribe (California)
- Defendant: AminoChain, Inc. (Delaware)
- Plaintiff's Counsel: Law Office of Daniel Francisco Uribe
- Case Identification: 1:26-cv-00661, D. Del., 08/25/2026
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant, AminoChain, Inc., is a Delaware corporation and therefore resides in the district for patent venue purposes.
- Core Dispute: Plaintiff alleges that Defendant's blockchain-based platform for managing biological samples infringes two patents related to using non-fungible tokens (NFTs) to track, manage, and secure biospecimens and their associated data.
- Technical Context: The technology operates within the emerging field of Decentralized Science (DeSci), applying blockchain principles to create a transparent, secure, and donor-controlled system for biobanking and genomic data management.
- Key Procedural History: The complaint alleges a detailed history of interaction between the parties. It states that U.S. Patent 11,915,808 was issued by first-action allowance with no rejections. In contrast, U.S. Patent 11,984,203 faced and overcame a patent eligibility rejection under 35 U.S.C. § 101 during prosecution, with the claims being allowed after amendment. The complaint further alleges that Defendant had knowledge of the Plaintiff's work and pending patent applications prior to their issuance and received formal written notice of infringement on September 3, 2024, after which Defendant proceeded to raise capital and expand its operations.
Case Timeline
| Date | Event |
|---|---|
| 2018-05-31 | Plaintiff files first provisional patent application in family |
| 2019-07-25 | Priority date for U.S. Patent 11,915,808 |
| 2019-09-24 | Plaintiff's article describing the technology published in Open Access Government |
| 2019-11-15 | Priority date for U.S. Patent 11,984,203 |
| 2020-05-30 | Plaintiff's peer-reviewed paper on the technology published in JBBA |
| 2022-11-17 | AminoChain officer Jelani Clarke allegedly initiates contact with Plaintiff |
| 2023-06-21 | AminoChain CEO Caspar Barnes allegedly communicates with Plaintiff about his work |
| 2024-02-27 | U.S. Patent 11,915,808 issues |
| 2024-05-14 | U.S. Patent 11,984,203 issues |
| 2024-06-17 | AminoChain CEO presents accused architecture at DeSci Berlin |
| 2024-09-03 | Plaintiff sends formal written notice of infringement to Defendant |
| 2024-09-25 | Defendant AminoChain announces $5 million seed funding round |
| 2025-10-01 | Defendant AminoChain announces its "Syndicate appchain" |
| 2026-01-16 | AminoChain CEO describes the accused platform in a podcast interview |
| 2026-08-25 | First Amended Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,915,808 - "Privacy-Preserving DNA/RNA/Microbiome/COVID-19 Test Kit Kiosk and Locker that Pairs to and Stores Results Data in Private Digital Wallet"
- Patent Identification: U.S. Patent No. 11,915,808 B1, issued February 27, 2024. Compl. ¶22
The Invention Explained
- Problem Addressed: The patent addresses the challenge of tracking biospecimens in a way that simultaneously ensures donor privacy and provides a tamper-evident, auditable chain of custody Compl. ¶19 Traditional centralized databases sacrifice tamper-evidence, while conventional immutable ledgers can compromise donor anonymity and control '808 Patent, col. 1:21-39
- The Patented Solution: The patent discloses a physical, standalone kiosk that serves as a secure point of interaction for a user to deposit a biospecimen '808 Patent, FIG. 1 The kiosk is equipped with sensors (e.g., GPS, temperature) to capture provenance data at the time of collection '808 Patent, col. 19:35-58 This information is bundled into a unique non-fungible token (NFT) on a public blockchain, which represents the physical specimen and is controlled by the user through a private digital wallet '808 Patent, col. 20:7-14
- Technical Importance: The invention provides a specific technical architecture to bind a physical asset (a biospecimen) to a unique digital token (an NFT), enabling decentralized, user-centric control over sensitive biological data.
Key Claims at a Glance
- The complaint asserts at least Claim 1 Compl. ¶75
- Independent Claim 1 of the '808 Patent recites a system comprising:
- A privacy-preserving biospecimen test kit kiosk and locker.
- A physical apparatus including a touchscreen, a metal outer body on a base platform, a plurality of locker boxes, and a camera.
- A set of sensors including air quality, temperature, humidity, and GPS sensors.
- A non-fungible token (NFT) on a public blockchain representing the biospecimen and created to include provenance data from the sensors.
- A private digital wallet that stores the retrieved data.
- A confirmation of the transaction upon the user placing the biospecimen in the kiosk.
U.S. Patent No. 11,984,203 - "System and Processes for Anonymous DNA/RNA Biospecimen Tracking for Human Families Using Filters and Non-Fungible-Tokens"
- Patent Identification: U.S. Patent No. 11,984,203 B1, issued May 14, 2024. Compl. ¶23
The Invention Explained
- Problem Addressed: The patent addresses the need for a system that can track biospecimens from multiple members of a family while enabling privacy-preserving analysis of familial genetic relationships and data usage '203 Patent, col. 1:49-2:7 This requires managing grouped consent and searching across related datasets without exposing identities.
- The Patented Solution: The patent describes a method that uses a "shared digital family wallet" to manage data from multiple family members '203 Patent, col. 3:1-5 It creates a "Self-Sovereign Digital DNA Fingerprint" for each donor from at least 50 single-nucleotide polymorphisms (SNPs) '203 Patent, col. 8:65-9:21 Critically, it employs a "bloom filter," a space-efficient probabilistic data structure, to allow family members to anonymously search for indications of how their biospecimens are being used across the network '203 Patent, col. 18:3-7 '203 Patent, FIG. 5
- Technical Importance: The claimed method provides a technical framework for complex, multi-party data governance and privacy-preserving search in a decentralized biobanking context, a key challenge for family-based genomic studies.
Key Claims at a Glance
- The complaint asserts at least Claim 1 Compl. ¶77
- Independent Claim 1 of the '203 Patent recites a method comprising:
- Creating a "shared digital family wallet" for at least three family members.
- Registering a biospecimen extraction kit to the shared wallet.
- Configuring a data governance scheme requiring family member signatures.
- Processing biospecimens and depositing encrypted data into a digital repository assigned to the shared wallet.
- Tokenizing the encrypted data using an NFT and storing it with the shared wallet.
- Creating a "Self-Sovereign Digital DNA Fingerprint" for each donor.
- Utilizing a "bloom filter" for family members to anonymously search for indications of biospecimen usage.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant's "Specimen Center" biospecimen marketplace, its "Donor Platform," its at-home collection kits, and the underlying "AminoChainDonation.sol" smart-contract architecture, which are collectively referred to as the "Accused Platform" Compl. ¶73A
Functionality and Market Context
- The complaint alleges the Accused Platform is a "blockchain protocol" that tokenizes biospecimens into NFTs using the ERC-721 standard to create "on-chain records of samples" Compl. ¶3 Compl. ¶28 Compl. ¶55A This system is marketed as an "NFT marketplace for bio banks" and is intended to authenticate patients, aggregate biosamples, and create a decentralized biobank Compl. ¶55A The complaint alleges Defendant has raised approximately $7.8 million in venture capital, including from prominent investors, to commercialize this platform Compl. ¶6 The platform is allegedly used by approximately twenty-five biobanks to track hundreds of thousands of biosamples Compl. ¶81
IV. Analysis of Infringement Allegations
'808 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a non-fungible token (NFT) associated with a public blockchain and which represents the personal biospecimen of the user | AminoChain's platform allegedly "mints an NFT out of that sample" using an ERC-721 smart contract to create a "Biosample NFT" for each specimen. | ¶29; ¶62 | col. 19:59-20:6 |
| created to include the set of provenance data associated with the personal biospecimen | AminoChain's NFT allegedly "records in its metadata information about the planned and past uses of the sample in research." | ¶30; ¶62 | col. 20:3-6 |
| a private digital wallet that stores the retrieved data | AminoChain's Terms of Service allegedly reference "digital assets stored in any non-custodial digital wallet managed on your behalf by AminoChain." | ¶4; ¶62 | col. 19:15-20 |
| a privacy-preserving biospecimen test kit Kiosk and locker ... comprising: a metal outer kiosk body ... a plurality of locker boxes ... and sensors | The complaint alleges infringement under the doctrine of equivalents, asserting that each of AminoChain's distributed "institutional nodes" (comprising freezers, workstations, and servers) performs substantially the same function as the claimed unitary kiosk. | ¶69; ¶75 | col. 19:10-14 |
'203 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| creating a shared digital family wallet for at least three members of a family | Alleged on information and belief to be met by AminoChain's platform-level governance protocol that links individual wallets of enrolled family members in its clinical studies, or its functional equivalent. | ¶72(b) | col. 10:30-36 |
| creating a Self-Sovereign Digital DNA Fingerprint for each DNA donor | AminoChain's system allegedly creates a "privacy-preserving biometric identifier" by hashing HLA gene data, which is alleged to be functionally equivalent to the claimed 50-SNP fingerprint. | ¶63; ¶73 | col. 8:65-9:21 |
| tokenizing the encrypted resulting data sets using a non-fungible token (NFT) and storing with the shared family digital wallet | AminoChain's platform allegedly creates "Biosample NFTs" representing biospecimens and stores them in wallets it manages for donors. | ¶70 | col. 12:23-34 |
| utilizing a bloom filter for the members of the family to anonymously search for indications of usage of the biospecimens | Alleged on information and belief that AminoChain's system for "anonymous donor matching" literally uses a bloom filter, or an equivalent probabilistic set-membership structure. | ¶70 | col. 18:3-7 |
Identified Points of Contention
- Scope Questions: A central issue for the '808 Patent will be whether AminoChain's distributed "institutional node" architecture at partner biobanks can be found to be an equivalent of the claimed unitary "kiosk." The complaint dedicates significant attention to this theory, suggesting it is a primary area of dispute Compl. ¶69 For the '203 Patent, a similar question arises regarding whether AminoChain's system of centrally-governed individual wallets is equivalent to a "shared digital family wallet" Compl. ¶72(b)
- Technical Questions: The infringement analysis for the '203 Patent will raise factual questions about AminoChain's specific implementation. For example, what evidence demonstrates that AminoChain's hashed HLA identifier is "created using at least fifty single-nucleotide polymorphisms" as required by the claim Compl. ¶73? Further, does the accused system's "anonymous donor matching" function actually use a "bloom filter," or a different technical method for which the plaintiff will need to prove equivalence Compl. ¶70? The complaint's visual evidence includes a pitch deck slide with the caption "Turn bio-specimen donations into NFTs," which may provide direct evidence of AminoChain's intent and architecture Compl. ¶40 Compl. Exhibit O Another visual, a technical diagram from a 2019 article attributed to Plaintiff's company, is alleged to depict the same architecture later adopted by the Defendant, which may be used to support allegations of copying Compl. ¶34 Compl. Exhibit N
V. Key Claim Terms for Construction
- The Term: "kiosk" (from '808 Patent, Claim 1)
- Context and Importance: This term appears central to the infringement analysis of the '808 Patent. The complaint alleges infringement of the physical apparatus claims under the doctrine of equivalents, arguing AminoChain's distributed network of hardware at institutional partners is equivalent to the claimed "kiosk" Compl. ¶69 The viability of this theory depends on the construed scope of "kiosk."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the list of constituent elements for the kiosk "is intended to be exemplary only" and that "equivalent elements... may be substituted... without changing the essential function or operation" '808 Patent, col. 5:25-33 This may support an interpretation focused on function over a specific physical form.
- Evidence for a Narrower Interpretation: The patent figures, particularly Figure 1, consistently depict a single, integrated, standalone physical apparatus '808 Patent, FIG. 1 The plain meaning of "kiosk" typically implies a self-contained structure, which may support a narrower construction.
- The Term: "Self-Sovereign Digital DNA Fingerprint" (from '203 Patent, Claim 1)
- Context and Importance: This is a patentee-coined term defined as being "created using at least fifty single-nucleotide polymorphisms (SNPs)" '203 Patent, claim 1 The complaint alleges that AminoChain's use of hashed Human Leukocyte Antigen (HLA) data meets this limitation Compl. ¶73 Practitioners may focus on this term because the dispute will likely involve technical expert testimony on whether deriving an HLA type is equivalent to "using at least fifty SNPs" in the manner claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the purpose of the fingerprint as creating a unique, privacy-preserving identifier for a donor '203 Patent, abstract A party might argue any method achieving this result using a comparable amount of genetic data falls within the scope.
- Evidence for a Narrower Interpretation: The claim explicitly requires "using at least fifty single-nucleotide polymorphisms." The patent provides a specific, exemplary list of SNPs '203 Patent, col. 9:3-23 This specificity may support an argument that the claim requires a direct process of using a set of SNPs, not a derivative hash of a genetic region like HLA.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that AminoChain induced infringement by providing its "Amino Node" software, Donor Platform, and at-home collection kits to third parties (biobanks, donors) with the specific intent that they use the platform to perform the patented methods Compl. ¶¶79-80 This intent is allegedly evidenced by marketing materials, partnership agreements, and public statements instructing users to "Turn bio-specimen donations into NFTs" Compl. ¶80 Compl. ¶82
- Willful Infringement: The complaint alleges willful infringement based on both pre- and post-notice conduct. It alleges AminoChain had pre-issuance knowledge of the technology and pending patents through direct communications between its executives and the plaintiff starting in late 2022 (Compl. ¶32; Compl. ¶33; Compl. ¶34; Compl. ¶35). Willfulness is further alleged based on AminoChain's conduct after receiving a formal notice of infringement on September 3, 2024, which allegedly included accelerating its business by announcing a $5 million funding round, expanding its network, and continuing to market the accused platform without taking a license Compl. ¶¶89-90
VII. Analyst's Conclusion: Key Questions for the Case
- A core issue will be one of equivalence and definitional scope: Can the '808 Patent's "kiosk," depicted and described as a unitary physical apparatus, be construed to cover AminoChain's accused system of distributed hardware and software deployed across multiple institutional sites? The outcome of this doctrine of equivalents argument appears critical to the infringement case for the '808 Patent.
- A key evidentiary question will be one of technical implementation: Does AminoChain's accused platform, on a technical level, actually practice the specific mechanisms of the '203 Patent? This will require discovery into whether its architecture uses a "bloom filter" and whether its method for creating a genetic identifier from HLA data meets the claim limitation of a "Self-Sovereign Digital DNA Fingerprint" created from at least fifty SNPs.
- The case will likely feature a significant dispute over willfulness and intent, turning on the extensive factual record alleged in the complaint. A central question for the court will be to weigh the evidence of the parties' pre-litigation interactions, Defendant's alleged knowledge of the technology, and its conduct after receiving formal notice of infringement against any defenses AminoChain may raise.
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