Jack Henry & Associates Inc v. DigitalDoors Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Jack Henry & Associates, Inc. (Delaware)
  • Defendant: DigitalDoors, Inc. (Florida)
  • Plaintiff’s Counsel: Polsinelli PC
• Case Identification: 3:26-cv-05011, W.D. Mo., 02/16/2026
• Venue Allegations: Plaintiff alleges venue is proper because it resides in the district and Defendant has purposefully directed enforcement and licensing activities into the district by accusing local businesses and customers of infringement.
• Core Dispute: Plaintiff seeks a declaratory judgment that its "SecurePort" products do not infringe four of Defendant's patents related to data processing and security, and further that those patents are invalid.
• Technical Context: The patents concern methods for identifying, classifying, filtering, and securing sensitive or important data within distributed and cloud-based computing systems, a technology domain critical to the financial services industry.
• Key Procedural History: The complaint identifies Defendant as a non-practicing entity that has previously asserted the patents-in-suit in over sixty lawsuits, primarily against financial institutions. Plaintiff highlights that Defendant's infringement theory is allegedly premised on the idea that compliance with the "Sheltered Harbor" data-security standard necessarily constitutes infringement, a premise Plaintiff contends Defendant has previously conceded is not true in separate litigation.

Case Timeline

Date	Event
2007-01-05	Priority Date for '301, '169, '073, and '639 Patents
2013-02-06	'301 Patent Prosecution Amendment Mentioned in Complaint
2015-04-21	U.S. Patent No. 9,015,301 Issued
2016-03-01	'169 Patent Prosecution Amendment Mentioned in Complaint
2017-08-15	U.S. Patent No. 9,734,169 Issued
2019-01-15	U.S. Patent No. 10,182,073 Issued
2019-04-02	U.S. Patent No. 10,250,639 Issued
2026-02-16	Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 9,015,301 - "Information Infrastructure Management Tools With Extractor, Secure Storage, Content Analysis And Classification And Method Therefor"

The Invention Explained

• Problem Addressed: The patent describes the need for enterprises to manage and protect large volumes of both structured and unstructured information, identifying risks associated with confidential data and intellectual property being exposed to insiders or external threats ('301 Patent, col. 1:35-43; '301 Patent, col. 2:7-14).
• The Patented Solution: The invention provides a method to organize and process data in a distributed computing system by using a set of "enterprise designated categorical filters" (e.g., content-based, contextual, taxonomic) to identify and aggregate "select content" deemed important to the enterprise. This aggregated content is then stored, and the system applies associated data processes (such as copying or archiving) to further incoming data based on the results of the initial filtering ('301 Patent, abstract; '301 Patent, col. 3:28-48).
• Technical Importance: This system offered a method for automating the application of complex, policy-based rules to large, heterogeneous datasets, a significant challenge as enterprise data volumes grew.

Key Claims at a Glance

• The complaint identifies Claim 1 as representative of the patent's claims (Compl. ¶50).
• Key elements of independent Claim 1 include:
  • Providing a plurality of "select content data stores" operative with a plurality of "enterprise designated categorical filters" (including content-based, contextual, and taxonomic filters) over a communications network.
  • Activating at least one filter and processing a data input to obtain "select content" and associated content as "aggregated select content."
  • Storing the "aggregated select content" in a corresponding data store.
  • Associating a data process (e.g., copy, extract, archive) with the activated filter.
  • Applying the associated data process to a further data input based on the filtering result.
  • Wherein the filter activation can be automatic (e.g., time-based, event-based) or manual.
• The complaint does not explicitly reserve the right to assert dependent claims but seeks a declaratory judgment on all claims of the patent (Compl. ¶56).

U.S. Patent No. 9,734,169 - "Digital Information Infrastructure and Method for Security Designated Data and With Granular Data Stores"

The Invention Explained

• Problem Addressed: The patent, which shares a common specification with the '301 Patent, addresses the challenge of securing sensitive information within an enterprise computing environment (Compl. ¶33).
• The Patented Solution: The invention claims a method for processing data in a distributed cloud-based system. The method involves extracting "security (SEC) designated data" from a data stream and storing it in secure "select content (SC) data stores," each with its own access controls. The non-sensitive "remainder data" is parsed and stored separately in "granular data stores." The system is designed so that the sensitive SEC data can only be withdrawn from its secure storage if the corresponding access controls are applied ('169 Patent, abstract; '169 Patent, col. 1:53-67).
• Technical Importance: This approach provided a specific architecture for enhancing data security in a cloud environment by segregating sensitive and non-sensitive data into distinct storage systems governed by different access rules.

Key Claims at a Glance

• The complaint identifies Claim 1 as the only independent claim and representative of all claims (Compl. ¶¶69-70).
• Key elements of independent Claim 1 include:
  • Providing, in a cloud-based system, a plurality of "select content (SC) data stores" for "security (SEC) designated data," a plurality of "granular data stores," and a cloud-based server.
  • Extracting and storing the SEC designated data in the SC data stores.
  • Activating an SC data store to permit access based on one or more access controls.
  • Parsing the "remainder data" (data not extracted) and storing it in the granular data stores.
  • The parsing step includes both random parsing and parsing based on a predetermined algorithm.
  • Withdrawing the SEC designated data and parsed data from their respective stores "only in the presence of said respective access controls."
• The complaint seeks a declaratory judgment on all claims of the patent (Compl. ¶79).

U.S. Patent No. 10,182,073 - "Information Infrastructure Management Tools With Variable and Configurable Filters and Segmental Data Stores"

Technology Synopsis

This patent describes a method for creating a data processing infrastructure using a plurality of filters. The method identifies "sensitive content" and "select content" using initially configured filters and then alters those filters (e.g., by expanding or contracting the content definitions) to generate modified filters for organizing further data throughput ('073 Patent, abstract; Compl. ¶92).

Asserted Claims

The complaint cites Claim 1 as representative of all claims (Compl. ¶93).

Accused Features

The complaint alleges that Defendant has accused Plaintiff's "SecurePort" products of infringing the Asserted Patents (Compl. ¶¶34-35).

U.S. Patent No. 10,250,639 - "Information Infrastructure Management Data Processing Tools for Processing Data Flow With Distribution Controls"

Technology Synopsis

This patent claims a method for processing data by using filters to identify and extract sensitive or select content. The extracted content is then classified using a taxonomic filter to generate "classification tags," which are then associated with the content and used to direct subsequent data processing actions like data mining, copying, and transfer ('639 Patent, abstract; Compl. ¶114).

Asserted Claims

The complaint cites Claim 1 as representative of all claims (Compl. ¶115).

Accused Features

The complaint alleges that Defendant has accused Plaintiff's "SecurePort" products of infringing the Asserted Patents (Compl. ¶¶34-35).

III. The Accused Instrumentality

Product Identification

The complaint identifies Plaintiff's "SecurePort" products as the accused instrumentalities (Compl. ¶35).

Functionality and Market Context

The complaint does not provide a technical description of the SecurePort products' functionality. Instead, it focuses on Defendant's alleged theory of infringement, which posits that any financial institution using products that comply with the "Sheltered Harbor" data-security standard necessarily infringes the Asserted Patents (Compl. ¶38). The complaint states that Plaintiff licenses its SecurePort products to various customers, including banks that have been accused of infringement by Defendant (Compl. ¶35; Compl. ¶36). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint is for a declaratory judgment of non-infringement and does not contain infringement allegations or a claim chart mapping product features to claim elements. The complaint's central argument for non-infringement is that Defendant's reliance on "Sheltered Harbor" compliance is legally and factually insufficient. It alleges that Defendant admitted in a prior court filing that a "Sheltered Harbor certified" software product did not infringe the patents-in-suit, thereby undermining its current infringement theory (Compl. ¶39). As such, the complaint does not provide sufficient detail for a claim-by-claim analysis of infringement allegations.

Identified Points of Contention

• Evidentiary Question: A central question will be what evidence, other than alleged compliance with the "Sheltered Harbor" standard, Defendant will rely on to prove that the "SecurePort" products perform the specific steps recited in the asserted claims.
• Legal Question: The dispute raises the legal question of whether infringement can be established by alleging compliance with a voluntary industry standard, or if direct evidence mapping the technical operation of the accused product to each claim limitation is required.

V. Key Claim Terms for Construction

The Term: "select content"

Context and Importance

This term appears in the independent claims of all four patents-in-suit and is a cornerstone of the claimed methods for organizing and processing data (Compl. ¶49; Compl. ¶68; Compl. ¶91; Compl. ¶113). The complaint argues this term is indefinite under 35 U.S.C. § 112, making its construction critical to the validity of all asserted patents. Practitioners may focus on this term because its allegedly subjective nature could render the claim scope impossible for a person of ordinary skill to determine.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The complaint points to language in the shared specification defining the term broadly, such as "of interest or importance to the enterprise" ('301 Patent, col. 3:4-5, as cited in Compl. ¶52) and "of particular interest to the user" ('301 Patent, col. 126:17-18, as cited in Compl. ¶52).
• Evidence for a Narrower Interpretation: The complaint also highlights definitions that suggest a more limited, security-oriented scope, such as "security sensitive content" ('301 Patent, col. 37:47, as cited in Compl. ¶52) or content that is "important in that its unauthorized release is some how detrimental to the enterprise" ('301 Patent, col. 37:49-51, as cited in Compl. ¶52). Plaintiff argues that these multiple, varied definitions are "inconsistent and ambiguous and cannot be reconciled" (Compl. ¶52).

VI. Other Allegations

Indirect Infringement

The complaint does not contain detailed allegations regarding indirect infringement. However, it notes that Defendant has accused Plaintiff's customers of infringement, and that Plaintiff has a contractual obligation to indemnify certain customers (Compl. ¶7; Compl. ¶36). This context suggests that Defendant's underlying legal theory against Plaintiff, the technology supplier, may include claims of induced or contributory infringement, although the declaratory judgment complaint does not elaborate on this.

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

This declaratory judgment action frames the dispute around two fundamental issues that will likely define the litigation:

• A core issue will be one of claim definiteness: Is the term "select content," which is foundational to all asserted patents and defined with subjective qualifiers like "important" or "of interest," fatally indefinite under 35 U.S.C. § 112? The resolution of this question could determine the validity of the entire asserted patent portfolio.
• A key legal and evidentiary question will be one of infringement theory sufficiency: Can infringement be proven merely by showing an accused product complies with an industry standard ("Sheltered Harbor"), or must the patent holder provide specific evidence demonstrating that the product's actual technical operation meets every limitation of the asserted claims? The court's view on this issue will shape the scope of discovery and the evidence required at trial.