DatRec LLC v. Greenhouse Software Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DatRec, LLC (Texas)
  • Defendant: Greenhouse Software, Inc. (Delaware)
  • Plaintiff's Counsel: David J. Hoffman
• Case Identification: 1:26-cv-02285, S.D.N.Y., 03/19/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the Southern District of New York and has committed alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant's software platform infringes a patent related to methods for secure communication over a public network using a database of verified user identity data.
• Technical Context: The technology concerns authenticating user identities in online communications by cross-referencing personal and relational data provided by multiple users to build a trusted network.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and has entered into settlement licenses with other entities in prior matters, asserting that these licenses did not require patent marking because they did not permit the production of a patented article.

Case Timeline

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

U.S. Patent No. 8,381,309 - "Methods and Systems for Secure Communication Over a Public Network"

The Invention Explained

• Problem Addressed: The patent addresses the challenge of modern internet communication where individuals are exposed to non-secure connections and communications from "unreliable or falsely-identified senders" '309 Patent, col. 1:22-25 The goal is to improve confidence in the identity of a party in an electronic communication '309 Patent, col. 2:63-65
• The Patented Solution: The invention proposes a system that builds a database of verified data about a plurality of individuals '309 Patent, abstract Users input data about themselves and their relationships to others (e.g., family members), creating "individual-associated data bits" (IDBs) '309 Patent, col. 3:60-65 The system verifies this data by comparing information about the same individual entered by different users, thereby determining a "level of reliability" '309 Patent, col. 4:4-6 Based on this verification, authenticated users can define levels of permitted communication with others, filtering or flagging messages from non-verified users '309 Patent, col. 2:13-17
• Technical Importance: The approach sought to create a trust layer for online interactions by systematically crowdsourcing and cross-validating identity information, moving beyond simple self-declared profiles '309 Patent, col. 2:31-35

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-17 Compl. ¶8 Independent claim 1 is a method claim.
• Essential Elements of Independent Claim 1:
  • (a) Providing a database of verified identity data, which is constructed by:
    • Permitting multiple individuals to enter "individual-associated data bits (IDB) comprising a personal identifier and relationship data indicative of a family tree."
    • Generating an "individual-associated data set (IDS)" from the IDB.
    • "Verifying the IDS for the individual by determining the level of reliability based on a degree of similarity between data on the individual entered by different individuals."
  • (b) "Compiling the individual data sets (IDSs) to construct the database, and defining one or more levels of permitted communication between individuals in the database and the verified individual on the basis of the verification."
• The complaint reserves the right to assert other claims, including dependent claims Compl. ¶8

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's "products and services such as Greenhouse's server system" and the "Greenhouse Platform and related systems" Compl. ¶10 Compl. ¶11

Functionality and Market Context

The complaint alleges that Defendant "maintains, operates, and administers a system and methods for secure communication over a public network" Compl. ¶8 It points to Defendant's website as offering products and services with "instruction or advertisement that suggests an infringing use" Compl. ¶11 The complaint does not provide specific technical details about how the accused platform functions, beyond these general allegations.
No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a "preliminary exemplary table attached as Exhibit B" to support its infringement allegations, but this exhibit was not provided with the complaint Compl. ¶9 The narrative allegations are general. A summary of the infringement theory for claim 1, based on the complaint's assertions, is presented below.

'309 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central dispute may concern the claim term "relationship data indicative of a family tree." The litigation will need to address whether professional or organizational relationships within a recruiting platform can be construed as meeting a limitation that the patent specification appears to define in terms of familial ties '309 Patent, col. 5:40-48
• Technical Questions: The complaint's allegations lack factual detail on the "verifying" step. A key question will be whether the Greenhouse Platform actually performs a cross-comparison of data about an individual entered by different users to assign a "level of reliability," as required by the claim '309 Patent, col. 10:40-54, or if it employs a different method for data validation.

V. Key Claim Terms for Construction

• The Term: "relationship data indicative of a family tree"

• Context and Importance: This term appears central to defining the scope of the invention. Its construction will be critical, as the accused product operates in a corporate recruiting context, which is facially distinct from the familial context heavily described in the patent. Practitioners may focus on this term because the infringement theory appears to depend on extending its meaning beyond its ordinary and specification-supported definition.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Parties seeking a broader construction may argue that "family tree" is merely one example of a hierarchical data structure and that "indicative of" suggests any data that can be organized in a similar relational manner falls within the claim's scope.
  • Evidence for a Narrower Interpretation: The patent specification repeatedly and explicitly discusses "familial data," "first degree family members (parents, brothers and sisters, spouse, children)," and "further (second, third, etc.) degree family members (grandparents, cousins, in-laws, etc.)" '309 Patent, col. 5:40-48 This language may support a narrower construction limited to actual kinship data.

• The Term: "verifying the IDS... by determining the level of reliability based on a degree of similarity between data on the individual entered by different individuals"

• Context and Importance: This term defines the core technical mechanism for authentication. The infringement analysis hinges on whether the accused system performs this specific type of cross-referential verification. The absence of specific factual allegations in the complaint on this point makes its construction pivotal.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue this language covers any system that compares data points from multiple sources to assess accuracy, a common feature in data management systems.
  • Evidence for a Narrower Interpretation: The specification describes a specific process where data strings from different users are compared for matches, and a reliability score is generated based on the degree of overlap '309 Patent, col. 10:40-67 '309 Patent, FIG. 3B This may support an interpretation requiring this specific multi-source comparison method.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. For inducement, it asserts Defendant actively encourages infringement through its "website and product instruction manuals" Compl. ¶10 Compl. ¶11 For contributory infringement, it alleges the accused product is "not a staple commercial product" and its "only reasonable use is an infringing use" Compl. ¶11
• Willful Infringement: Willfulness is alleged based on knowledge of the '309 Patent from "at least the filing date of the lawsuit" Compl. ¶10 Compl. ¶11 The complaint reserves the right to amend if pre-suit knowledge is found in discovery Compl. ¶10, n.1

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

• A core issue will be one of definitional scope: can the term "relationship data indicative of a family tree," which is described in the patent with explicit familial examples, be construed to cover the professional and organizational data managed by the accused corporate recruiting platform?
• A second key issue will be evidentiary and technical: does the complaint's general allegation of infringement find support in discovery? Specifically, can Plaintiff show that the Greenhouse Platform performs the claimed verification method of determining data "reliability" by comparing information about a single individual that was "entered by different individuals"?
• The case may also present a fundamental question of technological applicability: whether a patent directed at establishing trust and identity in general public network communications is infringed by a specialized, business-to-business software platform designed for managing the hiring process.