DCT

2:26-cv-00205

Native Pixel Inc v. Wavemaker Inc

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Amended Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Native Pixel Inc. v. WaveMaker, Inc., 2:26-cv-00205, E.D. Tex., 08/06/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains its principal U.S. headquarters and a regular and established place of business in Plano, Texas, where it employs personnel and from which it conducts development, marketing, sales, and support of the accused products, and has committed acts of infringement.
  • Core Dispute: Plaintiff alleges that Defendant's low-code application development platform infringes two patents related to an architecture for automatically generating device-native graphical user interface (GUI) code from design inputs.
  • Technical Context: The technology resides in the "design-to-code" software development market, which aims to accelerate application creation by automating the translation of visual designs into functional, platform-specific code.
  • Key Procedural History: This First Amended Complaint supersedes an original complaint and includes detailed allegations regarding the prosecution history of the asserted patents. The complaint notes that initial rejections under 35 U.S.C. § 101 during prosecution were overcome by adding the specific architectural limitations that are now central to the infringement allegations, a fact Plaintiff presents as evidence of their non-conventionality.

Case Timeline

Date Event
2016-11-16 Earliest Priority Date for '459 and '335 Patents
2017-02-10 '459 Patent Provisional Application Filing Date
2018-02-12 '459 Patent Application Filing Date
2018-10-01 '459 Patent Prosecution: Non-final Office Action
2023-06-09 '459 Patent Prosecution: Final Rejection
2023-10-05 '335 Patent Application Filing Date
2023-11-14 U.S. Patent No. 11,816,459 Issued
2024-06-14 '335 Patent Prosecution: Non-final Office Action
2024-08-26 '335 Patent Prosecution: Statement of Reasons for Allowance Date
2024-10-15 U.S. Patent No. 12,118,335 Issued
2025-02-01 Accused Product "AutoCode" Launch (approx.)
2026-02-19 Accused "Agentic App Generation Platform" Launch (approx.)
2026-03-16 Defendant Actual Notice of Patents (at latest)
2026-04-21 Defendant Announces Strategic Intent with Accenture (approx.)
2026-08-06 First Amended Complaint Filing Date

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

U.S. Patent No. 11,816,459 - "Graphical User Interface Programming System"

Issued November 14, 2023

The Invention Explained

  • Problem Addressed: The patent addresses the problem that creating software for multiple platforms is inefficient, expensive, and error-prone Compl. ¶7 Compl. ¶53 Prior methods required developers to manually write separate code for each platform or use intermediary "middleware" frameworks that consumed significant device resources like battery power, CPU, and memory Compl. ¶55 '459 Patent, col. 3:34-39
  • The Patented Solution: The invention describes a system that automates the generation of device-native code from a single graphical design input Compl. ¶8 It accomplishes this through a specific architecture: a "translation layer" converts a design into a tree data structure, and an algorithm then "recursively" selects, modifies, and updates native-code templates for each portion of the tree, including specialized "feature-based templates" for elements like buttons or text fields, before compiling the final code (Compl. ¶62; Compl. ¶63; Compl. ¶64; Compl. ¶65, Compl. ¶¶col. 7:40-52). This process is designed to eliminate the performance-draining middleware layer of the prior art Compl. ¶61
  • Technical Importance: This automated, template-driven architecture for generating native code was intended to significantly reduce front-end development time while improving the performance of the resulting application on the end-user's device Compl. ¶10 '459 Patent, col. 5:24-30

Key Claims at a Glance

  • The complaint charts claim 6 and references independent claims 1 and 17 Compl. ¶50 Compl. ¶110
  • Independent Claim 6 (a system) includes these essential elements:
    • A hardware processor.
    • A front-end development software tool with a UI element associated with a function.
    • A "translation layer" to associate the function with device-native code and convert a code representation for a first device to recreate the image on a second device.
    • A "template" that converts function data into native code for the second device by performing a sequence of steps:
      • "recursively selecting" templates for each portion of a "tree data structure";
      • "modifying" the templates to create output native source code;
      • "selecting" one or more "feature-based templates" for predetermined features; and
      • "updating" the feature-based templates with the native source code and GUI design elements.
  • The complaint reserves the right to assert additional claims Compl. ¶51

U.S. Patent No. 12,118,335 - "GUI Generation System"

Issued October 15, 2024

The Invention Explained

  • Problem Addressed: As a continuation of the '459 Patent's application, this patent addresses the same technical problems of inefficiency and performance degradation in traditional cross-platform GUI development (Compl. ¶48, Compl. ¶53; '335 Patent, Compl. ¶¶col. 2:13-26).
  • The Patented Solution: The '335 patent discloses the same core technical solution as the '459 patent: a system that converts a graphical input into device-native code by parsing it into a tree structure and applying a multi-step process of recursive template selection, modification, and updating Compl. ¶5 '335 Patent, abstract '335 Patent, col. 7:40-52 Figure 4 of the '335 patent, referenced by the complaint, provides a flowchart illustrating the claimed algorithmic process, including steps for selecting and modifying templates to generate native source code Compl. ¶63
  • Technical Importance: The invention aims to provide the same benefits of reduced development time and improved end-application performance by avoiding resource-intensive middleware Compl. ¶10 Compl. ¶11

Key Claims at a Glance

  • The complaint charts claim 19 and references independent claim 1 Compl. ¶50 Compl. ¶110
  • Independent Claim 19 (a system) includes these essential elements:
    • A computer processor.
    • A computer-readable non-transitory storage medium containing:
      • A front-end development software tool with a UI element and associated function.
      • A "translation layer" associating the function with device-native code.
      • A "template" that converts function data into native code by:
        • "recursively selecting" templates for each portion of a "tree data structure";
        • "modifying" the templates to create output native source code;
        • "selecting" "feature-based templates" for predetermined features; and
        • "updating" the feature-based templates with the native source code and the UI element.
  • The complaint reserves the right to assert additional claims Compl. ¶51

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Defendant's low-code application development platform and its components, including "WaveMaker Studio," "AutoCode," "CoPilot," and the "Agentic App Generation Platform" featuring a "Two-Pass/WML code-generation pipeline" Compl. ¶3 Compl. ¶123

Functionality and Market Context

  • The WaveMaker platform is a low-code development environment that allows users to create applications through a visual, "What You See Is What You Get" (WYSIWYG) design studio Compl. ¶25 It is alleged to take design inputs, such as Figma files, and automatically generate "standards-based, open-source code using Angular for web applications and React Native for mobile applications" Compl. ¶25
  • The complaint specifically focuses on an accused "Two-Pass Coding System" where an AI first generates a "tech-stack-agnostic application markup" or meta-model (referred to as "WML"), which is then converted by a deterministic engine into production code Compl. ¶28 This "reduce-then-generate" architecture is alleged to be the implementation of the claimed invention Compl. ¶28 The complaint also refers to Figure 5 of the patents' specification, which depicts the overall system architecture and data flow, including the interaction between a client and server component Compl. ¶70
  • The complaint alleges WaveMaker is a "leading low-code development platform" used by over 200 large enterprise customers and recognized by multiple industry analysts Compl. ¶22 Compl. ¶24

IV. Analysis of Infringement Allegations

'459 Patent Infringement Allegations

Claim Element (from Independent Claim 6) Alleged Infringing Functionality Complaint Citation Patent Citation
a translation layer for associating the function associated with the first UI element with a device native computer code... The first pass of the accused "Two-Pass Coding System," which converts design files into a tech-stack-agnostic intermediate markup called "WaveMaker Markup Language" or "WML." ¶115 col. 3:32-39
a template that converts data from the first function into computer code that is native to the second device by recursively selecting one or more templates for each portion in a tree data structure... The accused products allegedly parse design inputs into a hierarchical tree, traverse the hierarchy, and for each portion, select a matching code template. ¶116 col. 7:40-44
...modifying the one or more templates to create output native source code... The accused products allegedly modify selected templates to match the design input's specifications (sizing, colors, layout, etc.) to produce output source code in Angular or React Native. ¶117 col. 7:44-46
...selecting one or more feature-based templates for one or more predetermined features... The accused products allegedly select from a structured library of templates, such as "Prefabs" and widgets, which are keyed to predetermined GUI features like buttons, lists, and forms. ¶118 col. 7:46-48
...and updating the one or more feature-based templates with the native source code and one or more graphical user interface (GUI) design elements. The accused products' second-pass generation engine allegedly reintegrates the feature-level code (from feature-based templates) into the overall application by assembling the validated markup and feature output into a complete codebase. ¶119 col. 7:48-52

'335 Patent Infringement Allegations

Claim Element (from Independent Claim 19) Alleged Infringing Functionality Complaint Citation Patent Citation
a translation layer associating the function associated with the first UI element with a device native computer code... The first pass of the accused "Two-Pass Coding System," which converts design files into a tech-stack-agnostic intermediate markup ("WML"). ¶115 col. 3:32-39
a template that converts data... into computer code that is native to the first device by recursively selecting one or more templates for each portion in a tree data structure... The accused products allegedly parse design inputs into a hierarchical tree and, for each portion of the hierarchy, select a matching code template. ¶116 col. 7:40-44
...modifying the one or more templates to create output native source code... The accused products allegedly modify the selected templates to match sizing, color, and layout specifications from the design input, producing Angular or React Native code. ¶117 col. 7:44-46
...selecting one or more feature-based templates for one or more predetermined features... The accused products allegedly select from a library of "Prefabs" and widgets that are keyed to specific GUI features detected in the design input. ¶118 col. 7:46-48
...and updating the one or more feature-based templates with the native source code and the UI element. The accused products' second-pass engine allegedly assembles the intermediate markup and feature-level output into a complete, standardized application, reintegrating the feature-specific code into the overall structure. ¶119 col. 7:48-52
  • Identified Points of Contention:
    • Scope Questions: The infringement analysis may turn on whether the accused "Two-Pass Coding System," which uses AI to create an intermediate "WML" representation that is subsequently compiled, constitutes the claimed "translation layer" and the specific, ordered sequence of "recursively selecting," "modifying," and "updating" templates.
    • Technical Questions: A central question is whether the "Angular" and "React Native" code generated by Defendant's platform qualifies as "device native computer code" as required by the claims. The complaint alleges that code native to the execution environment (e.g., a browser or a mobile OS via a build process) satisfies this limitation Compl. ¶120, which suggests the potential for a significant claim construction dispute.

V. Key Claim Terms for Construction

  • The Term: "translation layer"

  • Context and Importance: This term defines a core component of the claimed architecture. The infringement case hinges on whether Defendant's "Two-Pass" system, with its intermediate "WML" format, falls within the scope of this term.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the invention as one that "eliminates the need for a middle-man framework" '459 Patent, col. 3:32-34 This language may be argued to support a construction that covers any architecture, including a two-pass system, that replaces prior art middleware and directly generates platform-specific code from a higher-level representation.
    • Evidence for a Narrower Interpretation: Claim 6 links the "translation layer" to a specific device-to-device image recreation function and is part of a system that includes a "template" performing a multi-step recursive process '459 Patent, cl. 6 This may support an argument that the term is not a generic intermediary but is functionally tied to the specific template-based process described.

  • The Term: "device native computer code"

  • Context and Importance: The nature of the code generated by the accused platform is critical. If the generated Angular and React Native code is not considered "device native," infringement may not be found. Practitioners may focus on this term because the patent's goal of improving performance by eliminating frameworks could be used to argue for a strict definition.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification discloses generating code for multiple target platforms, including web frameworks '459 Patent, col. 8:43-52 The complaint alleges that the '459 patent applicant distinguished prior art on the basis that it could not produce "human readable" code Compl. ¶66, and claim 17 of the '459 patent explicitly recites "computer-generated human readable created code." This may support a construction where "native" refers to code that runs in the target's natural execution environment (like JavaScript in a browser), not necessarily bare-metal machine code.
    • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes improving performance by eliminating frameworks that "consumed battery power, CPU usage, memory, and performance" '459 Patent, col. 3:34-39 This focus on machine-level efficiency could support a narrower construction limited to code compiled directly for a device's hardware, excluding code that relies on an interpretation layer like a JavaScript engine or a framework bridge.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant induces infringement by providing documentation, technical support, and promotional materials that instruct customers on how to use the accused platform in a manner that practices the claimed methods Compl. ¶134 Compl. ¶135 Compl. ¶151
  • Willful Infringement: The complaint alleges willful infringement based on Defendant's continued infringing conduct after receiving actual notice of the patents and infringement allegations, which occurred at least by the date of the original complaint Compl. ¶124 Compl. ¶125 The complaint also cites a post-notice announcement of a partnership with Accenture as evidence of ongoing promotion of the accused functionality Compl. ¶29

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

  • A core issue will be one of definitional scope: can the term "device native computer code," rooted in a patent that emphasizes eliminating performance-consuming frameworks, be construed to cover code such as Angular and React Native, which operate within their own runtime environments (a browser's JavaScript engine or a mobile framework's bridge)?
  • A second key question will be one of architectural equivalence: does Defendant's "Two-Pass" system-which allegedly uses AI to first generate an intermediate markup language ("WML") that is then compiled-perform the same specific, ordered sequence of "recursively selecting," "modifying," and "updating" templates as recited in the claims, or is there a fundamental mismatch in technical architecture?
  • A third issue, arising from the complaint's detailed pleading, will concern patent eligibility and non-conventionality: to what extent does the prosecution history, where the patentee allegedly overcame a § 101 rejection by adding the specific architectural limitations now asserted, demonstrate that the claimed combination was a non-conventional, technological improvement over the prior art at the time of the invention?
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