DCT

2:26-cv-00803

Stratopatent LLC v. Wipro Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00803, E.D. Tex., 09/09/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Wipro Limited is a foreign entity and because both defendants maintain a regular and established physical place of business in the District, specifically the Texas Technology Center in Plano, Texas, where they allegedly commit acts of infringement.
  • Core Dispute: Plaintiff alleges that Defendant’s Fashion Rental Solution, a cloud-based software platform for clothing rental businesses, infringes six patents related to the management of clothing-as-a-service (CaaS) subscription platforms.
  • Technical Context: The technology at issue relates to enterprise software systems for managing the complex logistics and data flows of online clothing rental and subscription services, a key component of the growing "circular economy" in the fashion industry.
  • Key Procedural History: The six asserted patents are part of a larger, closely-related family, with several patents being continuations of prior applications. This shared prosecution history may be relevant for claim construction across the asserted patents. The complaint does not mention any prior litigation or post-grant proceedings involving these patents.

Case Timeline

Date Event
2019-04-11 Earliest Priority Date for ’392, ’166, ’510, ’208, ’622 Patents
2019-11-01 Earliest Priority Date for ’149 Patent
2021-01-26 U.S. Patent No. 10,902,510 Issued
2021-08-10 U.S. Patent No. 11,087,392 Issued
2022-04-19 U.S. Patent No. 11,307,149 Issued
2022-05-31 U.S. Patent No. 11,348,166 Issued
2022-06-07 U.S. Patent No. 11,354,622 Issued
2024-07-09 U.S. Patent No. 12,033,208 Issued
2026-09-09 Complaint Filing Date

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

U.S. Patent No. 11,087,392 - "SYSTEMS AND METHODS FOR ANALYSIS OF WEARABLE ITEMS OF A CLOTHING SUBSCRIPTION PLATFORM"

The Invention Explained

  • Problem Addressed: The patent describes the challenge of managing the complex and interconnected data flows required to operate an online clothing subscription or rental service. This includes coordinating front-end user interactions, back-office tasks, and integrated business partner systems in an efficient and reliable manner (U.S. Patent No. 11,087,392, col. 1:32-51).
  • The Patented Solution: The invention provides a computer-implemented method for a connected platform that dynamically manages data for transactions of wearable items. The system receives wearable item data, hosts electronic portals for warehouse operations and administration, receives user transactions that associate specific users with specific items, and, in response to requests, initiates microservices to fulfill orders and ship items to users (’392 Patent, abstract; ’392 Patent, Fig. 12). This creates a responsive, automated workflow from user selection to physical fulfillment.
  • Technical Importance: The described architecture provides a streamlined and integrated system to manage the significant logistical complexity of CaaS platforms, which require coordinating digital storefronts with physical inventory management and fulfillment (’392 Patent, col. 1:40-51).

Key Claims at a Glance

  • The complaint asserts one or more claims, with specific allegations directed at independent claim 1 (Compl. ¶51).
  • Essential elements of claim 1 include:
    • Receiving, via processors, wearable item data describing items available for shipment via electronic transactions.
    • Hosting an electronic warehouse operations portal and/or an electronic administrative portal accessible over networks.
    • Receiving electronic user transactions associated with a unique user identifier and a unique item identifier, identifying an item to be placed in a virtual closet and rented.
    • Receiving wearable item operations requests from the portals to initiate order processing of the identified item for the user.
    • In response to the requests, initiating one or more microservices to fulfill the requests and initiate shipping of the item to the user.

U.S. Patent No. 11,348,166 - "SYSTEMS AND METHODS FOR ANALYSIS OF WEARABLE ITEMS OF A CLOTHING SUBSCRIPTION PLATFORM"

The Invention Explained

  • Problem Addressed: Similar to the '392 patent, the '166 patent addresses the operational complexity of managing an electronic platform for distributing wearable items, where customer actions and back-office tasks must be integrated efficiently (’166 Patent, col. 1:32-51).
  • The Patented Solution: The ’166 patent discloses a method for dynamically managing data associated with transactions of items, such as wearable garments. The method involves receiving item data, hosting electronic portals for warehouse and administrative functions, receiving user transactions for renting or purchasing items for a virtual closet, processing operational requests from the portals, and initiating microservices to fulfill those requests by shipping items to a physical address (’166 Patent, abstract; ’166 Patent, Fig. 12).
  • Technical Importance: This integrated approach allows for the automation and streamlining of the entire clothing rental lifecycle, from online user interaction to physical warehouse fulfillment, which is critical for the scalability of CaaS business models (’166 Patent, col. 1:40-51).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶66).
  • The essential elements of claim 1 are substantively identical to those of claim 1 of the ’392 patent, covering steps for receiving item data, hosting portals, receiving user transactions, processing operational requests, and initiating microservices for fulfillment.

Multi-Patent Capsules

  • U.S. Patent No. 10,902,510

    • Patent Identification: U.S. Patent No. 10,902,510, entitled "SYSTEMS AND METHODS FOR ANALYSIS OF WEARABLE ITEMS OF A CLOTHING SUBSCRIPTION PLATFORM," issued January 26, 2021.
    • Technology Synopsis: The ’510 patent describes a multi-tenant platform architecture for clothing subscription services. It specifically claims receiving wearable item data from "electronic tenant interfaces" (e.g., brand partners) and, in response to user transactions, performing a dual update to separate "transaction databases" and "analytics databases" before initiating shipment (’510 Patent, cl. 1(A), 1(F)).
    • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶81).
    • Accused Features: The complaint alleges that Wipro’s use of SAP Commerce Cloud as a "Multi-tenant solution" for fashion brands (the "tenants") to upload catalog data constitutes the claimed "electronic tenant interfaces." It further alleges that the FRS architecture's dual synchronization of data to a transactional SAP S/4HANA database and a separate analytics database on the SAP Business Technology Platform infringes the dual-update limitation (Compl. ¶¶33, 35, 82).

  • U.S. Patent No. 12,033,208

    • Patent Identification: U.S. Patent No. 12,033,208, entitled "SYSTEMS AND METHODS FOR ANALYSIS OF WEARABLE ITEMS OF A CLOTHING SUBSCRIPTION PLATFORM," issued July 9, 2024.
    • Technology Synopsis: The ’208 patent focuses on an architecture where item data is received via "application programming interfaces (APIs)" and fulfillment requests are handled by initiating APIs that are "implemented as a microservice hosted via a virtual private cloud" (’208 Patent, cl. 1(A), 1(E)). This isolates backend fulfillment processes in a secure, dedicated cloud environment.
    • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶96).
    • Accused Features: The infringement allegation centers on the FRS's reliance on SAP Commerce Cloud Integration APIs for data ingestion and its use of SAP Process Automation APIs (including RPA bots) to manage backend operations. The complaint alleges these automation microservices are hosted in isolated client-allocated Virtual Private Clouds (VPCs) on the SAP Business Technology Platform, satisfying the "virtual private cloud" limitation (Compl. ¶¶36-37, 97).

  • U.S. Patent No. 11,354,622

    • Patent Identification: U.S. Patent No. 11,354,622, entitled "SYSTEMS AND METHODS FOR THIRD PARTY WAREHOUSE INTEGRATION," issued June 7, 2022.
    • Technology Synopsis: The ’622 patent details a method for communication between an "internal server system" and an "external warehouse system." The method uses structured data payloads—an "Inventory Snapshot Entity" to get stock availability, an "Order Entity" to trigger shipment, and a "Return Entity" to confirm returns—to automate the drop-shipping and reverse logistics processes with a third-party partner (’622 Patent, cl. 1).
    • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶111).
    • Accused Features: The complaint alleges Wipro’s FRS platform acts as the "internal server system" and its retail clients' or third-party logistics partners' systems act as the "external warehouse systems." The alleged infringement involves the FRS programmatically querying external warehouse databases via SAP BTP APIs to receive stock data (the "Inventory Snapshot Entity"), packaging user orders into an SAP S/4HANA Sales Order payload (the "Order Entity") that is transmitted to the external system, and receiving an automated return confirmation (the "Return Entity") (Compl. ¶¶39-42, 112).

  • U.S. Patent No. 11,307,149

    • Patent Identification: U.S. Patent No. 11,307,149, entitled "SYSTEMS AND METHODS FOR INSPECTION AND DEFECT DETECTION," issued April 19, 2022.
    • Technology Synopsis: The ’149 patent describes a method for managing the reverse logistics of returned wearable articles. The method involves maintaining a database with an "inspection history" for each item, inspecting the surface of a returned item using a "visual inspection process and/or a defect inspection tool," accessing the item's electronic record by reading an affixed label, updating the record with the inspection result, and routing the item for further processing or return to inventory based on that result (’149 Patent, cl. 1).
    • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶126).
    • Accused Features: The allegations focus on the FRS's use of SAP BTP Machine Learning models to analyze photos of returned garments, which is alleged to be the claimed "visual inspection process" and "defect inspection tool." The process allegedly involves scanning a QR code on the garment to access its record, updating the record with the machine learning analysis results, and then routing the garment to either active inventory or a "Refurbishment" stream (Compl. ¶¶43-45, 127).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentality is Wipro's Fashion Rental Solution ("FRS") (Compl. ¶4).
  • Functionality and Market Context: The FRS is described as a pre-packaged, cloud-based software solution built on the SAP Business Technology Platform and marketed to retail and fashion organizations for launching online designer rental services (Compl. ¶¶4, 25). The complaint alleges the FRS is designed to manage the entire rental lifecycle, including product cataloguing, online consumer reservations, real-time visibility into inventory, quality control, and backend automation using technologies like Artificial Intelligence (AI), Machine Learning (ML), and Robotic Process Automation (RPA) (Compl. ¶¶10, 25). The platform allegedly integrates with core enterprise systems like SAP S/4HANA and SAP Commerce Cloud to provide what is marketed as an "End to End Integration" for the fashion rental business model (Compl. ¶¶11, 28). A marketing infographic in the complaint summarizes the FRS as enabling new business models by facilitating online rentals, offering transparency, and automating store operations (Compl. p. 9).

IV. Analysis of Infringement Allegations

  • ’392 Patent Infringement Allegations
Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
(A) Receiving, via one or more processors, wearable item data describing one or more wearable items made available for physical shipment to users via electronic transactions. The FRS platform utilizes processors to receive data describing designer garments that are made available for rental to consumers through subscription-based transactions. ¶52(A) col. 35:30-38
(B) Hosting, by the one or more processors, an electronic warehouse operations portal and/or an electronic administrative portal comprising user interfaces accessible from one or more devices over one or more networks. The FRS hosts an electronic warehouse operations portal for automating order and return processes, as well as an administrative portal for displaying cataloguing and rental status information. ¶52(B) col. 35:39-47
(C) Receiving, by the one or more processors, one or more electronic user transactions initiated at one or more user platforms, each associated with at least one unique user identifier and at least one unique item identifier identifying a wearable item... to be placed in a virtual closet and rented... The FRS receives electronic user transactions from user platforms, where each transaction associates a unique user ID with a unique item ID (such as a QR code on the garment) for renting the item. ¶52(C) col. 35:48-60
(D) Receiving, by the one or more processors, one or more wearable item operations requests from at least one of the electronic warehouse operations portal and the electronic administrative portal to initiate order processing of the wearable item... The FRS receives item operations requests from its warehouse and administrative portals to initiate the processing of a wearable item order for a specific user. ¶52(D) col. 35:61-68
(E) In response to receiving the one or more wearable item operations requests, initiating one or more microservices to fulfill the one or more wearable item operations requests to initiate shipping of the wearable item to the user at a physical address... In response to operations requests, the FRS allegedly initiates microservices, such as Robotic Process Automation (RPA), to automate fulfillment and initiate shipping of the garment to the user's address. ¶52(E) col. 36:1-8
  • ’166 Patent Infringement Allegations
Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
(A) Receiving, by one or more processors, item data describing one or more items made available for physical shipment to users via electronic transactions. The FRS platform utilizes processors to receive data describing designer garments that are made available to consumers via electronic subscription transactions. ¶67(A) col. 35:40-45
(B) Hosting, by the one or more processors, an electronic warehouse operations portal and/or an electronic administrative portal comprising user interfaces accessible from one or more devices over one or more networks. The FRS hosts an electronic warehouse portal to automate logistics and an administrative portal for managing cataloguing and viewing rental statuses. ¶67(B) col. 35:46-52
(C) Receiving, by the one or more processors, one or more electronic user transactions initiated at one or more user platforms, each... associated with at least one unique user identifier and at least one unique item identifier... The FRS receives electronic user transactions that associate a unique user ID with a unique item ID (a QR code on the garment) for renting or purchasing the item. ¶67(C) col. 35:53-65
(D) Receiving, by the one or more processors, one or more item operations requests from at least one of the electronic warehouse operations portal and the electronic administrative portal to initiate order processing of the item... The FRS receives requests from its portals to begin order processing of a specific wearable item for a specific user. ¶67(D) col. 35:66-col. 36:5
(E) In response to receiving the one or more item operations requests, initiating one or more microservices to fulfill the one or more item operations requests to initiate shipping of the item to the user at a physical address... In response to receiving requests, the FRS allegedly uses microservices, including Robotic Process Automation (RPA), to fulfill the order and ship the item to a physical address. ¶67(E) col. 36:6-14
  • Identified Points of Contention:
    • Technical Questions: The complaint's allegations are primarily based on high-level marketing materials and product descriptions from Wipro and its partner, SAP (Compl. ¶¶26-45). A central question for the court will be whether the actual, operational architecture of the FRS platform performs the specific steps recited in the claims. For example, what evidence does the complaint provide that the accused system’s "Robotic Process Automation" (Compl. ¶52(E)) constitutes the "one or more microservices" required by claim 1 of the ’392 patent? The complaint presents a screenshot illustrating "End to End Integration" between various SAP platforms (Compl. p. 11), but a key factual question will be whether this integration functions precisely as the multi-step methods claimed in the asserted patents.
    • Scope Questions: The case may raise questions about the scope of several claim terms. For instance, does the term "electronic tenant interfaces" as used in the ’510 patent (Compl. ¶82(A)) read on the alleged SAP Commerce Cloud platform where brand managers upload catalog data (Compl. ¶33)? Similarly, for the ’149 patent, does the alleged use of "Machine Learning image analysis models" (Compl. ¶44) meet the definitional scope of a "defect inspection tool" as that term is understood in the context of the patent?

V. Key Claim Terms for Construction

  • The Term: "microservice" (from claim 1 of the '392 and '166 patents)

  • Context and Importance: This term is critical as it defines the mechanism for fulfilling user requests, the final step in the core method of several asserted patents. The infringement case hinges on whether the accused FRS's use of tools like "Robotic Process Automation (RPA)" and other backend processes qualifies as "initiating one or more microservices" (Compl. ¶¶52(E), 67(E)). The construction of this term will determine if Wipro's backend automation architecture falls within the scope of the claims.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specifications of the ’392 and ’166 patents do not provide a narrow, explicit definition. They describe microservices functionally, listing examples such as order processing, inventory allocation, and fulfillment (’392 Patent, col. 28:10-48). A party could argue this supports a broader construction covering any discrete, automated backend process that performs these functions.
    • Evidence for a Narrower Interpretation: Other patents in the family, such as the ’208 patent, provide more architectural context, claiming "one or more APIs being implemented as a microservice hosted via a virtual private cloud" (’208 Patent, cl. 1(E)). A party could argue that this language, present within the same patent family, suggests the patentee contemplated a specific, modern software architecture where services are independently deployable and communicate over APIs, potentially narrowing the term's scope to exclude more monolithic or generalized automation scripts.

  • The Term: "unique item identifier" (from claim 1 of the '392 and '166 patents)

  • Context and Importance: This term is fundamental to the patents' ability to track individual physical garments through the rental lifecycle. The complaint alleges that a "unique QR code on the garment" meets this limitation (Compl. ¶¶52(C), 67(C)). The dispute may turn on whether a standard QR code, as allegedly used by Wipro, possesses the specific properties required by the term in the context of the patent family.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term itself suggests a functional definition: an identifier that is unique to a single item. A QR code is a common and effective way to implement such an identifier. The abstract of the ’392 patent refers to the system managing "transactions of wearable items," a process for which QR codes are well-suited.
    • Evidence for a Narrower Interpretation: The ’622 patent, which is part of the same family, elaborates on the role of unique identifiers in a third-party warehouse context, distinguishing between a "unique article identifier" and an "external warehouse unique identifier" (’622 Patent, cl. 1). A party might argue that this detailed treatment implies a more specific data structure or set of properties than a simple QR code, and that this context should inform the construction of the term in the related ’392 and ’166 patents.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. The inducement claims are based on allegations that Wipro actively encourages its customers to directly infringe by distributing "Technical Codebases and Deployment Packages," providing "Hands-On Installation and Support," and publishing "Instructional Demonstrations and Materials" that teach the use of the infringing FRS platform (Compl. ¶¶55, 70, 85, 100, 115, 130). The contributory infringement claims allege that Wipro provides software components (e.g., custom build packs, API adapters) that are a material part of the patented inventions, are not staple articles of commerce, and have no substantial non-infringing use (Compl. ¶¶56-57, 71-72, 86-87, 101-102, 116-117, 131-132).
  • Willful Infringement: For all asserted patents, the complaint alleges willful infringement based on Wipro's continued infringing conduct after having knowledge of the patents, with knowledge established "Upon and since the date of service of Stratopatent's Complaint" (Compl. ¶¶59, 74, 89, 104, 119, 134). This constitutes an allegation of post-suit willfulness.

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

  • A core issue will be one of definitional scope: can claim terms rooted in modern software architecture, such as "microservice" and "application programming interfaces (APIs)", be construed to cover the specific SAP enterprise software modules and Robotic Process Automation (RPA) bots that allegedly form the basis of Wipro’s Fashion Rental Solution? The outcome of claim construction for these terms will be pivotal to the infringement analysis.
  • A second key issue will be one of functional proof: the complaint builds its infringement case largely on publicly available marketing documents from Wipro and SAP. A central evidentiary question will be whether Stratopatent can demonstrate through discovery that the accused FRS platform, in its actual technical operation, performs each and every step of the asserted multi-step method claims, or if there is a fundamental mismatch between the marketing descriptions and the underlying software functionality.
  • The case also presents a question of patent differentiation: with six patents from the same family asserted, a key strategic issue will be how the infringement and validity arguments are distinguished for each patent. The analysis may focus on whether the specific accused features—such as the multi-tenant architecture (’510 patent), the use of APIs in a virtual cloud (’208 patent), the third-party warehouse integration (’622 patent), and the machine-learning-based inspection process (’149 patent)—are distinct enough to support infringement of each patent independently.