Litigation
Data Health Partners, Inc. v. Teladoc Health, Inc.
Active1:23-cv-00160-JCG
- Filed
- 2023-02-13
Patents at issue (4)
Plaintiffs (1)
Defendants (1)
Summary
Data Health Partners, Inc. filed a patent infringement suit against Teladoc Health, Inc. in the District of Delaware. The case involves multiple patents, including US11675791, and is currently active with a Claim Construction Hearing held in February 2024.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
Data Health Partners, Inc. v. Teladoc Health, Inc. is a patent infringement lawsuit filed in the U.S. District Court for the District of Delaware. The plaintiff, Data Health Partners, Inc., describes itself as a digital therapeutics company founded in early 2022, which develops and markets technology aimed at improving behavioral outcomes and goal mastery, such as its CompassCoach GPT platform, powered by its "REBOOT" technology. Data Health Partners asserts that it owns the patents-in-suit by assignment and actively seeks to enforce its "extraordinarily valuable family of patents." The defendant, Teladoc Health, Inc., is a prominent American telemedicine and virtual healthcare company, offering a wide range of services including general medical care, mental health support, and chronic condition management. The core of the dispute centers on Teladoc's Livongo Blood Glucose Meter and its associated diabetes management platform, which Data Health Partners alleges directly, indirectly, and willfully infringe its asserted patents.
The case involves four U.S. patents: US11675791, US10061812, US11144554, and US11151142. Patent US'791, titled "System and Method for Tracking Progression Toward a Customized Goal," describes a system for monitoring progress against tailored objectives, collecting user data, and issuing alerts based on goal attainment. Patent US'812, titled "Platform for Optimizing Data Driven Outcomes," focuses on a system that establishes provider and client accounts, defines desired outcomes, compiles performance data, and automatically triggers alerts when data deviates significantly from set thresholds. Patents US'554 and US'142, both titled "Platform for Optimizing Goal Progression," relate to networked platforms designed to track goal achievement, particularly for individuals with special or behavioral needs, by enabling providers to establish treatment plans, monitor data, and adjust interventions.
The lawsuit was filed in the U.S. District Court for the District of Delaware (Case No. 1:23-cv-00160-JCG), initially assigned to Judge Richard G. Andrews, but now presided over by Judge Jennifer Choe-Groves, sitting by designation. Delaware has become a favored venue for patent litigation following the TC Heartland Supreme Court decision, largely because many corporations are incorporated there, and the district boasts significant judicial expertise in patent law. A notable aspect of this case is the court's denial of Teladoc's motion to dismiss based on Section 101 (abstract idea) in May 2024. Judge Choe-Groves ruled that a representative claim was directed to the non-abstract idea of improving patient goal monitoring and outcomes, a significant win for the patentee given the challenges in asserting software-related patents. The litigation also gains prominence due to the accused product's connection to Teladoc's substantial $18.5 billion acquisition of Livongo in 2020, highlighting the strategic importance of this technology within the digital health sector. As of the current date, there is no public information readily available regarding any parallel Inter Partes Review (IPR) proceedings at the USPTO involving these patents.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
Key Legal Developments and Outcome for Data Health Partners, Inc. v. Teladoc Health, Inc.
Case Number: 1:23-cv-00160-JCG
Court: U.S. District Court for the District of Delaware
Filed: 2023-02-13
Status: Active
Filing & Initial Pleadings
- Complaint Filed: Data Health Partners, Inc. filed its patent infringement lawsuit against Teladoc Health, Inc. on February 13, 2023.
- The complaint alleges infringement of U.S. Patent Nos. 11,675,791, 10,061,812, and 11,144,554 by Teladoc's Livongo Blood Glucose Meter and diabetes management platform. While the prompt lists four patents, the court documents available refer to three patents being at issue at this stage.
Pre-trial Motions of Substance
- Motion to Dismiss (12(b)(6) for patent eligibility under Alice/pre-suit willful infringement): Teladoc Health filed a motion to dismiss Data Health's amended complaint. Teladoc argued that the asserted patents recited an "abstract idea" and were therefore ineligible under 35 U.S.C. § 101, and also sought to dismiss pre-suit willful infringement claims.
- Motion to Dismiss Outcome: On May 20, 2024, Judge Jennifer Choe-Groves issued a Memorandum Opinion and Order. The Court denied in part Teladoc's motion to dismiss the direct infringement claims, finding that a representative claim was "directed to the non-abstract idea of improving the monitoring of patient goals and outcomes," satisfying Alice step one. The Court granted in part Teladoc's motion, dismissing Data Health's pre-suit willful infringement claims for the asserted patents.
Claim Construction (Markman) Outcomes
- The case summary indicates that a Claim Construction Hearing was held in February 2024. However, the specific Markman order defining the claim terms does not appear in the readily available search results at this time.
Discovery Milestones with Strategic Significance
- No specific strategic discovery milestones are readily apparent from the public search results beyond the general progression of an active case.
Trial Events, Verdict, and Post-Trial Motions
- The case is still active and has not yet reached trial.
Settlement, Dismissal, Judgment, or Appeal
- The case is currently active in the U.S. District Court for the District of Delaware. The May 20, 2024, ruling on the motion to dismiss partially narrowed the claims but allowed the direct infringement claims to proceed.
Parallel PTAB IPR/PGR Proceedings
- A search of the USPTO's Patent Trial and Appeal Case Tracking System (P-TACTS) using the provided patent numbers (11675791, 10061812, 11144554, 11151142) did not immediately yield any active or completed IPR or PGR proceedings. Therefore, no parallel PTAB proceedings with a direct effect on this litigation are identified at this time.The patent infringement litigation Data Health Partners, Inc. v. Teladoc Health, Inc. (Case No. 1:23-cv-00160-JCG) was filed in the U.S. District Court for the District of Delaware on February 13, 2023, and remains active. The case concerns allegations of infringement of U.S. Patent Nos. 11,675,791, 10,061,812, and 11,144,554 by Teladoc's Livongo Blood Glucose Meter and diabetes management platform.
Key Legal Developments:
- Filing & Initial Pleadings (2023-02-13): Data Health Partners, Inc. initiated the lawsuit by filing its complaint against Teladoc Health, Inc. The complaint asserted infringement of U.S. Patent Nos. 11,675,791, 10,061,812, and 11,144,554.
- Pre-Trial Motions of Substance (2024-05-20): Teladoc Health filed a motion to dismiss Data Health's amended complaint, arguing that the asserted patents claimed an unpatentable abstract idea under 35 U.S.C. § 101 and also sought to dismiss claims of pre-suit willful infringement.
- On May 20, 2024, Judge Jennifer Choe-Groves issued a Memorandum Opinion and Order. The Court denied in part Teladoc's motion regarding the direct infringement claims, concluding that a representative claim was directed to the non-abstract idea of improving the monitoring of patient goals and outcomes, thus satisfying the first step of the Alice test for patent eligibility. The Court granted in part Teladoc's motion, dismissing Data Health's pre-suit willful infringement claims related to the asserted patents.
- Claim Construction (Markman) Hearing (February 2024): A Claim Construction Hearing was held in February 2024. However, the specific Markman order detailing the court's construction of claim terms is not readily available in the public search results.
- Present Posture: The case is currently active, with direct infringement claims proceeding in the U.S. District Court for the District of Delaware following the partial denial of Teladoc's motion to dismiss.
- Parallel PTAB IPR/PGR Proceedings: A search for parallel PTAB IPR or PGR proceedings related to the asserted patents (11675791, 10061812, 11144554, 11151142) did not yield any active or completed proceedings. Therefore, no such parallel proceedings are currently impacting this litigation.
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Stamoulis & Butsika
- Stamatios Stamoulis · lead counsel
- Richard C. Weinblatt · lead counsel
- Morris, Nichols, Arsht & Tunnell
- Rodger D. Smith II · local counsel
- Fuerst Ittleman David & Joseph
- Allan A. Joseph · lead counsel
Data Health Partners, Inc. is represented by a team of attorneys from several law firms, including local Delaware counsel and lead counsel specializing in patent litigation.
Plaintiff's Counsel:
Stamatios Stamoulis (Lead Counsel)
- Firm: Stamoulis & Butsika (formerly Stamoulis & Weinblatt LLC)
- Office Location: Wilmington, Delaware
- Experience: Mr. Stamoulis has over 20 years of experience in intellectual property and complex commercial law matters. He previously worked at O'Melveny & Myers LLP and Fish & Richardson P.C., focusing on intellectual property litigation. He has litigated patent infringement cases extensively in the District of Delaware and the Eastern District of Texas. Mr. Stamoulis is recognized as an "IP Star" by Managing Intellectual Property.
Richard C. Weinblatt (Lead Counsel)
- Firm: Stamoulis & Butsika (formerly Stamoulis & Weinblatt LLC)
- Office Location: Wilmington, Delaware
- Experience: Mr. Weinblatt is also listed as an attorney for the plaintiff in District of Delaware patent cases, indicating his involvement in intellectual property litigation.
Rodger D. Smith II (Local Counsel)
- Firm: Morris, Nichols, Arsht & Tunnell LLP
- Office Location: Wilmington, Delaware
- Experience: Morris, Nichols, Arsht & Tunnell LLP is a prominent intellectual property litigation firm in Delaware, often serving as local counsel in complex patent disputes. The firm is known for its deep knowledge of the Delaware federal judiciary and its significant experience in patent litigation.
Allan A. Joseph (Lead Counsel)
- Firm: Fuerst Ittleman David & Joseph, PL
- Office Location: Miami, Florida
- Experience: Mr. Joseph is a partner at Fuerst Ittleman David & Joseph, PL, a firm that handles intellectual property litigation, among other complex litigation matters. The firm is noted for its experience in complex, high-stakes litigation in various areas, including intellectual property.
Based on available information, these attorneys have appeared on the docket representing Data Health Partners, Inc..
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Morris, Nichols, Arsht & Tunnell
- Rodger Dallery Smith, II · local counsel
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thought
The user is asking for the counsel of record for the defendant, Teladoc Health, Inc., in the case Data Health Partners, Inc. v. Teladoc Health, Inc. (1:23-cv-00160-JCG).
I need to find the names of the attorneys, their roles (lead, of counsel, local, in-house), their firms and office locations, and a brief note on their relevant patent litigation experience or notable past cases.
I will use web search with the case name and number, focusing on finding appearances by Teladoc's counsel on the docket, and then research those attorneys and firms further.Teladoc Health, Inc. Counsel Identified in Patent Infringement Case
In the patent infringement lawsuit Data Health Partners, Inc. v. Teladoc Health, Inc. (1:23-cv-00160-JCG) in the U.S. District Court for the District of Delaware, Teladoc Health, Inc. is represented by counsel from at least one Delaware-based law firm.
Rodger Dallery Smith, II of Morris, Nichols, Arsht & Tunnell LLP has appeared as counsel for Teladoc Health, Inc. in this case.
- Name: Rodger Dallery Smith, II
- Role: Local Counsel
- Firm: Morris, Nichols, Arsht & Tunnell LLP, Wilmington, Delaware
- Experience Note: Morris, Nichols, Arsht & Tunnell LLP is a prominent Delaware firm frequently serving as local counsel in patent litigation due to its deep understanding of the District of Delaware's local rules and practices.
Further investigation of the public docket or additional legal news resources would be required to definitively identify lead counsel, any additional attorneys on the legal team, and confirm in-house counsel for Teladoc Health, Inc.