Litigation

IPR2022-00915

Final Written Decision

IPR2022-00915

Patents at issue (1)

Summary

This Inter Partes Review (IPR) case concerning patent 10257319 resulted in a Final Written Decision.

Case overview & background

Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.

This case involves an Inter Partes Review (IPR) before the Patent Trial and Appeal Board (PTAB), IPR2022-00915, initiated by Petitioner Major Data UAB against Patent Owner Bright Data Ltd., concerning U.S. Patent No. 10,257,319. While the specific nature of Major Data UAB is not explicitly stated in the provided search results, Bright Data Ltd. is defending its patent, suggesting it is either a patent assertion entity (PAE) or an operating company asserting its intellectual property. Major Data UAB sought to join an existing IPR (IPR2021-01492, the "NetNut IPR") after the original petitioner, NetNut, settled and was terminated from the proceeding, indicating a defensive strategy against patent assertions.

The IPR is directly linked to an underlying patent infringement litigation, Bright Data Ltd. v. Tefincom S.A., No. 2:19-cv-414, pending in the U.S. District Court for the Eastern District of Texas. The specific accused product, service, or technology in this district court case is not detailed in the provided information, nor is a one-line technical sketch of patent 10,257,319. The Eastern District of Texas is a well-known venue for patent litigation, often favored by patent owners due to its reputation for moving cases quickly to trial and its experienced patent juries. The procedural posture highlights a common interplay between district court litigation and PTAB proceedings, where IPRs are used as a parallel strategy to challenge patent validity.

This case is notable due to the strategic maneuvering seen with the IPR. Major Data UAB's attempt to join an existing IPR after the original petitioner settled suggests a concerted effort by alleged infringers to challenge the validity of the '319 patent, potentially indicating an NPE assertion pattern by Bright Data Ltd. or a patent that is broadly asserted in the industry. The PTAB's role in potentially preventing a patent owner from avoiding trial by settling with original petitioners underscores the significance of IPRs as a mechanism for challenging patent validity outside of district court.

Key legal developments & outcome

Major rulings, motions, claim construction, settlements, and the present posture or final disposition.

Key Legal Developments and Outcome for Patent Infringement Litigation Involving U.S. Patent 10,257,319

The legal developments surrounding U.S. Patent 10,257,319 primarily involve parallel Inter Partes Review (IPR) proceedings at the Patent Trial and Appeal Board (PTAB) and subsequent appeals to the Federal Circuit, which significantly impacted related patent infringement litigation in district courts. The core outcome is the unpatentability of claims within Patent 10,257,319.

Parallel PTAB IPR Proceedings

  • Filing of IPR2022-00915: MAJOR DATA UAB, as Petitioner, challenged U.S. Patent 10,257,319, owned by BRIGHT DATA LTD., in IPR2022-00915. This IPR was related to an earlier proceeding, IPR2021-01492 (the "NetNut IPR"), where the original petitioner, NetNut, settled and was terminated.
  • Motion for Joinder (2022-06-23): A reply in support of a motion for joinder in IPR2022-00915 was filed on June 23, 2022.
  • Final Written Decision (2023-06-23): The PTAB issued its Final Written Decision in IPR2022-00915 on June 23, 2023, finding the challenged claims of U.S. Patent 10,257,319 to be unpatentable. Several other IPRs were filed challenging related patents owned by Bright Data Ltd., including IPR2022-00103 by Code200 UAB, which also resulted in a Final Written Decision of "Unpatentable" on June 23, 2023.

Related District Court Litigation

Bright Data Ltd. was involved in multiple patent infringement lawsuits in the U.S. District Court for the Eastern District of Texas concerning U.S. Patent 10,257,319 and related patents, including:

  • Bright Data Ltd. v. Teso LT, UAB, Metacluster LT, UAB, Oxysales, UAB (E.D. Tex., Civil Action No. 2:19-CV-00395-JRG): This case involved allegations of infringement of U.S. Patent 10,257,319, along with U.S. Patents 10,484,510 and 10,469,614.
    • Jury Verdict Form (2021-11-05): A jury verdict form was filed on November 5, 2021.
    • Stay of Litigation: This case was stayed pending the final outcome of related patent invalidation proceedings before the USPTO. The Federal Circuit's subsequent affirmance of unpatentability for Patent 10,257,319 would likely lead to the dismissal of claims based on this patent in this district court action.
  • Bright Data Ltd. v. Code200, UAB, et al. (E.D. Tex., No. 2:19-cv-00396).
  • Bright Data Ltd. v. Tefincom S.A. (E.D. Tex., No. 2:19-cv-414).
  • Bright Data Ltd. v. NetNut Ltd. (E.D. Tex., No. 2:21-cv-225): This case was also pending at one point.

The progress and ultimate disposition of these district court cases were heavily influenced by the parallel IPR proceedings and their appeals.

Federal Circuit Appeals and Supreme Court Review

  • Federal Circuit Appeals (2023-07 to 2025-08-01): Bright Data Ltd. appealed the PTAB's unpatentability decisions to the U.S. Court of Appeals for the Federal Circuit. Multiple appeals were consolidated or heard concurrently, including:
    • Bright Data Ltd. v. Code200, UAB (Fed. Cir. No. 23-2144): Filed July 2023. On August 1, 2025, the Federal Circuit issued an opinion affirming the PTAB's decision that the challenged claims of four of Bright Data's patents, including U.S. Patent 10,257,319, were unpatentable.
    • Bright Data Ltd. v. The Data Company Technologies Inc. (Fed. Cir. Nos. 23-2145, 23-2146): On August 1, 2025, the Federal Circuit also issued opinions in these cases, affirming the unpatentability of patents, including U.S. Patent 10,257,319.
    • Bright Data Ltd. v. Code200, UAB (Fed. Cir. No. 23-2442, 23-2443): Opinions were also filed on August 1, 2025, by the Federal Circuit in these related appeals.

The Federal Circuit's affirmance of the PTAB's unpatentability findings for U.S. Patent 10,257,319 on August 1, 2025, effectively extinguished patent protection for these specific claims. This meant that the district court litigation relying on these claims would face significant challenges or likely be dismissed.

  • Petition for Certiorari to the U.S. Supreme Court (2026-01-05): Bright Data Ltd. filed a Petition for a Writ of Certiorari with the U.S. Supreme Court (Case No. 25-779, Bright Data Ltd. v. Code200, UAB) on January 5, 2026, seeking review of the Federal Circuit's decision invalidating claims of U.S. Patents 11,044,342, 10,257,319, and 10,484,510. Bright Data argued that the Federal Circuit's refusal to consider its express disclaimers of scope during IPR proceedings created uncertainty and inconsistency in claim construction.
  • Supreme Court Certiorari Denied (2026-02-23): The U.S. Supreme Court denied Bright Data's petition for certiorari on February 23, 2026. This denial concluded the matter at the Supreme Court level, leaving the Federal Circuit's decision of unpatentability for the challenged claims of U.S. Patent 10,257,319 intact and final.

Outcome

The ultimate outcome for U.S. Patent 10,257,319 is that its challenged claims were found unpatentable by the PTAB (Final Written Decision on June 23, 2023), and this decision was affirmed by the Federal Circuit on August 1, 2025. The U.S. Supreme Court's denial of certiorari on February 23, 2026, solidified this outcome. As a result, the claims of U.S. Patent 10,257,319 are unenforceable, and any pending patent infringement litigation based on these claims would likely be dismissed or significantly impacted by this final determination of unpatentability.

Plaintiff representatives

Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

Counsel of Record for Petitioner Major Data UAB in IPR2022-00915

The petitioner in IPR2022-00915, Major Data UAB, was represented by:

  • Name: Liang Huang
  • Role: Attorney for Petitioner
  • Firm: Maschoff Brennan Gilmore Israelsen & Mauriel LLP (doing business as Maschoff Brennan). Formerly Mauriel Kapouytian Woods LLP, which merged with Maschoff Brennan on January 1, 2024.
  • Office Location: New York, NY (15 W. 26th Street, Seventh Floor, New York, NY 10010). Liang Huang is also listed with a San Francisco, CA address in some records, but the New York office was the listed address for Mauriel Kapouytian Woods LLP when the IPR document was filed.
  • Relevant Patent Litigation Experience: Liang Huang (Reg. No. 67,016) is a registered patent attorney. While specific individual patent litigation cases for Liang Huang are not detailed in the provided search results, his prior firm, Mauriel Kapouytian Woods LLP, provided legal counsel in patent, trademark, copyright, and litigation matters. The merged firm, Maschoff Brennan, has extensive experience representing clients in federal and state courts, and before the USPTO, PTAB, and ITC, handling complex patent litigation across various technologies including semiconductors, wireless communications, AI, and medical devices. Maschoff Brennan's litigators handle a successful inter partes and ex partes practice at the USPTO. Liang Huang's USPTO data indicates affiliation with major applicants like Taiwan Semiconductor Manufacturing Company, Ltd. and DENSO CORPORATION.

Defendant representatives

Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

The defendant in Bright Data Ltd. v. Tefincom S.A., No. 2:19-cv-414 is Tefincom S.A..

Here is the counsel of record for Tefincom S.A. in the patent infringement case:

  • Korula T. Cherian

    • Role: Counsel of Record
    • Firm: Cherian LLP
    • Office Location: Berkeley, CA
    • Relevant Experience: Korula Cherian has represented Code200, UAB, a defendant in a related case to Bright Data, in a Supreme Court matter where Bright Data Ltd. was the petitioner.
  • Robert M. Harkins, Jr.

    • Role: Counsel
    • Firm: Cherian LLP
    • Office Location: Berkeley, CA