IP Law Daily, PATENT—D. Del.: Database patent infringement cases to proceed against AT&T and Verizon, (May 29, 2026)

By Carolin Dennis, B.Sc., LL.B., LL.M.

Database patent infringement claims survived the invalidity challenge because OnePass Data Technology LLC’s allegations plausibly established inventive concept.

In a patent infringement dispute, the federal district court in Delaware denied the defendants’ motions to dismiss the complaints filed by OnePass Data Technology LLC (OnePass). The district court found that OnePass sufficiently pled facts alleging an inventive concept that transforms the representative claim into a patent-eligible application of the abstract idea, and plausibly alleged sufficient factual allegations to put the defendants on notice of their alleged infringing behavior (OnePass Data Technology LLC v. AT&T Mobility LLC, No. 1:25-cv-01111-JCG (D. Del. May 26, 2026)), (OnePass Data Technology LLC v. Verizon Communications Inc., No. 1:25-cv-01112-JCG (D. Del. May 26, 2026)).

Background. OnePass was the assignee of all right, title, and interest in the U.S. Patent Numbers 7,376,680 (’680 Patent) and 8,682,866 (’866 Patent) (collectively, Asserted Patents). OnePass contended that the Asserted Patents recite inventions that are directed to innovative technological solutions for cleaning data records, providing significant improvements and advantages over conventional data cleansing technology. OnePass accused AT&T Mobility LLC (AT&T Mobility); AT&T Services, Inc. (AT&T Services); Verizon Communications Inc.; and Cellco Partnership d/b/a Verizon Wireless (collectively, defendants) of infringing the Asserted Patents. OnePass alleged that the defendants directly infringe at least Claims 1–7 of the ’680 Patent and Claims 1–3, 9, and 16 of the ’866 Patent. OnePass accused the defendants of using certain “Accused Methods” to infringe method claims of the Asserted Patents, and of making, implementing, using, and operating certain “Accused Systems” to infringe system claims of the ’866 Patent. The defendants moved to dismiss OnePass’s complaint for failure to state a plausible claim for relief and contended that all claims in the Asserted Patents are unpatentable under 35 U.S.C. § 101. The district court applied the two-step Alice test.

Representative claim. The district court determined that Claim 1 of the ’680 Patent is representative of all independent claims in the Asserted Patents.

Patent eligibility. In Alice Corp. v. CLS Bank International, 573 U.S. 208 (2014), the United States Supreme Court established a two-step framework for determining patent eligibility under 35 U.S.C. § 101. First, a court must ascertain whether the claims at issue are directed to a patent-eligible concept, and not, inter alia, an abstract idea. If the claims do not pass Step One, the patent may still qualify for eligibility at Step Two if the claim elements, both individually and as an ordered combination, present an inventive concept.

Abstract idea. The defendants argued that the Asserted Patents are directed to the abstract idea of updating records against a reference list, but that does not fully encapsulate the claim language, which includes the distinction of completing the entire multi-step process in “a single pass.” However, the district court found that the Asserted Patents are drawn to the abstract idea of reading and searching multiple data files to create a new data file in one cycle. Considering the claim’s character as a whole, the final, cleansed file that Claim 1 of the ’680 Patent produces is an abstract idea, and is created by invoking generic processes of reading and comparing data files to achieve the cleansed output file. The district court determined that the fact that the claim language instructs that the invention completes generic processing steps only once does not change that the claim language focuses on an abstract idea. The district court also noted that the focus of Claim 1 of the ’680 Patent is similar to cases that the Federal Circuit has concluded to be directed to ineligible abstract ideas. Accordingly, the district court concluded that Claim 1 of the ’680 Patent is directed to the abstract idea of reading and searching multiple data files to create a new data file in one cycle.

Inventive concept. At the second step, the district court determined that OnePass has sufficiently pled facts alleging an inventive concept that transforms the representative claim into a patent-eligible application of the abstract idea. The district court noted that the complaints stated that the claimed inventions are directed toward technological advances for cleaning data records that provide significant improvements and advantages over conventional data cleansing technology. Further, the Asserted Patents are “rooted in computer technology directed to specific architecture and methods that provide major advances to the efficiency, reliability, and operation of various applications in the data cleansing industry,” and describe “new computer system architecture and operation that did not previously exist and that improves data cleansing technology.” Therefore, the district court concluded that, at the pleading stage, OnePass has plausibly pled factual allegations regarding the Asserted Patents to pass Alice step two.

Failure to state a plausible claim. The district court noted that the defendants argued that complaint’s failure to define the “certain Accused Systems” or “certain Accused Methods” results in a lack of fair notice. However, the complaints alleged that the defendants have obtained U.S. Postal Service-issued Permit Authorization for First-Class Mail and Standard Mail, described what U.S. Postal Service-issued Permit Authorization entails, and alleged, on information and belief, that the defendants have implemented, operated, and used certain Accused Systems with computer architecture that conduct multiple steps to perform mailing list address record cleansing. Additionally, Counts I and II of the complaints detail how the Accused Methods and Systems recite the elements of Claims 1 and 16 of the Asserted Patents. 81. Thus, the district court concluded that OnePass plausibly alleged sufficient factual allegations to put the defendants on notice of their alleged infringing behavior.

Accordingly, the defendants’ motions to dismiss the complaints filed by OnePass were denied.

The Cases are No. 1:25-cv-01111-JCG and No. 1:25-cv-01112-JCG.

Judge: Choe-Groves, J.

Attorneys: Donald C. Vavala, III and David E. Wilks (Wilks Law LLC) for OnePass Data Technology LLC. Kelly E. Farnan (Richards Layton & Finger, P.A.) for AT&T Mobility LLC and AT&T Services, Inc. Benjamin Schladweiler (Greenberg Traurig, LLP) for Verizon Communications, Inc. and Cellco Partnership d/b/a Verizon Wireless.

Companies: OnePass Data Technology LLC; AT&T Mobility LLC; AT&T Services, Inc.; Verizon Communications Inc.; Cellco Partnership d/b/a Verizon Wireless; AT&T Mobility LLC

Cases: Patent DelawareNews TechnologyInternet