Judge Furman Declines to “Pink Slip” Infringement Lawsuit Against Work Management Tool Company | Patterson Belknap Webb & Tyler LLP
On June 21, 2024, Judge Jesse M. Furman (S.D.N.Y.) denied Monday.com Ltd. (“Monday”)’s motion to dismiss a complaint for patent infringement by plaintiff Michael Philip Kaufman. See Kaufman v. Monday.com Ltd., 23-CV-5864 (June 21, 2024).
Kaufman holds three patents (the ’981 Patent, the ’220 Patent, and the ’801 Patent) that he alleges implicate technology for “relational database[s]” by providing an automated process for “scan[ning] the structure of the entire database” and “construct[ing] a complete working user application for working with the relational database.” Monday.com is an Israeli company that sells professional management tools.
Kaufman alleged that Monday’s products, when launched, automatically download software to users’ computers that infringe claims in Kaufman’s patents. Specifically, he alleged that the software infringes the ’981 Patent by, among other things, scanning a user’s database and constructing a “client application” corresponding to that database. With respect to the ’801 Patent, Kaufman alleged that Monday’s software meets the limitations of one of the patent’s claims covering the relationship between multiple tables in a user’s database. And with respect to the ’220 Patent, Kaufman alleges that Monday’s software provides instructions to “automatically generat[e] an end-user interface for working with the data within a relational database.”
Monday moved to dismiss Kaufman’s complaint, contending that Kaufman’s theory of infringement is technically impossible. Judge Furman declined to dismiss the complaint, finding that Monday’s arguments are “premature,” as illustrated by “Monday.com’s repeated contention that Kaufman fails to back up his well-pleaded facts with ‘evidence.’” Op. 3. The Court found that Monday’s other arguments came down to “questions of claim construction or issues of fact that the Court cannot properly consider or resolve on a Rule 12(b)(6) motion to dismiss.” Id. Because Kaufman properly alleged that Monday’s software infringed specific claims in each of the three alleged patents, the Court found that his allegations were “enough” “for now,” even if they are—as Monday contends—technically impossible to prove. Id. at 2.
