Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 1 of 12 PageID #: 24347
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`BRIGHT DATA LTD.,
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` Plaintiff,
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`v.
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`TESO LT, UAB, OXYSALES, UAB, and
`METACLUSTER LT, UAB
`
`
`CODE200, UAB ET AL.,
`
` Defendants.
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`§
`§
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`§
`§
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`§
`§
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`§
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`SUPPLEMENTAL CLAIM CONSTRUCTION ORDER
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`Case No. 2:19-cv-00396-JRG
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`Case No. 2:19-cv-00395-JRG
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`Before the Court are three motions regarding claim construction issues. The first motion is
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`the Request for Clarification / Objections to Magistrate Judge Payne’s Claim Construction Order
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`(“Clarification Request”) filed by Plaintiff Bright Data Ltd., formerly Luminati Networks Ltd.
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`(“Plaintiff”) in Case No. 2:19-cv-00396-JRG (“Code200 Action”). Dkt. No. 102. Plaintiff’s
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`Clarification Request seeks clarification and revision of the Claim Construction Order (Code200
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`Action, Dkt. No. 97) as to two construed terms: (1) U.S. Patent No. 10,484,511 (the “’511 Patent”)
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`claim 1 regarding “sending . . . the first content identifier to the web server using the selected IP
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`address”; and (2) ‘511 Patent claim 25 regarding “source address.” Id. at 4–8.
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`The second motion is the Motion for Hearing Regarding O2 Micro Issue (“Motion for
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`Hearing”) filed by Defendants Code200, UAB, Oxysales, UAB, and Metacluster LT, UAB
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`(collectively, “Code200 Defendants”) in the Code200 Action and by Defendants Teso LT, UAB,
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`Oxysales, UAB, and Metacluster LT, UAB (collectively, “Teso Defendants”) (collectively,
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`“Defendants”) in Case No. 2:19-cv-00395-JRG (“Teso Action”). Code200 Action, Dkt. No. 234;
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`Teso Action, Dkt. No. 444. Defendants’ Motion for Hearing asserts that Plaintiff’s rebuttal
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 1 of 12
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`Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 2 of 12 PageID #: 24348
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`validity expert report takes a position as to the claim scope of “server” that requires the Court’s
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`intervention and requests four alleged clarifications that revise the Court’s existing claim
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`constructions for the terms “first server” and “second server” in certain patents. Id. at 1–2.
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`On April 20, 2021, the Court granted an unopposed motion for leave to supplement briefing
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`on Plaintiff’s Clarification Request. Code200 Action, Dkt. No. 143. Accordingly, Plaintiff’s
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`Clarification Request briefing includes Code200 Defendants’ Response (Code200 Action, Dkt.
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`No. 110), Plaintiff’s Reply (Code200 Action, Dkt. No. 163), and Defendants’ Sur-Reply (Code200
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`Action, Dkt. No. 179).
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`I.
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`“Source Address”
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`During claim construction, Plaintiff proposed the term “source address” be construed to
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`have its plain and ordinary meaning while Code200 Defendants sought a finding of indefiniteness.
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`Code200 Action, Dkt. No. 97 at 23. The Court construed “source address” to mean “address of the
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`web server.” Id. at 27. Plaintiff seeks to “clarify” that “source address” refers to “the IP address of
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`the sender of a communication” and “not the IP address of the web server.” Code200 Action, Dkt.
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`No. 102 at 6.
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`Plaintiff argues, as it asserts it did at oral argument, that the plain meaning of “source
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`address” to a POSA is the sender’s IP address. Id. at 4. Plaintiff notes that the specification never
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`uses “source address” to refer to content and that “[r]ather, the two uses of ‘source’ cited in the
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`Order (‘source program’ and ‘sources’ of content) are not used in the context of addresses.” Id. at
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`4–5. Plaintiff then discusses the HTTP protocol and TCP/IP protocol, arguing that the “source
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`address” is the address of the sender as opposed to the “destination address,” which Plaintiff asserts
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`is the address of the web server. Id. at 5. Plaintiff continues, “[w]hile a web server sometimes is
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`the source of a communication, it is never the source of the claimed step of ‘sending [a content
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 2 of 12
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`Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 3 of 12 PageID #: 24349
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`request] to the web server’ because in that situation the web server is the destination, not the
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`source.” Id. at 6.
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`Code200 Defendants respond that this is not a clarification request, but rather a request that
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`the Court change the construction to the opposite of what it found so that “source” refers to the IP
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`address of the “sender” of a communication rather than the IP address of the source of the content,
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`i.e., the web server. Code200 Action, Dkt. No. 110 at 1. Code200 Defendants are correct.
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`Code200 Defendants argue that Plaintiff asserts that it argued to the Court that “source
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`address” must be “the sender’s IP address,” but that the Court’s Claim Construction Order
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`demonstrated that Plaintiff argued at claim construction that “source address” has a “plain and
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`ordinary meaning” and that “source address” refers to an “IP address associated with a source.”
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`Id. at 2 (citing Dkt. No. 97 at 23). The Claim Construction Order identified Plaintiff’s proposed
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`construction of “source address” as “plain and ordinary meaning,” and stated, “Plaintiff submits:
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`The ‘source address’ refers to an ‘IP address associated with a source.’” Code200 Action, Dkt. No.
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`97 at 23 (citing Code200 Action, Dkt. No. 86 at 26–27 (“In Dr. Rhyne’s opinion: ‘[A] POSA
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`would understand the source address as referring to an IP address associated with a source . . .’”)
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`(quoting Code200 Action, Dkt. No. 86-3)).
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`With respect to Plaintiff’s note that the specification never uses “source address” to refer
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`to content, Code200 Defendants respond that the phrase “source address” is never used in the
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`patent written description. See Code200 Action, Dkt. No. 110 at 2. Code200 Defendants continue,
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`arguing that Plaintiff’s argument regarding HTTP and TCP/IP misses that the specification does
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`not ever point to HTTP or TCP/IP for a definition of “source address.” Id. Code200 Defendants
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`argue that Plaintiff has no basis to contest the Court’s explanation as to why “source address” is
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`limited to the address of the source of content. Code200 Action, Dkt. No. 110 at 3.
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 3 of 12
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`Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 4 of 12 PageID #: 24350
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`As Code200 Defendants pointed out, Plaintiff’s argument that the specification never uses
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`“source address” to refer to content falls flat because the specification never uses the term “source
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`address” at all. See Code200 Action, Dkt. No. 110 (citing Code200 Action, Dkt. No. 88 at 17
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`(citing Code200 Action, Dkt. No. 88-1 at ¶¶ 78–84)); see also Code200 Action, Dkt. No. 86-1 at
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`1–29. Accordingly, what must be understood is what a “source” is.
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`The Court’s Claim Construction Order previously explained that the ’511 Patent’s
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`specification “suggests that ‘source’ is used to refer to a content source rather than a
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`communication source.” Code200 Action, Dkt. No. 97 at 25 (emphasis added). As the Court
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`previously stated, “ultimately, when read in the context of the entire specification, including the
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`complete claim set and the description of the invention, the scope of ‘source address’ is reasonably
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`limited to the address of the source of content, which in Claim 1 is the web server.” Id. at 26 (citing
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`Phillips v. AWH Corp., 415 F.3d 1303, 1316 (Fed. Cir. 2005); Trs. of Columbia Univ. v. Symantec
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`Corp., 811 F.3d 1359, 1363 (Fed. Cir. 2016)) (emphasis added).
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`Plaintiff requested additional briefing on their Clarification Request. That briefing pointed
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`to Dr. Freedman’s December 31, 20201 declaration in which Dr. Freeman opined that a POSA
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`would not understand what “source address” means in the context of claim 25 of the ’511 Patent
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`but then testified in his March 22, 2021 deposition that “source address” is a term of art that refers
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`to the “sender address” rather than a “destination address.” Code200 Action, Dkt. No. 163 at 2–4.
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`Plaintiff argues “[t]he above conflicting testimony is material to the Court’s Claim Construction
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`Order as the Court cited Code200 Defendants’ argument that the ‘source address’ could refer to
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`the ‘source of content’ . . . .” Id. at 4 (citing Code200 Action, Dkt. No. 97 at 24–27).
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`1 Plaintiffs state that “[h]ere, Dr. Freedman provided a December 31, 2021 declaration . . . .” Dkt. No. 163 at 2. The
`Court interprets this as a typographic error for December 31, 2020.
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 4 of 12
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`Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 5 of 12 PageID #: 24351
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`Code200 Defendants respond that while Plaintiff quotes Dr. Freedman’s opinion in
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`paragraphs 80-81 that “source address” could refer to the source of content, Plaintiff omits
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`paragraph 82, where “Dr. Freedman opined that ‘source address’ could alternatively refer to the
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`source of the request (i.e., sender) rather than the source of content.” Code200 Action, Dkt. No.
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`179 at 3 (citations omitted). Paragraph 82 of Dr. Freedman’s declaration indeed provides,
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`“[a]lternatively, the patentees could be using ‘source’ to refer to the source of the content request
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`that is sent to the web server . . . .” Code200 Action, Dkt. No. 163-2 at ¶ 82.
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`This is additional evidence that “source address” may be used in the art to denote a sending
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`address. However, that the source address may be a sending address was never in dispute, and the
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`new evidence does not restrict “source address” to sending address in the art such that it could
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`mean only sending address in the patent. Ultimately, Plaintiff provides no new information and
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`merely rehashes arguments already resolved and explained by the Claim Construction Order.
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`Accordingly, the Court denies Plaintiff’s request to revise the construction of “source address.”
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`As the Court previously found, “ultimately, when read in the context of the entire
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`specification, including the complete claim set and the description of the invention, the scope of
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`‘source address’ is reasonably limited to the address of the source of content, which in Claim 1 is
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`the web server.” Id. at 26 (internal citations omitted). The Court retains its previous construction
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`that “source address” means “address of the web server.” See Code200 Action, Dkt. No. 97 at 27.
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`II.
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`“Sending . . .”
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`Plaintiff seeks clarification and revision of the construction of the ’511 Patent claim 1 term
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`“sending . . . the first content identifier to the web server using the selected IP address.” Code200
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`Action, Dkt. No. 102 at 6. The Court construed this term to mean “sending . . . the first content
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 5 of 12
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`Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 6 of 12 PageID #: 24352
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`identifier to the web server using the selected IP address as either the address of the first server or
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`of the web server.” Code200 Action, Dkt. No. 97 at 19.
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`Plaintiff asserts two problems with this construction: (1) the phrase “or of the web server”
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`should be deleted because the “source address” would never be the web server because the
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`communication is sent “to the web server” and (2) the Order appears to inadvertently omit
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`intermediaries from IP addresses that can be used for sending. Code200 Action, Dkt. No. 102 at
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`7. Plaintiff’s objection “requests that the Court clarify that the construction does not exclude
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`intermediaries such as the ‘client device’ of claims 2–5.” Id. at 8.
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`With respect to Plaintiff’s argument that the phrase “or of the web server” should be deleted
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`because the “source address” would never be the web server, neither the claims nor the description
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`of the invention exclude the address of the “web server” as the selected IP address. As Code200
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`Defendants note, Plaintiff points to the “incorrect construction” of “source address” as allegedly
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`causing the Court to insert “or of the web server” in the construction. See Code200 Action, Dkt.
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`No. 110 at 4; see also Code200 Action, Dkt. No. 102 at 7. Plaintiff’s argument carries over error
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`from its rejected “source address” argument. Because the “source address” is the address of the
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`web server, then the “selected IP address” of claim 1 may be used as the address of the web server.
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`The Court’s construction is specific to ’511 Patent claim 1. While the Court did state, “the
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`role played by the IP address used in the sending step, read in light of the entire specification, is
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`reasonably limited to using the IP address as a sending address or a receiving address (including
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`intermediaries),” the Court’s statement read the claim in light of the entire specification. See
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`Code200 Action, Dkt. No. 97 at 17–19. After making this statement, the Court recited Claims 1
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`through 4 and 25 of the ’511 Patent and stated, “Claims 2 through 5 are directed to using a client
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`device as an intermediary between the first server and the web server.” Id. at 18. The Court
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 6 of 12
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`

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`Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 7 of 12 PageID #: 24353
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`continued, “In contrast, Claim 25 uses the selected IP address as an address of a “source” rather
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`than of an intermediary.” Id.
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`The Court did not “inadvertently omit intermediaries from IP addresses that can be used
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`for sending” as Plaintiff’s Clarification Request suggests. See Code200 Action, Dkt. No. 102 at 7.
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`The Court purposefully did not include the language “including intermediaries” because although
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`’511 Patent Claims 2–5 are directed to using a client device as an intermediary, Claim 1 and Claim
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`25 are not, and in fact Claim 25 uses the selected IP address as an address of a “source” rather than
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`of an intermediary. See Code200 Action, Dkt. No. 97 at 17–18.
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`The Court clarifies that the Court’s construction does not exclude intermediaries
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`specifically with respect to ’511 Patent Claims 2–5. Unlike ’511 Patent Claims 1 and 25, “Claims
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`2 through 5 are directed to using a client device as an intermediary between the first server and the
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`web server.” See Id. at 18. However, in light of Plaintiff’s Clarification Request and in the interest
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`of avoiding jury confusion, the Court amends the construction of “sending . . . the first content
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`identifier to the web server using the selected IP address” to “sending . . . the first content identifier
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`to the web server using the selected IP address as either a sending address or a receiving address.”
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`The Court emphasizes that this amendment does not change the scope of the term in any way, but
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`merely seeks to avoid jury confusion.
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`III.
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`“Server” Terms2
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`Defendants’ Motion for Hearing requests a “clarification” of the Court’s constructions of
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`“first server” and “second server” and a hearing to address this issue in advance of pretrial
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`2 Citations in this section are to the Code200 Action unless identified otherwise. The motions in
`the Code200 Action and Teso Action are nearly identical except the Teso Action also urges
`resolution of another motion. That motion will not be addressed in this order.
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 7 of 12
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`Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 8 of 12 PageID #: 24354
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`conferences. Dkt. No. 234 at 1–2. The table below indicates the terms at issue, the relevant patents
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`for those terms, their current constructions, and the requested “clarifications:”
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`Term
`“first server”
`’614 Patent
`Teso
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`“first server”
`’511 Patent
`Code200
`“second server”
`’319/510 Patents
`Teso
`“second server”
`’968 Patent
`Code200
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`Construction
`“server that is not the client
`device”
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`“server that is not the client
`device or the web server”
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`“server that is not the client
`device”
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`“server that is not the client
`device or the first web server”
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`Requested Clarification
`“a device that is operating in the role of
`a server by offering
`information
`resources, services, and/or applications
`and that is not the client device”
`“a device that is operating in the role of
`a server and that is not the first client
`device or the web server”
`“a device that is operating in the role of
`a server and that is not the first client
`device”
`“a device that is operating in the role of
`a server and that is not the requesting
`client device or the first web server”
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`Defendants’ Motion for Hearing merely states that “it became apparent for the first time
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`based on Bright Data’s rebuttal validity expert report that Bright Data takes a position as to the
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`claim scope of “server” that requires the Court’s intervention to resolve the parties’ dispute
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`pursuant to O2 Micro . . . .” Id. at 1.
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`Plaintiff argues that “while framed as a Motion for Hearing Regarding O2 Micro Issue
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`(‘Motion’), Defendants are clearly and improperly requesting new claim constructions on the eve
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`of trial that were already rejected or waived during claim construction.” Dkt. No. 242 at 4.
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`Plaintiffs note that Defendants did not make these objections in their December 22, 2020
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`Objections to the Court’s Claim Construction Order in Bright Data Ltd. v. Teso lt UAB et al., 2:19-
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`cv-00395-JRG (“Teso Action”) or in their February 22, 2021 Objections to this Court’s Claim
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`Construction Order in the Code200 Action. Code200, Dkt. No. 242 at 4 (citing Teso Action, Dkt.
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`No. 200; Code200 Action, Dkt. No. 103).
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`Plaintiff contends that Defendants are seeking broad constructions that treat client devices
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`and servers interchangeably in contradiction of Defendants’ denial that they were making such an
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 8 of 12
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`Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 9 of 12 PageID #: 24355
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`argument as noted by the Court in its construction of “client device” for the ’614 Patent. Id. (citing
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`Teso Action, Dkt. No. 191 at 15 (“[Defendants] deny that they will claim client devices and servers
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`are interchangeable general use computers.”).
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`Plaintiff filed their response on July 6, 2021. Defendants’ reply deadline was July 13, 2021.
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`Defendants did not file a reply.
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`The Court’s Claim Construction Order in the Code200 Action stated, “[t]he issue in dispute
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`appears to be whether one component can simultaneously serve as more than one of: the client
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`device, the first server/second server, and the web server. It cannot.” Dkt. No. 97 at 13. The Court
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`found the recited operation of the claims suggests a distinction among these components and that
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`claim 1 of the ’511 Patent “plainly is directed to a ‘first server’ acting as an intermediary between
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`the ‘client device’ and ‘second server.’” Id. at 15. Defendants’ requested clarifications for the
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`Code200 Action server terms do not challenge this but rather ask the Court to define the “server”
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`in these terms as “a device that is operating in the role of a server” and replace “the client device”
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`with “the requesting client device.” Dkt. No. 234 at 2. Defendants’ requested clarifications for the
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`Teso Action “second server” term likewise asks the Court to define the “server” as “a device that
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`is operating in the role of a server” and replace “the client device” with “the first client device.”
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`Id. Finally, Defendants’ requested clarifications for the Teso Action “first server” asks the Court
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`to define the “server” as “a device that is operating in the role of a server by offering information
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`resources, services, and/or applications.” Id.
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`Plaintiff points to the Court’s construction of “client device” for the ’614 Patent as
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`accepting Defendants’ denial that they will claim client devices and servers are interchangeable
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`general use computers. Dkt. No. 242 at 4 (citing Teso Action, Dkt. No. 191 at 15). With respect to
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 9 of 12
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`Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 10 of 12 PageID #: 24356
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`this same “client device” term, the Court’s Claim Construction Order “reiterates and adopts the
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`reasoning and ruling of that order.” Dkt. No. 97 at 13 (citing Teso Action, Dkt. No. 191 at 10–12).
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`The language “a device that is operating in the role of” is language Defendants urged in
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`the construction of “client device” in the Teso Action, language originating in the construction
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`previously adopted by the Court in another case. Teso Action, Dkt. No. 191 at 11 (citing Dkt. No.
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`138 at 5–6; Id. at 6 n.4). The Court’s Claim Construction Order in the Teso Action states that
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`“[Plaintiff’s] second argument—that a client device is specifically not a server—is not supported
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`by the specification.” Id. The Court found “[t]he patents do not include servers as a type of
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`‘communication device,’ but that is not sufficient to construe ‘client device’ as unable to act as a
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`server in all cases.” Id. at 12.
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`Plaintiff’s argument
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`that Defendant seeks
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`to
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`treat client devices and servers
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`interchangeably, citing to the Court’s statement that “[Defendants] deny that they will claim client
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`devices and servers are interchangeable general user computers” is an oversimplification of the
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`issue. It is not that Defendants seek to “reduc[e] the recited server ↔ client device ↔ web server
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`architecture . . . and the recited client device ↔ server ↔ web server architecture . . . as an
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`indistinguishable computer ↔ computer ↔ computer architecture” as Plaintiffs argue. See Dkt.
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`No. 242 at 4. Rather, a component can be configured to operate in different roles—so long as it
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`does not “simultaneously serve as more than one of: the client device, the first server/second
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`server, and the web server.” See Dkt. No. 97 at 13.
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`The Court’s Claim Construction Order in the Code200 Action stated, “[t]he issue in dispute
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`appears to be whether one component can simultaneously serve as more than one of: the client
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`device, the first server/second server, and the web server. It cannot.” Dkt. No. 97 at 13. Consistent
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`with this, the Court construed in the Teso Action “client device” in the ’614 Patent as “device
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 10 of 12
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`operating in the role of a client by requesting services, functionalities, or resources from the
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`server.” Teso Action, Dkt. No. 191 at 15.
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`The Court’s Claim Construction Order in the Teso Action discussed this issue in detail with
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`respect to whether the second server must be a distinct device from the client device and the web
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`server. Teso Action, Dkt. No. 191 at 13–14. The Court stated that “[n]othing in the intrinsic record
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`suggests one device cannot perform both the role of a web server and a second server. To construe
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`the claim in such a way would improperly import a limitation into the claim language.” Id. at 14.
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`Defendants’ Motion for Hearing requests clarifications for the server terms but presents
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`them as new constructions. The Court finds that the clarifications Defendants seek are not
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`inconsistent with the Court’s previous findings about the nature of the client device, web server,
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`first server and second server. Said previous findings have already been stated with respect to the
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`constructions as they stand. Accordingly, the Court clarifies that Defendants’ understanding of the
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`scope of the constructions, as represented by the requested clarifications in Defendants’ Motion
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`for Hearing, is correct. The Court is not changing the construction of “first server” and “second
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`server,” as this understanding is already embedded in those terms’ construction. Further, the Court
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`is not now changing the scope of the terms in any way, but merely providing a clarification of the
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`scope of the terms as they stand.
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`IV. CONCLUSION
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`The Court DENIES Plaintiffs’ request to modify the Claim Construction Order with
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`respect to “source address” and GRANTS Plaintiffs’ request to modify the Claim Construction
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`Order with respect to “sending . . . the first content identifier to the web server using the selected
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`IP address,” which the Court now clarifies means “sending . . . the first content identifier to the
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 11 of 12
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`Case 2:19-cv-00395-JRG Document 453 Filed 08/06/21 Page 12 of 12 PageID #: 24358
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`web server using the selected IP address as either a sending address or a receiving address.” The
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`Court also clarifies the scope of the “first server” and “second server” terms as discussed above.
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`____________________________________
`ROY S. PAYNE
`UNITED STATES MAGISTRATE JUDGE
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`SIGNED this 3rd day of January, 2012.
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`SIGNED this 6th day of August, 2021.
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`Code200, UAB v. Bright Data Ltd.
`Code200's Exhibit 1020
`Page 12 of 12
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