Hantz Software, LLC v. Sage Intacct, Inc.

CourtDistrict Court, N.D. California
DecidedDecember 20, 2021
Docket4:21-cv-01987
StatusUnknown

This text of Hantz Software, LLC v. Sage Intacct, Inc. (Hantz Software, LLC v. Sage Intacct, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hantz Software, LLC v. Sage Intacct, Inc., (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 HANTZ SOFTWARE, LLC, Case No. 21-cv-01987-HSG

8 Plaintiff, ORDER GRANTING MOTION TO DISMISS AND DENYING AS FUTILE 9 v. MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT 10 SAGE INTACCT, INC., Re: Dkt. Nos. 47, 56 11 Defendant.

12 13 Before the Court is Defendant Sage Intacct, Inc.’s motion to dismiss Plaintiff Hantz 14 Software, LLC’s complaint, for which briefing is complete. See Dkt. Nos. 47 (“Mot.”), 50 15 (“Opp.”), 51 (“Reply”). The Court heard oral argument on the motion on October 14, 2021. See 16 Dkt. No. 55. For the reasons explained below, the Court GRANTS Defendant’s motion to 17 dismiss. 18 I. BACKGROUND 19 On March 22, 2021, Plaintiff Hantz Software, LLC brought this patent infringement action 20 against Defendant Sage Intacct, Inc. See Dkt. No. 1. The operative complaint asserts 21 infringement of United States Patent Nos. 8,055,559 (“the ’599 Patent”) and 8,055,560 (“the ’560 22 Patent”) (collectively, “the Asserted Patents”). Dkt. No. 41 (“Compl.”) ¶ 1. The Asserted Patents 23 relate to computer-implemented accounting methods or systems for accounts receivable and 24 accounts payable within a multi-company system. See id. 25 The operative complaint recites allegations that “[p]rior to the inventions claimed in the 26 [Asserted Patents], conventional approaches to financial accounting methods and solutions for 27 multi-company enterprises were far too time consuming and inefficient, especially where accurate 1 inefficiencies and delays” in performing these “conventional” approaches created a “long felt need 2 in the marketplace” for patented, computer-implemented methods that “enhance[d] and 3 streamline[d]” the approaches. Id. ¶¶ 18-20. To solve this problem, beginning in 2006, Roy 4 Gelerman reviewed the existing landscape of multi-company accounting platforms, including 5 those offered by Defendant. Id. ¶¶ 22, 23, 25, 26. During a February 2008 demonstration of 6 Defendant’s multi-company accounting product, Mr. Gelerman identified the products’ 7 shortcomings in accuracy, speed, and completeness. Id. ¶ 27. At this demonstration, Defendant 8 personnel confirmed to Mr. Gelerman “that the [Defendant’s] accounting products did not include 9 features and functions capable of creating an [accounts receivable invoice or accounts payable 10 bill] with detail lines from multiple companies.” Id. ¶ 28. Defendant personnel believed “that 11 would be too hard.” Id. After his competitive research, Mr. Gelerman confirmed that:

12 none of the commercially available accounting products included the functions and features that allow a payment for a multi-company AP 13 bill, or AR invoice, to be recorded in the accounting system to reduce the outstanding AP or AR balances of each company and the system 14 automatically adds a pair of multi-company generated “Due To/Due From” lines as “Due To/Due From” entries to balance the money 15 owed between the distinct companies” [sic] and to keep each companies’ balance sheet in balance. 16 17 Id. ¶ 30. Plaintiff and Mr. Gelerman then sought patent protection for a solution incorporating Mr. 18 Gelerman’s findings and drafted the patent applications that would issue as the ’559 and ’560 19 Patents. Id. ¶ 32. 20 The ’559 Patent and the ’560 Patent are related and claim priority to the same parent 21 application. The two patents share near identical titles. Compare ’559 Patent (“Multi-Company 22 Business Accounting System And Method For Same Including Account Receivable” (emphasis 23 added)) with ’560 Patent (“Multi-Company Business Accounting System And Method For Same 24 Including Account Payable” (emphasis added)). While the ’559 Patent refers to “invoices” for 25 accounts receivable and the ’560 Patent refers to “vouchers” for accounts payable, both patents 26 share substantially the same written description. The patents’ specifications identify problems in 27 multi-company business accounting systems that record and organize company financial activity. 1 To/Due From’ entries to keep each company in balance.” See, e.g., ’559 Patent, 2:14-16. “This is 2 a huge burden, as nearly 30% of the accounting entries are inter-company balancing entries.” Id. 3 at 2:16-18. To remedy this gap, the Asserted Patents use “balancing lines” to “automatically add” 4 “input invoice detail lines” and “define an outstanding balance associated with each of the distinct 5 companies.” Id. at 2:46-50. This claimed invention allows the user to “accurately report the 6 Accounts Receivable for each of the distinct companies,” “provid[ing] results that were not 7 possible in conventional methods and systems.” Opp. at 9. 8 The ’559 Patent and the ’560 Patent each have four independent claims: claims 1, 31, 32, 9 and 33. Claim 1 of the ’559 Patent recites:

10 1. A computer implemented method for Account Receivable (AR) accounting for use within a multi-company accounting system that 11 operates on a computer arrangement and which is accessible by one or more persons defining an interface user, the method comprising: 12 at a processor, creating a multi-company invoice with the multi- company accounting system, the interface user entering financial data 13 into the multi-company accounting system via the computer arrangement including: 14 entering an invoice total money amount; and entering input invoice detail lines, each of the input invoice detail 15 lines having an entered account associated with one of a plurality of companies of a multi-company group and an amount of money, at 16 least two of the input invoice detail lines being associated with two distinct companies of the multi-company group, wherein the distinct 17 companies are affiliated with each other and wherein each uses the multi-company accounting system for tracking money flow and 18 balancing balance sheets for their respective accounting operations; at the processor, automatically adding via the multi-company 19 accounting system at least a pair of multi-company generated balancing lines associated with the multi-company invoice for 20 balancing money owed to each of the distinct companies to define an outstanding balance associated with each of the distinct companies, 21 thereby keeping Accounts Receivable for each of the distinct companies in balance; 22 at the processor, entering a payment for paying the multi-company invoice including the interface user entering an amount of the 23 payment into the multi-company accounting system via the computer arrangement; and 24 at the processor, applying the payment to the multi-company invoice to reduce the outstanding balances for the distinct companies 25 including the multi-company accounting system automatically adding at least a pair of multi-company generated Due To/Due From lines as 26 Due To/Due From entries to balance the money owed between the distinct companies, thereby keeping the Accounts Receivable for each 27 of the distinct companies in balance. 1 Claim 31 of the ’559 Patent recites:

2 31.

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Hantz Software, LLC v. Sage Intacct, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/hantz-software-llc-v-sage-intacct-inc-cand-2021.