Kaufman v. Monday.com Ltd.

Background

Michael Philip Kaufman sued Monday.com Ltd., alleging direct infringement of three patents: U.S. Patent No. 7,885,981, U.S. Patent No. 10,977,220, and U.S. Patent No. 10,025,801. Kaufman alleged that the patents advanced technology for relational databases by automatically scanning a database and constructing a working user application without requiring additional human input for each table.

According to the amended complaint, Monday.com provides online work-management, sales and customer-relationship-management, and development or product-team services. Kaufman alleged that Monday.com’s services automatically caused files containing data and executable software—called “Monday.com Downloaded Software,” or “MDS”—to download to users’ systems for execution in web browsers. He alleged that the MDS performed functions covered by claims in each of the three patents, including database-table operations, scanning and representing database structures and relationships, replacing foreign-key references with descriptions from related data, and automatically generating interfaces for working with relational-database data.

Motion to Dismiss

Monday.com moved to dismiss under Rule 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. At this stage, the court accepts the complaint’s factual allegations as true, draws reasonable inferences in the plaintiff’s favor, and asks whether the allegations make liability plausible. The plaintiff does not yet have to prove the case.

Monday.com argued that Kaufman’s infringement theory was a technical impossibility and that he had access to evidence that should have supported his allegations. The court rejected those arguments as premature. It concluded that Kaufman’s amended complaint provided enough factual detail—including descriptions and illustrative screenshots—to plausibly allege that the MDS met the relevant patent-claim requirements.

The court also stated that Monday.com’s remaining arguments raised claim-construction questions or factual issues. Claim construction is the process of determining what patent-claim terms mean. The court held that those issues could not properly be resolved on a motion to dismiss, before discovery and claim construction.

Ruling and Case Status

The court denied Monday.com’s motion to dismiss. The ruling did not determine whether Monday.com ultimately infringed the patents; it determined only that Kaufman’s claims were sufficient to proceed beyond the pleading stage. Unless the court ordered otherwise, Monday.com had to answer the claims within two weeks. The court also reinstated and rescheduled the initial pretrial conference for July 17, 2024, and directed the Clerk of Court to terminate ECF No. 36.