Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 1 of 23
`
`AMY H. CANDIDO, State Bar No. 237829
`(acandido@wsgr.com)
`CATHERINE R. LACEY, State Bar No. 291591
`(clacey@wsgr.com)
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`One Market Plaza
`Spear Tower, Suite 3300
`Telephone: (415) 947-2000
`Facsimile:
`(415) 947-2009
`Attorneys for Plaintiff Carrum Health, Inc.
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`CASE NO.:
`
`COMPLAINT FOR
`DECLARATORY JUDGMENT OF
`NON-INFRINGEMENT OF U.S.
`PATENT NOS. 9,123,072; 11,030,665;
`11,244,370; 11,315,160; AND
`11,341,556
`
`DEMAND FOR JURY TRIAL
`
`)))))))))))))
`
`Carrum Health, Inc.,
`
`Plaintiff,
`
`v.
`
`MDsave Shared Services, Inc. and MDsave, Inc.,
`
`Defendants.
`
`COMPLAINT FOR DECLARATORY JUDGMENT
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`Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 2 of 23
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`Plaintiff Carrum Health, Inc. (“Carrum”) hereby seeks a declaratory judgment of non-
`infringement of United States Patent Nos. 9,123,072; 11,030,665; 11,244,370; 11,315,160; and
`11,341,556 as follows:
`
`NATURE OF THE ACTION
`This is an action for a declaratory judgment of non-infringement arising under the
`1.
`patent laws of the United States, Title 35 of the United States Code. Carrum requests this relief
`because Defendants MDsave Shared Services, Inc. and MDsave, Inc. (collectively, “MDsave”)
`claim that Carrum infringes U.S. Patent Nos. 9,123,072 (the “’072 Patent”); 11,030,665 (the
`“’665 Patent”); 11,244,370 (the “’370 Patent”); 11,315,160 (the “’160 Patent”); and 11,341,556
`(the “’556 Patent”) (collectively, the “Asserted Patents”) by “offer[ing] a variety of services.”1
`MDsave’s affirmative allegations of infringement of the Asserted Patents has created a
`justiciable controversy between Carrum and MDsave.
`2.
`As a result of MDsave’s communication to Carrum of its intention to pursue
`claims of infringement of the Asserted Patents against Carrum, Carrum is under reasonable
`apprehension of suit by MDsave.
`
`PARTIES
`Plaintiff Carrum is a Delaware corporation with its principal place of business
`3.
`located at 395 Oyster Point Boulevard, South San Francisco, California 94080.
`4.
`On information and belief, Defendant MDsave Shared Services, Inc. is a
`Delaware corporation with its principal place of business at 100 Winners Circle North, Suite 202,
`Brentwood, Tennessee 37027.
`5.
`On information and belief, Defendant MDsave, Inc. is a Delaware corporation
`with its principal place of business at 100 Winners Circle North, Suite 202, Brentwood,
`Tennessee 37027.
`
`1 See, e.g., Ex. 1 at 60.
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`COMPLAINT FOR DECLARATORY JUDGMENT
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`Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 3 of 23
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`JURISDICTIONAL STATEMENT
`This action arises under the Declaratory Judgment Act, 28 U.S.C. § 2201, and
`6.
`under the patent laws of the United States, 35 U.S.C. §§ 1-390.
`7.
`This Court has subject matter jurisdiction over this action under 28 U.S.C.
`§§ 1331, 1338(a), and 2201(a).
`8.
`This Court has personal jurisdiction over MDsave. According to its public
`statements, MDsave is “co-located in Brentwood, Tenn[essee], and San Francisco, Calif[ornia],”
`which is in this District.2 At least four MDsave employees are based in the San Francisco Bay
`Area, including MDsave’s Chief Technology Officer, Product Management Lead, Principal
`Software Engineer, and a UX Designer.3 On information and belief, MDsave also maintains
`office space in San Francisco, California. MDsave is at home in this District and maintains
`continuous and systematic contacts with this District, and therefore this District has personal
`jurisdiction over MDsave.
`9.
`In addition, this suit arises out of and relates to MDsave’s contacts with the State
`of California and this District. MDsave’s Chief Technology Officer, who is located in San
`Francisco, California, is a named inventor of the asserted ’160 Patent. MDsave has also alleged
`that its web platform practices or implements each of the Asserted Patents.4 This MDsave web
`platform has a dedicated page for California, inviting prospective users to “FIND
`PROCEDURES IN CALIFORNIA,” listing doctors located in California, and inviting California
`residents to “Ask your doctor to join MDsave” with a link to a flyer to provide to one’s doctor.5
`The MDsave web platform further purports to be governed by “Terms & Conditions” directed to
`California residents, providing: “If you are a resident of California, you specifically waive
`
`2 See, e.g., Ex. 2 (https://www.linkedin.com/company/MDsave/) at 1; Ex. 3
`(https://www.MDsave.com/media/MDsave-rated-klas-research) at 2.
`
`3 Ex. 4.
`4 Ex. 1 at 10, 20, 29, 35, and 51.
`5 Ex. 5 (https://www.MDsave.com/california).
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`COMPLAINT FOR DECLARATORY JUDGMENT
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`Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 4 of 23
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`California Civil Code §1542, which states . . . .”6 In addition, on information and belief, aspects
`of MDsave’s web platform, which MDsave contends practices the Asserted Patents, were
`designed and developed in this District by MDsave employees.
`10. Moreover, MDsave has purposely directed into California and this District its
`enforcement activities regarding the Asserted Patents and related patents. On October 22, 2015,
`counsel for MDsave sent a letter to Carrum at its offices in San Mateo in this District to the
`attention of its Chief Executive Officer, who at the time lived and worked in this District and
`continues to live and work in this District.7 The letter specifically referred to one of the Asserted
`Patents and “recommend[ed] that Carrum Health carefully review MDsave’s issued patent and
`their growing portfolio with counsel to assess whether the ‘072 patent or the recently allowed
`‘081 application are relevant to the online healthcare marketplace products and/or services that
`Carrum Health is currently offering or developing.”8
`11.
`On January 3, 2022, Liquidax Capital, LLC (“Liquidax”) issued a press release
`that “it is now representing MDsave in the execution and program management of the company’s
`patent and technology licensing program within the Direct-to-Consumer (DTC) healthcare
`market.”9 The press release referred to MDsave’s “portfolio of intellectual property assets that
`currently include nine (9) patent families and over twenty-five (25) patents and/or patents
`pending,” and asserted that “Companies in the Direct-to-Consumer (DTC) Healthcare space may
`not realize that they need to obtain a patent license from MDsave.”10
`12.
`On January 7, 2022, Liquidax sent a letter to Carrum’s Chief Executive Officer in
`San Mateo, California, in which it described itself as an “intellectual property (‘IP’) management
`
`6 Ex. 6 (https://www.mdsave.com/termsandconditions) at 16.
`7 Ex. 7.
`8 Id. at 1-2.
`9 Ex. 8 (https://www.einnews.com/pr_news/559698434/liquidax-partners-with-mdsave-to-
`execute-patent-licensing-program-for-direct-to-consumer-dtc-healthcare-markets) at 2.
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`10 Id. at 3 & 4.
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`COMPLAINT FOR DECLARATORY JUDGMENT
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`Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 5 of 23
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`firm” that “exclusively represent[s] MDsave, Inc. and its sister organization MDsave Shared
`Services, Inc. (together known as ‘MDsave’) in the administration of its business-to-business
`patent and technology licensing programs.”11 The letter further referred to Carrum “products and
`services relating to an online marketplace in which transactions of medical services and
`payments are facilitated” and alleged that the “Carrum solution is overlapping in specific areas
`with the MDsave intellectual property portfolio.”12 The letter attached a spreadsheet titled
`“MDsave Shared Services Patent Portfolio” that listed each of the Asserted Patents or the patent
`application that led to it.13 The January 7, 2022 letter asked Carrum to “review and discuss the
`aforementioned patents with your technical and legal staff” and “get back to us as soon as
`possible—ideally by January 21st, 2022.”14
`13.
`On January 28, 2022, Carrum’s counsel responded to Liquidax requesting that all
`correspondence regarding the matter be directed to counsel.15
`14.
`On or around February 20, 2022, on behalf of MDsave, Liquidax provided to
`Carrum a presentation asserting the “MDsave patent portfolio covers a variety of technology
`concepts important to operate online healthcare services.”16 The presentation also asserted that
`“Carrum Health is using MDsave’s patented technology.”17 The presentation specifically
`discussed the ’072 Patent, asserted there was an “Implementation by MDsave,” and included
`slides showing side-by-side claim language from the ’072 Patent with “Evidence from Carrum
`
`11 Ex. 9 at 1.
`12 Id. at 2.
`13 Id. at 3-6.
`14 Id. at 2.
`15 Ex. 10.
`16 Ex. 11 at 3.
`17 Id. at 6.
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`COMPLAINT FOR DECLARATORY JUDGMENT
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`Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 6 of 23
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`Health Website.”18 The presentation included similar slides for the ’665 Patent.19 The
`presentation concluded with the allegation that: “Carrum Health offers [a] variety of services
`that are using technologies patented by MDsave. These patents are - US9123072B2, and
`US11030665B2.”20
`15.
`On or around June 7, 2022, on behalf of MDsave, Liquidax provided to Carrum a
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`“Follow up” version of the presentation addressed to Carrum’s Chief Executive Officer and
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`General Counsel.21 This version accused Carrum of infringing all five of the Asserted Patents,
`
`concluding: “Carrum Health offers a variety of services that are using technologies patented by
`
`MDsave. These patents are - US9123072B2, US11315160B2, US20220005098A1,
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`US11244370B2, US11030665B2, and perhaps others,” where US20220005098A1 corresponds
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`to the U.S. patent application that led to the ’556 Patent, which had in fact issued at the time.22
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`The presentation also included slides for each patent, asserting there was an “Implementation by
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`MDsave” and comparing claim language from each patent to “Evidence from Carrum Health
`
`website.”23
`
`16.
`
`In July 2022, on behalf of MDsave, Liquidax provided to Carrum a document
`
`titled “Summary of Key Terms” for “MDsave, Inc. / MDsave Shared Services, Inc. Intellectual
`
`Property Portfolio Patent License & Opportunity.”
`
`17.
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`On August 11, 2022, Carrum’s Chief Operating Officer had a discussion by phone
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`with an MDsave representative at Liquidax regarding, among other things, the Summary of Key
`
`18 Id. at 9-18.
`19 Id. at 20-29.
`20 Id. at 31.
`21 Ex. 12 at 1.
`22 Id. at 52.
`23 Id. at 9-50.
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`COMPLAINT FOR DECLARATORY JUDGMENT
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`Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 7 of 23
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`Terms. Shortly thereafter, Liquidax provided Carrum another presentation again accusing
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`Carrum of “offer[ing] services that are using technologies patented by MDsave,” and identifying
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`those patents as the five Asserted Patents here as well as an additional U.S. Patent Publication
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`No. 17/715,973.24
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`18.
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`On August 17, 2022, Liquidax provided Carrum a document with “Expanded
`
`Summaries & Representative Claims” of the Asserted Patents and additional MDsave patents.
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`This District has personal jurisdiction over MDsave because it has engaged in
`19.
`actionable conduct directed at Carrum, including attempts to license and/or enforce its patents in
`this District, and other conduct directed at this District relating to this action including promoting
`and, on information and belief, designing and developing its own web platform in this District
`which it contends practices the Asserted Patents, and employing one of the named inventors in
`this District.
`Venue is proper in this district under 28 U.S.C. § 1391. A substantial part of the
`20.
`events giving rise to Carrum’s claims occurred in this district, and MDsave is subject to personal
`jurisdiction here, as discussed above. For example, in February and June of this year, MDsave
`provided to Carrum, which is headquartered in this District, presentations expressly accusing
`Carrum of infringing the Asserted Patents and mapping alleged evidence and analysis of the
`operation of Carrum’s products and services to the claims of the Asserted Patents.
`21.
`Due to the circumstances discussed above, an immediate, real, and justiciable
`controversy exists between Carrum and MDsave as to whether Carrum is infringing or has
`infringed the Asserted Patents. In addition, shortly before Liquidax began communicating with
`Carrum about the Asserted Patents on MDsave’s behalf, MDsave had sued three defendants in
`the Western District of Texas for alleged infringement of the ’072 Patent and a related patent.
`See MDsave, Inc. v. Sesame, Inc. et al., Case No. 21-1338 (W.D. Tex.).
`
`24 Ex. 1 at 60.
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`COMPLAINT FOR DECLARATORY JUDGMENT
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`Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 8 of 23
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`INTRADISTRICT ASSIGNMENT
`For purposes of intradistrict assignment under Civil Local Rules 3-2(c) and 3-
`22.
`5(b), this Intellectual Property Action will be assigned on a district-wide basis.
`FIRST CAUSE OF ACTION
`NON-INFRINGEMENT OF U.S. PATENT NO. 9,123,072
`Carrum repeats and realleges each and every allegation set forth in the above
`23.
`paragraphs and incorporates them by reference herein.
`24. MDsave claims to own all rights, title, and interest in and under the ’072 Patent.
`A true and correct copy of the ’072 Patent is attached hereto as Exhibit 13.
`25.
`Carrum does not directly or indirectly infringe the ’072 Patent, either literally or
`under the doctrine of equivalents, at least because neither Carrum’s products nor services
`comprise or utilize any apparatus or system claimed in the independent claims of the ’072 Patent,
`nor perform any method claimed in the independent claims of the ’072 Patent.
`26.
`As to claim 1, neither Carrum’s products nor services comprise or utilize an
`“apparatus for facilitating purchases of healthcare services offered by healthcare service
`providers, the apparatus comprising: an application server providing a network service that is
`accessible to a plurality of users through a plurality of client systems communicatively coupled
`to the application server via a network; and a data storage system storing a service offer database
`that is maintained by the application server, the service offer database comprising a plurality of
`service offer information records respectively associated with a plurality of service offers, the
`plurality of service offers including at least one service offer for a bundled set of healthcare
`services, each service offer information record comprising an indication of a primary healthcare
`service of the associated service offer, a purchase price for the associated service offer, an
`indication of a corresponding healthcare service provider for the primary healthcare service, a
`payment amount for the primary healthcare service, and compensation information for the
`primary healthcare service, and wherein, upon being accessed by a user of one of the client
`systems, the network service is operable to receive an indication from the client system of a
`selected service offer being selected from the plurality of service offers for purchase by the user,
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`COMPLAINT FOR DECLARATORY JUDGMENT
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`wherein, upon receiving purchase information for the user specifying a funding source to use for
`purchasing the selected service offer from the client system, the network service is operable to
`issue a request to the funding source for funds corresponding to the purchase price included in
`the service offer information record associated with the selected service offer to process a
`purchase of the selected service offer by the user, and wherein the network service is operable to,
`upon processing the purchase of the selected service offer by the user: generate a respective
`purchase information record for the purchase that comprises a unique confirmation number for
`the purchase, an indication of the corresponding healthcare service provider for the primary
`healthcare service for the purchased service offer, an indication of a corresponding healthcare
`service provider for each of any secondary healthcare service of the purchased service offer, and
`an indication of whether, for each of the primary healthcare service and any secondary healthcare
`service of the purchased service offer, the purchase has been redeemed with respect to the
`healthcare service that is initially set to indicate that the purchase has not been redeemed with
`respect to the healthcare service, store the respective purchase information record for the
`purchase within a transaction information database that is maintained within the data storage
`system by the application server, and transmit a set of voucher information to the client system
`generated based on the respective purchase information record for the processed purchase for
`rendering a voucher for the user within a user interface implemented at the client system that
`specifies the unique confirmation number for the purchase, the corresponding healthcare service
`provider for the primary healthcare service for the purchased service offer, and the corresponding
`healthcare service provider for each of any secondary healthcare service of the purchased service
`offer.”
`
`For example, neither Carrum’s products nor services comprise or utilize “an
`27.
`application server providing a network service . . . wherein, upon receiving purchase information
`for the user specifying a funding source to use for purchasing the selected service offer from the
`client system, the network service is operable to issue a request to the funding source for funds
`corresponding to the purchase price included in the service offer information record associated
`with the selected service offer to process a purchase of the selected service offer by the user”, nor
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`COMPLAINT FOR DECLARATORY JUDGMENT
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`“wherein the network service is operable to . . . transmit a set of voucher information to the client
`system generated based on the respective purchase information record for the processed purchase
`for rendering a voucher for the user within a user interface implemented at the client system that
`specifies the unique confirmation number for the purchase, the corresponding healthcare service
`provider for the primary healthcare service for the purchased service offer”. nor “based on the
`respective purchase information record for the processed purchase for rendering a voucher for
`the user within a user interface implemented at the client system that specifies the unique
`confirmation number for the purchase, the corresponding healthcare service provider for the
`primary healthcare service for the purchased service offer.”
`28.
`As to claim 13, neither Carrum’s products nor services perform a “method for
`facilitating purchases of healthcare services offered by healthcare service providers, the method
`comprising: providing, at an application server, a network service that is accessible to a plurality
`of users through a plurality of client systems communicatively coupled to the application server
`via a network; maintaining, in a data storage system, a service offer database comprising a
`plurality of service offer information records respectively associated with a plurality of service
`offers, where the plurality of service offers include at least one service offer for a bundled set of
`healthcare services, and each service offer information record comprises an indication of a
`primary healthcare service of the associated service offer, a purchase price for the associated
`service offer, an indication of a corresponding healthcare service provider for the primary
`healthcare service, a payment amount for the primary healthcare service, and compensation
`information for the primary healthcare service; receiving, from one of the client systems being
`operated by a user to access the network service, an indication of a selected service offer being
`selected from the plurality of service offers for purchase by the user and purchase information
`for the user specifying a funding source purchasing the selected service offer; issuing a request to
`the funding source for funds corresponding to the purchase price included in the service offer
`information record associated with the selected service offer to process a purchase of the selected
`service offer by the user; generating a respective purchase information record for the purchase
`that comprises a unique confirmation number for the purchase, an indication of the
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`COMPLAINT FOR DECLARATORY JUDGMENT
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`corresponding healthcare service provider for the primary healthcare service for the purchased
`service offer, an indication of a corresponding healthcare service provider for each of any
`secondary healthcare service of the purchased service offer, and an indication of whether, for
`each of the primary healthcare service and any secondary healthcare service of the purchased
`service offer, the purchase has been redeemed with respect to the healthcare service that is
`initially set to indicate that the purchase has not been redeemed with respect to the healthcare
`service; storing the respective purchase information record for the purchase within a transaction
`information database that is maintained within the data storage system; and transmitting a set of
`voucher information to the client system generated based on the respective purchase information
`record for the processed purchase for rendering a voucher for the user within a user interface
`implemented at the client system that specifies the unique confirmation number for the purchase,
`the corresponding healthcare service provider for the primary healthcare service for the
`purchased service offer, and the corresponding healthcare service provider for each of any
`secondary healthcare service of the purchased service offer.”
`29.
`For example, neither Carrum nor its product perform a “method . . . comprising . .
`. receiving, from one of the client systems being operated by a user to access the network service,
`an indication of a selected service offer being selected from the plurality of service offers for
`purchase by the user and purchase information for the user specifying a funding source
`purchasing the selected service offer”, nor do they “issue[] a request to the funding source for
`funds corresponding to the purchase price included in the service offer information record
`associated with the selected service offer to process a purchase of the selected service offer by
`the user”, nor do they “transmit[] a set of voucher information to the client system generated
`based on the respective purchase information record for the processed purchase for rendering a
`voucher for the user within a user interface implemented at the client system that specifies the
`unique confirmation number for the purchase, the corresponding healthcare service provider for
`the primary healthcare service for the purchased service offer.”
`30.
`As to claim 25, neither Carrum’s products nor services comprise or utilize a
`“system for facilitating purchases of healthcare services offered by healthcare service providers,
`
`COMPLAINT FOR DECLARATORY JUDGMENT
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`the system comprising: an application server providing a network service; a plurality of client
`systems configured to communicatively couple to the application server via a network to access
`the network service; and a data storage system storing a service offer database that is maintained
`by the application server, the service offer database comprising a plurality of service offer
`information records respectively associated with a plurality of service offers, the plurality of
`service offers including at least one service offer for a bundled set of healthcare services, each
`service offer information record comprising an indication of a primary healthcare service of the
`associated service offer, a purchase price for the associated service offer, an indication of a
`corresponding healthcare service provider for the primary healthcare service, a payment amount
`for the primary healthcare service, and compensation information for the primary healthcare
`service, and wherein, upon being accessed by a user through operation of one of the client
`systems, the network service is operable to receive an indication from the client system of a
`selected service offer being selected from the plurality of service offers for purchase by the user,
`wherein, upon receiving purchase information for the user specifying a funding source for
`purchasing the selected service offer from the client system, the network service is operable to
`issue a request to the funding source for funds corresponding to the purchase price included in
`the service offer information record associated with the selected service offer to process a
`purchase of the selected service offer by the user, and wherein the network service is operable to,
`upon processing the purchase of the selected service offer by the user: generate a respective
`purchase information record for the purchase that comprises a unique confirmation number for
`the purchase, an indication of the corresponding healthcare service provider for the primary
`healthcare service for the purchased service offer, an indication of a corresponding healthcare
`service provider for each of any secondary healthcare service of the purchased service offer, and
`an indication of whether, for each of the primary healthcare service and any secondary healthcare
`service of the purchased service offer, the purchase has been redeemed with respect to the
`healthcare service that is initially set to indicate that the purchase has not been redeemed with
`respect to the healthcare service, store the respective purchase information record for the
`purchase within a transaction information database that is maintained within the data storage
`
`COMPLAINT FOR DECLARATORY JUDGMENT
`
`-12-
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`

`

`Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 13 of 23
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`system by the application server, and transmit a set of voucher information to the client system
`generated based on the respective purchase information record for the processed purchase for
`rendering a voucher for the user within a user interface implemented at the client system that
`specifies the unique confirmation number for the purchase, the corresponding healthcare service
`provider for the primary healthcare service for the purchased service offer, and the corresponding
`healthcare service provider for each of any secondary healthcare service of the purchased service
`offer.”
`
`For example, neither Carrum’s products nor services comprise or utilize a “a
`31.
`network service . . . wherein, upon receiving purchase information for the user specifying a
`funding source for purchasing the selected service offer from the client system, the network
`service is operable to issue a request to the funding source for funds corresponding to the
`purchase price included in the service offer information record associated with the selected
`service offer to process a purchase of the selected service offer by the user,” nor “wherein the
`network service is operable to. . . transmit a set of voucher information to the client system
`generated based on the respective purchase information record for the processed purchase for
`rendering a voucher for the user within a user interface implemented at the client system that
`specifies the unique confirmation number for the purchase, the corresponding healthcare service
`provider for the primary healthcare service for the purchased service offer, and the corresponding
`healthcare service provider for each of any secondary healthcare service of the purchased service
`offer.”
`
`A substantial, immediate, and real controversy therefore exists between Carrum
`32.
`and MDsave regarding whether Carrum infringes the ’072 Patent. A judicial declaration is
`appropriate and necessary to determine the parties’ respective rights regarding the ’072 Patent.
`33.
`Carrum seeks a judgment declaring that Carrum does not directly or indirectly
`infringe any claim of the ’072 Patent.
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`COMPLAINT FOR DECLARATORY JUDGMENT
`
`-13-
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`

`Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 14 of 23
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`SECOND CAUSE OF ACTION
`NON-INFRINGEMENT OF U.S. PATENT NO. 11,030,665
`Carrum repeats and realleges each and every allegation set forth in the above
`34.
`paragraphs and incorporates them by reference herein.
`35. MDsave claims to own all rights, title, and interest in and under the ’665 Patent.
`A true and correct copy of the ’665 Patent is attached hereto as Exhibit 14.
`36.
`Carrum does not directly or indirectly infringe the ’665 Patent, either literally or
`under the doctrine of equivalents, at least because neither Carrum’s products nor services
`comprise or utilize any apparatus claimed in the sole independent claim of the ’665 Patent.
`37.
`As to claim 1 neither Carrum’s products nor services comprise or utilize an
`“apparatus comprising: a processor; and a memory operably coupled with the processor, wherein
`the memory comprises processor executable program instructions configured that when executed
`by the processor cause the apparatus to implement a database server communicatively coupled to
`an application server configured with a machine learning algorithm, and a data store; the
`application server comprising: a customer portal; a provider portal; and a virtual payment system
`manager linked to the customer portal and the provider portal; the application server providing a
`network service to a plurality of users through a plurality of client systems via a communication
`network, the network service being accessible via a graphical user interface provided by a client
`application implemented on each of the client systems; the data store maintained by the
`application server comprising: a service offer database storing a bundled set of healthcare service
`offers linked to at least one of: a customer profile database configured to register users thereby
`providing user's personal information for purchasing healthcare services; a physician profile
`database configured to register and maintain records of individual physician offering healthcare
`services; a condition information database configured to register and maintain information
`records for various health conditions and diseases for which corresponding healthcare services
`are offered; a hospital system profile database configured to register and maintain account
`information records for hospital system administrators providing pre-paid healthcare services; an
`available service database configured to register and maintain records of various healthcare
`
`COMPLAINT FOR DECLARATORY JUDGMENT
`
`-14-
`
`

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`Case 3:22-cv-04896 Document 1 Filed 08/26/22 Page 15 of 23
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`services offered by at least one of: a physician; and a hospital; and a tra