DigitalDoors Inc v. BNC National Bank

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigitalDoors, Inc. (Florida)
  • Defendant: BNC National Bank (Arizona)
  • Plaintiff’s Counsel: Bycer & Marion
• Case Identification: 2:25-cv-03999, D. Ariz., 10/24/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Arizona because Defendant maintains a regular and established place of business in the district, including physical branch locations, employees, and the generation of substantial revenue.
• Core Dispute: Plaintiff alleges that Defendant’s data backup and disaster recovery systems infringe four patents related to methods for filtering, segmenting, and securely storing sensitive data in a distributed computing environment.
• Technical Context: The dispute is situated in the financial services industry's data security sector, where robust disaster recovery systems, such as those compliant with the Sheltered Harbor standard, are critical for maintaining operational continuity and regulatory compliance.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with actual notice of the patents-in-suit via a letter dated June 20, 2025, which Defendant allegedly acknowledged but upon which it refused to act, a fact which may become relevant to claims of willful infringement.

Case Timeline

Date	Event
2007-01-05	Earliest Priority Date for all Patents-in-Suit
2015-01-01	Sheltered Harbor industry initiative launched
2015-04-21	U.S. Patent No. 9,015,301 Issued
2017-08-15	U.S. Patent No. 9,734,169 Issued
2019-01-15	U.S. Patent No. 10,182,073 Issued
2019-04-02	U.S. Patent No. 10,250,639 Issued
2025-06-20	Plaintiff sends notice letter to Defendant
2025-10-24	Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,015,301 - "Information Infrastructure Management Tools with Extractor, Secure Storage, Content Analysis and Classification and Method Therefor"

The Invention Explained

• Problem Addressed: The patent describes a technical environment where enterprises struggled with managing large volumes of both structured and unstructured data, classifying sensitive information inefficiently, and securing open-access information ecosystems from threats (’301 Patent, col. 1:31-2:27). Conventional approaches focused on managing data at the file level, which was inadequate for granular security and lifecycle management (Compl. ¶40).
• The Patented Solution: The invention proposes a method for organizing and processing data at the content level rather than the file level. It employs a system of "categorical filters" (e.g., content-based, contextual, taxonomic) to automatically identify and extract important "select content" from a data stream. This extracted content is then stored in designated, secure data stores and associated with specific data processes, such as copying, archiving, or destruction, according to enterprise policies (’301 Patent, Abstract; col. 3:17-4:35).
• Technical Importance: This content-centric approach enabled more granular control over sensitive information, allowing for enhanced security and more efficient data management in distributed systems, particularly for disaster recovery and compliance purposes (Compl. ¶¶12-13).

Key Claims at a Glance

• The complaint asserts independent claim 25.
• The essential elements of Claim 25 include:
  • A method of organizing and processing data in a distributed computing system having select content important to an enterprise.
  • Providing a plurality of select content data stores operative with a plurality of designated categorical filters.
  • Activating at least one filter and processing a data input to obtain select content and associated select content.
  • Storing the aggregated select content in a corresponding data store.
  • Associating at least one data process (from a group including copy, extract, archive, distribution, and destruction) with the activated filter.
  • Applying the associated data process to a further data input based on the result of the further data being processed by the activated filter.
  • Wherein the activation is automatic (time-based, condition-based, or event-based) or manual.

U.S. Patent No. 9,734,169 - "Digital Information Infrastructure and Method for Securing Designated Data with and with Granular Data Stores"

The Invention Explained

• Problem Addressed: The patent addresses the security risks of storing data, particularly sensitive data, in centralized or easily accessible locations that are vulnerable to cyberattacks or other system failures ('169 Patent, col. 2:4-15).
• The Patented Solution: The invention describes a distributed, cloud-based computing system that separates data into two categories: "security designated data" (sensitive content) and "remainder data." The sensitive data is extracted and stored in secure, access-controlled "select content data stores," while the non-sensitive remainder data is parsed and stored separately in "granular data stores." A cloud-based server, coupled to the stores via a communications network, manages access controls and facilitates the secure withdrawal and reconstruction of the data ('169 Patent, Abstract).
• Technical Importance: By physically and logically separating sensitive data from non-sensitive data and distributing it across different storage systems with distinct access controls, the invention creates a multi-layered defense that increases the difficulty for an unauthorized party to access the complete, coherent information (Compl. ¶¶65-66).

Key Claims at a Glance

• The complaint asserts independent claim 1.
• The essential elements of Claim 1 include:
  • A method of organizing and processing data in a distributed cloud-based computing system.
  • Providing a plurality of select content data stores, a plurality of granular data stores, and a cloud-based server with access controls at each select content data store.
  • Providing a communications network coupling the stores and server.
  • Extracting and storing security designated data in the select content data stores.
  • Activating a select content data store to permit access based on applying access controls.
  • Parsing remainder data not extracted from the data and storing it in the granular data stores.
  • Withdrawing the security designated data and parsed data only in the presence of the respective access controls.

U.S. Patent No. 10,182,073 - "Information Infrastructure Management Tools with Variable Configurable Filters and Segmental Data Stores"

• Technology Synopsis: The ’073 Patent describes an information infrastructure that processes data using a plurality of "initially configured filters" to identify and separate sensitive and select content. The core innovation is the ability to dynamically "alter" these filters—by expanding, contracting, or reclassifying them—and then generate "modified configured filters" to organize subsequent data throughput, allowing the security system to adapt over time. (’073 Patent, Abstract; col. 3:1-26).
• Asserted Claims: Claim 1.
• Accused Features: The complaint alleges infringement by the Defendant's data security systems that use and modify "protection policies" (the alleged filters) to identify and store critical customer account data, thereby altering how data is processed and stored (Compl. ¶¶194, 214-215).

U.S. Patent No. 10,250,639 - "Information Management Data Processing Tools for Regulated Data Flow with Distribution Controls"

• Technology Synopsis: The ’639 Patent discloses a method for "sanitizing" data in a distributed system. The process involves extracting sensitive content from a data input based on its sensitivity level and an associated security clearance. The extracted sensitive content and the "remainder data" are stored in separate, networked data stores. This separation creates a sanitized version of the data, and the invention further claims inferencing this sanitized data using various filters. (’639 Patent, Abstract).
• Asserted Claims: Claim 16.
• Accused Features: The complaint targets the Defendant's data vaulting systems that extract sensitive customer data for secure, isolated storage, which allegedly creates "sanitized" versions of data that remain in the production environment while the sensitive portions are vaulted (Compl. ¶¶225-226, 250).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Accused Instrumentalities" as the systems and methods used by BNC National Bank for data processing, backup, and disaster recovery (Compl. ¶111). These systems are alleged to be compliant with the financial industry's "Sheltered Harbor" specification or an "operational equivalent" thereof (Compl. ¶¶111, 114).

Functionality and Market Context

• The complaint alleges that the accused systems function by providing secure data vaulting for critical customer financial information. This process is described as extracting critical data from a production environment and replicating it to a secure, isolated "data vault" that is immutable and "air-gapped" (physically or logically disconnected) from the main corporate network (Compl. ¶¶84, 88, 91). This vaulting is typically performed automatically on a nightly basis (Compl. ¶106). The diagram from a Dell Technologies solution brief, provided in the complaint, illustrates this architecture, showing data moving from a "Production Environment" across an "Air-gap" to a "Data Vault Environment" for secure processing and storage (Compl. p. 31, ¶87). The complaint positions these systems as a critical and standard practice in the banking industry, compelled by regulatory pressure and the need to maintain customer confidence and data resiliency in the face of cyberattacks (Compl. ¶¶6-13, 76).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,015,301 Infringement Allegations

Claim Element (from Independent Claim 25)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
...providing, in said distributed computing system, a plurality of select content data stores operative with a plurality of designated categorical filters...	The accused systems allegedly provide a data vault containing multiple data stores (e.g., for backup, copy, lock, analyze) that operate with "protection policies" which function as the claimed categorical filters.	¶129, ¶131	col. 3:54-61
...activating at least one of said designated categorical filters and processing a data input therethrough to obtain said select content and associated select content...	The accused systems allegedly implement protection policies, using aggregated tags and metadata, to process incoming data and extract critical financial account information (the select content).	¶133-¶134	col. 4:1-5
...storing said aggregated select content for said at least one categorical filter in said corresponding select content data store...	The extracted critical data is allegedly stored in corresponding designated storage units (or "storage trees") within the secure data vault.	¶137-¶138	col. 4:5-9
...associating at least one data process from the group of data processes including a copy process, a data extract process, a data archive process, a data distribution process and a data destruction process...	The data storage vault allegedly associates specific actions (copying, archiving, distributing data) with specific data types in accordance with enterprise policies.	¶140-¶141	col. 4:9-14
...applying the associated data process to a further data input based upon a result of said further data being processed by said activated categorical filter...	Once a protection policy is established, all subsequent data inputs are allegedly processed automatically under the same policy rules.	¶143-¶144	col. 4:15-19
...said automatic activation is time-based, distributed computer system condition-based, or event-based.	Activation is allegedly time-based (e.g., nightly backups), condition-based (e.g., upon detection of new assets), or event-based as part of the standard Sheltered Harbor protocol.	¶146-¶147	col. 14:45-51

• Identified Points of Contention:
  • Scope Questions: A primary question may be whether the "protection policies" and tagging rules used in modern data backup systems, as described in the complaint, meet the specific definition of "designated categorical filters" as contemplated by the patent. The defense may argue that such policies are general rules, not the specific filtering technologies described in the patent's specification.
  • Technical Questions: The analysis may turn on what evidence shows that the accused system "associates" one of the five specific claimed "data processes" and then "applies" that same process to "further data input" based on the filter's output, as the claim requires a causal link between the filtering result and the subsequent data processing step.

U.S. Patent No. 9,734,169 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
...providing in said distributed cloud-based computing system: (i) a plurality of select content data stores...; and (ii) a plurality of granular data stores; and (iii) a cloud-based server...	The accused system allegedly comprises a secure data vault (the select content stores), production/backup systems (the granular data stores), and a management server, which may be implemented on a cloud platform.	¶160, ¶164-¶167	col. 3:35-43
...providing a communications network operatively coupling said plurality of select content data stores and cloud-based server...	The complaint alleges the existence of a network that includes a "logical, air-gapped, dedicated connection" coupling the production environment with the data vault environment.	¶169-¶170	col. 3:41-43
...extracting and storing said security designated data in respective select content data stores...	The system allegedly extracts critical customer account data using protection policies and stores it in the secure data vault.	¶171-¶172	col. 4:1-5
...activating at least one of said select content data stores... thereby permitting access to said select content data stores and respective security designated data based upon an application of one or more of said access controls...	Access to the data vault is allegedly safeguarded by strict, credential-controlled measures, including multi-factor authentication.	¶177-¶178	col. 4:6-10
...parsing remainder data not extracted from data processed by said cloud-based system and storing the parsed data in respective granular data stores.	Non-extracted data ("remainder data") is allegedly stored in the production and backup systems, which are outside the data vault. A diagram shows this separation of production workloads from the vault. (Compl. p. 74).	¶180-¶181	col. 4:11-13
...withdrawing some or all of said security designated data and said parsed data from said respective data stores only in the presence of said respective access controls applied thereto.	Data can allegedly be withdrawn from the vault for restoration only after satisfying strict security protocols and access controls.	¶186-¶187	col. 4:14-18

• Identified Points of Contention:
  • Scope Questions: The dispute may focus on whether the accused system's standard production environment and backup systems can be properly characterized as "granular data stores" for "remainder data" as that term is used in the patent, and whether routine backup constitutes "parsing" and "storing the parsed data."
  • Technical Questions: The infringement analysis raises the question of whether the accused system performs an active "parsing" step on the remainder data, or if it simply stores whatever data is not extracted. The definition of "parsing" will likely be a key point of contention.

V. Key Claim Terms for Construction

• The Term: "designated categorical filters" (’301 Patent, Claim 25)

• Context and Importance: This term is foundational to the infringement theory for the ’301 Patent. Plaintiff's case appears to rely on construing this term to encompass the "protection policies," tagging, and metadata-based rules common in modern data management and disaster recovery systems (Compl. ¶¶131, 134). The viability of the infringement claim may depend on whether these modern constructs fall within the patent's definition of a "categorical filter."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests filters can be based on a wide range of enterprise policies, including "service policy, customer privacy policy, supplier privacy policy, enterprise human resource privacy policy," among others (’301 Patent, col. 4:20-27). This language could support an interpretation that covers the broad "protection policies" alleged to be used by the Defendant.
  • Evidence for a Narrower Interpretation: The specification provides specific examples of filters, such as "content-based filters, contextual filters, and taxonomic classification filters" (’301 Patent, col. 3:62-65), and dedicates significant discussion to "knowledge expander" search engines and hierarchical taxonomies (col. 10:22-32). This may support an argument that the term requires a specific type of analytical or classification technology, not just general rule-based data handling.

• The Term: "parsing remainder data" (’169 Patent, Claim 1)

• Context and Importance: This step is critical for infringement of the ’169 Patent, as it defines the action taken on the data not selected for secure vaulting. The complaint alleges that storing this non-extracted data in production and backup systems satisfies this element (Compl. ¶¶180-¶181). Practitioners may focus on whether "parsing" implies more than just storing what is left over.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not provide an explicit, limiting definition of "parsing." A party could argue for its plain and ordinary meaning, which might broadly cover any form of processing or handling data for storage.
  • Evidence for a Narrower Interpretation: The claim language recites "parsing remainder data... and storing the parsed data," which could imply that parsing is a distinct action that transforms or structures the data before it is stored. The patent focuses on the secure dispersal of data; a defendant might argue that "parsing" implies a complementary dispersal or segmentation of the remainder data for security, an operation more complex than a standard backup. The specification mentions dispersing granular pieces of data to different locations to increase security ('169 Patent, col. 17:25-30), which could inform the meaning of "parsing."

VI. Other Allegations

• Indirect Infringement: The complaint does not contain explicit counts for indirect or induced infringement. The allegations focus on Defendant's direct infringement through its own making, using, and controlling of the accused systems (Compl. ¶¶121, 154, 194, 225).
• Willful Infringement: The complaint alleges that Defendant's infringement became willful and deliberate after it received notice of the asserted patents. This allegation is based on a notice letter Plaintiff allegedly sent on June 20, 2025, which identified the patents and infringing instrumentalities. The complaint further alleges that Defendant acknowledged the letter but refused to take a license or cease its infringing activities, thereby acting despite an objectively high likelihood that its actions constituted infringement (Compl. ¶¶115-118, 150, 190, 221, 259).

VII. Analyst’s Conclusion: Key Questions for the Case

• A central issue will be one of definitional scope: can the patents’ terminology, rooted in concepts like "categorical filters" and "parsing," be construed to cover the more generalized "protection policies" and standard backup procedures used in modern, industry-standard data vaulting systems like those alleged to be used by the Defendant? The outcome may depend on whether these modern practices are merely new names for the patented methods or are technically distinct.
• A key evidentiary question will be one of technical implementation: the complaint extensively details the requirements of the Sheltered Harbor standard, but it provides limited specifics on the Defendant's actual systems. The case will likely require discovery to determine if Defendant's infrastructure performs each specific, ordered step of the asserted method claims, or if there is a fundamental mismatch between the industry standard's high-level goals and the patents' granular technical requirements.
• A third question will relate to non-obviousness and the state of the art: the complaint argues that the long development timeline and industry-wide effort behind the Sheltered Harbor standard (launched in 2015) is evidence that the patented inventions (with a 2007 priority date) were unconventional and non-obvious. The court may need to examine whether these industry developments were an independent creation or an implementation of the technologies taught by the patents-in-suit.