DCT
8:25-cv-02728
Asafi v. Western Digital Tech Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Jamil Asafi as Trustee for 301 Patent Trust (Texas)
- Defendant: Western Digital Technologies, Inc. (Delaware)
- Plaintiff’s Counsel: DNL Zito
- Case Identification: 8:25-cv-2728, C.D. Cal., 12/09/2025
- Venue Allegations: Venue is alleged to be proper as Defendant is headquartered and has a regular and established place of business within the Central District of California.
- Core Dispute: Plaintiff alleges that Defendant’s enterprise hard disk drives featuring dual-actuator technology infringe a patent related to simultaneously reading and writing data across multiple platter surfaces within a single drive.
- Technical Context: The technology addresses a long-standing performance bottleneck in data storage, where the mechanical speed of hard drives has lagged behind processor and memory speeds, by enabling parallel data operations within a single drive.
- Key Procedural History: The complaint alleges that Defendant became aware of the patent-in-suit at least as early as February 12, 2019, when it was sued in a prior case, Tormasi v. Western Digital, in the Northern District of California. This allegation forms the basis for the claim of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2004-05-03 | ’301 Patent Priority Date |
| 2005-01-10 | ’301 Patent Application Filing Date |
| 2008-01-29 | ’301 Patent Issue Date |
| 2019-02-12 | Prior lawsuit filed against Defendant, allegedly establishing knowledge of the ’301 Patent |
| 2025-12-09 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,324,301 - "Striping Data Simultaneously Across Multiple Platter Surfaces", issued January 29, 2008 (’301 Patent)
The Invention Explained
- Problem Addressed: The patent's background section identifies that in computer systems, hard drives "constitute a major bottleneck in data transportation and processing" because their data transfer rates have remained "relatively modest" compared to rapid advancements in microprocessors and memory speed ('301 Patent, col. 3:12-21). Conventional hard drives with a single actuator mechanism, where all read/write heads move in unison, are inherently limited to serial data access ('301 Patent, col. 2:40-51).
- The Patented Solution: The invention proposes a hard disk drive architecture that incorporates an "actuator with independently movable arms" and a "custom printed circuit board" ('301 Patent, Abstract). This design allows for the simultaneous reading and writing of "alternate or interleaving bits or blocks of data... across a plurality of platter surfaces within the same physical drive" ('301 Patent, Abstract; col. 4:51-60). This effectively implements a data striping configuration, similar to RAID Level 0, within a single physical drive to increase data throughput ('301 Patent, col. 4:52-57).
- Technical Importance: This approach aimed to achieve significant increases in drive performance without the traditional disadvantages of multi-drive RAID 0 systems, such as increased power consumption, physical space, cost, and failure probability ('301 Patent, col. 4:35-48).
Key Claims at a Glance
- The complaint provides an exemplary analysis of independent claim 2 (Compl. ¶20).
- The essential elements of independent claim 2 are:
- An information storage and retrieval apparatus comprising at least one circular substrate with at least two carrier surfaces for storing data.
- An actuator mechanism with at least two arms, each assigned to different carrier surfaces.
- Means for moving said arms simultaneously and independently across the carrier surfaces with radial movement.
- A logic holder with electronic architecture for controlling the apparatus, which executes means for permitting data to be read or written simultaneously and independently across a plurality of carrier surfaces.
- The complaint alleges infringement of claims 1-77, including independent claims 1, 41, and 71, and reserves the right to assert additional claims (Compl. ¶¶19, 35).
III. The Accused Instrumentality
Product Identification
The accused products are Western Digital enterprise hard disk drives that incorporate "dual-actuator and/or triple-stage-actuator architectures" (Compl. ¶23). The complaint specifically identifies the "Ultrastar DC HS760 20TB dual-actuator HDD" as an exemplary product (Compl. ¶¶21, 23).
Functionality and Market Context
The complaint alleges the accused products contain "dual-arm systems allowing for the independent and simultaneous reading and writing of data across multiple carrier surfaces" (Compl. ¶21). This dual-actuator technology is presented as a key feature of Defendant's high-performance enterprise hard drives, designed to increase data throughput and performance, mirroring the objectives of the patented invention (Compl. ¶¶13-14).
IV. Analysis of Infringement Allegations
The complaint provides an annotated image and narrative allegations that map elements of the accused products to claim 2 of the ’301 Patent (Compl. ¶¶20, 27). An annotated photograph of an opened hard drive shows arrows pointing from claim limitations to corresponding physical components, such as the actuator arms and disks (Compl. p. 6).
’301 Patent Infringement Allegations
| Claim Element (from Independent Claim 2) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| at least one circular substrate, said substrate or substrates aggregating at least two carrier surfaces capable of storing data... | The physical hard drive platters ("disks") within the accused drives. | ¶¶20, 27; p. 6 | col. 2:28-34 |
| an actuator mechanism with at least two arms, each of said arms assigned to different carrier surfaces | The dual-actuator system in the accused drives, which is alleged to have two independent arms ("Arm 1 assigned to top set of disks and Arm 2 assigned to lower set"). | ¶¶20, 27; p. 6 | col. 4:40-41 |
| means for moving said arms simultaneously and independently across corresponding carrier surfaces... | The "Drive Motors" that control the movement of the dual actuator arms. | ¶¶20, 27; p. 6 | col. 4:51-60 |
| and a logic holder... wherein... said... apparatus executes means for permitting alternate or interleaving bits or blocks of data to be read or written simultaneously and independently... | The "Hard Drive controller and interface" that allegedly manages the simultaneous and independent data operations across the multiple platter surfaces. | ¶¶20, 27; p. 6 | col. 6:23-35 |
Identified Points of Contention
- Scope Questions (Means-Plus-Function): Claim 2 contains two means-plus-function limitations ("means for moving" and "means for permitting"). The infringement analysis will require the court to first construe these terms by identifying the corresponding structures disclosed in the '301 patent specification (e.g., the specific electromagnetic coil arrangement for "moving" and the microcontroller's shuffling algorithm for "permitting") and then determine if the accused products' structures are the same or equivalent ('301 Patent, col. 4:51-60; col. 6:23-35).
- Technical Questions: A central technical question may be whether the accused dual-actuator systems operate "independently" in the manner required by the claim. The complaint alleges independent operation, but the defense may argue that the actuators, while separate, operate in a coordinated or dependent manner that falls outside the scope of the claims as construed in light of the patent's specification.
V. Key Claim Terms for Construction
The Term: "moving said arms simultaneously and independently"
- Context and Importance: The concept of "independent" movement is fundamental to the patent's asserted novelty over conventional single-actuator designs. The definition of this term will be critical to determining whether the accused dual-actuator drives, which may feature some level of coordination between the two actuators, meet this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification contrasts the invention with conventional actuators where arms are physically prevented from "moving independently" and are forced to move "in unison" ('301 Patent, col. 2:46-49). This may support a construction where "independently" simply means not being physically locked together in unison.
- Evidence for a Narrower Interpretation: The specification also states that while operating independently, the arms "actually move in near synchronization" according to an identical read/write pattern ('301 Patent, col. 8:6-9). This language could be used to argue for a narrower construction that requires a specific type of coordinated, yet separate, movement rather than fully asynchronous, unconstrained independence.
The Term: "logic holder"
- Context and Importance: This term defines the electronic control system of the apparatus. Its construction will determine what specific electronic architecture is required to infringe. The complaint maps this term to the general "Hard Drive controller and interface" (Compl. p. 6).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 2 broadly defines the holder by its function: comprising "electronic architecture for electronically controlling" the apparatus. This functional language may support a broad interpretation covering various controller designs.
- Evidence for a Narrower Interpretation: The specification discloses a specific embodiment comprising "four RW/VCM controllers 55" and a "common microcontroller circuitry 60" ('301 Patent, FIG. 6; col. 6:11-14). A defendant may argue that the term "logic holder" should be limited to this disclosed architecture or its structural equivalents, particularly in relation to the "means for permitting" function it executes.
VI. Other Allegations
Willful Infringement
The complaint alleges that Defendant has been willfully infringing since at least February 12, 2019, the date it was sued in a prior case (Tormasi v. Western Digital) involving the same ’301 Patent (Compl. ¶31). This prior litigation is alleged to have provided Defendant with actual knowledge of the patent and its alleged infringement, which Defendant subsequently disregarded by continuing to sell the accused products (Compl. ¶31).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope under 35 U.S.C. § 112(f): Given the use of means-plus-function language, the dispute will likely focus on whether the specific motor and controller architectures in Western Digital's dual-actuator drives are structurally equivalent to the "electromagnetic coils" and "microcontroller" logic disclosed in the '301 patent's specification for achieving "independent" movement and data striping.
- A key technical question will be one of operational definition: What degree of freedom is required for the two actuator arms to be considered moving "independently"? The case may turn on evidence detailing the precise nature of the coordination, or lack thereof, between the two actuators in the accused products, and how that compares to the patent's description of "near synchronization."
- A critical question for damages will be willfulness: Does the prior lawsuit cited in the complaint establish pre-suit knowledge of infringement that was objectively reckless to disregard, potentially exposing the Defendant to enhanced damages if infringement is found?