DCT
3:13-cv-02944
eDigital Corp v. Micron Technology Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: e.Digital Corporation (Delaware)
- Defendant: Micron Technology, Inc. (Delaware)
- Plaintiff’s Counsel: Handal & Associates
- Case Identification: 3:13-cv-02944, S.D. Cal., 03/21/2014
- Venue Allegations: Venue is alleged based on Defendant’s sales and business activities within the Southern District of California, and the location of Plaintiff's headquarters and place of business within the district.
- Core Dispute: Plaintiff alleges that Defendant’s flash memory storage products, including its USB, SSD, SD, and microSD devices, infringe a patent related to a method for managing data in non-volatile memory.
- Technical Context: The technology concerns file management systems for non-volatile flash memory, a foundational component of modern solid-state storage devices.
- Key Procedural History: The operative pleading is a First Amended Complaint, which superseded an original complaint filed in 2013. The complaint does not mention any prior litigation, licensing history, or administrative proceedings involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 1996-03-07 | '108 Patent Priority Date |
| 1998-11-17 | '108 Patent Issue Date |
| 2014-03-21 | First Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 5,839,108 - Flash Memory File System In A Handheld Record And Playback Device (Issued Nov. 17, 1998)
The Invention Explained
- Problem Addressed: The patent describes drawbacks in prior art methods for managing flash memory that emulated conventional disk operating systems like DOS ('108 Patent, col. 2:2-6). These systems allegedly suffered from performance overhead and a lack of fault tolerance because they required copying data from non-volatile flash memory to volatile RAM for manipulation, and the RAM-based file map could be lost during a power failure ('108 Patent, col. 2:7-19).
- The Patented Solution: The invention discloses a method of memory management that operates directly on the non-volatile medium. Instead of requiring physically contiguous storage, the method writes new data segments to any available space and then creates "logical links" to connect that new segment to the previous one ('108 Patent, col. 11:10-27). This process creates a sequential file from physically non-contiguous blocks, which is intended to reduce reliance on RAM and increase data throughput and fault tolerance ('108 Patent, col. 1:15-21).
- Technical Importance: The patent addresses the challenge of adapting file systems for the unique characteristics of flash memory, proposing a linked-list approach to data organization to avoid the inefficiencies of traditional block-based file systems.
Key Claims at a Glance
- The complaint asserts independent Claim 1 ('108 Patent, Compl. ¶11).
- The essential elements of Claim 1 include:
- A method of memory management for a primary memory created from a non-volatile storage medium.
- Coupling a "cache memory" (for temporary, volatile storage) to the primary memory.
- Writing a new data segment from the cache memory to an available space in the primary memory.
- "Creating a logical link" between the new data segment and the "sequentially previous logical data segment" to provide a path for sequential access.
- Continuing to create links for subsequent data segments.
- Storing the data segments in a manner consistent with an "industry standard data storage format" while retaining the linking between segments.
- The complaint focuses exclusively on Claim 1.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "Micron's Flash Memory Storage products including but not limited to its USB, SSD, SD, microSD, and/or Compact Flash products" (Compl. ¶10). The complaint notes these products are also marketed under the "Crucial" and "Crucial Memory" brand names (Compl. ¶1, p. 3).
Functionality and Market Context
The complaint alleges the accused products have a "primary and substantial purpose" of writing and storing electronic data in non-volatile flash memory (Compl. ¶10). The infringement allegation is based on the products' alleged use of a method of memory management that involves writing electronic data segments from volatile to non-volatile memory by "linking data segments" (Compl. ¶11). The complaint points to a "demonstration and informational video" posted by Micron as an example showing data being transferred to an accused product (Compl. ¶15).
IV. Analysis of Infringement Allegations
’108 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) creating the primary memory from a non-volatile, long-term storage medium, wherein the primary memory comprises a plurality of blocks in which the data segments are to be stored; | The accused products are flash memory storage devices that function as non-volatile primary memory. | ¶10 | col. 1:12-15 |
| (b) coupling a cache memory to the primary memory, said cache memory providing temporary and volatile storage for at least one of the data segments; | The accused products are alleged to use a method involving writing data from a temporary, volatile memory to a non-volatile, long-term storage medium. | ¶11 | col. 2:10-13 |
| (c) writing a new data segment from the cache memory to the primary memory by linking said new data segment to a sequentially previous logical data segment by the following steps: | The accused products are alleged to link data segments when writing to and storing electronic data. | ¶11, ¶14 | col. 11:10-15 |
| (4) creating a logical link between the previous logical data segment and the new data segment such that the logical link provides a path for sequentially accessing the data segments... | The accused products allegedly create links between data segments to manage stored data. | ¶11 | col. 11:24-27 |
| (6) storing the data segments to primary memory in a manner consistent with an industry standard data storage format while retaining linking between data segments created in previous steps. | The accused products are alleged to perform the claimed method when used for their normal purpose of storing data, which implies presenting a standard interface to a host computer. | ¶14 | col. 11:35-39 |
Identified Points of Contention
- Scope Questions: The patent is titled and primarily describes a "Handheld Record And Playback Device" ('108 Patent, Title; col. 2:47-50). A point of contention may be whether the scope of the claimed method, which is not textually limited to a specific device, should be constrained by the specification's focus, given it is asserted against general-purpose storage products like SSDs.
- Technical Questions: The complaint alleges that the accused products' memory management systems perform the specific "linking" steps of Claim 1 (Compl. ¶11). A central technical question is what evidence exists to show that modern Flash Translation Layers (FTLs)—which use complex logical-to-physical address mapping—perform the specific sequence recited in the claim, as opposed to a technologically distinct method of managing data.
V. Key Claim Terms for Construction
The Term: "cache memory"
- Context and Importance: The patent criticizes prior art systems for their heavy reliance on RAM ('108 Patent, col. 2:20-28). The construction of "cache memory" is critical to determining whether the ubiquitous DRAM buffers in modern storage devices meet this limitation, or if the term implies a more limited structure in light of the patent's overall disclosure.
- Intrinsic Evidence for a Broader Interpretation: The claim itself provides a broad, functional definition: "temporary and volatile storage for at least one of the data segments" ('108 Patent, col. 11:8-10), which could be argued to read on any standard RAM buffer.
- Intrinsic Evidence for a Narrower Interpretation: The repeated criticism of RAM-heavy systems in the "Prior Art" section could be used to argue that "cache memory" should be construed as something distinct from the large RAM maps and buffers the inventor sought to improve upon ('108 Patent, col. 2:37-44).
The Term: "creating a logical link"
- Context and Importance: This term describes the core inventive step. Its construction will determine whether the claim covers the sophisticated, table-based address mapping of modern FTLs or is limited to a simpler, direct pointer-chaining system.
- Intrinsic Evidence for a Broader Interpretation: The claim describes the link's function as providing "a path for sequentially accessing the data segments" ('108 Patent, col. 11:25-27), which a party could argue covers any data structure that achieves this result, including a mapping table.
- Intrinsic Evidence for a Narrower Interpretation: A party may argue that the term, in the context of overcoming a FAT-style system, refers to a specific implementation of serially connecting data blocks with pointers, and does not read on the distinct architecture of a modern logical-to-physical address translation table.
VI. Other Allegations
Indirect Infringement
The complaint alleges both induced and contributory infringement. The inducement claim is based on allegations that Micron provides "operating manuals, guides, instructional and/or informational videos" that instruct and encourage customers to use the accused products in an infringing manner (Compl. ¶19(c), ¶19(e)). The contributory infringement claim alleges that the products' memory management components are not staple articles of commerce and were specially adapted for an infringing use (Compl. ¶20(c)-(e)).
Willful Infringement
Willfulness is alleged based on Micron's knowledge of the '108 patent "since at least the filing of the original complaint in this matter, if not sooner" (Compl. ¶21). The allegations appear to support a claim for post-filing willfulness, as no specific facts supporting pre-suit knowledge are pleaded.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of applicability and scope: can a patent explicitly directed to a "handheld record and playback device" be interpreted to cover the memory management methods of modern, general-purpose SSDs, USB drives, and memory cards, or will the claims be narrowed by the specification's disclosed embodiments?
- A key evidentiary question will be one of technical mechanism: does the complex, table-based Flash Translation Layer (FTL) used in modern flash controllers perform the specific, sequential method of "creating a logical link" as recited in Claim 1, or is there a fundamental mismatch in technical operation between the patented method and the accused technology?
- The outcome may also depend on a question of claim construction: will the term "cache memory" be given its plain meaning of any volatile buffer, or will the patent’s explicit criticism of RAM-heavy prior art systems persuade a court to adopt a narrower construction that could potentially exclude the accused products?