DCT

4:25-cv-11030

DigitalDoors Inc v. Bank Of Ann Arbor

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-11030, E.D. Mich., 04/10/2025
  • Venue Allegations: Venue is alleged to be proper based on Defendant maintaining a regular and established business presence within the Eastern District of Michigan, where it directs its services and targets customers.
  • Core Dispute: Plaintiff alleges that Defendant’s data backup and disaster recovery systems, which are asserted to be compliant with the financial industry’s “Sheltered Harbor” standard, infringe four patents related to methods for securely filtering, extracting, and storing sensitive data in distributed computing systems.
  • Technical Context: The technology concerns granular data security and survivability, a critical function for financial institutions that must protect sensitive customer account information from cyberattacks and ensure operational continuity.
  • Key Procedural History: The complaint asserts the patents-in-suit are "pioneering" and have been cited as relevant prior art in hundreds of subsequent U.S. patent applications from numerous technology and financial companies.

Case Timeline

Date Event
2007-01-05 Earliest Priority Date for all Patents-in-Suit
2015-04-21 U.S. Patent No. 9,015,301 Issued
2015-01-01 Sheltered Harbor initiative launched (approximate date)
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
2025-04-10 Complaint Filing Date

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"

  • Patent Identification: U.S. Patent No. 9,015,301, titled "Information Infrastructure Management Tools With Extractor, Secure Storage, Content Analysis And Classification And Method Therefor," issued April 21, 2015 (the "’301 Patent").

The Invention Explained

  • Problem Addressed: The patent's background, as referenced in the complaint, identifies deficiencies in prior art data management systems circa 2007, including an inability to manage unstructured content, the vulnerability of open enterprise ecosystems, and the lack of robust information rights management to address the changing sensitivity of data over its lifecycle (Compl. ¶¶28, 32, 33; ’301 Patent, col. 1:31-2:61).
  • The Patented Solution: The invention provides a method for organizing and processing data by using a plurality of "designated categorical filters" within a distributed computing system. These filters are activated to process a data input, obtain "select content" (important information) and associated contextual or taxonomic data, and store the resulting aggregated content in corresponding data stores. The system then associates specific data processes—such as copying, archiving, or destruction—with the filtered data, allowing for automated, policy-based data management. (Compl. ¶27; '301 Patent, Abstract; '301 Patent, col. 3:17-4:35).
  • Technical Importance: This approach enabled a shift from managing entire data files to managing the specific sensitive content within them, providing a more granular and secure method for data protection and disaster recovery (Compl. ¶¶28, 30).

Key Claims at a Glance

  • The complaint asserts independent claim 25 ('301 Patent, Compl. ¶99).
  • The essential elements of claim 25 include:
    • A method of organizing and processing data in a distributed computing system.
    • Providing a plurality of select content data stores operative with a plurality of enterprise designated categorical filters.
    • Activating at least one filter and processing a data input to obtain select content and associated content (contextually or taxonomically associated).
    • Storing the aggregated select content in a corresponding data store.
    • Associating a data process (e.g., copy, extract, archive, distribute, destroy) with the activated filter.
    • Applying the associated data process to a further data input based on the result of processing 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 and With Granular Data Stores"

  • Patent Identification: U.S. Patent No. 9,734,169, titled "Digital Information Infrastructure and Method for Securing Designated Data and With Granular Data Stores," issued August 15, 2017 (the "’169 Patent").

The Invention Explained

  • Problem Addressed: The invention addresses the need for a secure and resilient data storage architecture, particularly in a distributed or cloud-based environment, where critical data must be protected from loss while remaining accessible for authorized reconstruction (Compl. ¶¶131-132; ’169 Patent, Abstract).
  • The Patented Solution: The patent describes a method implemented in a distributed cloud-based computing system that includes select content data stores, granular data stores, and a cloud-based server. The system extracts "security designated data" and stores it in the secure "select content data stores," which have specific access controls. The "remainder data" not extracted is parsed and stored separately in "granular data stores." Data can be withdrawn from both types of stores for reconstruction only when permitted by the access controls, ensuring that sensitive information is isolated and protected. (Compl. ¶¶137, 152; '169 Patent, Abstract; ’169 Patent, col. 3:29-4:41).
  • Technical Importance: This architecture provides a method for enhancing data survivability by physically or logically separating highly sensitive data from the bulk of an enterprise's data, storing it under different conditions and access controls, thereby reducing the attack surface for critical information (Compl. ¶¶132, 140).

Key Claims at a Glance

  • The complaint asserts independent claim 1 ('169 Patent, Compl. ¶130).
  • The essential elements of claim 1 include:
    • A method of organizing and processing data in a distributed cloud-based computing system.
    • Providing select content data stores, granular data stores, and a cloud-based server coupled by a communications network.
    • Extracting and storing security designated data in the select content data stores.
    • Activating a select content data store to permit access based on one or more access controls.
    • Parsing remainder data not extracted and storing it in the granular data stores.
    • Withdrawing the security designated data and the parsed remainder data from their respective stores only in the presence of the applied access controls.

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

  • Patent Identification: U.S. Patent No. 10,182,073, titled "Information Infrastructure Management Tools With Variable and Configurable Filters and Segmental Data Stores," issued January 15, 2019 (the "’073 Patent").
  • Technology Synopsis: The ’073 Patent describes an information infrastructure where data throughput is processed using a plurality of initially configured filters to identify sensitive and select content. A key aspect of the invention is the ability to subsequently alter these filters by expanding or contracting their scope or by imposing or removing classifications, thereby allowing for dynamic and adaptive data management over time. (Compl. ¶¶167, 182; ’073 Patent, Abstract). The complaint includes a screenshot from a Dell instructional video showing a user interface for generating reports, which provides a menu of optional filters that can be applied, illustrating the concept of configurable filtering (Compl. p. 89).
  • Asserted Claims: Claim 1 (Compl. ¶166).
  • Accused Features: The accused systems' use of modifiable "protection policies" that function as filters to identify and process critical financial data. The ability for the enterprise to define, run, monitor, and modify these policies is alleged to constitute the claimed filter alteration. (Compl. ¶¶183, 185).

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

  • Patent Identification: U.S. Patent No. 10,250,639, titled "Information Infrastructure Management Data Processing Tools for Processing Data Flow With Distribution Controls," issued April 2, 2019 (the "’639 Patent").
  • Technology Synopsis: The ’639 Patent discloses a method for "sanitizing" data in a distributed system. The system processes data containing both sensitive and select content, where sensitive content is organized into a plurality of sensitivity levels with associated security clearances. The method involves extracting sensitive content, storing it in secure data stores corresponding to its sensitivity level, and using content, contextual, and taxonomic filters to "inference" the data to obtain a sanitized version. (Compl. ¶¶194, 219; ’639 Patent, Abstract).
  • Asserted Claims: Claim 16 (Compl. ¶193).
  • Accused Features: The accused systems' alleged process of extracting critical financial data (sensitive content) based on predefined policies (filters), storing it in a secure data vault (extract stores), and using those policies to infer which data is critical and requires protection according to its sensitivity. (Compl. ¶¶204, 217, 220).

III. The Accused Instrumentality

Product Identification

  • The "Accused Instrumentalities" are identified as the systems and methods that Defendant Bank of Ann Arbor "makes, owns, operates, uses, or otherwise exercises control over" for data processing, backup, and disaster recovery. The complaint alleges these systems are either compliant with the "Sheltered Harbor" specification or are functionally equivalent. (Compl. ¶96).

Functionality and Market Context

  • The complaint alleges the accused systems perform secure data vaulting for disaster recovery, a practice standardized by the Sheltered Harbor initiative for the financial services industry (Compl. ¶63). The core functionality involves extracting "critical financial information," converting it to a standard format, and transmitting it for storage in a secure, isolated "data vault" that is immutable and air-gapped from production networks (Compl. ¶¶70, 77). The complaint references a diagram from Dell, an endorsed Sheltered Harbor solution provider, which illustrates this architecture as a "Production Environment" connected via a secure, air-gapped replication process to a separate "Data Vault Environment" (Compl. p. 31). This vault is designed to protect critical customer data from destructive cyberattacks and allow the institution to restore essential services (Compl. ¶71). The complaint asserts that these systems are implemented using interconnected hardware (servers) and software that Defendant controls (Compl. ¶96).

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 enterprise designated categorical filters which stores are operatively coupled over a communications network The accused systems provide a "data vault" with designated data stores for sensitive content, which operate based on "protection policies" that function as categorical filters. ¶105, ¶107 col. 14:7-14
activating at least one of said designated categorical filters and processing a data input therethrough to obtain said select content and associated select content...as aggregated select content The accused systems activate protection policies (filters) using aggregated tags to process data and extract critical financial account information for protective vaulting. ¶109, ¶110 col. 14:15-22
storing said aggregated select content for said at least one categorical filter in said corresponding select content data store The extracted critical account data is stored in the corresponding storage units within the secure data vault. ¶113, ¶114 col. 14:23-26
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 system's policies associate specific actions (copying, archiving, extracting) with specific data types to be vaulted. ¶116, ¶117 col. 14:27-33
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 automatically processed in the same way, such as through nightly backups. ¶119-¶121 col. 14:34-41
said activating a designated categorical filter encompasses an automatic activation...[which] is time-based, distributed computer system condition-based, or event-based The processing is alleged to occur automatically at designated time intervals (e.g., nightly), upon a designated condition (e.g., detection of new data), or manually. ¶122-¶124 col. 15:1-5

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... (ii) a plurality of granular data stores; and (iii) a cloud-based server... The accused system allegedly includes a secure data vault (select content stores), production and backup systems outside the vault (granular data stores), and is implemented in a cloud-based or hybrid-cloud environment. A diagram in the complaint illustrates "Backup Workloads" in a data center separate from a "Cyber Recovery Vault" (Compl. p. 33). ¶137-¶141 col. 132:15-23
providing a communications network operatively coupling said plurality of select content data stores and cloud-based server The accused systems comprise an operatively coupled network that connects the production environment to the data vault, which the complaint alleges is required to be "completely separated" but still connected for data transfer. ¶142, ¶143 col. 132:21-23
extracting and storing said security designated data in respective select content data stores Critical financial data is extracted from the production environment and stored in the secure data vault. ¶144, ¶147 col. 132:24-26
activating at least one of said select content data stores in said cloud-based computing system thereby permitting access to said select content data stores...based upon an application of one or more of said access controls thereat Access to the data vault is alleged to be safeguarded by strict security measures, including credentialed and multi-factor authentication. ¶149, ¶150 col. 132:27-32
parsing remainder data not extracted from data processed by said cloud-based system and storing the parsed data in respective granular data stores Data that is not extracted for vaulting remains in the production and standard backup systems, which are alleged to be the "granular data stores." ¶152, ¶153 col. 132:33-36
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 The restoration of data from the vault and production systems is alleged to occur only after satisfying strict security and access control protocols. ¶158, ¶159 col. 132:37-41
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the defendant's implementation of an industry-wide standard (Sheltered Harbor), often using third-party vendor technology (such as Dell PowerProtect), constitutes direct infringement of the claimed methods. The analysis may focus on the degree of control and direction the defendant exercises over the system's operation.
    • Technical Questions: A likely point of dispute will be whether the accused system's "protection policies" meet the definition of "categorical filters" as described in the '301 Patent, which includes specific taxonomic and contextual types. Similarly, for the '169 Patent, a question is whether the production/backup systems function as the claimed "granular data stores" for "parsed remainder data," or if "parsing" requires a more active process than simply not selecting data for extraction.

V. Key Claim Terms for Construction

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

  • Context and Importance: This term is fundamental to the infringement theory against the '301 Patent. Plaintiff's case appears to depend on construing this term to read on the "protection policies" and rule sets used in the accused Sheltered Harbor-compliant systems (Compl. ¶107). Practitioners may focus on this term because its scope will determine whether standard data backup policies fall within the patent's claims.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification states that enterprise-designated filters can screen data for policies such as "service level of policy, customer privacy policy, supplier privacy policy, enterprise human resource privacy policy," among others, suggesting a broad, policy-based meaning ('301 Patent, col. 4:15-23).
    • Evidence for a Narrower Interpretation: The specification describes specific, complex filter types, such as "content-based filters, contextual filters and taxonomic classification filters" ('301 Patent, col. 14:10-12) and a "knowledge expander search engine" ('301 Patent, col. 10:22-24). This language may support an argument that the term requires more than simple, rule-based data selection.

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

  • Context and Importance: The infringement allegation hinges on the idea that data not sent to the secure vault is the "remainder data" and that leaving it in production/backup systems constitutes "parsing" and "storing." The meaning of "parsing" is therefore critical.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term could be interpreted broadly to mean simply separating the data stream into two parts: the extracted portion and the portion left behind. The abstract refers to a process that "extracts and/or sends select/sensitive data" to a secure store, implying the remainder is what is not sent ('169 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The specification describes "parsing" in more active terms, such as breaking a data stream "into granular parts for context" or using algorithms to "split and disperse" data ('169 Patent, col. 16:32-35, col. 17:1-3). This may support a narrower construction requiring active processing of the remainder data, not just its passive non-selection.

VI. Other Allegations

  • Willful Infringement: The complaint includes a count for knowledge and willfulness, alleging Defendant had actual notice of the patents since at least the date of service of the complaint (Compl. ¶228). In the alternative, it alleges pre-suit notice dating back to September 30, 2024, based on arguments allegedly made during the prosecution of Defendant's own patent applications that referenced the DigitalDoors patents (Compl. ¶228). The complaint further alleges that Defendant maintains a policy of not reviewing the patents of others, constituting willful blindness (Compl. ¶229).

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

  • A core issue will be one of definitional scope: can the term “categorical filters,” which the patent describes with reference to complex taxonomic and contextual analysis, be construed broadly enough to cover the rule-based “protection policies” that are standard in modern data backup and disaster recovery systems like those adhering to the Sheltered Harbor specification?
  • A second key question will be one of functional operation: does the accused system’s act of leaving non-critical data in a production environment constitute “parsing remainder data” as required by Claim 1 of the ’169 Patent, or does the claim require a more active manipulation or structuring of that non-extracted data?
  • A significant factual question for willfulness will be whether the defendant's alleged reference to the plaintiff's patents during its own patent prosecution created an affirmative duty to investigate infringement, potentially exposing the defendant to charges of pre-suit willful infringement.