DCT
2:16-cv-00538
Lambeth Magnetic Structures LLC v. Seagate Technology US Holdings Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lambeth Magnetic Structures, LLC (Pennsylvania)
- Defendant: Seagate Technology (US) Holdings, Inc. (Delaware) and Seagate Technology LLC (Delaware)
- Plaintiff’s Counsel: The Webb Law Firm
- Case Identification: 2:16-cv-00538, W.D. Pa., 04/29/2016
- Venue Allegations: Venue is based on Defendant Seagate's regular transaction of business in the Western District of Pennsylvania, including direct sales and shipping of allegedly infringing products to consumers in the district via its website.
- Core Dispute: Plaintiff alleges that Defendant’s hard disk drives and their internal recording heads infringe a patent related to specialized magnetic material structures that enable higher data storage density.
- Technical Context: The technology concerns advanced materials science for magnetic thin films, a field critical to increasing the storage capacity of hard disk drives (HDDs) without increasing their physical size.
- Key Procedural History: The complaint alleges that Seagate has been aware of the patent-in-suit since at least March 2011, when it acquired the hard drive business of Samsung Corporation, which had previously licensed the patent. Plaintiff asserts that the accused products are not covered by the terms of that acquired license.
Case Timeline
| Date | Event |
|---|---|
| 2001-08-29 | ’988 Patent Priority Date |
| 2006-10-31 | ’988 Patent Issue Date |
| 2011-03-01 | Alleged date of Seagate’s awareness of the ’988 Patent |
| 2016-04-29 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,128,988 - “Magnetic Material Structures, Devices and Methods,” issued October 31, 2006
The Invention Explained
- Problem Addressed: The patent addresses the challenge of precisely controlling the magnetic properties of thin films used in data storage devices. Specifically, achieving a "uniaxial anisotropy"—a single preferred magnetic orientation—is critical for performance, but has been difficult, especially for high-performance body-centered cubic (bcc) materials that do not naturally form the ideal crystalline structure. (’988 Patent, col. 1:45-53, col. 5:11-16).
- The Patented Solution: The invention discloses a multi-layer material structure that induces the desired magnetic properties. The solution involves epitaxially growing a bcc-type magnetic layer on a specially prepared "(111) textured hexagonal atomic template." (’988 Patent, Abstract). This specific layering process creates a "symmetry broken" crystalline structure in the magnetic layer, which in turn produces the sought-after oriented uniaxial magnetic properties. (’988 Patent, col. 13:52-60).
- Technical Importance: This method was designed to allow the use of bcc materials with high saturation magnetization in devices like hard drive recording heads, enabling increased data storage density and performance beyond what was achievable with conventional materials. (Compl. ¶18).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 27. (Compl. ¶¶26-27).
- Independent Claim 1 recites a magnetic material structure comprising:
- a substrate;
- at least one bcc-d layer which is magnetic, forming a uniaxial symmetry broken structure; and
- at least one layer providing a (111) textured hexagonal atomic template disposed between said substrate and said bcc-d layer.
- Independent Claim 27 recites a magnetic device that incorporates the structure of Claim 1.
- The complaint also states that dependent claims 6, 7, 9, 11, and 13 are infringed. (Compl. ¶26).
III. The Accused Instrumentality
Product Identification
- The complaint identifies a range of Seagate hard disk drives (HDDs) and solid-state hybrid drives (SSHDs), collectively referred to as the "Accused Seagate Drives." (Compl. ¶20). The 1TB HDD Model No. ST3000DM001 is identified as a representative product. (Compl. ¶20).
Functionality and Market Context
- The infringement allegations focus on the internal components of the drives, specifically the "recording head for writing data." (Compl. ¶22). The complaint alleges that these recording heads are manufactured using the patented magnetic material structure to achieve high data storage capacity. (Compl. ¶¶18, 23). A photograph provided in the complaint shows the exterior of a representative accused product, the Seagate 3TB Desktop HDD SATA model ST3000DM001. (Compl. p. 5).
IV. Analysis of Infringement Allegations
’988 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a substrate | The recording heads in the Accused Seagate Drives are built upon a substrate. | ¶23, ¶25 | col. 28:10-12 |
| at least one bcc-d layer which is magnetic, forming a uniaxial symmetry broken structure | The accused recording heads allegedly include a magnetic layer made from iron cobalt (Fe,Co) that has a body-centered cubic derivative ("bcc-d") structure and forms the claimed "uniaxial symmetry broken structure." | ¶23, ¶24 | col. 13:52-68 |
| at least one layer providing a (111) textured hexagonal atomic template disposed between said substrate and said bcc-d layer | The accused recording heads allegedly use an intermediate layer made from nickel (Ni), nickel alloy, or other seedlayer material that provides the "(111) textured hexagonal atomic template" on which the magnetic bcc-d layer is formed. | ¶23, ¶25 | col. 13:55-59 |
- Identified Points of Contention:
- Technical Question: The complaint asserts that Seagate's use of an iron-cobalt magnetic layer and a nickel-based seedlayer results in the claimed "uniaxial symmetry broken structure." (Compl. ¶¶23-25). A key technical question will be whether Seagate's manufacturing process creates the specific, structurally distinct crystalline state described in the patent, or merely a material with generally similar functional properties.
- Evidentiary Question: The complaint acknowledges that Seagate acquired a license to the ’988 patent from Samsung but alleges the accused products are not covered by that license. (Compl. ¶21). The scope of this license agreement and its applicability to the enumerated Seagate products will likely be a significant point of factual dispute.
V. Key Claim Terms for Construction
The Term: "uniaxial symmetry broken structure"
- Context and Importance: This term is central to the invention, defining the novel characteristic of the magnetic layer. Its construction will be critical for determining infringement, as the dispute may focus on what precise physical arrangement of crystals meets this definition. Practitioners may focus on this term because it is not a standard term of art and appears to be defined by the patentee.
- Intrinsic Evidence for a Broader Interpretation: A party may argue the term is met so long as the final structure is created by depositing a bcc-d layer on a hexagonal template and exhibits the functional property of uniaxial anisotropy. The patent abstract links the "symmetry broken" structure to the promotion of "oriented uniaxial magnetic properties." (’988 Patent, Abstract).
- Intrinsic Evidence for a Narrower Interpretation: A party may argue the term requires a specific, physically demonstrable crystalline state. The patent defines a "crystallographically 'symmetry broken' material" as one in which "individual, variant sets do not contain an equal amount of all six of the (110) textured bcc-d variants." (’988 Patent, col. 24:38-41). This suggests the term requires proof of a specific non-uniform distribution of crystalline variants, not just a resulting magnetic behavior.
The Term: "(111) textured hexagonal atomic template"
- Context and Importance: This term defines the underlayer upon which the key magnetic layer is grown. Its scope will determine what types of "seedlayers" satisfy the claim.
- Intrinsic Evidence for a Broader Interpretation: The specification provides several examples, stating that "fcc, (111) textured fcc derivative, or an (0002) textured hcp crystals are examples of the (111) textured hexagonal atomic template." (’988 Patent, col. 13:55-59). This supports the complaint's allegation that a layer of "nickel, nickel alloy, or some other seedlayer material" can meet this limitation. (Compl. ¶25).
- Intrinsic Evidence for a Narrower Interpretation: The patent's detailed discussion of epitaxial growth emphasizes the importance of lattice matching and a high degree of crystalline order to induce the desired structure in the subsequent magnetic layer. (’988 Patent, col. 9:38-51). An argument could be made that a generic "seedlayer" is insufficient unless it provides the specific, high-quality "template" necessary for the claimed symmetry breaking to occur.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, asserting that Seagate knowingly sells the infringing magnetic heads to third-party manufacturers like Apple Inc. for incorporation into consumer products (e.g., iMac computers, game consoles) that are then sold in the U.S. (Compl. ¶¶30-31). The alleged inducing acts include providing marketing materials and sales efforts directed at these customers. (Compl. ¶31).
- Willful Infringement: The willfulness allegation is based on pre-suit knowledge of the patent. The complaint alleges that Seagate has been aware of the ’988 Patent since "at least as early as March 2011" as a result of its acquisition of Samsung's HDD business and the associated patent license. (Compl. ¶28). The complaint also seeks a finding that the case is "exceptional" under 35 U.S.C. § 285, which could permit recovery of attorney's fees. (Compl. ¶33).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural proof: Can Plaintiff produce evidence that Seagate's mass-produced recording heads contain the specific "uniaxial symmetry broken structure" as defined by the patent, which is described as a non-uniform distribution of distinct crystalline variants, rather than simply a material that functions in a uniaxially anisotropic manner?
- A key threshold question will be contractual scope: Do the terms of the patent license Seagate acquired from Samsung cover the accused products, potentially providing a complete defense, or, as Plaintiff alleges, are these products expressly excluded from the license grant?
- A central claim construction dispute will likely be one of definitional precision: Does the term "(111) textured hexagonal atomic template" refer broadly to any seedlayer that promotes a (111) texture, or does it require a specific degree of crystalline quality and lattice matching necessary to enable the complex epitaxial growth process described in the patent?