ServStor Tech LLC v. Celestica Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ServStor Technologies LLC (Texas)
  • Defendant: Celestica Inc. (Canada)
  • Plaintiff’s Counsel: Fabricant LLP; Rubino IP; Truelove Law Firm, PLLC
• Case Identification: 2:23-cv-00181, E.D. Tex., 04/21/2023
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is not a U.S. resident and may therefore be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s server products infringe five patents related to server architecture, remote management, and network-addressable storage partitioning.
• Technical Context: The technologies at issue concern foundational aspects of modern data center hardware, including high-density server design, out-of-band system management, and network-attached storage.
• Key Procedural History: The complaint alleges that Defendant had knowledge of the patents-in-suit due to a series of lawsuits Plaintiff filed against Defendant's competitors on the same patents beginning in 2022, which forms the basis for the willfulness allegations.

Case Timeline

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

U.S. Patent No. 7,191,274 - “Method and System for Providing Independent Server Functionality in a Single Personal Computer,” issued March 13, 2007

The Invention Explained

• Problem Addressed: The patent describes the problem of independent servers consuming extensive physical space and generating significant heat, which is inefficient, particularly in racked installations (’274 Patent, col. 1:11-20).
• The Patented Solution: The invention proposes a single computer chassis containing multiple, independent server cards that share a common power supply. Crucially, these server cards are designed to be independent, communicating externally through their own dedicated connections rather than with each other over a common internal system bus, thus allowing for a modular and dense server architecture (’274 Patent, Abstract; col. 2:54-61; Fig. 1).
• Technical Importance: This architecture provided a method for increasing server density and power efficiency, anticipating design principles later popularized in blade server systems (’274 Patent, col. 2:49-54).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶22).
• The key elements of independent claim 1 are:
  • A computer system comprising a chassis with a plurality of slots for circuit cards.
  • A shroud coupled to the chassis to form an enclosure.
  • A plurality of planar shaped circuit cards within the enclosure, each configured to provide an independent, dedicated server function.
  • Each circuit card is configured to be "free from any direct communication connection with any inter-card bus inside said enclosure."
• The complaint reserves the right to assert other claims (Compl. ¶21).

U.S. Patent No. 7,870,271 - “Disk Drive Partitioning Methods and Apparatuses,” issued January 11, 2011

The Invention Explained

• Problem Addressed: The patent identifies the challenge of traditional data storage, which is typically dependent on and controlled by a host computer's operating system, thereby limiting direct, peer-to-peer access from other networked devices (’271 Patent, col. 1:39-54).
• The Patented Solution: The invention discloses a storage device where individual partitions can be assigned their own unique IP addresses. A "storage element" within the device can receive a network request to create a partition, obtain an IP address for that new partition from a DHCP server, and associate the requesting client's name with that IP address, effectively making the storage partition an independent, addressable entity on the network (’271 Patent, Abstract; col. 4:20-49).
• Technical Importance: This technology disaggregates storage from a host operating system, a key concept in the development of modern Network-Attached Storage (NAS) where storage resources are directly accessible over a network (’271 Patent, col. 2:53-56).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶32).
• The key elements of independent claim 1 are:
  • An apparatus comprising a storage medium, a network interface, and a storage element.
  • The storage element is configured to receive a request for a partition allocation that includes a name.
  • The storage element then creates and allocates a partition based on the request.
  • The storage element obtains an IP address for the partition from a DHCP server.
  • The storage element associates the provided name with the obtained IP address.
• The complaint reserves the right to assert other claims (Compl. ¶31).

Multi-Patent Capsule: U.S. Patent No. 7,000,010

• Patent Identification: U.S. Patent No. 7,000,010, “System and Method for Caching Web Pages on a Management Appliance for Personal Computers,” issued February 14, 2006 (Compl. ¶7).
• Technology Synopsis: The patent addresses the difficulty of post-crash system diagnosis (’010 Patent, col. 4:26-36). The invention is a management appliance with a web page cache that stores recent status web pages from a host computer, allowing an administrator to retrieve them via an "out-of-band" connection to analyze the system's state immediately preceding a failure (’010 Patent, Abstract).
• Asserted Claims: At least independent claim 6 (Compl. ¶41).
• Accused Features: The complaint alleges that the accused servers' remote monitoring capabilities, which use a management appliance with a microserver to monitor host computer web pages, infringe this patent (Compl. ¶42).

Multi-Patent Capsule: U.S. Patent No. 6,738,930

• Patent Identification: U.S. Patent No. 6,738,930, “Method and System for Extending the Functionality of an Environmental Monitor for an Industrial Personal Computer,” issued May 18, 2004 (Compl. ¶10).
• Technology Synopsis: The patent seeks to solve the problem of inflexibility in legacy environmental monitors for industrial computers (’930 Patent, col. 1:36-44). The solution is an alarm card that includes a "microserver," enabling it to access web-based content on the host computer and allowing remote configuration and monitoring of system parameters via a network connection (’930 Patent, Abstract).
• Asserted Claims: At least independent claim 8 (Compl. ¶50).
• Accused Features: The complaint accuses the method of monitoring a remote computer performed by the accused servers, which allegedly uses an alarm card with a micro-server for monitoring web pages on the host CPU (Compl. ¶51).

Multi-Patent Capsule: U.S. Patent No. 7,310,750

• Patent Identification: U.S. Patent No. 7,310,750, “Method and System for Extending the Functionality of an Environmental Monitor for an Industrial Personal Computer,” issued December 18, 2007 (Compl. ¶11).
• Technology Synopsis: As a continuation of the '930 patent, this patent covers similar technology for enhancing remote monitoring. It describes an alarm card with a server that monitors web-based information on the host computer and reports this information to an external network via an out-of-band connection, even if the host computer has crashed (’750 Patent, Abstract; col. 4:5-13).
• Asserted Claims: At least independent claim 8 (Compl. ¶59).
• Accused Features: The complaint targets the accused servers' method of monitoring a remote computer using an alarm card with a server to monitor web pages from the host CPU (Compl. ¶60).

III. The Accused Instrumentality

• Product Identification: The complaint names Celestica servers generally, including the Athena, Nebula, Titan, Ares, and Heimdall server lines, with a specific focus on the Athena G2 SC4200 (Compl. ¶¶17-18, 23).
• Functionality and Market Context: The accused products are servers and server racks sold by Defendant, who is alleged to be a "leading manufacturer and seller" of such equipment (Compl. ¶2). The complaint alleges these servers incorporate technology such as management modules with a Baseboard Management Controller (BMC) for remote management, chassis that hold multiple planar circuit cards, and drive technology with associated software (Compl. ¶¶17, 23, 33). A visual from a product datasheet shows the accused Athena G2 SC4200 supports a "BMC (ASPEED AST2500)," which is central to the infringement allegations for the '010, '930, and '750 patents (Compl. ¶42, p. 10).

IV. Analysis of Infringement Allegations

'274 Patent Infringement Allegations

Identified Points of Contention ('274 Patent)

• Technical Question: A primary factual dispute will likely concern whether the server cards in the accused products are truly "free from any direct communication connection with any inter-card bus." The inquiry will focus on the specific architecture of the server backplane and whether any management, power, or other low-level communication pathways constitute a "direct communication connection" prohibited by the claim.

'271 Patent Infringement Allegations

Identified Points of Contention ('271 Patent)

• Evidentiary Question: The complaint's allegations for this patent are made entirely "upon information and belief." A key question will be whether discovery yields evidence that the accused servers' storage systems perform the specific, claimed sequence of receiving a named request, creating a partition, and then obtaining and associating a unique IP address for that partition via DHCP.

V. Key Claim Terms for Construction

Term ('274 Patent): "free from any direct communication connection with any inter-card bus"

• Context and Importance: This term is the central point of novelty for the '274 patent's architectural claims. Its construction will determine whether the patent reads on modern server architectures that may have various types of inter-card links (e.g., for management or chassis control) that are not the primary data-plane bus.
• Intrinsic Evidence for a Broader Interpretation: A party might argue the term refers only to primary data buses (e.g., PCI) that would require "system software" changes or cause "interference," not ancillary control buses. The specification's focus on avoiding "interference in the communication of signals in and out of other independent dedicated server cards" could support this view ('274 Patent, col. 2:58-61).
• Intrinsic Evidence for a Narrower Interpretation: A party could argue "any direct communication connection" is absolute and unambiguous, encompassing any physical electrical trace that allows for inter-card communication, regardless of its purpose. The patent's repeated emphasis on the "independent" nature of the cards could support a strict interpretation ('274 Patent, col. 3:3-4).

Term ('271 Patent): "storage element"

• Context and Importance: Infringement of the '271 patent hinges on this "element" performing the entire claimed method of partition creation and IP address acquisition. The definition of this term—whether it is a specific hardware controller, a software module, or a functional combination—is critical to mapping the claim to the accused products.
• Intrinsic Evidence for a Broader Interpretation: A party may contend "storage element" is a functional term that covers any component or combination of components (e.g., firmware, drivers, software agents) that collectively performs the claimed steps. The patent claims the element functionally ("configured to receive... to create... to obtain...") without imposing strict structural limitations ('271 Patent, cl. 1).
• Intrinsic Evidence for a Narrower Interpretation: A party could argue the term implies a discrete hardware or software component responsible for all recited functions. The complaint's allegation that the "Athena G2 SC4200's storage element is configured to..." suggests a singular entity, though it is not further defined (Compl. ¶33).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for all patents, asserting that Defendant provides the accused servers to customers and end-users with the intent that they will be used in an infringing manner (Compl. ¶¶24, 34, 43, 52, 61).
• Willful Infringement: The complaint alleges that Defendant had knowledge of the patents-in-suit "at least as of the filing of suits against their direct competitors" in 2022 (Compl. ¶17, fn. 1). The pleading asserts that Defendant either knew of its infringement or was willfully blind, forming the basis for enhanced damages (Compl. ¶¶26, 36, 45, 54, 63).

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

• A key technical question will be one of architectural equivalence: does the internal backplane of the accused servers meet the '274 patent's strict requirement of being "free from any direct communication connection" between server cards, or do modern management buses create a disqualifying link?
• A central evidentiary challenge will be one of operational proof: can the plaintiff demonstrate that the accused servers' storage systems, as alleged on "information and belief" for the '271 patent, actually perform the specific claimed method of creating network partitions by requesting and associating unique IP addresses via DHCP?
• A core issue of claim scope will be one of functional mapping: for the three monitoring patents ('010, '930, '750), does the functionality of a modern Baseboard Management Controller (BMC) equate to the claimed "management appliance" or "alarm card" that specifically "monitor[s] web pages" generated by the host, or is there a fundamental mismatch in the specific technical operation being monitored?