ServStor Tech LLC v. Inventec Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ServStor Technologies LLC (Texas)
  • Defendant: Inventec Corporation (Taiwan)
  • Plaintiff’s Counsel: Fabricant LLP; Rubino IP; Truelove Law Firm, PLLC
• Case Identification: 2:23-cv-00184, E.D. Tex., 04/21/2023
• Venue Allegations: Venue is alleged to be proper because Defendant is not a resident of the United States and may therefore be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s servers, server racks, and related data center hardware infringe five U.S. patents concerning server architecture, remote management, and network-addressable storage partitioning.
• Technical Context: The patents address foundational technologies for data center efficiency, including high-density server designs, remote out-of-band management, and the virtualization of storage resources over a network.
• Key Procedural History: The complaint alleges Defendant had pre-suit knowledge of the patents-in-suit based on a series of infringement lawsuits Plaintiff filed against Defendant's competitors beginning in 2022, a fact which may be material to the allegations of willful infringement.

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 that independent, dedicated servers, common in data centers, consume excessive physical space and generate significant heat, largely because each server requires its own power supply (’274 Patent, col. 1:12-20).
• The Patented Solution: The invention proposes a single computer chassis that houses multiple "planar shaped circuit cards," each acting as an independent server. These cards are installed in standard expansion slots but only draw power from a shared supply; they are configured to be "free from any direct communication connection" over an internal system bus. Instead, each server card communicates externally through its own dedicated port, enabling a dense, power-efficient server architecture. (’274 Patent, col. 2:27-39, 2:54-61).
• Technical Importance: This design allows for a higher density of servers in a rack while reducing the heat and space footprint, a concept foundational to modern blade server systems and hyperscale data centers (’274 Patent, col. 1:49-53).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶22).
• The essential elements of independent claim 1 are:
  • A computer system with a chassis and a shroud forming an enclosure.
  • The chassis has a plurality of slots for receiving planar circuit cards.
  • A plurality of planar circuit cards, each configured to provide an "independent dedicated server function."
  • A configuration where each card is "free from any direct communication connection with any inter-card bus inside said enclosure."
• The complaint alleges infringement of "one or more claims," reserving the right to assert others (Compl. ¶21).

U.S. Patent No. 7,870,271 - "Disk Drive Partitioning Methods and Apparatus," issued January 11, 2011

The Invention Explained

• Problem Addressed: The patent notes that conventional disk access is controlled by a central operating system (OS), creating a dependency that limits direct, flexible network access to storage and hinders the use of storage in disaggregated computing environments (’271 Patent, col. 1:39-54).
• The Patented Solution: The invention discloses a storage apparatus where individual partitions can be dynamically created and assigned their own unique IP addresses, for instance by obtaining them from a DHCP server. This allows any device on the network to access a specific storage partition directly on a peer-to-peer basis, bypassing the traditional OS-mediated access path. (’271 Patent, col. 2:59-65; col. 4:30-35).
• Technical Importance: This approach enables network-addressable storage at a granular, sub-drive level, a core concept behind modern Storage Area Networks (SANs) and Network Attached Storage (NAS) where storage is virtualized and provisioned as a network resource (’271 Patent, col. 1:16-24).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶32).
• The essential elements of independent claim 1 are:
  • An apparatus with a storage medium, a network interface, and a "storage element."
  • The storage element is configured to receive a network request for a partition allocation that includes a "name."
  • It then creates a partition on the storage medium based on the request.
  • It obtains a unique IP address for that new partition from a DHCP server.
  • It associates the provided "name" with the obtained IP address.
• The complaint alleges infringement of "one or more claims," reserving the right to assert others (Compl. ¶31).

Multi-Patent Capsule: 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

• Technology Synopsis: The patent addresses the loss of diagnostic information when a host computer crashes. The invention is a management appliance, such as an alarm card, that periodically caches status-reporting web pages from the host computer, making a record of the host's last known state available for remote analysis via an out-of-band network connection even after a crash. (’010 Patent, Abstract; col. 4:11-23).
• Asserted Claims: At least method claim 6 is asserted (Compl. ¶41).
• Accused Features: The complaint accuses remote management features of Inventec's Seadra server, which allegedly uses a Baseboard Management Controller (BMC) to monitor the host and report status information over a dedicated network connection (Compl. ¶42; p. 11, fn. 2).

Multi-Patent Capsule: 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

• Technology Synopsis: This patent aims to solve the problem of inflexibility in hardware-based environmental monitors. The solution is an alarm card equipped with its own microserver that communicates with a software "agent" on the host computer, allowing monitoring parameters to be reconfigured remotely via the network without physical access to the hardware. (’930 Patent, Abstract; col. 3:13-24).
• Asserted Claims: At least method claim 8 is asserted (Compl. ¶50).
• Accused Features: The infringement allegations target the remote monitoring and management capabilities of the Seadra server, specifically its use of a BMC to monitor various computer statuses that can be configured remotely (Compl. ¶51; p. 13, fn. 3).

Multi-Patent Capsule: 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

• Technology Synopsis: Related to the ’930 patent, this invention also describes an enhanced environmental monitoring system. It focuses on an alarm card with an integrated server capable of handling web-based content and communicating via an out-of-band network connection, enabling remote monitoring and management of the host computer. (’750 Patent, Abstract; col. 5:1-17).
• Asserted Claims: At least method claim 8 is asserted (Compl. ¶59).
• Accused Features: The allegations again point to the Seadra server's remote management system, which allegedly uses an alarm card with an onboard server (the BMC) to monitor web-based status information from the host CPU and report it externally (Compl. ¶60; p. 15, fn. 4).

III. The Accused Instrumentality

Product Identification

The complaint names a broad range of Inventec products, including servers (e.g., Golduck K880G6, Seadra), storage elements (e.g., U30G4), server racks (e.g., A30G3), and accessory cards. The infringement narrative specifically exemplifies the "A30G3 server rack" and the "Seadra server." (Compl. ¶¶ 17, 23, 33).

Functionality and Market Context

The accused products are described as enterprise-grade computer and server equipment sold in the United States (Compl. ¶2). The complaint alleges that these products possess the specific technical capabilities targeted by the patents-in-suit. For example, the A30G3 server rack is alleged to be a chassis system for housing multiple circuit cards (Compl. ¶23). The Seadra server is alleged to contain a storage element that creates and allocates network-addressable partitions and a management module for remote monitoring (Compl. ¶¶ 33, 42). The complaint provides a table from an Inventec product page for the Seadra server, which lists "System Management" being handled by a "Dedicated 1x 100M/1GbE Base-T (AST2500)" (Compl. p. 11, fn. 2). Inventec is positioned as a "leading manufacturer and seller" of such equipment, suggesting the products have significant commercial presence (Compl. ¶2).

IV. Analysis of Infringement Allegations

’274 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The infringement analysis for the ’274 patent may turn on the negative limitation "free from any direct communication connection with any inter-card bus." The question for the court will be whether the backplane in the accused A30G3 server rack has any bus structure that could be construed as an "inter-card bus," even if it is a low-bandwidth management or sideband bus not used for primary server functions.

’271 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: The infringement allegations for the ’271 patent are made "upon information and belief." A key question will be evidentiary: what proof will be presented to demonstrate that the accused Seadra server's "storage element" actually performs the specific, sequential steps of receiving a named request, creating a partition, obtaining a unique IP address via DHCP for that partition, and associating the name with the IP, as required by the claim?

V. Key Claim Terms for Construction

Term: "free from any direct communication connection" (’274 Patent, Claim 1)

• Context and Importance: This negative limitation is central to distinguishing the invention from prior art systems with integrated backplanes. Its construction is critical; a broad reading may favor the patentee, while a narrow, literal reading may favor the defendant if any inter-card signaling path exists.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent’s objective is to solve space and heat issues by eliminating the need for full-featured, communicative backplanes. The specification states this allows for "insertion of a new server card without the need to make changes to the system software," suggesting the focus is on avoiding functional data buses, not necessarily every single electrical trace (’274 Patent, col. 2:54-61).
  • Evidence for a Narrower Interpretation: The use of the word "any" could be interpreted strictly to mean the absence of any electrical path for communication between cards on the backplane, aside from shared power and ground. The claim language itself does not qualify the type of "communication connection" that must be absent, which may support a very restrictive definition (’274 Patent, col. 4:3-4).

Term: "storage element" (’271 Patent, Claim 1)

• Context and Importance: Claim 1 requires this single "storage element" to perform a series of intelligent, network-aware actions. The case may turn on whether the accused products contain a single, identifiable component that performs all recited functions, or if these tasks are distributed across hardware and software in a way that does not meet the claim’s structural and functional requirements.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent describes "elements" on the network as "peers" and notes that the required functionality "could be designed into the devices," which may support a construction where the "storage element" is a logical or software-defined entity, rather than a single, discrete hardware component (’271 Patent, col. 3:32-34, 4:5-10).
  • Evidence for a Narrower Interpretation: The claims and specification consistently refer to "a storage element" in the singular, which is configured to perform multiple steps. This could support an interpretation that a single, cohesive module (e.g., a specific controller or firmware instance) must be responsible for all the recited functions, rather than a loose confederation of the host CPU, OS drivers, and network interface (’271 Patent, col. 9:39-40).

VI. Other Allegations

Indirect Infringement

The complaint alleges that Inventec induces infringement by providing the accused products to customers and end-users with the knowledge and intent that they will be used in a manner that directly infringes the patents-in-suit. For the ’274 patent, this is using the chassis to house multiple server cards; for the other patents, this is using the remote management and storage partitioning features. (Compl. ¶¶ 24, 34, 43, 52, 61).

Willful Infringement

Willfulness is alleged for all counts. The complaint asserts that Inventec had knowledge of the patents-in-suit "at least as of the filing of suits against their direct competitors" in 2022 and subsequently "remained willfully blind to its infringement" (Compl. ¶17, fn. 1). This alleged pre-suit knowledge forms the primary basis for the claim of willful infringement.

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

• A core issue will be one of structural scope: For the ’274 patent, can the negative limitation "free from any direct communication connection" be met by a modern server backplane that may contain ancillary management or sideband buses, or does the term require absolute electrical isolation between cards?
• A key evidentiary question will be one of functional mapping: The complaint makes allegations regarding complex, multi-step methods "upon information and belief." The case will likely turn on whether discovery produces evidence that the accused servers' storage systems and management controllers perform the specific, ordered functions recited in the claims of the ’271, ’010, ’930, and ’750 patents, and whether those functions can be attributed to a single "storage element" or "alarm card" as claimed.
• A central legal question will concern willfulness and knowledge: The court will need to assess whether knowledge of patents being asserted against industry competitors is sufficient to establish the "knowledge of the patent and knowledge of infringement" required for claims of indirect and willful infringement, or if more direct notice to the defendant is required.