DCT

2:24-cv-00021

Valtrus Innovations Ltd v. SAP America Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00021, E.D. Tex., 07/29/2024
  • Venue Allegations: Venue is alleged based on Defendant SAP America, Inc. maintaining a regular and established place of business in Plano, Texas, within the district, and over SAP, SE as a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s SAP HANA products and related enterprise computing systems infringe seven patents related to foundational technologies such as multi-processor cache coherency, fault-tolerant messaging, data redundancy, and dynamic resource partitioning.
  • Technical Context: The technologies at issue concern high-performance, high-availability computing, which is critical for enterprise-level database management, disaster recovery, and large-scale data processing systems.
  • Key Procedural History: The complaint alleges that Defendant was on notice of its infringement of several patents-in-suit well before the complaint was filed, with notice dates as early as March 4, 2022, for two of the patents. These allegations of pre-suit knowledge form the basis for claims of willful infringement.

Case Timeline

Date Event
2000-10-31 U.S. Patent No. 6,889,244 Priority Date
2001-01-31 U.S. Patent No. 6,691,139 Priority Date
2001-09-28 U.S. Patent No. 6,823,409 Priority Date
2002-03-06 U.S. Patent No. 6,871,264 Priority Date
2003-06-06 U.S. Patent No. 7,152,182 Priority Date
2003-07-25 U.S. Patent No. 7,936,738 Priority Date
2004-02-10 U.S. Patent No. 6,691,139 Issue Date
2004-06-14 U.S. Patent No. 7,313,575 Priority Date
2004-11-23 U.S. Patent No. 6,823,409 Issue Date
2005-03-22 U.S. Patent No. 6,871,264 Issue Date
2005-05-03 U.S. Patent No. 6,889,244 Issue Date
2006-12-19 U.S. Patent No. 7,152,182 Issue Date
2007-12-25 U.S. Patent No. 7,313,575 Issue Date
2011-05-03 U.S. Patent No. 7,936,738 Issue Date
2022-03-04 Alleged notice of infringement for the ’409 and ’264 Patents
2023-11-14 Alleged notice of infringement for the ’182, ’575, and ’738 Patents
2024-07-29 Complaint Filing Date

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

U.S. Patent No. 6,823,409 - "Coherency Control Module for Maintaining Cache Coherency in a Multi-Processor-Bus System," issued November 23, 2004

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of maintaining data consistency (coherency) across separate caches in a multi-processor, multi-bus computer system, which can create performance bottlenecks due to the need for extensive "snoop cycles" to check other caches for modified data (U.S. Patent No. 6,823,409, col. 3:23-34).
  • The Patented Solution: The invention proposes a dedicated "tag control (TCON) module" that acts as a snoop filter to manage memory access requests efficiently. This module uses a request queue, an active snoop queue (ASQ), and an interface to a tag RAM to minimize the number of required snoop cycles, thereby improving system performance by reducing latency in obtaining cache state information (’409 Patent, col. 5:11-20; Fig. 2).
  • Technical Importance: This technology aimed to increase the efficiency of high-performance servers by reducing the communication overhead required to maintain cache coherence, a critical problem as the number of processors in systems grew (’409 Patent, col. 3:19-22).

Key Claims at a Glance

  • The complaint asserts independent claim 10 (Compl. ¶34).
  • Essential elements of claim 10 include:
    • A coherency control module for controlling access to cache memory.
    • A "request module" to receive and order requests from multiple buses.
    • An "active snoop queue (ASQ) module" to maintain a list of currently processing requests and prevent simultaneous access to a single cache address.
    • A "static RAM interface module" to access an address look-up table for data in the cache memory.
  • The complaint reserves the right to assert other claims (Compl. ¶34).

U.S. Patent No. 6,889,244 - "Method and Apparatus for Passing Messages Using a Fault Tolerant Storage System," issued May 3, 2005

The Invention Explained

  • Problem Addressed: The patent identifies the high cost and complexity of building reliable distributed applications, which traditionally required two separate fault-tolerant systems: one for network messaging and another for data storage. Messaging over transient network media provides no mechanism for retransmitting a message if the receiving application fails after receipt (’244 Patent, col. 3:55-4:7).
  • The Patented Solution: The invention proposes a unified system where the interconnection fabric of a Fault Tolerant Storage System (FTSS) is used to carry both file I/O and application messages. By incorporating "message agents" within the FTSS itself, messages are stored in persistent, reliable media as part of the transmission process, allowing applications to recover lost messages after a failure and enhancing overall system reliability (’244 Patent, Abstract; col. 5:8-24).
  • Technical Importance: This approach sought to reduce the cost and complexity of high-availability systems by leveraging the inherent reliability of an FTSS for messaging, thereby eliminating the need for a separate, redundant messaging network (’244 Patent, col. 5:35-43).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶41).
  • Essential elements of claim 1 include the steps of:
    • Transmitting a message from a first node to a "communication agent in the FTSS".
    • Storing the message in a data structure within the "highly reliable fault-tolerant storage media of the FTSS".
    • Processing the message "at the FTSS" according to a messaging paradigm.
    • Transmitting the message "from the FTSS" to a second node.
  • The complaint reserves the right to assert other claims (Compl. ¶41).

U.S. Patent No. 7,152,182 - "Data Redundancy System and Method," issued December 19, 2006

  • Technology Synopsis: The patent describes a multi-layered data redundancy architecture for disaster recovery. It discloses a primary storage facility with a first redundancy appliance and a second "shadow" appliance, mirrored by a secondary (remote) storage facility that also contains a third appliance and a fourth "shadow" appliance, creating a highly fault-tolerant system (’182 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶45).
  • Accused Features: SAP's data redundancy and system replication functionalities, which are alleged to create primary and secondary storage facilities, each with shadowing appliances as claimed (Compl. ¶45).

U.S. Patent No. 7,313,575 - "Data Services Handler," issued December 25, 2007

  • Technology Synopsis: The patent relates to a system for real-time data integration. It describes a "data services handler" that includes a "real time information director" (RTID) which transforms data from multiple sources based on "polymorphic meta data" that defines security models and data integrity rules (’575 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶53).
  • Accused Features: SAP's systems, including SAP Data Services, that enable real-time data transformation and integration from multiple sources (Compl. ¶53).

U.S. Patent No. 6,691,139 - "Recreation of Archives at a Disaster Recovery Site," issued February 10, 2004

  • Technology Synopsis: The patent discloses a bandwidth-efficient method for disaster recovery. Instead of transmitting an entire archive file, the system computes a "delta image" representing the difference between an active file and an archive file, and transmits this much smaller delta image to the remote site for recreation of the full archive (’139 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶60).
  • Accused Features: SAP's system replication features that allegedly use "delta data shipping" to produce a delta image at a primary site for use at a standby site (Compl. ¶60).

U.S. Patent No. 7,936,738 - "Fault Tolerant Systems," issued May 3, 2011

  • Technology Synopsis: The patent describes a method for preserving system state in a message-based communication system to ensure fault tolerance. The method involves selectively storing "context information" from a protocol stack layer within an outgoing message, such that a response message will contain the necessary context to rebuild the layer's state after a failover event (’738 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶64).
  • Accused Features: SAP's systems that use Kafka messages for data streaming, particularly where SAP advertises that events can be consumed by subscribing to a dedicated Kafka topic, allegedly for purposes of maintaining state and enabling notifications (Compl. ¶¶ 64, 66).

U.S. Patent No. 6,871,264 - "System and Method for Dynamic Processor Core and Cache Partitioning on Large-Scale Multithreaded, Multiprocessor Integrated Circuits," issued March 22, 2005

  • Technology Synopsis: The patent addresses dynamic resource allocation in multi-processor integrated circuits. It describes a system with an "allocation controller" that dynamically assigns allocable blocks of cache memory to different processors on the chip, allowing resources to be shifted to optimize system performance for critical tasks (’264 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶72).
  • Accused Features: SAP's use of multi-processor integrated circuits, such as AMD EPYC processors, which are alleged to contain the claimed components for dynamic resource partitioning (Compl. ¶¶ 72, 75).

III. The Accused Instrumentality

Product Identification

The primary accused instrumentalities are the "SAP HANA products" (Compl. ¶34). The complaint also broadly accuses hardware and software that use AMD processors with "Zen 2" and "Zen 3" architectures, such as AMD EPYC processors (Compl. ¶¶ 37, 75).

Functionality and Market Context

The complaint alleges that the accused SAP HANA products are advertised as providing "high-performance solutions" with "scalability, availability, reliability, performance, and capacity" (Compl. ¶36). The infringement allegations target the underlying architecture of these systems, including how they manage memory access in multi-core processors (Compl. ¶37), handle messaging via fault-tolerant storage (Compl. ¶41), implement data redundancy for high availability (Compl. ¶45), and partition processor resources (Compl. ¶75).
No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references exemplary claim chart exhibits for each asserted patent; however, these exhibits were not filed with the complaint. The infringement theories are therefore summarized based on the narrative allegations.

’409 Patent Infringement Allegations

The complaint alleges that SAP HANA products, particularly those utilizing multi-core processors such as AMD EPYC processors, infringe at least claim 10 (Compl. ¶¶ 34, 37). The infringement theory suggests that the processor's internal architecture for managing concurrent access to shared cache memory from multiple processor cores embodies the claimed "coherency control module" (Compl. ¶34). The complaint alleges that these systems perform "maintenance of ordering of requests from multiple cores," which it maps to the claimed "request module", and prevent "multiple simultaneous access to a single address in the cache," which it maps to the "active snoop queue (ASQ) module" (Compl. ¶37).

  • Identified Points of Contention:
    • Scope Questions: A primary question may be whether the integrated memory controller of a general-purpose CPU can be said to contain the distinct "request module", "active snoop queue module", and "static RAM interface module" required by the claim, or if these claimed modules represent a specific architecture not present in the accused processors.
    • Technical Questions: The complaint does not specify how the accused processors implement the claimed "active snoop queue." The court may need to consider what technical evidence distinguishes the accused functionality from generic memory arbitration and access control common to all modern multi-core processors.

’244 Patent Infringement Allegations

The complaint alleges that SAP's products directly infringe at least claim 1 by providing capabilities to transmit, store, and process messages using a fault tolerant storage system (FTSS) (Compl. ¶41). The theory is that SAP's system architecture uses its FTSS not merely for persistent data storage, but as an active component in the messaging pathway between different software applications or system nodes, thereby practicing all steps of the claimed method (Compl. ¶41).

  • Identified Points of Contention:
    • Scope Questions: A key dispute may arise over the meaning of "communication agent in the FTSS" and "processing the message at the FTSS." The analysis may turn on whether SAP's messaging agents are software components that execute within the FTSS hardware/firmware environment, or if they are application-level components that merely use the FTSS as a storage endpoint.
    • Technical Questions: The complaint does not provide detail on the specific accused "communication agent" or how it is integrated with the FTSS. The central technical question will be whether the accused systems use the FTSS and its interconnection fabric for message transport, as opposed to using standard network protocols for transport and the FTSS for storage in a "store-and-forward" manner.

V. Key Claim Terms for Construction

Term: "active snoop queue (ASQ) module" (’409 Patent, claim 10)

  • Context and Importance: This term appears to be the central technical element distinguishing the invention from a generic memory controller. The definition of this term will be critical to determining whether the internal logic of the accused AMD processors meets this limitation. Practitioners may focus on this term because its structure and function as described in the patent suggest more than simple access arbitration.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the ASQ's function as including "buffers to maintain a list of current cycles" and to "prevent multiple accesses to the same index simultaneously" (’409 Patent, col. 6:5-9), language that Plaintiff may argue reads on any hardware buffer that tracks active memory transactions.
    • Evidence for a Narrower Interpretation: The patent also describes list structures for managing requests as "two dimensional doubly-linked lists" (’409 Patent, col. 8:28-29; Fig. 4). A defendant may argue that this specific data structure is a required feature of the claimed ASQ module, potentially narrowing the claim scope away from the architecture of a general-purpose CPU.

Term: "communication agent in the FTSS" (’244 Patent, claim 1)

  • Context and Importance: The location specified by "in the FTSS" is dispositive for infringement. If the agent is found to be outside the FTSS (e.g., at the application layer), there can be no direct infringement. Practitioners may focus on this term as it defines the fundamental architecture of the claimed system.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The Abstract states the FTSS "includes several message agents," which Plaintiff may argue means the FTSS as a system includes the agents, regardless of whether the agent's code executes on the storage controller itself or on a tightly integrated host (’244 Patent, Abstract).
    • Evidence for a Narrower Interpretation: Figure 5 of the patent depicts "Messaging Agents" as a block (102) located within the boundary of the FTSS block (44) (’244 Patent, Fig. 5). A defendant may cite this figure as evidence that the inventors conceived of the agent as a component internal to the storage system, separate from external computer systems.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for all asserted patents. The inducement claims are based on allegations that SAP advertises and provides documentation encouraging customers to use the infringing features of its products (e.g., Compl. ¶¶ 36, 66, 74). The contributory infringement claims allege that SAP provides a material part of the claimed inventions that is not a staple article of commerce and is incapable of substantial non-infringing use (e.g., Compl. ¶¶ 37, 75).

Willful Infringement

Willfulness is alleged for all asserted patents, based on alleged pre-suit knowledge for five of the seven patents. The complaint provides specific dates of notice: March 4, 2022, for the ’409 and ’264 patents, and November 14, 2023, for the ’182, ’575, and ’738 patents (Compl. ¶¶ 33, 44, 52, 63, 71). For all patents, willfulness is further alleged based on Defendant’s failure to cease infringement after being notified (Compl. ¶¶ 38, 49, 57, 68, 76).

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

  • A core issue will be one of architectural correspondence: Do the claimed modules and controllers in patents such as the ’409 and ’264 find direct structural counterparts within the highly integrated architecture of general-purpose, multi-core CPUs, or does the complaint map claim limitations onto mere functional descriptions of different underlying hardware?
  • Another central question will be one of system boundaries: For patents like the ’244, does the accused "communication agent" operate in the Fault Tolerant Storage System as claimed, or does it run on an application server that merely uses the FTSS for storage? The resolution of this issue will likely determine whether the accused system architecture falls inside or outside the scope of the claims.
  • A key evidentiary question will be one of operational equivalence: For the method patents asserted (’139, ’738), the case will turn on whether the accused SAP systems perform the specific, ordered steps required by the claims—for instance, does SAP’s replication technology create a "delta image" by "computing a difference" as taught in the ’139 patent, or does it achieve a similar outcome through a technically distinct process?