DCT
2:24-cv-00204
ServStor Tech LLC v. Lenovo Group Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: ServStor Technologies LLC (Texas)
- Defendant: Lenovo Group Limited (China)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP; Truelove Law Firm, PLLC
- Case Identification: 2:24-cv-00204, E.D. Tex., 03/21/2024
- Venue Allegations: Venue is alleged to be proper because Defendant is not a resident of the United States and may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s server products, including its ThinkSystem and Flex System lines, infringe five U.S. patents related to server architecture, remote management, and network-addressable storage.
- Technical Context: The technologies at issue concern methods for improving the density, management, and data accessibility of enterprise-level servers, which are fundamental components of modern data centers.
- Key Procedural History: The complaint alleges Defendant had knowledge of the patents-in-suit based on a series of lawsuits Plaintiff filed against other technology companies beginning in 2022, forming the basis for its willful infringement allegations.
Case Timeline
| Date | Event |
|---|---|
| 2000-12-22 | Priority Date for ’930, ’010, and ’750 Patents |
| 2001-08-20 | Priority Date for ’274 Patent |
| 2002-11-12 | Priority Date for ’271 Patent |
| 2004-05-18 | ’930 Patent Issued |
| 2006-02-14 | ’010 Patent Issued |
| 2007-03-13 | ’274 Patent Issued |
| 2007-12-18 | ’750 Patent Issued |
| 2011-01-11 | ’271 Patent Issued |
| 2024-03-21 | Complaint Filing Date |
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, single-function servers consuming significant physical space and generating excessive heat, largely due to each server requiring its own power supply (’274 Patent, col. 1:12-21).
- The Patented Solution: The invention proposes a computer system architecture where multiple, independent server cards are housed within a single chassis and share a common power supply. Crucially, these server cards are designed to be functionally independent by being "free from any direct communication connection with any inter-card bus," communicating instead through dedicated, external connectors (’274 Patent, col. 2:55-61; Fig. 1). This arrangement aims to increase server density and power efficiency.
- Technical Importance: This architecture provides a method for hardware consolidation in data centers, improving physical density and reducing power consumption compared to deploying numerous individual server boxes.
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶22).
- Claim 1 Essential Elements:
- A computer system comprising a chassis with multiple slots for "planar shaped circuit cards."
- A shroud coupled to the chassis to form an enclosure.
- The plurality of circuit cards are 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 does not explicitly reserve the right to assert dependent claims.
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 a trend toward disaggregating functionality and relying on networked resources, but notes that data storage has lagged because disk access has traditionally been controlled by a host computer's operating system, creating dependency and limiting direct access (’271 Patent, col. 1:15-45).
- The Patented Solution: The invention describes a storage device with partitions that are separately and directly addressable on a network via distinct IP addresses. A "storage element" within the device can receive a request to create a partition, obtain a unique IP address for that new partition from a DHCP server, and associate the partition with a name provided in the request, enabling peer-to-peer access without a central OS intermediary (’271 Patent, col. 4:18-44; Fig. 3).
- Technical Importance: This technology represents a step toward modern network-attached storage (NAS) and storage area networks (SANs), where storage resources are abstracted from specific host computers and made directly available on a network.
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶33).
- Claim 1 Essential Elements:
- An apparatus with a storage medium and a network interface.
- A "storage element" coupled to the medium and interface.
- The storage element is configured to receive a request for a "partition allocation" that includes a "name."
- The storage element is configured to create and allocate a partition based on the request.
- The storage element is configured to obtain an IP address for the partition from a DHCP server.
- The storage element is configured to "associate the name with the IP address."
- The complaint does not explicitly reserve the right to assert dependent claims.
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.
- Technology Synopsis: The patent addresses the loss of diagnostic data when a host computer fails. It discloses a management appliance (e.g., a card) that independently caches status-reporting web pages from the host, ensuring that the last known status of the host is available to an administrator over an out-of-band network connection even if the host CPU has crashed (’010 Patent, Abstract; col. 4:11-41).
- Asserted Claims: The complaint asserts method claim 6 (Compl. ¶43).
- Accused Features: The accused Lenovo servers are alleged to perform a monitoring method using a "management appliance with a microserver" that monitors web pages generated by the host CPU (Compl. ¶44).
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.
- Technology Synopsis: The patent seeks to improve upon static environmental monitors in industrial computers. The invention is an "alarm card" containing a microserver that communicates with the host computer, allowing it to monitor web-based status information and make that information available to a remote administrator via an "out-of-band" network connection (’930 Patent, Abstract; col. 3:4-11). The complaint includes a diagram of the accused system's "Chassis Management Module," showing its dedicated network and management ports (Compl. p. 15).
- Asserted Claims: The complaint asserts method claim 8 (Compl. ¶52).
- Accused Features: The accused servers allegedly perform a monitoring method by providing a remote computer, an administrator computer, a network connection, and an "alarm card with a micro-server" for monitoring web pages (Compl. ¶53).
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.
- Technology Synopsis: Similar to the ’930 Patent, this patent describes enhancing an environmental monitor for an industrial computer. The solution involves an alarm card with a microserver that accesses web-enabled information on the host computer and communicates it over an out-of-band connection, allowing for more flexible and remote monitoring (’750 Patent, Abstract; col. 2:1-14).
- Asserted Claims: The complaint asserts method claim 8 (Compl. ¶61).
- Accused Features: The infringement allegations are nearly identical to those for the ’930 Patent, targeting a monitoring method that uses an "alarm card with a server thereon" (Compl. ¶62).
III. The Accused Instrumentality
Product Identification
- The complaint names "all Lenovo ThinkSystem and Lenovo Flex System servers" (Compl. ¶17). Specific examples cited include the Lenovo Flex System Enterprise Chassis, Lenovo ThinkSystem SN550 Compute Node, Lenovo ThinkSystem SN850 Node, and ThinkSystem SR635 Rack Server (Compl. ¶17).
Functionality and Market Context
- The complaint alleges these products are blade and rack servers used in enterprise computing environments (Compl. ¶17-18). The infringement allegations focus on two key functionalities:
- The physical architecture of blade servers, where multiple compute nodes ("planar shaped circuit cards") are inserted into a single chassis (Compl. ¶23). The complaint includes a product photograph of the Lenovo Flex System Enterprise Chassis to illustrate this modular structure (Compl. p. 7).
- The remote management capabilities, provided by "management modules" and software such as Lenovo XClarity, which allegedly enable provisioning and monitoring of the servers (Compl. ¶17, ¶34). The complaint presents a screenshot of marketing text for "Lenovo XClarity" to support allegations of provisioning and systems management (Compl. p. 9).
IV. Analysis of Infringement Allegations
’274 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a chassis, having a plurality of slots thereon each configured for receiving one of a plurality of planar shaped circuit cards therein; | The Lenovo Flex System Enterprise Chassis is a chassis with a plurality of slots for receiving blade servers. | ¶23 | col. 4:1-4 |
| a shroud coupled to said chassis to form an enclosure about said plurality of planar shaped circuit cards; | The Lenovo Flex System Enterprise Chassis has a shroud that forms an enclosure around the circuit cards. | ¶24 | col. 4:5-7 |
| said plurality of planar shaped circuit cards each configured for providing an independent dedicated server function; | The blade server circuit cards are each configured to provide an independent, dedicated server function. | ¶24 | col. 4:8-10 |
| each of said plurality of planar shaped circuit cards being configured so as to be free from any direct communication connection with any inter-card bus inside said enclosure. | Each blade server is configured to be free from any direct communication connection with any inter-card bus inside the enclosure. | ¶24 | col. 4:11-14 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the term "free from any direct communication connection with any inter-card bus." The infringement analysis will question whether the backplane in the accused Lenovo chassis, which connects the blade servers, facilitates any form of direct inter-card communication (e.g., for management or control) and whether such a connection falls within the scope of the claim's prohibition.
- Technical Questions: What evidence does the complaint provide that the accused blade servers are truly "free from any direct communication" via the backplane? The complaint's assertion is conclusory (Compl. ¶24), and the actual architecture of the Flex System backplane will be a critical factual question for discovery.
’271 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a storage element... configured to receive, via the network interface, a request for a partition allocation, the request including a name; | The Lenovo ThinkSystem SN550's storage element is configured to receive a request for a partition allocation that includes a name, via its network interface. | ¶34 | col. 7:42-45 |
| to create and allocate a partition of the storage medium based at least in part on the request; | The storage element is configured to create and allocate a partition of its storage medium based on the request. | ¶35 | col. 7:46-48 |
| to obtain, from a dynamic host configuration protocol (DHCP) server, an internet protocol (IP) address for the partition of the storage medium; | Upon information and belief, the storage element is configured to obtain an IP address for the partition from a DHCP server. | ¶35 | col. 7:49-52 |
| and to associate the name with the IP address. | Upon information and belief, the storage element is configured to associate the provided name with the obtained IP address. | ¶35 | col. 7:53-54 |
- Identified Points of Contention:
- Technical Questions: The complaint alleges the final, most specific steps of the claim "upon information and belief" (Compl. ¶35). A key question is what evidence exists that the accused Lenovo products, via XClarity or otherwise, perform the precise function of obtaining a unique IP address for a newly created partition from a DHCP server and then associating that specific IP with the user-provided name of the partition, as required by the claim.
V. Key Claim Terms for Construction
For the ’274 Patent:
- The Term: "free from any direct communication connection with any inter-card bus"
- Context and Importance: This term is the central point of novelty claimed over prior art blade systems. The infringement case for the ’274 patent hinges on whether the accused Lenovo chassis meets this negative limitation. Practitioners may focus on this term because blade server systems commonly use a backplane bus for management, power, and sometimes data, creating a factual dispute over the nature of the "connection."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (Plaintiff's likely view): The specification emphasizes creating "unique server cards" that do not have "interference in the communication of signals in and out of other independent dedicated server cards" (col. 2:54-61). This context might support an interpretation that the prohibition applies only to shared data or system buses that would create functional interference, not necessarily to isolated management or power connections.
- Evidence for a Narrower Interpretation (Defendant's likely view): The claim language "any direct communication connection" is absolute. The specification states "no direct communication connections between the cards... via an internal system bus" (col. 2:55-58), which could be interpreted to forbid all forms of signaling between cards over a common bus structure, including for management.
For the ’271 Patent:
- The Term: "storage element"
- Context and Importance: The claim requires a single "storage element" to perform a series of complex, network-aware functions. The definition of this term is critical to determining whether the accused functionality, which may be distributed across hardware controllers and management software (like XClarity), can be mapped to this single claim element.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (Plaintiff's likely view): The patent does not provide an explicit definition for "storage element," which may allow for a functional interpretation where the term covers any combination of hardware and software that collectively performs the recited steps of receiving requests, creating partitions, and handling IP addresses.
- Evidence for a Narrower Interpretation (Defendant's likely view): The term is used as a discrete component in a list of apparatus components ("a storage medium," "a network interface," and "a storage element") (’271 Patent, col. 7:36-40). This structure may support an argument that it must be a specific, identifiable hardware or firmware component, not a disaggregated system of server software and remote management tools.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement for all five patents, stating that Lenovo provides customers with infringing products along with instructions on how to use them in an infringing manner through "website, product literature and packaging, and other publications" (e.g., Compl. ¶37-38, ¶47, ¶56, ¶65).
- Willful Infringement: Willfulness is alleged for all patents based on Lenovo's purported knowledge of the patents-in-suit. This knowledge is not alleged to come from direct contact, but rather from ServStor's prior infringement lawsuits against Lenovo's "direct competitors" (Compl. ¶17, fn. 1). The complaint asserts that, at a minimum, Lenovo was "willfully blind" to its infringement (e.g., Compl. ¶18, ¶37).
VII. Analyst’s Conclusion: Key Questions for the Case
- Architectural Reality vs. Claim Language: A core issue for the ’274 patent will be one of technical and definitional scope. The case will likely turn on a factual determination of what, if any, communication occurs between blades over the accused Lenovo Flex System backplane, and a legal determination of whether that communication constitutes a "direct communication connection with any inter-card bus" as prohibited by the claim.
- Evidentiary Sufficiency for a Complex Method: For the ’271 patent and the related management patents (’010, ’930, ’750), a key question will be evidentiary. Can the plaintiff prove, beyond the "information and belief" pleading, that the accused Lenovo servers and their associated management software (e.g., XClarity) actually perform the specific, multi-step methods recited in the claims, particularly the nuanced interactions with DHCP and the association of names with IP-addressed partitions?
- The Standard for Willfulness: A significant legal question will be whether knowledge of lawsuits against competitors is sufficient to establish the "subjective willfulness" required for enhanced damages under the Halo standard, or if the court will require evidence of more direct knowledge or egregious conduct.