DCT
2:24-cv-00760
ServStor Tech LLC v. MediaTek Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: ServStor Technologies LLC (Texas)
- Defendant: MediaTek Inc. (Taiwan)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP
- Case Identification: 2:24-cv-00760, E.D. Tex., 09/19/2024
- Venue Allegations: Plaintiff alleges venue is 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 MediaTek MT7620 system-on-a-chip (SoC) infringes four patents related to methods for routing data, managing network communications with split identifiers, and accelerating packet processing.
- Technical Context: The technology concerns protocols and hardware for managing data transfer in networked environments, particularly for disaggregated storage systems where components like storage and processing are separated and connected via a network.
- Key Procedural History: The complaint does not allege any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2002-11-12 | Earliest Priority Date for ’773, ’476, ’814, and ’473 Patents |
| 2009-10-13 | U.S. Patent No. 7,602,773 Issues |
| 2010-01-05 | U.S. Patent No. 7,643,476 Issues |
| 2010-03-30 | U.S. Patent No. 7,688,814 Issues |
| 2010-06-22 | U.S. Patent No. 7,742,473 Issues |
| 2024-09-19 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,602,773 - "Transferring Data to a Target Device"
The Invention Explained
- Problem Addressed: The patent addresses the complexity and overhead associated with using layered communication protocols (like TCP/IP) to transmit data between devices, especially in networked systems with physically separate or "disaggregated" components. (’773 Patent, col. 1:13-21, col. 2:50-54).
- The Patented Solution: The invention proposes a communication protocol that facilitates direct data transfers between two devices, prompted by a command from a third device. It uses packets containing both a command and specific addresses for storage locations on different network elements, enabling peer-to-peer communication even across Network Address Translation (NAT) bridges. (’773 Patent, Abstract; col. 3:3-23). The concept of "packet atomicity" is introduced, where each packet contains a self-sufficient command that can be executed without reference to prior or subsequent packets. (’773 Patent, col. 2:64-3:2).
- Technical Importance: This approach is designed to improve performance and simplify communication in masterless, peer-to-peer networks, which is relevant for architectures like network-attached storage (NAS) and other distributed systems. (’773 Patent, col. 2:50-54).
Key Claims at a Glance
- The complaint asserts independent claim 11. (Compl. ¶19).
- Claim 11 requires an apparatus comprising:
- a network interface to communicatively couple the apparatus to a network;
- storage having a storage location; and
- a controller coupled to the network interface and storage, configured to:
- receive, from a first device via the network interface, a first packet including a command, a first address corresponding to the apparatus's storage location, and a second address corresponding to a storage location of a second device; and
- transmit, to the second device via the network interface, a second packet to effect a transfer of data between the apparatus's storage location and the second device's storage location based on the command.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,643,476 - "Communication Protocols, Systems and Methods"
The Invention Explained
- Problem Addressed: As with the related ’773 Patent, this invention seeks to reduce the overhead of traditional layered network protocols for data transfer in disaggregated systems. (’476 Patent, col. 1:17-25).
- The Patented Solution: The patent discloses a method of addressing data using a "split identifier" (SID). This identifier is divided into at least two segments: one segment, located in an outer (encapsulating) packet, identifies a broader storage area (e.g., a device or partition via its IP address), while a second segment, located in an inner (encapsulated) packet, identifies a specific storage block within that area (e.g., a logical block address or LBA). (’476 Patent, Abstract; col. 6:44-59; Fig. 2). This structure allows for direct and granular addressing of data across a network.
- Technical Importance: The split-ID mechanism allows for more efficient routing and processing of storage-related commands by enabling a device to determine both the target storage area and the specific data block from a single nested packet structure. (’476 Patent, col. 7:45-54).
Key Claims at a Glance
- The complaint asserts independent claim 11. (Compl. ¶29).
- Claim 11 requires an apparatus comprising:
- a controller configured to:
- generate a first packet with a control portion having a first identifier segment of a split identifier, corresponding to a storage area of a target device;
- generate a second packet with a control portion having a second identifier segment of the split identifier, corresponding to a storage block of the storage area; and
- encapsulate the second packet within the first packet.
- a network interface coupled to the controller and configured to transmit the first packet, with the encapsulated second packet, to the target device across the network.
- a controller configured to:
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,688,814 - "Methods of Conveying Information Using Fixed Sized Packets"
- Technology Synopsis: This patent addresses efficient data transfer between devices that may have different native data block sizes. The invention describes generating a first packet with a data portion sized to match the target device's native block size (which is smaller than the source's) and encapsulating it within a second packet for transmission, using a split identifier to maintain addressing context. (’814 Patent, Abstract; Compl. ¶40).
- Asserted Claims: Independent claim 11. (Compl. ¶39).
- Accused Features: The complaint alleges the MediaTek MT7620’s controller is configured to generate and encapsulate packets where the data portion size is managed relative to the native block sizes of the communicating devices. (Compl. ¶40).
U.S. Patent No. 7,742,473 - "Accelerator Module"
- Technology Synopsis: This patent discloses a "stateless storage accelerator module" designed to speed up network storage operations. The module uses filter functions to examine incoming packets and, based on a stored "destination context" associated with the packet's address, can bypass portions of the standard communication stack to pass the packet directly to the relevant application. (’473 Patent, Abstract; Compl. ¶50).
- Asserted Claims: Independent claim 13. (Compl. ¶49).
- Accused Features: The MediaTek MT7620 is alleged to contain an accelerator module that accesses a destination context based on a packet's address and bypasses a portion of the communication stack to accelerate packet transmission. (Compl. ¶50).
III. The Accused Instrumentality
Product Identification
- The MediaTek MT7620, identified as a microchip, system-on-a-chip (SoC), and/or application-specific integrated circuit (ASIC). (Compl. ¶18).
Functionality and Market Context
- The complaint alleges the MediaTek MT7620 is a "router-on-a-chip" that integrates an 802.11n MAC and baseband, a CPU core, and a 5-port switch. (Compl. ¶20). A datasheet screenshot provided in the complaint indicates the product is designed for applications such as routers and Network Attached Storage (NAS) devices and includes interfaces like USB for accessing external storage. (Compl. p. 5). The complaint asserts that these features enable the MT7620 to perform the functions of a network interface and controller for routing and transferring data packets. (Compl. ¶20).
IV. Analysis of Infringement Allegations
’773 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a network interface configured to communicatively couple the apparatus to a network; | The MediaTek MT7620 comprises a network interface, including an 802.11n MAC/baseband and a 5-port switch, that couples the SoC to a network. | ¶20 | col. 7:4-8 |
| storage having a storage location; | The MediaTek MT7620 comprises storage having a storage location, which can include on-chip memory or externally connected storage via its interfaces. | ¶20 | col. 7:11-14 |
| a controller coupled to the network interface and the storage and configured to receive, from a first device via the network interface, a first packet including a command, a first address that corresponds to the storage location of the apparatus, and a second address that corresponds to a storage location of a second device; | The MT7620's controller is alleged to be configured to receive a first packet containing a command and addresses for two different storage locations (one on the MT7620-based device, one on a second device). | ¶20 | col. 25:40-48 |
| and to transmit, to the second device via the network interface, a second packet to effect a transfer of data between the storage location of the apparatus and the storage location of the second device based at least in part on the command. | The MT7620's controller is alleged to be configured to transmit a second packet to the second device, causing a data transfer between the two specified storage locations based on the received command. | ¶20 | col. 25:48-54 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the packet processing performed by the MT7620, a general-purpose networking SoC, constitutes the specific claimed sequence of receiving a "first packet" with three distinct components (command, first address, second address) that in turn causes the transmission of a "second packet" to "effect a transfer." The analysis may focus on whether standard network protocols processed by the chip can be mapped to this specific claimed functionality.
- Technical Questions: What evidence does the complaint provide that the MT7620 is configured to parse a single incoming packet to identify two distinct storage locations (one local, one remote) and then, based on a command therein, generate a separate outbound packet specifically to initiate a data transfer between those two locations, as opposed to simply forwarding data from a source to a destination? The complaint provides a programming guide screenshot showing settings for IGMP messages, which may be offered as evidence of the chip's ability to process command-like packets. (Compl. p. 6).
’476 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a controller configured to generate a first packet with a control portion having a first identifier segment of a split identifier, the first identifier segment corresponding to a storage area of a target device remotely disposed from the apparatus across a network; | The MT7620 comprises a controller alleged to generate a packet with a control portion containing a first part of a "split identifier," corresponding to a target device's storage area. | ¶30 | col. 6:44-51 |
| to generate a second packet with a control portion having a second identifier segment of the split identifier, the second identifier segment corresponding to a storage block of the storage area; | The controller is alleged to generate a second packet with a control portion containing the second part of the "split identifier," corresponding to a specific storage block. | ¶30 | col. 6:51-54 |
| to encapsulate the second packet within the first packet; | The controller is alleged to be configured to encapsulate the second packet within the first packet. | ¶30 | col. 6:55-56 |
| a network interface coupled to the controller, and configured to transmit the first packet, with the encapsulated second packet, to the target device across the network. | The MT7620 comprises a network interface configured to transmit the resulting nested packet structure to the target device. | ¶30 | col. 8:58-63 |
- Identified Points of Contention:
- Scope Questions: The primary dispute will likely center on the definition of "split identifier." The key question is whether the standard packet structures and addressing schemes (e.g., IP address in an outer header, port number or other data in an inner header) processed by the MT7620 can be construed as the claimed "split identifier" where segments are intentionally placed in encapsulating and encapsulated packets to address a storage area and block, respectively.
- Technical Questions: Does the complaint offer evidence that the MT7620 is specifically configured to generate two distinct packets and then perform the claimed encapsulation step to create the split-ID structure, or does it merely perform standard network-layer encapsulation (e.g., placing a TCP/UDP segment inside an IP packet) that Plaintiff will argue meets the claim limitations?
V. Key Claim Terms for Construction
For the ’773 Patent
- The Term: "a second packet to effect a transfer of data" (Claim 11)
- Context and Importance: The definition of this term is critical to determining the nature of the infringing act. It addresses whether the accused device must send a packet that contains the actual data to be transferred, or merely a command packet that causes the transfer to occur through other means. The complaint alleges the MT7620 transmits a packet "to effect a transfer," mirroring the claim language. (Compl. ¶20).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language "to effect a transfer" does not explicitly require the data to be in the second packet, suggesting a command packet that triggers a separate data flow could suffice.
- Evidence for a Narrower Interpretation: The specification repeatedly describes "TRANSFER" packets that include a "data portion" containing the data block being transferred, which suggests the transfer is effected by the packet that carries the data. (’773 Patent, col. 11:58-12:21).
For the ’476 Patent
- The Term: "split identifier" (Claim 11)
- Context and Importance: This is the central technical concept of the patent. Its construction will determine whether the addressing schemes used by the accused MT7620 fall within the scope of the claims. Practitioners may focus on whether this term requires a purpose-built addressing scheme or can read on the incidental separation of addressing information in standard layered protocols.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests that an IP address can serve as the storage area identifier and a Logical Block Address (LBA) can serve as the storage block identifier, which are standard networking and storage terms. (’476 Patent, col. 8:36-41). An argument could be made that any protocol that separates these standard identifiers into encapsulating and encapsulated packets meets the definition.
- Evidence for a Narrower Interpretation: The patent defines a "split-id packet" as one specifically comprising "an encapsulating and an encapsulated packet where the split-id packet also includes an identifier that is split." (’476 Patent, col. 6:44-48). This may suggest the structure is a defining characteristic, not an incidental result of standard layering. The detailed description of SID packet structures in Figures 1-6 may also support a more limited construction. (’476 Patent, Figs. 1-6).
VI. Other Allegations
Indirect Infringement
- The complaint alleges induced infringement for all patents-in-suit. The basis for this allegation is that Defendant supplies the accused MT7620 products to its customers and end-users along with "instructions on how to operate the infringing technology," allegedly via its website, product literature, and packaging, with the intent to cause direct infringement by those parties. (Compl. ¶¶ 21-23, 31-33, 41-43, 51-53).
Willful Infringement
- The complaint alleges willful infringement. The basis for this claim is a theory of willful blindness, asserting that Defendant "has adopted a policy of not reviewing the patents of others...thereby remaining willfully blind to the Patents-in-Suit at least as early as the issuance of the Patents-in-Suit." (Compl. ¶¶ 22, 32, 42, 52). Knowledge is also alleged as of the date of the complaint, supporting a claim for post-suit willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "split identifier," described in the patents as a specific two-part addressing structure split between nested packets, be construed to cover the conventional separation of addressing information (e.g., IP address and LBA/port number) in standard network protocols as handled by the accused general-purpose SoC?
- A key evidentiary question will be one of functional mapping: does the complaint provide sufficient technical evidence to demonstrate that the accused MT7620's processing of network traffic performs the specific, multi-step functions required by the claims—such as generating and encapsulating packets to create a split ID, or bypassing a communication stack based on a "destination context"—or is there a fundamental mismatch between the patented methods and the actual operation of the accused device?