DigitalDoors Inc v. Centennial Bank

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigitalDoors, Inc. (Florida)
  • Defendant: Centennial Bank (Arkansas) and Happy State Bank (Texas)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:24-cv-00779, E.D. Tex., 09/25/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains physical branch locations, employs staff, and purposefully directs its business activities, including the allegedly infringing services, to customers within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s data backup and disaster recovery systems, which are compliant with or equivalent to the financial industry's "Sheltered Harbor" standard, infringe four patents related to methods for granularly identifying, extracting, storing, and managing sensitive data in a distributed computing environment.
• Technical Context: The technology relates to data security and survivability, particularly for protecting critical financial account information from catastrophic events like cyberattacks to ensure operational continuity.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or other dispositive events concerning the patents-in-suit.

Case Timeline

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

U.S. Patent No. 9,015,301 - Information Infrastructure Management Tools with Extractor, Secure Storage, Content Analysis and Classification and Method Therefor

• Patent Identification: U.S. Patent No. 9,015,301, issued April 21, 2015.
• The Invention Explained:
  • Problem Addressed: The patent describes a business environment with open, distributed computer networks that are vulnerable to security breaches. It notes deficiencies in prior art methods for managing and securing sensitive information, stating they were inefficient, struggled with unstructured data, and focused on securing entire files rather than the specific sensitive content within them (’301 Patent, col. 1:31-2:27).
  • The Patented Solution: The invention proposes a method of using various "categorical filters" (such as content-based, contextual, and taxonomic filters) to automatically identify and process specific, important pieces of data, termed "select content," from a larger data stream. This select content is then stored in a corresponding secure data store. The system associates specific data processes (e.g., copy, archive, extract) with the filtered content and can apply these processes automatically based on time, system conditions, or events (’301 Patent, Abstract; col. 3:20-4:14).
  • Technical Importance: The claimed invention represented a shift from file-level security to content-level security, enabling more granular, flexible, and automated control over sensitive information in a distributed network (Compl. ¶32).
• Key Claims at a Glance:
  • The complaint asserts independent claim 25 (Compl. ¶101).
  • Essential elements of claim 25 include:
    • A method of organizing and processing data in a distributed computing system.
    • Providing a plurality of select content data stores operative with a plurality of designated categorical filters.
    • Activating at least one filter and processing a data input to obtain select content and associated select content.
    • Storing the aggregated select content in a corresponding data store.
    • Associating a data process (e.g., copy, extract, archive) with the activated filter.
    • Applying that data process to a further data input based on the filter's result.
    • Wherein the filter activation can be automatic and based on time, system condition, or an event.

U.S. Patent No. 9,734,169 - Digital Information Infrastructure and Method for Security Designated Data and with Granular Data Stores

• Patent Identification: U.S. Patent No. 9,734,169, issued August 15, 2017.
• The Invention Explained:
  • Problem Addressed: The patent addresses the need to secure sensitive data in distributed systems, particularly in cloud-based environments where data is stored and processed across multiple locations, increasing the attack surface (’169 Patent, col. 1:60-2:16).
  • The Patented Solution: The invention claims a method for a "distributed cloud-based computing system" that provides separate data stores for "security designated data" and "granular data." The system extracts the sensitive data and stores it in secure "select content data stores" with specific access controls. The non-extracted "remainder data" is parsed and stored separately in "granular data stores." Data can only be withdrawn from these stores when the proper access controls are applied (’169 Patent, Abstract).
  • Technical Importance: The technology provides a specific architectural framework for segregating sensitive and non-sensitive data within a cloud environment to enhance security and control access (Compl. ¶29).
• Key Claims at a Glance:
  • The complaint asserts independent claim 1 (Compl. ¶132).
  • Essential elements of claim 1 include:
    • A method of organizing and processing data in a distributed cloud-based computing system.
    • Providing select content data stores, granular data stores, and a cloud-based server, coupled by a communications network.
    • Extracting and storing security-designated data in the select content data stores.
    • Activating a data store to permit access based on access controls.
    • Parsing remainder data not extracted and storing it in the granular data stores.
    • Parsing the remainder data using both random and predetermined algorithms.
    • Withdrawing data from the stores only in the presence of the respective access controls.

U.S. Patent No. 10,182,073 - Information Infrastructure Management Tools with Variable and Configurable Filters and Segmental Data Stores

• Patent Identification: U.S. Patent No. 10,182,073, issued January 15, 2019.
• Technology Synopsis: This patent describes an information infrastructure where data is processed using a plurality of filters. The key inventive concept is the ability to alter or modify these initially configured filters by expanding, contracting, or changing the classification of the content they are designed to identify. This allows the system to dynamically adapt its data processing rules (’073 Patent, Abstract; col. 3:5-13).
• Asserted Claims: Claim 1 (Compl. ¶168).
• Accused Features: The complaint alleges that the accused systems, which implement data protection policies, allow the enterprise to modify those policies (e.g., by changing parameters), which it equates to the claimed step of "altering said respective initially configured filters" (Compl. ¶184-185).

U.S. Patent No. 10,250,639 - Information Infrastructure Management Data Processing Tools for Processing Data Flow with Distribution Controls

• Patent Identification: U.S. Patent No. 10,250,639, issued April 2, 2019.
• Technology Synopsis: This patent discloses a method for "sanitizing" data by extracting sensitive content based on different sensitivity levels and storing it separately from the remainder data. The invention then describes a step of "inferencing" the sanitized data using content, contextual, and taxonomic filters to analyze it without exposing the underlying sensitive information (’639 Patent, Abstract).
• Asserted Claims: Claim 16 (Compl. ¶195).
• Accused Features: The complaint alleges that the accused systems sanitize data by extracting critical financial information for storage in a secure vault. It further alleges that the systems use filters to analyze content, which is mapped to the patent's "inferencing" limitation (Compl. ¶217, ¶220-221).

III. The Accused Instrumentality

• Product Identification: The "Accused Instrumentalities" are identified as the data processing, backup, and disaster recovery systems and methods used by Defendant that are compliant with the "Sheltered Harbor" industry specification, or are functionally equivalent (Compl. ¶98).
• Functionality and Market Context: The complaint alleges that these systems are designed to protect critical customer financial data from catastrophic loss, such as a major cyberattack. Their core function is to extract critical account data, place it in a standardized format, and transfer it to an "ultra secure," "air-gapped," and immutable "data vault" that is physically or logically isolated from the bank's primary production network (Compl. ¶72, ¶79, ¶84). This process is typically performed nightly to ensure an up-to-date, recoverable backup exists. The Sheltered Harbor standard is described as a widely adopted, industry-driven initiative for the U.S. financial sector to ensure market stability and protect consumer confidence (Compl. ¶65, ¶68). The complaint uses Dell's "PowerProtect Cyber Recovery for Sheltered Harbor" solution as a representative example of a compliant system (Compl. ¶74). A diagram from a Dell solution brief illustrates the accused architecture, showing a "Production Environment" connected via a secure, air-gapped replication link to a separate "Data Vault Environment" (Compl. ¶75).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,015,301 Infringement Allegations

U.S. Patent No. 9,734,169 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The primary dispute may center on the meaning of "extracting select content." The patents often describe extracting granular data within a document while leaving the rest. The complaint alleges that the accused systems, which back up entire sets of critical account data, meet this limitation. This raises the question of whether selecting a whole category of data for backup is equivalent to the granular "extraction" described in the patents.
  • Technical Questions: For the ’169 Patent, the complaint alleges the accused systems are "optionally implemented" in the cloud (Compl. ¶135). A potential point of contention is whether Defendant's specific implementation is, in fact, a "cloud-based computing system" as required by the claim, or if it is a conventional on-premises distributed network that falls outside the claim's scope.

V. Key Claim Terms for Construction

• The Term: "select content" (’301 Patent, cl. 25; ’169 Patent, cl. 1)

  • Context and Importance: This term is foundational to the infringement theories. Its construction will determine whether the accused act of backing up entire financial records or datasets can be considered the same as "obtaining said select content." Practitioners may focus on this term because the patents' examples often show granular extraction (e.g., a social security number from a document), whereas the accused systems appear to copy entire datasets designated as "critical."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a high-level definition: "select content which is of interest or importance to the enterprise" (’301 Patent, col. 3:13-15). This could support a reading where an entire dataset deemed "critical" constitutes "select content."
    • Evidence for a Narrower Interpretation: The detailed description and figures often illustrate a process where "select content" is separated from "common text" or "remainder data" within a single source document, implying a more granular process than wholesale data backup (’301 Patent, col. 37:54-38:11; FIG. 4).

• The Term: "categorical filters" (’301 Patent, cl. 25)

  • Context and Importance: The complaint equates the accused systems' "protection policies" with this claim term. The viability of this theory depends on whether a policy that designates an entire class of data (e.g., "critical account data") for backup qualifies as a "categorical filter."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states the "system may operate on a categorical filter" and that "enterprise designated categorical filters are used to store select content relative to the category" (’301 Patent, col. 13:51-52; col. 12:2-4). This language could support the idea that a filter can operate on a broad category of data.
    • Evidence for a Narrower Interpretation: The specification describes these filters as including "content-based filters, contextual filters and taxonomic classification filters," which suggests a multi-faceted and analytical filtering process beyond simply identifying a dataset by its title or location (’301 Patent, col. 13:34-37).

VI. Other Allegations

• Indirect Infringement: The complaint does not plead separate counts for induced or contributory infringement, focusing its counts on allegations of direct infringement by the Defendant.
• Willful Infringement: The complaint alleges willful infringement based on Defendant’s purported knowledge of the patents-in-suit since at least the date of service of the complaint. It also alleges an alternative, earlier date of knowledge based on Defendant’s alleged awareness of prior lawsuits filed by DigitalDoors against competitor financial institutions. The complaint further alleges willful blindness, asserting that Defendant has a policy or practice of not reviewing third-party patents (Compl. ¶229-230).

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

• A core issue will be one of definitional scope: can the term “extracting said select content,” which is described in the patents with examples of granular data element removal, be construed to cover the accused systems' function of backing up entire datasets of "critical account information" into a separate disaster recovery vault?
• A related and central legal question will be one of technical mapping: do the accused systems' high-level "protection policies" function as the multi-faceted "categorical filters" required by the claims, or is there a fundamental mismatch in the complexity and operation of the filtering technology?
• For certain claims, a key factual question will be one of architecture: does the Defendant's specific data recovery infrastructure meet the "cloud-based computing system" limitation of the ’169 patent, or is it an on-premises system that falls outside the claim's scope?