DCT
2:25-cv-00081
Valtrus Innovations Ltd v. Home Depot Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Valtrus Innovations Ltd. and Key Patent Innovations Ltd. (Ireland)
- Defendant: The Home Depot, Inc. and Home Depot U.S.A., Inc. (Delaware)
- Plaintiff’s Counsel: Fabricant LLP
- Case Identification: 2:25-cv-00081, E.D. Tex., 01/27/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendants operate physical retail stores and fulfillment centers within the district, which are integrated with the accused online e-commerce platform that targets and serves customers residing in the district.
- Core Dispute: Plaintiff alleges that Defendant’s backend IT and cloud infrastructure, which utilizes technologies such as Apache Hadoop, Kubernetes, and Google Cloud Platform, infringes five patents related to data security, grid computing, network load balancing, and storage performance monitoring.
- Technical Context: The technologies at issue are foundational elements of large-scale, distributed computing systems used for data storage, application deployment, and network traffic management in modern enterprise IT and cloud environments.
- Key Procedural History: The complaint alleges that Plaintiff sent multiple rounds of correspondence to Defendant regarding infringement of the patents-in-suit, beginning in April 2022 and continuing through February 2024, to which Defendant has not responded.
Case Timeline
| Date | Event |
|---|---|
| 2000-10-13 | Earliest Priority Date (’326 Patent) |
| 2000-11-27 | Earliest Priority Date (’597 Patent) |
| 2001-09-27 | Earliest Priority Date (’832 Patent) |
| 2006-06-27 | ’597 Patent Issued |
| 2006-09-12 | ’326 Patent Issued |
| 2006-10-10 | ’832 Patent Issued |
| 2006-12-27 | Earliest Priority Date (’332 Patent) |
| 2008-05-13 | Earliest Priority Date (’686 Patent) |
| 2009-12-29 | ’332 Patent Issued |
| 2011-03-08 | ’686 Patent Issued |
| 2015-01-01 | Alleged first use of Apache Kafka/Cassandra (approx.) |
| 2016-01-01 | Alleged first use of Google Cloud Platform (approx.) |
| 2017-01-01 | Alleged first use of HDFS (approx.) |
| 2019-01-01 | Alleged first use of Kubernetes (approx.) |
| 2022-04-11 | Alleged first pre-suit notice of infringement |
| 2025-01-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,904,686 - “Data Security For Use With A File System”
The Invention Explained
- Problem Addressed: The patent addresses the problem of unauthorized data copying from storage devices, noting that individuals can bypass application-level security by directly accessing a file's constituent data blocks on a disk using its index node (inode) information (’686 Patent, col. 1:25-34).
- The Patented Solution: The invention proposes a file system-level security method where a "block distribution engine" intercepts file system requests. This engine applies a "mapping function" to the standard data block numbers listed in a file's inode to generate new, algorithm-specific block numbers. Data is stored at these new, mapped locations, rendering the file's contents inaccessible or incoherent to anyone trying to read the blocks directly without the specific mapping function provided by the engine (’686 Patent, Abstract; col. 2:5-14; Fig. 1).
- Technical Importance: This approach provides data security at the file system layer, making it transparent to applications while aiming to prevent reconstruction of files from raw disk access.
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶41).
- Claim 1 requires a method comprising:
- applying a mapping function to data block numbers that are associated with a file, wherein the data block numbers are contained in an index node associated with said file; and
- obtaining mapped data block numbers after applying the mapping function, wherein the mapped data block numbers are addresses of data of the file in a storage device.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,640,332 - “System and Method for Hot Deployment/Redeployment in Grid Computing Environment”
The Invention Explained
- Problem Addressed: The patent’s background describes the difficulty of upgrading applications in a large grid computing environment. Such environments may contain numerous servers running different applications, and traditional updates can require restarting an application's container, which may impact other applications or necessitate a system-wide suspension (’332 Patent, col. 1:49-60).
- The Patented Solution: The invention provides a method for "hot deployment" to avoid downtime. When a new version of an application is placed in a central repository, a discovery service identifies which grid nodes are running the application. A "client application manager" on each affected node is then notified. This manager selects an appropriate "hot deployment plug-in" based on the notification and uses it to deploy the new application version on its local servers without requiring a restart (’332 Patent, Abstract; Fig. 1).
- Technical Importance: This method facilitates zero-downtime "rolling updates" in complex, distributed computing environments, a critical feature for maintaining the high availability of services.
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶57).
- Claim 1 requires a method comprising:
- adding a new version of an application release bundle in a repository server;
- determining by a discovery services module which of the one or more grid nodes are running an application associated with the added new version;
- notifying a client application manager associated with one or more of the determined grid nodes about adding the new version and a data transfer protocol to use; and
- hot deploying/redeploying the new version on application servers using an appropriate hot deployment plug-in based on the data transfer protocol.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,068,597 - “System and Method for Automatic Load Balancing in a Data-Over-Cable Network”
- Technology Synopsis: The patent discloses a method for network load balancing where an intermediary device intercepts a client's initial message. The device determines the client's capabilities and applies a set of rules to assign the client's request to a specific "channel pair" (a resource with a server) based on those capabilities, the channel pair's load factor, and its capacity (’597 Patent, Abstract).
- Asserted Claims: At least Claim 1 (Compl. ¶74).
- Accused Features: The complaint accuses Home Depot's use of the Google Cloud Platform (GCP), including IAM for Cloud Load Balancing, Backend service-based external TCP/UDP Network Load Balancing, and External HTTP(S) Load Balancing (Compl. ¶¶33, 73).
U.S. Patent No. 7,120,832 - “Storage Device Performance Monitor”
- Technology Synopsis: The patent describes a system that monitors the performance of a storage device by intercepting and analyzing communications between the device and a computer system. Based on this analysis, the system can respond to a decline in performance by, for example, reallocating data on the storage device to enhance its performance (’832 Patent, Abstract).
- Asserted Claims: At least Claim 25 (Compl. ¶101).
- Accused Features: The complaint accuses Home Depot's implementation of systems that use Apache Kafka Streams with RocksDB Universal Compaction and Apache Cassandra (Compl. ¶¶34, 100).
U.S. Patent No. 7,107,326 - “Method and System for Integrating IP Address Reservations with Policy Provisioning”
- Technology Synopsis: The patent discloses a method for managing network access and provisioning policies. An intermediary device intercepts a client message, uses an identifier in the message to identify the client device, and then manages the assignment of configuration settings from a database based on that identifier and associated policies (’326 Patent, Abstract).
- Asserted Claims: At least Claim 1 (Compl. ¶120).
- Accused Features: The complaint accuses Home Depot's use of the Google Cloud Platform, including its Identity and Access Management (“IAM”) features for various Cloud Load Balancing services (Compl. ¶¶35, 119).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are internal, backend enterprise IT systems and cloud computing infrastructure used to operate Home Depot's business, rather than products sold to the public (Compl. ¶¶31-35). These include systems implementing Apache Hadoop Distributed File System (HDFS), Kubernetes, Google Cloud Platform (GCP) load balancing services, Apache Kafka Streams with RocksDB, and Apache Cassandra (Compl. ¶¶31-35).
Functionality and Market Context
- The complaint alleges these technologies are foundational to Home Depot's data processing, application deployment, and e-commerce operations (Compl. ¶¶9-11). HDFS is allegedly used for distributed storage and processing of large data volumes (Compl. ¶31). Kubernetes is allegedly used for deploying and managing containerized applications with "rolling updates" to maintain high availability (Compl. ¶32, 59). GCP is allegedly used for network load balancing to direct user traffic for its online platforms, and Apache Kafka and Cassandra are used for high-performance data streaming and storage systems (Compl. ¶¶33, 34). The complaint presents a screenshot of a product page for a drill, alleging the system's ability to provide in-store location information (e.g., "Aisle 29, Bay EC1") is part of the infringing activity (Compl. p. 6, ¶13).
IV. Analysis of Infringement Allegations
U.S. Patent No. 7,904,686 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| applying a mapping function to data block numbers that are associated with a file, wherein the data block numbers are contained in an index node associated with said file; | The HDFS NameNode performs a “mapping function” by determining the data block locations for a file, which are stored in its memory (an "index node"). | ¶44 | col. 2:5-10 |
| and obtaining mapped data block numbers after applying the mapping function, wherein the mapped data block numbers are addresses of data of the file in a storage device. | The NameNode determines and provides “the addresses of the data nodes” (storage devices) where the file’s data blocks are stored; these addresses are alleged to be the "mapped data block numbers." | ¶46 | col. 2:10-14 |
Identified Points of Contention
- Scope Questions: A central question may be whether the term "mapping function" as used in the context of the ’686 Patent’s "data security" purpose can read on the standard block-to-node mapping inherent in a distributed file system like HDFS. The dispute may focus on whether the function must have a security-specific purpose or if any logical-to-physical address transformation suffices.
- Technical Questions: What evidence does the complaint provide that the HDFS NameNode's mapping serves a security function, as opposed to the conventional function of managing data distribution across a cluster of nodes? The complaint alleges HDFS "provides various security features," but the infringement allegations focus on the standard mapping architecture (Compl. ¶43). The complaint presents a diagram of the HDFS read process, where a client gets block locations from the NameNode before accessing the DataNodes (Compl. p. 17).
U.S. Patent No. 7,640,332 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| adding a new version of an application release bundle in a repository server; | A new version of software is created as a "container image" (an application release bundle) and stored in a "registry" (a repository server). | ¶60 | col. 2:35-39 |
| determining by a discovery services module which of the one or more grid nodes are running an application associated with the added new version...; | The Kubernetes "control plane has a deployment controller" (a discovery services module) that determines which nodes in a cluster require the new container image. | ¶61 | col. 2:40-45 |
| notifying a client application manager associated with one or more of the determined grid nodes about adding the new version...; | The deployment controller notifies "Kubelet processes" (client application managers) on the worker nodes of the new desired configuration. | ¶62 | col. 2:46-51 |
| hot deploying/redeploying the new version... using an appropriate hot deployment plug-in... | The Kubelet process performs a "rolling update" by deploying the new container image on its worker node. | ¶63 | col. 2:52-59 |
Identified Points of Contention
- Scope Questions: The analysis may focus on whether the distinct components described in the claim (e.g., "discovery services module," "client application manager," "hot deployment plug-in") have direct, one-to-one counterparts in the integrated architecture of Kubernetes, or if the complaint combines multiple Kubernetes functions to meet a single claim element.
- Technical Questions: Does the Kubernetes process of a Kubelet pulling a new container image and starting a new pod constitute "using an appropriate hot deployment plug-in" as described by the patent? The complaint presents a diagram showing the relationship between the Kubernetes Master components and the Worker nodes with Kubelets (Compl. p. 27).
V. Key Claim Terms for Construction
’686 Patent
- The Term: "mapping function"
- Context and Importance: This term is the core of the invention. Its construction will determine whether HDFS's standard mechanism for locating distributed data blocks can be considered infringing. Practitioners may focus on this term because the patent's explicit framing is around "data security," while HDFS's primary purpose for mapping is distributed system management.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself does not limit the purpose of the function, only its technical inputs (data block numbers) and outputs (mapped data block numbers). The abstract describes the act of "applying a mapping function" without an explicit security-related qualifier in that clause (’686 Patent, Abstract).
- Evidence for a Narrower Interpretation: The patent's title, "Data Security For Use With A File System," and the "Background" section frame the invention entirely as a solution to security problems. A court may be asked to import this stated purpose into the construction of the term (’686 Patent, Title; col. 1:11-15).
’332 Patent
- The Term: "client application manager"
- Context and Importance: The infringement theory equates this term with the "Kubelet process" in Kubernetes. The viability of the infringement claim depends on whether a Kubelet's functions align with the patent's description of this manager.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the manager functionally as an entity that "registers with the repository server and can accept notifications from a server using grid notification mechanisms" (’332 Patent, col. 3:1-5). The complaint alleges the Kubelet performs these functions (Compl. ¶62).
- Evidence for a Narrower Interpretation: The claim requires the manager to use a "hot deployment plug-in." The specification's description of this plug-in may provide a basis to argue that the Kubelet's native container orchestration process is technically distinct from the "plug-in" architecture envisioned by the patent (’332 Patent, col. 2:52-59).
VI. Other Allegations
Indirect Infringement
- The complaint alleges inducement of infringement for all asserted patents. The allegations state Defendants provide "instructions on how to operate the infringing technology" through its website and other publications, and induce infringement by "customers and end-users" (Compl. ¶¶48, 50, 65, 67). These allegations may raise questions of applicability given the accused instrumentalities are internal backend systems.
Willful Infringement
- Willfulness is alleged for all patents based on pre-suit knowledge. The complaint cites a series of correspondence sent to Defendant beginning in April 2022 and claims Defendant "has not responded to any of Plaintiffs letters or emails" (Compl. ¶49, fn. 23; ¶66, fn. 44). The complaint also alleges that Defendants have "adopted a policy of not reviewing the patents of others," suggesting willful blindness (Compl. ¶49).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of conceptual scope: can patent claims describing solutions for specific purposes, such as "data security" or "hot deployment," be construed to cover the general-purpose, operational functions of widely adopted, standardized technologies like HDFS and Kubernetes, whose primary design goals may differ from those articulated in the patents?
- A key evidentiary question will be one of architectural mapping: does the complaint provide sufficient evidence to demonstrate that the integrated, multi-component architectures of the accused systems (e.g., Kubernetes control plane, GCP services) map directly onto the discrete functional elements recited in the claims, or is there a fundamental mismatch in technical operation and structure?
- A central question for damages will be the basis for a reasonable royalty: given that the accused systems are internal infrastructure and not products sold for revenue, the dispute will likely focus on establishing the value and cost-savings these technologies allegedly provide to Defendant’s extensive retail and e-commerce operations.