DCT
2:25-cv-00081
Valtrus Innovations Ltd v. Home Depot Inc
Key Events
Amended Complaint
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; Truelove Law Firm, PLLC
- Case Identification: 2:25-cv-00081, E.D. Tex., 10/30/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant operates physical stores and fulfillment centers within the district that are integrated with its e-commerce platform. The complaint asserts that online transactions for customers in the district are fulfilled by these local stores and that in-store and/or edge servers process information related to infringing activities within the district.
- Core Dispute: Plaintiff alleges that Defendant's backend data infrastructure and e-commerce platform, which utilize technologies such as Apache Hadoop, Kubernetes, Google Cloud Platform, and Apache Kafka, infringe five patents related to data security, grid computing, network load balancing, and storage performance monitoring.
- Technical Context: The technologies at issue relate to foundational aspects of large-scale distributed computing, data storage, and network management, which are critical for operating modern e-commerce platforms and cloud-based infrastructure.
- Key Procedural History: The complaint alleges that Plaintiff sent multiple letters and emails notifying Defendant of infringement of the patents-in-suit, with communications starting as early as April 2022 and continuing through February 2024. The complaint asserts that Defendant has not responded to these communications.
Case Timeline
| Date | Event |
|---|---|
| 2000-10-13 | U.S. Patent No. 7,107,326 Priority Date |
| 2000-11-27 | U.S. Patent No. 7,068,597 Priority Date |
| 2001-09-27 | U.S. Patent No. 7,120,832 Priority Date |
| 2006-06-27 | U.S. Patent No. 7,068,597 Issue Date |
| 2006-09-12 | U.S. Patent No. 7,107,326 Issue Date |
| 2006-10-10 | U.S. Patent No. 7,120,832 Issue Date |
| 2006-12-27 | U.S. Patent No. 7,640,332 Priority Date |
| 2008-05-13 | U.S. Patent No. 7,904,686 Priority Date |
| 2009-12-29 | U.S. Patent No. 7,640,332 Issue Date |
| 2011-03-08 | U.S. Patent No. 7,904,686 Issue Date |
| 2015 | Alleged use of Apache Kafka Streams begins |
| 2016 | Alleged use of Google Cloud Platform begins |
| 2017 | Alleged use of HDFS begins |
| 2019 | Alleged use of Kubernetes begins |
| 2022-04-11 | Plaintiff alleges sending notice of infringement for '597 and '326 patents |
| 2023-05-26 | Plaintiff alleges sending notice of infringement for '832 patent |
| 2024-02-08 | Plaintiff alleges sending notice of infringement for '686 and '332 patents |
| 2025-10-30 | 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,” issued March 8, 2011
The Invention Explained
- Problem Addressed: The patent describes a vulnerability in file systems where, even with application-level security, an individual could reconstruct a file by directly accessing its constituent data blocks on a storage device, bypassing security checks by using information from the file’s index node (inode) (’686 Patent, col. 1:26-34).
- The Patented Solution: The invention introduces a "block distribution engine" that intercepts file system requests and applies a "mapping function" to the logical block numbers stored in a file's inode. This generates a new set of "algorithm-specific" block numbers where the file's data is physically stored. This obfuscates the actual data locations, thereby preventing file reconstruction from the raw inode data (’686 Patent, Abstract; col. 3:17-24). A diagram in the complaint shows the relationships between a client, a "Namenode" that holds metadata, and "Datanodes" that hold data blocks (Compl. p. 20, Fig. 22).
- Technical Importance: This approach provides security at the file system level by decoupling a file's logical block list from its physical storage locations, complicating efforts to copy protected data by directly reading a storage device (’686 Patent, col. 4:5-6).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶ 41).
- Claim 1 Elements:
- A method of providing data security for use with a file system, 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 reserves the right to assert other claims by alleging infringement of "one or more claims" (Compl. ¶ 40).
U.S. Patent No. 7,640,332 - “System and Method for Hot Deployment/Redeployment in Grid Computing Environment,” issued December 29, 2009
The Invention Explained
- Problem Addressed: The patent addresses the difficulty of updating applications ("hot deployment") in heterogeneous grid computing environments where different applications run on various servers. Manually tracking which servers need updates and using correct update protocols can be inefficient and lead to service downtime (’332 Patent, col. 1:49-62).
- The Patented Solution: The invention describes a system where a repository server, upon receiving a new application version, uses a "discovery services module" to identify which grid nodes are running that application. It then notifies a "client application manager" on each affected node, providing the update information and specifying a "data transfer protocol." The local manager then uses an appropriate "hot deployment plug-in" to update the application without interrupting service (’332 Patent, Abstract; col. 2:35-67).
- Technical Importance: The invention provides a framework for automating application updates across diverse, distributed computing environments, which can reduce manual overhead and improve system availability.
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶ 57).
- Claim 1 Elements:
- A method for hot deployment and/or redeployment in a grid computing environment, 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 of the application release bundle;
- notifying a client application manager associated with one or more of the determined grid nodes about adding the new version of the application release bundle along with a type of data transfer protocol to use; and
- hot deploying/redeploying the new version of the application release bundle on running one or more application servers in an associated grid node using an appropriate hot deployment plug-in based on the data transfer protocol by a respective one of the client application managers.
- The complaint reserves the right to assert other claims (Compl. ¶ 56).
U.S. Patent No. 7,068,597
- Patent Identification: 7068597, “System and Method for Automatic Load Balancing in a Data-Over-Cable Network,” issued June 27, 2006 (Compl. ¶ 27).
- Technology Synopsis: The patent discloses a network load balancing system where a management device intercepts a client's initial message. The manager determines the client's capabilities, applies a set of rules, and assigns the client to a specific "channel pair" based on device capabilities, channel load factors, and capacity thresholds, thereby distributing network traffic (’597 Patent, Abstract).
- Asserted Claims: At least claim 1 (Compl. ¶ 74).
- Accused Features: The complaint accuses Google Cloud Platform ("GCP") services used by Home Depot, including IAM for Cloud Load Balancing, Backend service-based external TCP/UDP Network Load Balancing, and External HTTP(S) Load Balancing (Compl. ¶ 73).
U.S. Patent No. 7,120,832
- Patent Identification: 7120832, “Storage Device Performance Monitor,” issued October 10, 2006 (Compl. ¶ 28).
- Technology Synopsis: The patent describes a method to monitor storage device health by intercepting communications between the device and a computer system. The system analyzes communications (e.g., access times, error reports) against a performance threshold. If performance degrades, it can trigger a response, such as reallocating data on the storage device to a better-performing area, to mitigate issues before a predicted failure (’832 Patent, Abstract).
- Asserted Claims: At least claim 25 (Compl. ¶ 101).
- Accused Features: The complaint accuses Home Depot's use of Apache Kafka Streams with RocksDB Universal Compaction (Compl. ¶ 100).
U.S. Patent No. 7,107,326
- Patent Identification: 7107326, “Method and System for Integrating IP Address Reservations with Policy Provisioning,” issued September 12, 2006 (Compl. ¶ 29).
- Technology Synopsis: The patent details a system for managing network access and provisioning policies. A network device intercepts an incoming message, uses an identifier within the message to identify the originating network device, and then uses a database to look up and assign a plurality of configuration settings (such as an IP address or service class) based on that identifier (’326 Patent, Abstract).
- Asserted Claims: At least claim 1 (Compl. ¶ 116).
- Accused Features: The complaint accuses GCP services used by Home Depot, including GCP Cloud Load Balancing, IAM for Cloud Load Balancing, and various backend load balancing services (Compl. ¶ 115).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is Home Depot's backend data processing and e-commerce infrastructure, which the complaint alleges is composed of specific technologies including Apache Hadoop Distributed File System (HDFS), Kubernetes, Google Cloud Platform (GCP), and Apache Kafka Streams using RocksDB (Compl. ¶¶ 31-35).
Functionality and Market Context
The complaint alleges that these technologies underpin Home Depot's "interconnected retail strategy," which integrates its physical stores with its online platform, homedepot.com (Compl. ¶¶ 9-11). The complaint presents a screenshot from the website showing that a customer can see product availability and the specific in-store aisle and bay location for pickup (Compl. p. 6). The complaint cites Defendant's 2022 Annual Report, which states that online sales represented 14.2% of net sales and were a growing part of the business (Compl. ¶ 10). The use of these specific technologies is supported by citations to LinkedIn profiles of individuals identified as Home Depot employees or contractors (Compl. ¶¶ 42, 58, 102).
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, which manages the file system namespace and metadata (analogous to an index node), performs a mapping function by determining the locations of a file's data blocks on various DataNodes. This mapping information is stored in a file named fsimage. |
¶44-45 | col. 3:17-24 |
| 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 | After applying the mapping function, the NameNode determines "the addresses of the data nodes" where the file's data blocks are stored. These addresses are the mapped data block numbers, and the DataNodes are the storage devices. | ¶46 | col. 4:1-6 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the HDFS NameNode's metadata repository (the
fsimage) constitutes an "index node" as contemplated by the patent. Further, it raises the question of whether HDFS's block placement logic, which is designed for distributed storage and fault tolerance, qualifies as the "mapping function" described in the patent, which is taught in the context of providing data security. - Technical Questions: What evidence does the complaint provide that the "mapping" performed by the HDFS NameNode serves a security purpose analogous to that described in the ’686 Patent? The infringement analysis may turn on whether the function's purpose (data distribution vs. data obfuscation) is a material element of the claim.
- Scope Questions: A central question may be whether the HDFS NameNode's metadata repository (the
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, which is an "executable software bundle," and pushed to a registry, which functions as a repository server. | ¶60 | col. 2:36-39 |
| 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" includes a "Deployment controller" that monitors application instances and determines which "Nodes" (grid nodes) across the cluster are running the application to be updated. | ¶61 | col. 2:59-62 |
| notifying a client application manager associated with one or more of the determined grid nodes about adding the new version... along with a type of data transfer protocol to use | The Deployment controller notifies the "Kubelet" process (alleged to be the client application manager) on each worker node of the desired new configuration, including the new application and associated protocol information. A diagram in the complaint illustrates the relationship between the master components and the worker Kubelets (Compl. p. 27). | ¶62 | col. 2:62-65 |
| hot deploying/redeploying the new version of the application release bundle on running one or more application servers... using an appropriate hot deployment plug-in... | Kubernetes performs "rolling updates" where the Kubelet on each node ensures that new containers (pods) with the updated application image are deployed and running, thereby achieving hot deployment. | ¶63 | col. 3:1-5 |
- Identified Points of Contention:
- Scope Questions: The analysis may focus on whether the components of the Kubernetes architecture directly map to the claimed elements. For example, does the Kubernetes "Deployment controller" meet all the limitations of the claimed "discovery services module," and does the "Kubelet" function as the claimed "client application manager"?
- Technical Questions: The claim requires "notifying... along with a type of data transfer protocol to use." A technical question will be what evidence demonstrates that a data transfer protocol is explicitly communicated as part of the update notification from the controller to the Kubelet, as opposed to being an inherent or pre-configured aspect of the cluster's operation.
V. Key Claim Terms for Construction
For U.S. Patent No. 7,904,686:
- The Term: "mapping function"
- Context and Importance: This term is the central mechanism of the invention. The outcome of the case may depend on whether HDFS's standard block placement and management logic is construed as a "mapping function." Practitioners may focus on this term because its construction will determine whether a system designed for distributed storage can infringe a claim rooted in providing data security through obfuscation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of claim 1 does not explicitly limit the purpose of the "mapping function." It only requires "applying a mapping function to data block numbers" and "obtaining mapped data block numbers."
- Evidence for a Narrower Interpretation: The patent is titled "Data Security For Use With A File System." The specification describes the block distribution algorithm as one that "provides security to data blocks" (’686 Patent, col. 5:3-4) and solves the problem of unauthorized data reconstruction (col. 1:26-34). This context suggests the term may be limited to functions with a security purpose.
For U.S. Patent No. 7,640,332:
- The Term: "notifying a client application manager... along with a type of data transfer protocol to use"
- Context and Importance: Infringement hinges on whether the communication within the accused Kubernetes system meets this multi-part limitation. Defendant may argue that the protocol is an implicit part of the system's architecture rather than information actively conveyed "along with" the notification.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language does not specify the format or method of notification, which could support an argument that an implicit or system-level configuration satisfies the requirement.
- Evidence for a Narrower Interpretation: The patent's abstract states that the client application manager uses the protocol information to select an "appropriate hot deployment plug-in." This suggests the "type of data transfer protocol" is an operative piece of information used for selection, supporting a narrower reading that requires the explicit communication of a protocol type.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for all five patents. The factual basis for inducement is Defendant's alleged act of supplying the infringing systems and providing instructions to customers and end-users on how to operate them through its website and other materials (Compl. ¶¶ 48, 50, 65, 67).
- Willful Infringement: The complaint alleges willful infringement based on alleged pre-suit knowledge of the patents. It cites a series of correspondence sent to Defendant notifying it of infringement of various asserted patents, with the first alleged notice dating to April 2022 and subsequent notices in 2023 and 2024 (Compl. ¶ 49, fn. 23; ¶ 66, fn. 44; ¶ 94, fn. 73). The complaint also alleges willful blindness based on a purported "policy of not reviewing the patents of others" (Compl. ¶ 49).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural mapping: can the components of modern, open-source infrastructures like the HDFS NameNode and the Kubernetes control plane/Kubelet be mapped to the functional elements described in the patents, such as "index node" and "client application manager," or is there a fundamental mismatch in their respective architectures and operations?
- A key evidentiary question will be one of functional purpose: for the '686 patent, does the accused HDFS block management system, primarily designed for large-scale, fault-tolerant data distribution, perform the claimed "mapping function" for the purpose of "data security" as described in the patent's specification, or is its function technically distinct from the security problem the patent claims to solve?
- The infringement analysis for the '332 patent may turn on a question of explicit versus implicit action: does the accused Kubernetes system "notify" its node agent "along with a type of data transfer protocol to use," as required by the claim, or is the protocol an inherent, pre-configured aspect of the system that is not actively communicated as part of the update process?