Storage Vectors LLC v. Seagate Technology Holdings

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Storage Vectors LLC (NM)
  • Defendant: Seagate Technology Holdings plc (Ireland)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00275, E.D. Tex., 03/06/2025
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas on the basis that the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s storage devices infringe a patent related to using different physical storage formats for different types of data—specifically, error-tolerant streaming data versus general-purpose data—on the same storage medium.
• Technical Context: The technology addresses optimizing data storage devices, such as hard disk drives and flash memory, by applying different data integrity standards to different data types, a concept relevant to consumer electronics that handle both critical system files and streaming media.
• Key Procedural History: The patent-in-suit claims priority through a chain of applications back to a PCT application filed in March 2008, indicating a lengthy history of prosecution.

Case Timeline

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

U.S. Patent No. 10,095,426 - “Error tolerant or streaming storage device,” issued October 9, 2018

The Invention Explained

• Problem Addressed: The patent asserts that conventional data storage devices, like hard disk drives and flash memory, are "over designed" for storing error-tolerant data such as streaming audio/visual (AV) content (’426 Patent, col. 2:5-9). These devices apply the same stringent error-correction standards required for general-purpose (GP) data (e.g., system files) to streaming (ETS) data, which can function adequately even with some errors, leading to inefficient use of the storage medium (’426 Patent, col. 1:49-58).
• The Patented Solution: The invention proposes a method and system where a single storage device distinguishes between GP data and ETS data and stores them using different "physical storage format attributes" on the same medium (’426 Patent, col. 2:30-36). For ETS data, the device can use a format that prioritizes storage density or access speed over error-free integrity, for example by increasing the bits per inch (BPI) or using larger data blocks, thereby better aligning the storage resources with the data's actual requirements (’426 Patent, col. 4:29-34, 60-67). Figure 1 of the patent illustrates this core concept, showing separate formatting paths for ETS and GP data leading to different target Bit Error Rates (BER) (’426 Patent, Fig. 1).
• Technical Importance: This approach allows a storage device to increase its effective capacity or performance for media-centric applications without requiring more advanced physical media, by intelligently allocating its data integrity resources based on the type of data being stored (’426 Patent, col. 2:17-25).

Key Claims at a Glance

• The complaint does not identify specific claims, instead referring to "Exemplary '426 Patent Claims" detailed in an external exhibit not attached to the complaint (Compl. ¶11). Claim 1 is the first independent method claim of the patent.
• Essential elements of Independent Claim 1 include:
  • providing a storage medium as part of the storage system;
  • storing general purpose data on the storage medium using a first physical storage format attribute;
  • storing streaming data on the storage medium using a second physical storage format attribute different than said first physical storage format attribute;
  • said first and second physical storage attributes being associated with differing storage qualities selected from the group consisting of: resilience to errors, data integrity, storage density, and storage capacity.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify specific accused products by name. It refers to "Exemplary Defendant Products" that are detailed in charts within Exhibit 2, which was not filed with the complaint (Compl. ¶¶ 11, 16).

Functionality and Market Context

The complaint alleges that the accused products are storage devices made, used, and sold by the Defendant (Compl. ¶11). It asserts that these products "practice the technology claimed by the '426 Patent" by satisfying all elements of the exemplary claims, but provides no specific technical details about how the accused products operate (Compl. ¶16). The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint’s substantive infringement allegations are incorporated by reference from an external document, Exhibit 2, which was not provided (Compl. ¶¶ 16-17). The complaint itself contains only conclusory allegations of infringement. It states that Defendant’s products practice the claimed technology and that the charts in Exhibit 2 compare the "Exemplary '426 Patent Claims to the Exemplary Defendant Products" to show that all claim elements are satisfied (Compl. ¶16). Without access to Exhibit 2 or more detailed factual allegations, a claim-by-claim analysis is not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Technical Questions: A central factual question will be whether the accused storage devices actually employ different "physical storage format attributes" for different data types. For example, what evidence does the complaint provide that the accused products write streaming video data to a disk with a different areal density, block size, or track format than is used for operating system files on the same disk?
• Scope Questions: The dispute may turn on the definition of storing data "using" a particular attribute. If the accused devices have firmware capable of implementing different storage modes, but this functionality is not enabled or used for the data types specified in the claims, a dispute over whether the devices "store" data in an infringing manner could arise.

V. Key Claim Terms for Construction

• The Term: "physical storage format attribute"

• Context and Importance: This term is central to the claimed invention, as the differentiation between the "first" and "second" attributes forms the basis of the infringement allegation. The case's outcome will heavily depend on whether the accused product features are found to fall within the court's construction of this term.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party might argue the term should be read broadly to encompass any configurable parameter that results in one of the listed "differing storage qualities" (e.g., resilience, density), even if controlled by high-level firmware. The claim language itself is functional, linking the attribute to its effect on storage quality (’426 Patent, col. 10:23-27).
  • Evidence for a Narrower Interpretation: The specification provides concrete, physical examples of such attributes, including arranging data tracks in a "continuous spiral pattern" versus "concentric circles" (’426 Patent, col. 4:46-54), using larger physical block sizes (e.g., 4,096 bytes vs. 512 bytes) (’426 Patent, col. 4:60-67), and increasing the "levels per cell" in flash memory (’426 Patent, col. 5:42-53). A party may argue the term should be limited to these or analogous low-level, physical modifications to data layout on the storage medium itself.

• The Term: "streaming data"

• Context and Importance: The scope of this term defines one of the two data categories the patent purports to manage differently. Whether the data handled by the accused products qualifies as "streaming data" will be a prerequisite for infringement of claims reciting this term.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes streaming data as being "file-like" and provides Audio/Visual (AV) data as an example, suggesting it could cover any large, sequential data set that is tolerant to some errors (’426 Patent, col. 1:39-42).
  • Evidence for a Narrower Interpretation: The specification also references a specific industry standard, stating that ETS data can be delineated through the "'AV Stream' channel of the ATA/ATAPI-7 protocol" (’426 Patent, col. 3:32-37). A party could argue that "streaming data" should be limited to data identified or transmitted via such specific streaming-oriented commands or protocols recognized by the storage device.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the ’426 Patent (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based on post-suit conduct. The complaint asserts that the filing of the lawsuit itself provides Defendant with "actual knowledge of infringement" and that any continued infringing activity thereafter is willful (Compl. ¶¶ 13-14). No facts suggesting pre-suit knowledge are alleged.

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

The resolution of this dispute will likely depend on the answers to two fundamental questions:

1. A core issue will be one of claim scope and construction: How will the court define "physical storage format attribute"? Will the term be construed to require a tangible difference in the low-level, physical layout of data on the storage medium, as exemplified in the patent's detailed description, or could it encompass higher-level firmware settings that simply alter logical parameters affecting data integrity?

2. A key evidentiary question will be one of technical proof: Assuming a construction, what specific, non-public technical evidence can Plaintiff produce from discovery to demonstrate that Defendant's storage devices actually implement two distinct and different physical storage modes for general-purpose versus streaming data on the same device, as required by the claims? The complaint's lack of factual detail on this point elevates the importance of technical discovery into the internal operations of the accused products.