Storage Vectors LLC v. ADATA Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Storage Vectors LLC (New Mexico)
  • Defendant: ADATA Technology Co., Ltd. (Taiwan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00855, E.D. Tex., 08/25/2025
• Venue Allegations: Plaintiff asserts venue is proper because Defendant is a foreign corporation and has allegedly committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s storage products infringe a patent related to methods for storing different types of data using distinct physical formats to increase storage density.
• Technical Context: The technology addresses the efficient use of storage media, such as hard disk drives or flash memory, by tailoring the data storage method to the error tolerance of the data, which is significant for consumer electronics that handle both high-integrity system files and error-tolerant media streams.
• Key Procedural History: No prior litigation, licensing history, or other procedural events are mentioned in the complaint.

Case Timeline

Date	Event
2007-03-10	U.S. Patent No. 10,095,426 Earliest Priority Date
2015-06-18	U.S. Patent No. 10,095,426 Application Filing Date
2018-10-09	U.S. Patent No. 10,095,426 Issued
2025-08-25	Complaint Filed

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’s background section states that conventional storage devices like disk drives and flash memory are "over designed for AV data storage by many orders of magnitude" (’426 Patent, col. 2:8-9). These devices are built to achieve extremely low bit error rates (BER) suitable for general purpose (GP) data (e.g., application files), where a single bit error can be catastrophic (’426 Patent, col. 1:51-54). However, error tolerant or streaming (ETS) data, such as compressed video, can withstand a much higher BER without a noticeable loss in quality, making the stringent error correction of standard drives an inefficient use of storage capacity (’426 Patent, col. 1:46-51, col. 2:10-14).
• The Patented Solution: The invention is a method for a storage device to handle GP and ETS data differently. The device receives both data types and stores them using distinct "physical storage format attribute[s]" (’426 Patent, col. 9:18-24). As illustrated in Figure 1, this dual-format approach allows ETS data to be stored at a higher density and with a higher (but acceptable) BER (e.g., 10⁻⁹), while GP data is stored with a lower BER (e.g., 10⁻¹⁵) required for data integrity (’426 Patent, Fig. 1; Abstract). For a hard disk, this could involve using tighter track spacing for ETS data; for flash memory, it could involve storing more bits per cell (’426 Patent, col. 4:36-41, col. 5:40-53).
• Technical Importance: This approach allows a single storage device to increase its effective capacity for media-heavy applications by "better align[ing] the resources of a data storage device to the requirements of ETS data content" (’426 Patent, col. 2:20-22).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying them in the pleading itself, instead referring to an external exhibit (Compl. ¶11). The following analysis focuses on independent claim 1 as a representative claim.
• Independent Claim 1: A method of storing data, comprising the steps of:
  • 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.

III. The Accused Instrumentality

Product Identification

The complaint does not identify specific accused products by name. It refers generally to "Defendant products identified in the charts incorporated into this Count" as the "Exemplary Defendant Products" (Compl. ¶11). These charts were not attached to the filed complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context, as all such detail is incorporated by reference from an external exhibit (Compl. ¶¶16-17).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s products practice the technology claimed in the ’426 Patent but provides no specific factual allegations mapping claim elements to product features in the body of the pleading (Compl. ¶16). It states that such a comparison is provided in claim charts in an external "Exhibit 2," which was not included with the complaint (Compl. ¶16, 17). Therefore, a claim chart summary cannot be constructed from the provided documents. The narrative infringement theory is that the "Exemplary Defendant Products" directly infringe by satisfying all elements of the asserted claims (Compl. ¶16).

No probative visual evidence provided in complaint.

• Identified Points of Contention: Given the lack of specific allegations, any infringement analysis will depend on evidence introduced during discovery. Key questions suggested by the patent's claims include:
  • Technical Questions: Does the defendant's storage technology differentiate between data types that could be classified as "general purpose" versus "streaming"? If so, what is the mechanism for this differentiation?
  • Scope Questions: Do the accused products employ different "physical storage format attribute[s]" for these data types? What evidence will show that any differences in storage methods result in "differing storage qualities," such as a measurable change in storage density or error resilience, as required by the claim?

V. Key Claim Terms for Construction

• The Term: "physical storage format attribute"
• Context and Importance: This term is central to the infringement analysis, as the claims require that GP and streaming data be stored using different attributes. The scope of this term will determine whether the accused products infringe. A narrow definition focused on low-level physical characteristics might exclude infringement, while a broader definition encompassing logical formatting could favor the plaintiff’s position.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of what the attribute could be, including "block size, storage of error correction codes, utilization of error correction codes, storage area density, physical format pattern, storage verification, or reaction to failed storage verification" (’426 Patent, col. 2:40-44). This list suggests the term is not limited to a single physical characteristic but can encompass a range of formatting and operational parameters.
  • Evidence for a Narrower Interpretation: The detailed embodiments focus on fundamental physical-layer modifications. For hard disk drives, the key examples are increasing "Bits per inch (BPI) and tracks per inch (TPI)" and using a "continuous spiral pattern" for tracks (’426 Patent, col. 4:36-54). For flash memory, the examples are changing the "levels per cell" (LPC) and "cells per area" (CPA) (’426 Patent, col. 5:1-19). A defendant may argue that the term should be construed to require these types of direct, physical-media-level alterations rather than higher-level logical formatting choices.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users" to use the accused products in an infringing manner (Compl. ¶14). The complaint references Exhibit 2 as containing these materials (Compl. ¶14).
• Willful Infringement: The complaint does not use the term "willful," but it alleges that Defendant has had "Actual Knowledge of Infringement" since the service of the complaint (Compl. ¶13). It further alleges that "at least since being served by this Complaint," Defendant has "actively, knowingly, and intentionally continued to induce infringement" (Compl. ¶15). These allegations form a basis for potential post-suit enhancement of damages.

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

The complaint, by deferring all substantive infringement allegations to an external exhibit, raises immediate questions about the factual basis of its claims. The case will likely turn on the following core issues:

1. An Evidentiary Question of Operation: What specific technical evidence will Plaintiff provide to demonstrate that Defendant's products perform the claimed method? The central factual dispute will be whether the accused devices actually distinguish between "general purpose" and "streaming" data and, crucially, alter a "physical storage format attribute" in response, leading to measurably different storage qualities.

2. A Definitional Question of Scope: The dispute will likely center on the claim construction of "physical storage format attribute." Can this term be construed to cover modern storage management techniques that may not map directly to the hard disk and flash memory examples detailed in the patent, or will it be limited to the specific physical-layer modifications disclosed, such as altering track spacing or cell voltage levels? The answer to this question will likely determine the outcome of the infringement analysis.