Storage Vectors LLC v. Doke Communication HK Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Storage Vectors LLC (New Mexico)
  • Defendant: Doke Communication HK Ltd (Hong Kong)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00856, E.D. Tex., 08/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to methods for storing different types of data on a storage medium using distinct physical formats to optimize storage density.
• Technical Context: The technology addresses the different data integrity requirements for general-purpose computer data versus error-tolerant streaming data (like video), proposing that storage devices can operate more efficiently by using different storage densities and error-correction schemes for each data type.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or administrative proceedings involving the patent-in-suit.

Case Timeline

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

U.S. Patent No. 10,095,426 - "Error tolerant or streaming storage device"

• Patent Identification: 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 notes that conventional data storage devices, such as disk drives and flash memory, are designed to meet the stringent data integrity requirements of general-purpose (GP) data, where even a single-bit error can be critical (’426 Patent, col. 1:47-53). However, other data types, such as streaming audio/visual (AV) media, are inherently more tolerant of errors. Applying the same high-integrity storage methods to this "error tolerant or streaming" (ETS) data is described as being "over designed... by many orders of magnitude," leading to inefficient use of the storage medium (’426 Patent, col. 2:7-8).
• The Patented Solution: The invention proposes a method where a single storage device receives both GP and ETS data and stores them using different "physical storage format attributes" (’426 Patent, col. 9:15-24). For ETS data, the device can use a format that increases storage density (e.g., by increasing bits per inch or tracks per inch on a disk) at the cost of a higher, but still acceptable, bit error rate (’426 Patent, col. 4:36-40). This allows the device to store more ETS data, such as video files, on the same physical medium compared to prior art methods (’426 Patent, col. 2:16-19; Fig. 1).
• Technical Importance: This approach allows storage device manufacturers to increase the effective capacity of their products for media-heavy applications without changing the underlying hardware, by tailoring the physical data format to the specific requirements of the content being stored (’426 Patent, col. 3:60-64).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" and "exemplary claims" without specifying claim numbers (Compl. ¶11). Independent claim 1 is analyzed here as representative.
• Independent Claim 1:
  • A method of storing data on a storage system comprising:
  • 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; and
  • 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 "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers to "Exemplary Defendant Products" that are allegedly identified in claim charts attached as Exhibit 2 (Compl. ¶11). This exhibit was not filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. It makes only a conclusory allegation that the products "practice the technology claimed by the '426 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from an unfiled Exhibit 2 (Compl. ¶17). The narrative infringement theory alleges that the "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶16). Without the specific products or claim charts, a detailed mapping is not possible based on the complaint's text. The core of the infringement allegation appears to be that Defendant's products make, use, sell, or import devices that employ different physical storage characteristics for different types of data, in a manner that falls within the scope of the asserted claims (Compl. ¶11).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question will be whether the accused products, once identified, actually use a "second physical storage format attribute" for "streaming data" that is "different than" the attribute used for "general purpose data," as required by claim 1. The dispute may turn on whether routine file system operations or standard wear-leveling algorithms in modern storage devices meet this claim limitation.
  • Technical Questions: What evidence does the complaint provide that Defendant’s products differentiate between "general purpose" and "streaming" data at the physical storage level? The complaint lacks any specific factual allegations about the technical operation of the accused devices that would support this inference.

V. Key Claim Terms for Construction

• The Term: "physical storage format attribute"
• Context and Importance: This term is the central technical element of the independent claims. Its construction will determine the scope of infringement, as the core inventive concept rests on using different such attributes for GP and ETS data. A narrow construction could place many modern storage techniques outside the claim scope, while a broad construction could potentially read on them.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 2, which depends on claim 1, lists several examples of how a storage medium can be "utilized differently," including "block size, storage of error correction codes, utilization of error correction codes, storage area density, physical format pattern, storage verification, and reaction to failed storage verification" (’426 Patent, col. 9:28-34). Plaintiff may argue this list is illustrative, not exhaustive, supporting a broader definition of "attribute."
  • Evidence for a Narrower Interpretation: The specification provides specific, detailed embodiments, such as using spiral tracks for ETS data versus concentric tracks for GP data (’426 Patent, col. 4:46-54), or using larger 4,096-byte blocks for ETS data versus 512-byte blocks for GP data (’426 Patent, col. 4:65-67). Defendant may argue the term should be limited to these or technologically similar, explicitly disclosed physical-level distinctions, rather than more abstract differences in data handling.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, asserting that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14).
• Willful Infringement: The complaint alleges that Defendant has had "actual knowledge" of the ’426 Patent since being served with the complaint and corresponding claim charts (Compl. ¶13). The allegations of knowing and intentional inducement are also based on this post-filing knowledge (Compl. ¶15). This framing suggests a basis for post-suit willful infringement.

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

1. A primary issue will be one of evidentiary proof: Given the complaint's lack of specificity, what technical evidence will be brought forward to demonstrate that the accused products actually implement two distinct and different "physical storage format attributes" corresponding to "general purpose data" and "streaming data" as claimed?
2. The case will likely turn on a question of claim construction: How will the court define "physical storage format attribute"? Whether this term is construed broadly to encompass a wide range of logical or physical data management techniques, or narrowly to the specific embodiments disclosed in the patent (e.g., spiral vs. concentric tracks), will be critical to the infringement analysis.