Storage Vectors LLC v. Shenzhen Gotron Electronic Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Storage Vectors LLC (New Mexico)
  • Defendant: Shenzhen Gotron Electronic Co., LTD. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00858, E.D. Tex., 08/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign corporation, pursuant to 28 U.S.C. § 1391(c).
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods for increasing storage density by using different physical storage formats for error-tolerant data versus general-purpose data.
• Technical Context: The technology addresses data storage efficiency in devices like hard disk drives and flash memory, particularly for applications involving large streaming media files which can tolerate higher error rates than critical system or user data.
• Key Procedural History: The patent-in-suit is subject to a terminal disclaimer. The complaint does not allege any other significant procedural events, such as prior litigation or administrative challenges to the patent.

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 "’426 Patent").

The Invention Explained

• Problem Addressed: The patent asserts that conventional storage devices, such as hard disk drives and flash memory, are "over designed" for storing error-tolerant or streaming (ETS) data, such as audio/visual streams (Compl., Ex. 1, ’426 Patent, col. 2:7-9). These devices are typically built to achieve a very low bit error rate (BER) required for general-purpose (GP) data (e.g., system files), a standard that is unnecessarily stringent and capacity-limiting for media files where minor errors may be imperceptible (’426 Patent, col. 1:51-58).
• The Patented Solution: The invention proposes a method where a single storage device uses two different physical storage methods simultaneously. It stores sensitive GP data using a high-integrity, lower-density format, while storing error-tolerant ETS data using a lower-integrity, higher-density format (’426 Patent, Abstract). This is achieved by altering physical parameters, such as increasing the bits per inch on a disk platter or the number of voltage levels per cell in flash memory, for the portions of the media storing ETS data (’426 Patent, col. 4:36-40, col. 5:16-19). This dual-format approach allows the device to maximize its storage capacity for media-heavy applications (’426 Patent, col. 3:26-29; Fig. 1).
• Technical Importance: This method allows for a significant increase in the effective storage capacity of a device for certain applications (e.g., consumer electronics with video content) without changing its physical components, by better aligning the storage resources with the specific error-tolerance requirements of the data being stored (’426 Patent, col. 4:1-4).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" and references "Exemplary '426 Patent Claims" in an external exhibit not provided with the complaint (Compl. ¶11, ¶16).
• For the purpose of analysis, independent method claim 1 is representative. Its essential elements 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 the first;
  • Wherein the first and second attributes are associated with differing storage qualities selected from resilience to errors, data integrity, storage density, and storage capacity.
• The complaint does not specify whether dependent claims are asserted but reserves the right to do so.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any accused products by name (Compl. ¶11). It refers generally to "Exemplary Defendant Products" that are purportedly detailed in charts within an external document, Exhibit 2, which was not provided with the complaint filing (Compl. ¶16, ¶17).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market positioning. It makes only conclusory allegations that the unidentified products "practice the technology claimed by the '426 Patent" (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference an external claim chart (Exhibit 2) which was not provided (Compl. ¶16, ¶17). Therefore, a detailed claim chart summary cannot be constructed from the available documents. The infringement theory appears to be that the Defendant's unidentified "Exemplary Defendant Products" utilize different physical storage formats for different types of data, thereby infringing the ’426 Patent (Compl. ¶11, ¶16).

• Identified Points of Contention: Based on the patent claims and the general nature of the dispute, several technical and legal questions may arise.
  • Scope Questions: A central question will concern the definition of "physical storage format attribute" (’426 Patent, cl. 1). The dispute may turn on whether this term requires a fundamental change in how bits are physically recorded (e.g., track density, flash cell voltage levels), or if it can be read more broadly to include different logical block sizes or error correction schemes applied to different data types.
  • Technical Questions: A key evidentiary question will be whether the accused products actually implement distinct physical storage modes. It raises the question of what evidence Plaintiff will present to demonstrate that a standard storage device sold by Defendant alters its low-level physical formatting based on whether it is storing, for example, an operating system file versus an MPEG video file.

V. Key Claim Terms for Construction

• The Term: "physical storage format attribute" (appearing in independent claim 1).
• Context and Importance: This term is the central limitation of the asserted method. Its construction will determine the scope of infringement, as it defines what constitutes the allegedly inventive act of using "different" storage methods on the same medium. Practitioners may focus on whether this requires modification of hardware-level parameters or if software-based distinctions suffice.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language states the attribute is "associated with differing storage qualities" such as "resilience to errors" or "storage density," which could arguably encompass different error correction code (ECC) schemes or logical block sizes that affect these qualities (’426 Patent, cl. 1).
  • Evidence for a Narrower Interpretation: The specification provides specific, concrete examples of physical attributes, such as "Bits per inch (BPI) and tracks per inch (TPI)" for hard drives, "continuous spiral pattern" versus concentric tracks, and "levels per cell" in flash memory (’426 Patent, col. 4:36-54, col. 5:36-40). A defendant may argue the term should be limited to these physical-level embodiments.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to use the accused products in an infringing manner (Compl. ¶14). The complaint notes these materials are referenced in the unprovided Exhibit 2 (Compl. ¶14).
• Willful Infringement: The complaint alleges willful infringement based on knowledge of the ’426 Patent obtained from the service of the complaint itself (Compl. ¶13, ¶15). No allegations of pre-suit knowledge are made.

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

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

1. A core issue will be one of claim scope: can the term “physical storage format attribute,” which the patent specification illustrates with hardware-level examples like track density and flash memory cell levels, be construed to cover more common software-level distinctions in data handling or error correction within modern storage devices?

2. A key evidentiary question will be one of technical proof: what evidence can Plaintiff provide to demonstrate that Defendant's commercially available storage products actually perform the claimed method of dynamically applying physically distinct storage formats based on an assessment of the data type (general purpose vs. streaming)?