Storage Vectors LLC v. Shenzhen Huafurui Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Storage Vectors LLC (New Mexico)
  • Defendant: Shenzhen Huafurui Technology Co., Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00859, E.D. Tex., 08/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign corporation that has committed acts of patent infringement within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s storage products infringe a patent related to methods for storing error-tolerant or streaming data differently from general-purpose data to increase storage density.
• Technical Context: The technology addresses the efficient use of storage media in devices like hard disk drives or flash memory, a significant issue in consumer electronics that handle large volumes of streaming media alongside critical system data.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or post-grant 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 addresses the inefficiency of conventional data storage devices, which are designed to provide a very low bit error rate (BER) for all data types. This high level of data integrity is necessary for general-purpose (GP) data like system files but is "over designed" and capacity-inefficient for error-tolerant or streaming (ETS) data, such as audio/visual media, which can tolerate a higher BER without perceptible loss of quality (’426 Patent, col. 2:5-10).
• The Patented Solution: The invention proposes a storage device that differentiates between GP and ETS data and stores them using distinct methods. It stores ETS data using physical format attributes that increase storage density (e.g., more bits per inch or tracks per inch) at the expense of a higher, but still acceptable, BER. In contrast, it stores GP data using conventional, high-integrity formats. This dual-mode approach allows the device to optimize its total storage capacity for its most common use case—storing large media files—while preserving the integrity required for system data (’426 Patent, Abstract; col. 4:25-34; Fig. 1).
• Technical Importance: This approach allows for a significant gain in storage capacity on a given physical medium, which is particularly valuable for consumer electronics where storage of streaming content is a primary function (’426 Patent, col. 3:61-65).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" of the ’426 Patent without specifying which claims are asserted (Compl. ¶11). Independent claim 1 is representative of the patented method.
• Claim 1 essential elements:
  • Providing a storage medium as part of a storage system;
  • Storing general purpose data on the medium using a first physical storage format attribute;
  • Storing streaming data on the medium using a second, different physical storage format attribute; and
  • Wherein the first and second attributes are associated with differing storage qualities (e.g., resilience to errors, data integrity, storage density, storage capacity).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products by name. It refers generally to "Exemplary Defendant Products" that are identified in charts referenced as Exhibit 2, which is not attached to the complaint itself (Compl. ¶¶11, 16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It alleges only that these products practice the technology claimed by the ’426 Patent (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint does not contain specific infringement allegations or claim charts in its body, instead incorporating by reference an unprovided document, "Exhibit 2" (Compl. ¶17). The narrative theory is that the "Exemplary Defendant Products" satisfy all elements of the asserted claims by practicing the patented technology (Compl. ¶16). The complaint alleges these products are made, used, sold, and imported by the Defendant and that Defendant’s employees also internally test and use them, constituting direct infringement (Compl. ¶¶11-12).

No probative visual evidence provided in complaint.

Identified Points of Contention

Given the lack of specific product details, the analysis will likely focus on fundamental questions about the operation of the accused devices.

• Technical Questions: A central factual question will be whether the accused products actually employ different physical storage methods for different data types. What evidence does the complaint, through its unprovided exhibits, purport to show that establishes a distinction between how "general purpose" data and "streaming" data are physically stored on the media?
• Scope Questions: Do the accused products handle data that qualifies as "streaming data" and "general purpose data" as understood within the context of the patent? For example, does the device itself differentiate between these data types, or does it treat all incoming data identically, which may suggest a mismatch with the claim requirements?

V. Key Claim Terms for Construction

"physical storage format attribute"

• Context and Importance: This term is the core of the invention, defining the mechanism by which the storage differentiation is achieved. Its construction will determine what types of technical implementations fall within the scope of the claims.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 recites that the attributes are associated with "differing storage qualities selected from the group consisting of: resilience to errors, data integrity, storage density, and storage capacity" (’426 Patent, col. 9:24-28). The specification also provides a non-exhaustive list of factors, 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. 2:39-44). A plaintiff may argue this broad language and list of examples supports a wide range of differentiating techniques.
  • Evidence for a Narrower Interpretation: A defendant may argue the term should be limited to the specific embodiments detailed in the patent, such as using spiral versus concentric tracks for hard disk drives or varying the levels per cell in flash memory (’426 Patent, col. 4:46-54; col. 5:29-34).

"streaming data"

• Context and Importance: The applicability of the patent hinges on whether the accused devices process "streaming data." The definition of this term is critical to establishing infringement of a key claim limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 itself uses the term "streaming data" without explicit qualification. A plaintiff may argue it should be given its plain and ordinary meaning: any data that is transferred in a continuous stream.
  • Evidence for a Narrower Interpretation: The patent consistently equates "streaming data" with "Error Tolerant or Streaming (ETS) data" (’426 Patent, Abstract; col. 1:35-37). The background specifies that ETS data is "either error tolerant... or streaming... or both" and gives examples like MPEG-4 encoded TV programs (’426 Patent, col. 1:37-45). A defendant may argue that for data to be "streaming data" under the patent, it must also be shown to be "error tolerant" in nature, potentially narrowing the claim scope.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the ’426 Patent" (Compl. ¶14).
• Willful Infringement: The complaint alleges Defendant has "Actual Knowledge of Infringement" based on the service of the complaint and its attached claim charts (Compl. ¶13). It further alleges that despite this knowledge, Defendant continues its infringing activities, which may form the basis for a claim of post-suit willful infringement (Compl. ¶14).

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

1. A core issue will be one of definitional scope: How broadly will the court construe the term "physical storage format attribute"? Will it encompass any software- or hardware-level technique that results in different storage qualities, or will it be limited to the specific physical media formatting examples described in the patent?
2. The central evidentiary question will be one of technical implementation: What factual proof can Plaintiff provide to demonstrate that Defendant's devices actively differentiate between "general purpose" and "streaming" data types and, crucially, apply distinct physical storage methods to each as required by the claims?
3. A secondary question will be the characterization of data: Can the data processed by the accused products be properly classified as "streaming data" under the patent's implicit requirement that such data also be "error tolerant," or is all data handled in a uniform, high-integrity manner, regardless of its type?