Storage Vectors LLC v. Shenzhen Longsys Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Storage Vectors LLC (New Mexico)
  • Defendant: Shenzhen Longsys Electronics Co., Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00860, E.D. Tex., 08/25/2025
• Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods for storing different types of data (e.g., streaming video vs. general files) using different physical formats on a single storage device to improve efficiency.
• Technical Context: The technology addresses optimizing data storage density in devices like hard disk drives and flash memory by relaxing error-correction standards for data types that are inherently error-tolerant, such as streaming media.
• Key Procedural History: The asserted patent is a continuation of a patent family tracing back to a 2008 PCT application. The complaint does not mention 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 “’426 Patent”).

The Invention Explained

• Problem Addressed: The patent’s background section asserts that conventional storage devices like hard disk drives and flash memory are "over designed" for storing audio/visual (AV) or other streaming data (Compl. ¶9; ’426 Patent, col. 2:7-9). These devices are built to achieve a very low bit error rate (BER) (e.g., 10⁻¹⁵) suitable for general purpose (GP) data where a single error can be critical, but this level of integrity is unnecessary for error-tolerant streaming (ETS) data, which can function acceptably with a much higher BER (e.g., 10⁻⁶) (’426 Patent, col. 2:5-17). This "over-design" results in suboptimal storage density.
• The Patented Solution: The invention is a method for a single storage device to handle both GP data and ETS data by using different physical storage methods for each type (’426 Patent, Abstract). For ETS data, the device employs a storage format that trades a higher (but acceptable) error rate for increased storage density or capacity (’426 Patent, col. 2:30-36). For example, a hard drive might store ETS data with tighter track spacing, while a flash memory device might use more levels per cell to store more bits per cell for ETS data (’426 Patent, col. 4:25-33, col. 5:48-53).
• Technical Importance: This approach allows a storage device to dynamically align its resources with the actual requirements of the data, thereby increasing the effective storage capacity for media-heavy consumer electronics applications (’426 Patent, col. 3:60-65).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," including "exemplary claims" identified in an attached but unprovided exhibit (Compl. ¶11, ¶16). Independent claim 1 is representative of the core invention.
• Independent Claim 1:
  • 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; and
  • Wherein the first and second attributes are associated with differing storage qualities, such as resilience to errors, data integrity, storage density, and storage capacity.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" listed in charts incorporated as Exhibit 2 (Compl. ¶11). However, Exhibit 2 was not filed with the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the functionality of the accused products. It alleges in a conclusory manner that the products "practice the technology claimed by the ’426 Patent" (Compl. ¶16). No specific product features, functions, or market positioning details are provided in the body of the complaint.

IV. Analysis of Infringement Allegations

The complaint states that "Exhibit 2 includes charts comparing the Exemplary ’426 Patent Claims to the Exemplary Defendant Products" but this exhibit is not publicly available (Compl. ¶16). The narrative infringement theory alleges that Defendant’s products infringe by storing different data types in a manner that satisfies all elements of the asserted claims (Compl. ¶11, ¶16). Without the claim charts, a detailed analysis of the infringement allegations is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent and the general nature of the allegations, the dispute may focus on several key questions:
  • Scope Questions: A central issue may be whether the accused products implement two genuinely "different" physical storage format attributes. The parties may dispute whether software-level formatting decisions (e.g., allocating different file system block sizes for different files) meet this limitation, or if it requires lower-level hardware modifications to the storage medium itself, such as altering track spacing or flash memory cell programming (’426 Patent, col. 4:25-33, col. 5:48-53).
  • Technical Questions: A key evidentiary question will be whether Plaintiff can demonstrate that the accused products actually achieve "differing storage qualities" (e.g., increased storage density) for streaming data as a direct result of using a different storage attribute, as required by the claim. The complaint provides no specific technical evidence on this point.

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 entire method depends on using a "first" attribute for GP data and a "second, different" attribute for streaming data. The definition of what constitutes such an "attribute" will likely be determinative of infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of what could be considered different utilization of the storage medium, 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). Plaintiff may argue that any of these software- or firmware-level differences qualify.
  • Evidence for a Narrower Interpretation: The detailed description provides specific, hardware-level embodiments, such as increasing "Bits per inch (BPI) and tracks per inch (TPI)" on a hard disk drive or dynamically modifying the "levels per cell" in flash memory (’426 Patent, col. 4:25-33; col. 5:22-25). Defendant may argue that the term should be limited to these more fundamental physical alterations rather than higher-level formatting choices.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by distributing "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14).
• Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after receiving notice of the ’426 Patent via the service of the complaint (Compl. ¶13, ¶15). The complaint does not allege any pre-suit knowledge.

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

The resolution of this dispute will likely depend on the court’s determination of two central issues:

1. A core issue will be one of definitional scope: What constitutes a "different physical storage format attribute" under claim 1? The case may turn on whether this term can be construed to cover conventional software-based data management or if it is limited to the lower-level, hardware-centric modifications described in the patent's specific embodiments.
2. A key evidentiary question will be one of technical proof: Assuming a construction is adopted, what factual evidence will Plaintiff be able to marshal to prove that the accused products actually implement two distinct storage modes for different data types that result in "differing storage qualities," such as a measurable increase in storage density for streaming data?