DigitalDoors Inc v. BROADWAY Bancshares Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigitalDoors, Inc. (Florida)
  • Defendant: Broadway Bancshares, Inc. (Texas)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 7:25-cv-00103, W.D. Tex., 03/06/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established business presence, including physical branch locations, within the district and specifically targets customers there.
• Core Dispute: Plaintiff alleges that Defendant’s data backup and disaster recovery systems, particularly those compliant with the financial industry’s "Sheltered Harbor" standard, infringe four patents related to methods for securely filtering, extracting, storing, and managing sensitive data in a distributed computing environment.
• Technical Context: The technology addresses secure data management and disaster recovery, a critical function for financial institutions facing increasing risks from sophisticated cyberattacks.
• Key Procedural History: The complaint does not reference prior litigation or post-grant proceedings involving the patents-in-suit. Plaintiff notes that the patents have been cited as relevant prior art in hundreds of subsequent patent applications by major technology and financial companies, which it presents as evidence of the inventions being "pioneering."

Case Timeline

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

U.S. Patent No. 9,015,301 - "Information Infrastructure Management Tools with Extractor, Secure Storage, Analysis and Classification and Method Therefor"

The Invention Explained

• Problem Addressed: The patent describes a state of the art where enterprises struggled to manage and secure sensitive information within large volumes of both structured and unstructured data. Conventional systems were vulnerable due to open ecosystems, had difficulty classifying data semantically, and could not effectively manage the changing sensitivity of information over its lifecycle (Compl. ¶27; '301 Patent, col. 1:31-2:61).
• The Patented Solution: The invention proposes a method and system for organizing and processing data in a distributed system by using a plurality of "categorical filters" (e.g., content-based, contextual, taxonomic) to identify and extract "select content" that is important to the enterprise. This extracted content is then stored in corresponding secure data stores, and specific data processes (like copying, archiving, or destruction) are associated with it based on enterprise policies (’301 Patent, Abstract; col. 3:17-4:35).
• Technical Importance: The technology aimed to shift data management from a file-based approach to a more granular, content-based approach, allowing for more nuanced security and improved survivability by storing sensitive data pieces in distributed locations (Compl. ¶¶27, 36).

Key Claims at a Glance

• The complaint asserts at least independent Claim 25 (Compl. ¶98).
• Claim 25 is a method claim comprising the steps of:
  • Providing a plurality of select content data stores operative with a plurality of designated categorical filters in a distributed computing system.
  • Activating at least one of the categorical filters and processing a data input to obtain select content.
  • Storing the aggregated select content in a corresponding data store.
  • Associating at least one data process (from a group including copy, extract, archive, distribution, and destruction) with the activated filter.
  • Applying the associated data process to a further data input based on the processing result.
  • The activation of the filter includes an automatic activation that is time-based, condition-based, or event-based.

U.S. Patent No. 9,734,169 - "Digital Information Infrastructure and Method for Security Designated Data and with Granular Data Stores"

The Invention Explained

• Problem Addressed: The patent addresses the need for secure data management in distributed, and specifically cloud-based, systems where sensitive data needs to be separated from non-sensitive data, stored securely, and accessed only by authorized users (’169 Patent, col. 2:1-12).
• The Patented Solution: The invention describes a method for processing data in a distributed cloud-based system that includes select content data stores, granular data stores, and a cloud-based server. The system extracts sensitive "security designated data" and stores it in the select content stores, while the "remainder data" is stored separately in the granular data stores. Access to the sensitive data is governed by access controls, and data can only be withdrawn when those controls are satisfied (’169 Patent, Abstract; col. 4:27-41).
• Technical Importance: This approach provides a framework for secure, multi-layered data storage in a cloud environment, enhancing security by separating sensitive content and controlling access to it while allowing the bulk of non-sensitive data to remain more accessible.

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶129).
• Claim 1 is a method claim comprising the steps of:
  • Providing a distributed cloud-based system with select content data stores, granular data stores, and a cloud-based server, coupled by a communications network.
  • Extracting and storing security-designated data in the select content data stores.
  • Activating a select content data store to permit access based on access controls.
  • Parsing remainder data not extracted and storing it in the granular data stores.
  • The parsing and storing of remainder data includes both random parsing and parsing according to a predetermined algorithm.
  • Withdrawing the security-designated data and parsed remainder data from their respective stores only when the access controls are applied.

U.S. Patent No. 10,182,073 - "Information Infrastructure Management Tools with Variable and Configurable Filters and Segmental Data Stores"

• Technology Synopsis: The patent describes creating an information infrastructure that uses a plurality of filters to process data. A key aspect is the ability to identify sensitive and select content using initially configured filters, and then dynamically alter those filters (e.g., by expanding or contracting their scope) to generate modified filters for organizing subsequent data throughput (’073 Patent, Abstract; Compl. ¶¶171, 181).
• Asserted Claims: At least independent Claim 1 is asserted (Compl. ¶165).
• Accused Features: The accused systems allegedly infringe by using configurable "protection policies" to identify and extract critical financial data, and by providing user interfaces that allow the enterprise to define and modify these policies for ongoing data backup operations (Compl. ¶¶182, 185).

U.S. Patent No. 10,250,639 - "Information Infrastructure Management Data Processing Tools for Processing Data Flow with Distribution Controls"

• Technology Synopsis: The patent discloses a method for "sanitizing" data by processing a data input to separate sensitive content from remainder data. The system extracts the sensitive content, stores it in a secure "extract store," stores select content in "select content data stores," and then uses various filters (content, contextual, taxonomic) to "inference" the sanitized data for further analysis or use (’639 Patent, Abstract; Compl. ¶¶193, 217).
• Asserted Claims: At least independent Claim 16 is asserted (Compl. ¶192).
• Accused Features: The accused systems allegedly perform the claimed sanitization method by extracting critical customer account data (sensitive content) for storage in a secure data vault, leaving the non-critical data (remainder data) in the production environment, and thereby creating sanitized versions of the enterprise's data (Compl. ¶¶211, 214).

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are Defendant Broadway Bancshares' systems and methods for processing and backing up data, specifically those which are collectively compliant with the "Sheltered Harbor" specification or provide substantially equivalent functionality (Compl. ¶95).

Functionality and Market Context

• The complaint alleges the accused systems implement the Sheltered Harbor standard, an industry-wide initiative for financial institutions to protect critical customer data from catastrophic events like cyberattacks (Compl. ¶62). The core functionality involves (1) extracting critical customer account data daily, (2) converting it into a standard format, and (3) storing it in a secure, immutable, and physically or logically isolated "data vault" that is air-gapped from production networks (Compl. ¶¶69, 75, 76). The system is designed to allow for the restoration of customer accounts and funds even if the institution's primary systems and backups fail (Compl. ¶70). A Dell PowerProtect Cyber Recovery solution is identified as an exemplary system that implements these standards (Compl. ¶71).
• The complaint presents the Sheltered Harbor standard as a near-uniform requirement for the financial services industry, created to maintain public confidence and ensure market stability (Compl. ¶¶62, 65, 94). A diagram from Dell illustrates this architecture, showing data moving from a "Production Environment" through a secure replication process and "Air-gap" into a "Data Vault Environment" (Compl. ¶72, p. 32).

IV. Analysis of Infringement Allegations

'301 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question may be whether the "protection policies" and "tags" used in modern backup systems like Dell PowerProtect (Compl. ¶¶87, 88) meet the definition of "designated categorical filters" as described in the patent, which details content-based, contextual, and taxonomic filter classifications. The analysis may explore whether the accused functionality is merely a named-based filter or if it performs the more complex analysis contemplated by the patent.
• Technical Questions: The complaint alleges that once a policy is established, "all further data inputs processed under the filter are processed in the same way" (Compl. ¶¶90, 119). A potential point of contention could be whether the accused system applies a single, pre-associated data process (e.g., "copy") to all subsequent data or whether it makes dynamic decisions for each data input, which could raise questions about the "applying the associated data process" limitation.

'169 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The term "distributed cloud-based computing system" may be a key point of dispute. The defense could argue its system is primarily on-premises or a hybrid that does not meet the patent's definition of "cloud-based," while the plaintiff may argue that any use of remote or virtualized resources qualifies.
• Technical Questions: A factual question may arise regarding whether the accused systems perform all the claimed steps within a single, controlled system as required for direct infringement. For example, if data extraction happens on one set of servers and secure storage is managed by a separate cloud vendor, it raises the question of whether a single party "performs" every step of the claimed method.

V. Key Claim Terms for Construction

For the ’301 Patent (Claim 25)

• The Term: "designated categorical filters"
• Context and Importance: This term is the core mechanism of the invention for identifying important data. The infringement allegation hinges on whether the "protection policies" of the accused systems (Compl. ¶87) are functionally equivalent to the claimed "categorical filters." Practitioners may focus on this term because its construction will determine whether a broad range of modern data management rules infringe or if the claim is limited to the specific filter types disclosed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is broad, not limiting the filters to specific types. The summary of the invention refers to filters that include "content-based filters, contextual filters and taxonomic classification filters," suggesting these are examples, not an exhaustive list (’301 Patent, col. 3:37-40).
  • Evidence for a Narrower Interpretation: The detailed description repeatedly and specifically discusses "content-based filters, contextual filters, and taxonomic filters" as the mechanisms for selection, often in conjunction with a "knowledge expander" search engine (’301 Patent, col. 10:22-32). A defendant may argue that to be "categorical," a filter must perform the kind of substantive analysis described in these specific embodiments, not just simple rule-based sorting.

For the ’169 Patent (Claim 1)

• The Term: "parsing remainder data"
• Context and Importance: The claim requires two types of "parsing" for the remainder data: "randomly parsing" and "parsing...according to a predetermined algorithm." The complaint equates this to encryption (Compl. ¶155). The construction of "parsing" will be critical to determining if standard encryption satisfies this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not appear to explicitly define "parsing." Plaintiff may argue that encryption is a form of parsing because it transforms data into a different format (ciphertext) according to an algorithm, and the random component is supplied by cryptographic keys or initialization vectors.
  • Evidence for a Narrower Interpretation: The specification discusses "parsing" in the context of splitting a document into granular pieces or data streams (’169 Patent, col. 16:30-38). A defendant may argue that "parsing" in the context of the patent means structural decomposition of data, which is technically distinct from the mathematical transformation of encryption.

VI. Other Allegations

Willful Infringement

The complaint alleges that Defendant has been on notice of the patents at least since the filing of the complaint. It further alleges pre-suit knowledge based on "awareness of the patent infringement lawsuits filed by DigitalDoors against competitor financial institutions" since November 21, 2023 (Compl. ¶226). Willfulness is also alleged on the basis that Defendant maintains a "policy or practice of not reviewing the patents of others," which Plaintiff characterizes as willful blindness (Compl. ¶227).

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

This case appears to center on whether the patented methods for granular, filter-based data security, conceived in the mid-2000s, read on modern, standardized disaster recovery architectures adopted by the financial industry. The outcome may depend on the answers to several key questions:

• A core issue will be one of definitional scope: Can the term "categorical filters," which the patent describes as involving contextual and taxonomic analysis, be construed broadly enough to cover the "protection policies" and "tags" used in the accused industry-standard data vaulting systems?
• A second key question will be one of technical interpretation: Does standard data encryption, as used in the accused systems to secure data at rest and in transit, constitute the specific claim limitations of "randomly parsing" and "parsing...according to a predetermined algorithm"?
• An overarching evidentiary question will be one of system architecture: Can Plaintiff demonstrate that the Defendant, as a single entity, directs or controls a "distributed cloud-based computing system" that performs every step of the asserted method claims, particularly where functionality may be split between on-premises hardware and third-party cloud services?