DigitalDoors Inc v. City Bank

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigitalDoors, Inc. (Florida)
  • Defendant: City Bank (Texas)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 7:25-cv-00104, W.D. Tex., 03/06/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains physical business locations, employs personnel, and generates substantial revenue within the Western District of Texas.
• 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, and storing sensitive data in a distributed computing environment.
• Technical Context: The technology addresses secure data management for disaster recovery, a critical function for financial institutions which face significant operational and reputational risks from catastrophic cyberattacks.
• Key Procedural History: The complaint alleges the inventions were developed to address data security and survivability needs for the U.S. government and military. It also alleges Defendant had pre-suit awareness of the patents due to infringement lawsuits filed by DigitalDoors against competitor financial institutions.

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, Content Analysis and Classification and Method Therefor”

• Issued: April 21, 2015 (’301 Patent)

The Invention Explained

• Problem Addressed: Prior to the invention, enterprises struggled to manage and secure large volumes of unstructured data within open, vulnerable ecosystems. Conventional methods were inefficient for classifying sensitive data, could not adapt to the changing sensitivity of information over its lifecycle, and focused on securing entire files rather than the specific sensitive content within them (Compl. ¶27; ’301 Patent, col. 1:31-2:61).
• The Patented Solution: The invention provides a method for organizing and processing data in a distributed system by using a plurality of filters (e.g., content-based, contextual, taxonomic) to identify and obtain “select content” that is important to the enterprise. This extracted content is stored in corresponding data stores, and specific data processes (such as copying, archiving, or destruction) can be associated with the activated filters to automate data management policies (’301 Patent, Abstract; col. 3:17-4:35).
• Technical Importance: This approach represented a shift from file-level security to content-level security, allowing for more granular, automated, and flexible control over sensitive information within a distributed architecture (Compl. ¶27; ’301 Patent, col. 9:46-58).

Key Claims at a Glance

• The complaint asserts at least independent Claim 25 (Compl. ¶98).
• Essential elements of Claim 25 include:
  • A method of organizing and processing data in a distributed computing system having select content important to an enterprise.
  • Providing a plurality of select content data stores operative with a plurality of designated categorical filters.
  • Activating at least one filter 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 (e.g., copy, extract, archive) with the activated filter.
  • Applying the associated data process to a further data input.
  • Wherein the filter activation is automatic (e.g., time-based or event-based) or manual.

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

• Issued: August 15, 2017 (’169 Patent)

The Invention Explained

• Problem Addressed: As enterprises moved toward cloud-based and distributed computing, protecting sensitive data became more complex than traditional perimeter security could handle. A breach of the main system could expose all data, creating a need to segment and separately secure the most critical information (Compl. ¶131; ’169 Patent, col. 1:49-2:4).
• The Patented Solution: The invention describes a method for a distributed, cloud-based system that enhances security by segregating data. The system provides multiple types of data stores: "select content data stores" for sensitive, security-designated data and "granular data stores" for other data. A process extracts the sensitive data, stores it in the secure "select content" stores with strict access controls, while the non-extracted "remainder" data is parsed and stored separately in the granular stores ('169 Patent, Abstract).
• Technical Importance: This architecture creates layers of defense by isolating critical data, reducing the attack surface, and ensuring that a compromise of the primary production systems does not automatically lead to a breach of the most sensitive information (Compl. ¶¶ 130, 151-152).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶129).
• Essential elements of Claim 1 include:
  • A method of organizing and processing data in a distributed cloud-based computing system.
  • Providing a plurality of select content data stores for security-designated data, a plurality of granular data stores, and a cloud-based server.
  • Extracting and storing security-designated data in the select content data stores.
  • Activating a data store to permit access to the security-designated data based on access controls.
  • Parsing remainder data not extracted from the data processed.
  • Storing the parsed remainder data in the granular data stores.
  • Withdrawing data from the stores only when respective access controls are applied.

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

• Issued: January 15, 2019 (’073 Patent)
• Technology Synopsis: The patent describes creating an information infrastructure that processes data using a plurality of filters. A key aspect is the ability to alter these initially configured filters by expanding, contracting, or reclassifying the definitions of sensitive and select content, allowing the system to adapt dynamically to new information or changing security policies (’073 Patent, Abstract).
• Asserted Claims: At least independent Claim 1 (Compl. ¶165).
• Accused Features: The accused systems allegedly infringe by using configurable and modifiable "protection policies" to define what data is extracted and vaulted. The complaint alleges these policies can be altered by the enterprise, which corresponds to the claimed feature of altering filters (Compl. ¶¶ 181-182).

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

• Issued: April 2, 2019 (’639 Patent)
• Technology Synopsis: The patent claims a method for "sanitizing" data by processing it through filters that operate based on different sensitivity levels and security clearances. The system extracts sensitive content into secure data stores corresponding to its sensitivity level, leaving behind remainder data, thereby creating a "sanitized" version of the original data flow for less secure environments (’639 Patent, Abstract).
• Asserted Claims: At least independent Claim 16 (Compl. ¶192).
• Accused Features: The accused systems are alleged to perform the claimed sanitization by extracting "critical account information" (sensitive content) for storage in a secure vault, while the non-critical data (remainder) stays in the production environment. This process creates a sanitized data set (the vaulted data) protected according to its high sensitivity level (Compl. ¶¶ 214-215).

III. The Accused Instrumentality

Product Identification

• The Accused Instrumentalities are Defendant City Bank’s data backup and disaster recovery systems that are compliant with the Sheltered Harbor specification or are otherwise functionally equivalent (Compl. ¶¶ 95, 99). This includes systems like the Dell PowerProtect Cyber Recovery solution, which the complaint presents as an exemplary infringing technology (Compl. ¶71).

Functionality and Market Context

• The complaint alleges the accused systems perform data vaulting for cyber resilience. The core functionality involves extracting critical customer account data from the bank's main production environment, converting it into a standard format, and storing it in a secure, isolated, and immutable "data vault" (Compl. ¶¶ 69, 72, 75-76). This vault is "air-gapped," meaning it is disconnected from the production network except during brief, controlled data synchronization events (Compl. ¶81). A diagram in the complaint illustrates this architecture, showing data moving from a "Production Environment" through a secure replication process across an "Air-gap" to a "Data Vault Environment" (Compl. ¶72, p. 32). In the event of a catastrophic failure of the production systems, the vaulted data can be used on a "restoration platform" to recover basic banking services (Compl. ¶77).
• Sheltered Harbor is described as a critical, industry-wide standard in the financial services sector, developed and adopted by major institutions to protect the stability of the U.S. financial system against severe cyberattacks (Compl. ¶¶ 62, 64-65).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,015,301 Infringement Allegations

Identified Points of Contention

• Scope Questions: The central dispute may turn on whether the accused system's "protection policies" and "rules" (Compl. ¶¶ 87, 109) fall within the scope of the claim term "designated categorical filters." The defense may argue that its policies are simple data-type selectors, whereas the patent describes more complex content-based, contextual, and taxonomic filters (’301 Patent, col. 11:25-50).
• Technical Questions: A question for the court may be whether the "applying" step requires a dynamic, result-based feedback loop, or if it is satisfied by the ongoing, repetitive application of a static policy (e.g., "back up nightly") as alleged in the complaint (Compl. ¶119).

U.S. Patent No. 9,734,169 Infringement Allegations

Identified Points of Contention

• Scope Questions: A significant point of contention may be whether the accused system, with its physically or logically "air-gapped" vault (Compl. ¶81), qualifies as a "distributed cloud-based computing system." The defense may argue the isolation of the vault is fundamentally different from the interconnected nature implied by "cloud-based."
• Technical Questions: The complaint's theory appears to be that leaving non-critical data in the production environment satisfies the "parsing remainder data... and storing" limitation (Compl. ¶151). The defense may argue that this limitation requires an active step of parsing and storing the remainder, not merely failing to extract it.

V. Key Claim Terms for Construction

The Term: "categorical filters" (’301 Patent, Claim 25)

• Context and Importance: This term is foundational to how the patented method identifies data for processing. Its construction will determine whether the "protection policies" and "rules" used by the Sheltered Harbor systems (Compl. ¶87) meet the claim limitation. Practitioners may focus on this term because the infringement case for the ’301 patent hinges on this equivalence.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that "designated categorical filters are used to store select content relative to the category in certain SC stores," and lists a wide range of categories including enterprise policies like "customer privacy policy" or "financial data handling policy" (’301 Patent, col. 11:51-12:3), which may support Plaintiff's theory that a bank's policy to protect critical data is a "categorical filter."
  • Evidence for a Narrower Interpretation: The specification provides specific examples of filters, such as "content-based filters, contextual filters and taxonomic classification filters" (’301 Patent, col. 13:34-36). The defense may argue that the term should be limited to these enumerated types of analytical filters, rather than broader administrative "policies."

The Term: "parsing remainder data" (’169 Patent, Claim 1)

• Context and Importance: This step defines what happens to the data that is not extracted as sensitive. The viability of the infringement allegation depends on whether the accused system's act of leaving non-critical data in the production environment constitutes "parsing" and "storing" it.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's abstract states the method involves "extracting and storing SEC designated data" and "parsing remainder data not extracted... and storing the parsed data." One could argue that the process of separating the data stream into "extracted" and "not extracted" inherently constitutes a form of parsing, where the "remainder" is the result of that separation and is already "stored" in its original location.
  • Evidence for a Narrower Interpretation: The claim uses the active verbs "parsing" and "storing." The defense may argue this requires an affirmative process applied to the remainder data itself, rather than the passive act of leaving it untouched. The specification describes separating a source document into "extracted text" and "common text & placeholders" (e.g., ’169 Patent, Fig. 4), which suggests a more active manipulation of both data portions.

VI. Other Allegations

• Indirect Infringement: The complaint focuses on direct infringement, alleging Defendant "makes, owns, operates, uses, or otherwise exercises control over" the accused systems and that the systems themselves "directly perform all infringing steps" (Compl. ¶¶ 95, 98).
• Willful Infringement: Willfulness is alleged based on two theories. First, continued infringement after Defendant received notice via service of the complaint (Compl. ¶¶ 125, 161, 188, 223). Second, pre-suit willfulness based on alleged actual notice since at least November 21, 2023, arising from "awareness of the patent infringement lawsuits filed by DigitalDoors against competitor financial institutions," combined with an alleged policy of willful blindness to the patent rights of others (Compl. ¶¶ 226-227).

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

• A core issue will be one of definitional scope: can the term "categorical filter," which the patents describe in the context of content, context, and taxonomy, be construed to cover the high-level "protection policies" used by financial institutions to designate "critical account data" for vaulting in the accused Sheltered Harbor systems?
• A key infringement question will be one of process interpretation: does the accused system's architecture, which extracts and vaults critical data while leaving the remaining data in the production environment, satisfy the '169 patent's affirmative requirement to "parse" and "store" the "remainder data"?
• The case may also turn on a technological classification question: does the "air-gapped," isolated data vault architecture of the accused systems fall within the meaning of a "distributed cloud-based computing system" as required by the '169 patent, or does its isolated nature place it outside the scope of the claims?