DigitalDoors Inc v. Intl Bancshares Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigitalDoors, Inc. (Florida)
  • Defendant: International Bancshares Corp., d/b/a IBC BANK, COMMERCE BANK, and INTERNATIONAL BANK OF COMMERCE (Texas)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 7:25-cv-00105, 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 in the district, including physical locations and employees, and specifically targets customers within the district.
• 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 filtering, securing, and storing sensitive data in a distributed computing environment.
• Technical Context: The technology at issue involves systems for ensuring data survivability and business continuity, a critical function in the financial services industry where institutions must protect customer account information from catastrophic loss due to cyberattacks or other disasters.
• Key Procedural History: The complaint alleges the inventions were conceived to address data security deficiencies identified in U.S. government and military operations. It further alleges that the financial industry's collective development of the "Sheltered Harbor" data vaulting standard, beginning in 2015, demonstrates the non-obviousness and novelty of the patented technology. Plaintiff also asserts that Defendant was on notice of the patents due to prior lawsuits filed against other financial institutions.

Case Timeline

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

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

• Patent Identification: 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.

The Invention Explained

• Problem Addressed: The patent’s background section describes the state of the art as being deficient in managing unstructured data, classifying sensitive information without inefficient semantic or taxonomic analysis, and securing open information ecosystems with numerous access points (Compl. ¶27; ’301 Patent, col. 1:31-2:27). Enterprises lacked a conventional approach to automatically categorize and manage data at the content level rather than the file level (Compl. ¶27).
• The Patented Solution: The invention proposes a method and system for organizing data in a distributed system by using "categorical filters" to process a data input, obtain "select content" based on the filters, and store that content in corresponding data stores ('301 Patent, Abstract). The system then associates specific "data processes" (e.g., copy, archive, distribution, destruction) with the filtered content, allowing for automated, policy-driven management of granular data ('301 Patent, col. 4:1-17).
• Technical Importance: The claimed invention represented a shift from managing entire data files to managing the sensitive content within those files, enabling more granular security and recovery protocols (Compl. ¶27).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 25 ('301 Patent, col. 131:22-132:21; Compl. ¶98).
• The 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 and associated select content (which is contextually or taxonomically associated).
  • Storing the aggregated select content in a corresponding data store.
  • Associating a data process (e.g., copy, extract, archive, distribution, destruction) with the activated filter.
  • Applying the associated data process to a further data input based on the processing result.
  • Wherein the filter activation is automatic (time-based, condition-based, or event-based) or manual.

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

• Patent Identification: 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.

The Invention Explained

• Problem Addressed: The patent identifies the need for improved methods of securing designated data within a distributed or cloud-based system, where data is vulnerable at multiple points and must be protected yet accessible for authorized use ('169 Patent, col. 1:28-2:68).
• The Patented Solution: The invention claims a method for processing data in a distributed cloud-based system by providing separate data stores for "security designated data" (select content) and "granular data" (remainder data) ('169 Patent, Abstract). The system extracts and stores the sensitive data in secure "select content data stores" with access controls, while parsing and storing the non-extracted "remainder data" in separate "granular data stores." This architectural separation enhances security by isolating critical information ('169 Patent, col. 3:28-4:24).
• Technical Importance: This patent specifically addresses the architectural implementation of secure data management in a cloud environment by bifurcating sensitive and non-sensitive data into distinct, controlled storage locations (Compl. ¶130).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 ('169 Patent, col. 132:13-132:61; Compl. ¶129).
• The essential elements of Claim 1 include:
  • A method of organizing and processing data in a distributed cloud-based computing system.
  • Providing: (i) select content data stores for security designated data, (ii) granular data stores, and (iii) a cloud-based server, with the stores coupled over a communications network.
  • Extracting and storing security designated data in the select content data stores.
  • Activating the select content data stores to permit access based on access controls.
  • Parsing remainder data not extracted and storing it in the granular data stores.
  • Withdrawing data from the stores only when access controls are applied.

Multi-Patent Capsules

• Patent Identification: U.S. Patent No. 10,182,073, "Information Infrastructure Management Tools with Variable and Configurable Filters and Segmental Data Stores," issued January 15, 2019.

• Technology Synopsis: This patent discloses an information infrastructure where data throughput is processed by a plurality of initially configured filters. The core inventive concept appears to be the ability to dynamically alter these filters—by expanding, contracting, or reclassifying the criteria for sensitive and select content—and then generating modified filters to organize further data throughput ('073 Patent, Abstract).

• Asserted Claims: At least independent Claim 1 is asserted (Compl. ¶165).

• Accused Features: The complaint alleges that the accused systems, which allow an enterprise to define, run, and modify "policies" for data replication and vaulting, infringe the claims directed to altering and generating modified filters (Compl. ¶¶181, 182, 184).

• Patent Identification: U.S. Patent No. 10,250,639, "Information Infrastructure Management Data Processing Tools for Data Flow with Distribution Controls," issued April 2, 2019.

• Technology Synopsis: This patent describes a method for "sanitizing" data based on sensitivity levels and security clearances. It involves extracting sensitive content from a data input to obtain both the "extracted sensitive data" and the "remainder data." The system then uses various filters (content, contextual, taxonomic) to "inference" the sanitized data ('639 Patent, Abstract).

• Asserted Claims: At least independent Claim 16 is asserted (Compl. ¶192).

• Accused Features: The complaint alleges infringement by the accused systems' function of extracting critical account data (sensitive content) into a secure vault while leaving other data (remainder data) in the production environment, and subsequently using filters and analytics to manage the data (Compl. ¶¶ 202, 211, 217).

III. The Accused Instrumentality

Product Identification

• The "Accused Instrumentalities" are identified as the data backup and disaster recovery systems and methods that Defendant IBC makes, owns, operates, or uses, which are alleged to be compliant with the "Sheltered Harbor" specification or its operational equivalent (Compl. ¶95).

Functionality and Market Context

• The complaint alleges these systems provide for the secure vaulting of critical customer account data to protect against catastrophic system loss (Compl. ¶95). The core functionality involves extracting critical financial data, converting it to an industry-standard format, and storing it in an "ultra secure," "air-gapped," and immutable data vault that is isolated from production and backup systems (Compl. ¶¶ 69, 76). The complaint repeatedly uses the Dell PowerProtect Cyber Recovery solution as an exemplary system that satisfies the Sheltered Harbor standard (Compl. ¶71). A diagram included in the complaint illustrates this architecture, showing a "Production Environment" where data is extracted, replicated across an "Air-gap," and stored in a "Data Vault Environment" (Compl. ¶72). This standard is allegedly positioned as a critical resiliency measure for the entire U.S. financial services industry (Compl. ¶62).

IV. Analysis of Infringement Allegations

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

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the "protection policies" of the Sheltered Harbor standard, which appear to designate entire datasets (e.g., customer account databases) for backup, meet the claim limitation of a "categorical filter" that processes a "data input therethrough to obtain said select content." The defense may argue that selecting a whole database for backup is different from the granular, content-aware filtering of a data stream described in the patent.
  • Technical Questions: The complaint's assertion that the accused systems use "contextually associated" and "taxonomically associated" content relies on equating this with the use of "aggregated tags" and "metadata" (Compl. ¶¶ 108, 110). A point of contention may be whether the simple tagging or metadata grouping for backup management performs the specific function of establishing the contextual or taxonomic relationships required by the claim.

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

• Identified Points of Contention:
  • Scope Questions: The claim requires a "distributed cloud-based computing system." A potential dispute is whether the accused systems, which the complaint concedes can be on-premises (Compl. ¶72), meet this limitation. The analysis may turn on whether the mere capability of cloud deployment is sufficient, or if the system must be inherently cloud-native in its architecture.
  • Technical Questions: What evidence supports the allegation that the accused systems "parse" the "remainder data"? The complaint describes pulling data from backup storage on the production side (Compl. ¶152), which may not involve the kind of "parsing" envisioned by the patent, raising a question of technical mismatch.

V. Key Claim Terms for Construction

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

• The Term: "activating at least one of said designated categorical filters and processing a data input therethrough to obtain said select content"
• Context and Importance: This phrase is central to the infringement analysis. Its construction will determine whether applying a "protection policy" to an entire dataset for backup, as the accused systems allegedly do, constitutes "processing a data input therethrough" a "filter" to "obtain" content. Practitioners may focus on this term because it appears to describe an active filtering operation, which may differ from a policy that simply designates a data source for copying.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states that the data input may be "structured or unstructured" and can be processed by a filter that "may be the same as the initial data input" ('301 Patent, col. 14:26-31). This could support an interpretation where the "filter" is a broad policy and "processing" includes applying that policy to the entire dataset.
  • Evidence for a Narrower Interpretation: The specification describes filters that identify and extract specific content based on "content-based filters, contextual filters and taxonomic classification filters" ('301 Patent, col. 13:35-38). FIG. 3 shows a "SC Filter" (45) operating on "Data 1A" and "Data 1B" to produce a "Result Command" (51), suggesting a more granular, operational process than simply designating a file for backup.

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

• The Term: "cloud-based computing system"
• Context and Importance: This term appears in the preamble and body of the independent claim, making it a likely limitation. The case against IBC may depend on whether its specific implementation of the Sheltered Harbor standard qualifies as "cloud-based."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide a specific, limiting definition of "cloud-based." It describes distributed computing systems using the internet and remote servers, which is consistent with a general understanding of cloud computing ('169 Patent, col. 43:55-44:20).
  • Evidence for a Narrower Interpretation: The specification's primary embodiment for a distributed system is a personal computer connected to servers over the internet or a LAN/WAN (e.g., FIG. 6). A defendant could argue this describes a traditional client-server architecture, not a modern, virtualized, and scalable "cloud-based system" as the term is now understood, and therefore the claim should be limited to that specific architecture.

VI. Other Allegations

• Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement, focusing instead on allegations that Defendant directly infringes by making and using the accused systems.
• Willful Infringement: The complaint alleges that Defendant’s infringement is willful (Compl. ¶¶ 125, 161, 188, 223). The basis for this allegation is Defendant's alleged continued infringement after having received notice of the patents. The complaint claims notice was effective upon service of the complaint or, alternatively, as of November 21, 2023, due to Defendant's alleged awareness of lawsuits filed by DigitalDoors against competitor financial institutions (Compl. ¶226). Plaintiff further alleges that Defendant maintains a policy of "willfully blind[ing]" itself to the patent rights of others (Compl. ¶227).

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

This case appears to hinge on the alignment between the specific, granular data filtering and management methods described in the DigitalDoors patents and the alleged functionality of the industry-standard "Sheltered Harbor" disaster recovery systems. The central questions for the court will likely be:

• A core issue will be one of definitional scope: can the patents’ concept of using "categorical filters" to "extract select content" from a data stream be construed to cover the accused systems' use of "protection policies" to back up entire critical datasets, such as customer account databases, into a secure vault?
• A key evidentiary question will be one of architectural equivalence: does the accused system, which separates a production environment from a secure data vault, practice the specific architectural elements of the claims, such as parsing and storing "remainder data" in "granular data stores" ('169 patent) or dynamically "altering" filters ('073 patent)?
• A threshold question for at least one patent will be technological classification: does the accused instrumentality, which can be deployed either on-premises or in a third-party data center, constitute a "cloud-based computing system" as that term is used and defined within the context of the ’169 patent?