DigitalDoors Inc v. Pinnacle Bank

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigitalDoors, Inc. (Florida)
  • Defendant: Pinnacle Bank (Texas)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 7:25-cv-107, 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, 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 securely filtering, storing, and processing sensitive data in distributed computing systems.
• Technical Context: The technology addresses secure data vaulting for disaster recovery, a critical function for financial institutions facing increasing risks of destructive cyberattacks.
• Key Procedural History: The complaint notes the patents-in-suit are "pioneering" and have been cited as relevant prior art in hundreds of subsequent patent applications by major technology and financial services companies. No prior litigation or post-grant proceedings are mentioned in the complaint.

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 (’301 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section describes the state of the art as suffering from several deficiencies, including the inability to effectively manage unstructured content, the inefficiency of classifying sensitive data without semantic analysis, and the vulnerability of open enterprise ecosystems to security breaches (Compl. ¶27; ’301 Patent, col. 1:31-2:27). Enterprises also struggled to manage the changing sensitivity of information over its lifecycle (Compl. ¶32; ’301 Patent, col. 2:28-61).
• The Patented Solution: The invention proposes a method of organizing and processing data that shifts focus from the data file to the content itself (’301 Patent, Abstract). It achieves this by using a system of designated "categorical filters" to process data, identify and obtain "select content," associate that content with specific data processes (e.g., copy, archive, destroy), and store the resulting aggregated content in corresponding data stores (Compl. ¶¶89-90; ’301 Patent, col. 3:20-4:18).
• Technical Importance: This approach provided a method for granular, content-aware data management, which enables enhanced data security and survivability in distributed systems compared to conventional file-level security protocols (Compl. ¶¶27, 36; ’301 Patent, col. 9:46-58).

Key Claims at a Glance

• The complaint asserts independent method claim 25 (’301 Patent, Claim 25; Compl. ¶98).
• The essential elements of Claim 25 include:
  • 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 can be automatic (time-based, condition-based, or event-based) or manual.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

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 (’169 Patent).

The Invention Explained

• Problem Addressed: The patent addresses the need to secure designated data within a distributed or cloud-based system where data is stored in multiple locations and requires controlled access for processing and reconstruction (’169 Patent, Abstract).
• The Patented Solution: The invention describes a method for organizing and processing data in a distributed, cloud-based system. The system provides separate "select content data stores" for sensitive data and "granular data stores" for other data, managed by a cloud-based server with access controls (’169 Patent, Abstract). The method involves extracting and storing the sensitive ("security designated") data, while parsing the non-extracted "remainder data" and storing it separately. Access to and withdrawal of the secured data is permitted only through the application of access controls (’169 Patent, Abstract; col. 3:28-4:9).
• Technical Importance: This patent describes an architecture for what is effectively a secure data vault, separating critical information from the remainder and controlling access, which is foundational to modern cyber-resilience strategies (Compl. ¶¶130, 136).

Key Claims at a Glance

• The complaint asserts independent method claim 1 (’169 Patent, Claim 1; Compl. ¶129).
• The essential elements of Claim 1 include:
  • Providing a distributed cloud-based system with (i) select content data stores for security designated data, (ii) granular data stores, and (iii) a cloud-based server, all coupled over a communications network.
  • Extracting and storing security designated data in the select content data stores.
  • Activating a data store to permit access based on access controls.
  • Parsing remainder data not extracted from the processed data.
  • Storing the parsed remainder data in the granular data stores.
  • Withdrawing security designated data and parsed data from their respective stores only when access controls are applied.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 10,182,073

• 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 (’073 Patent).
• Technology Synopsis: This patent focuses on an information infrastructure where the filters used to process data are dynamic. It claims a method that includes identifying sensitive and select content with initially configured filters and then altering those filters by expanding, contracting, or changing their classification structure, and then generating modified filters based on those alterations (Compl. ¶¶181, 184; ’073 Patent, Claim 1).
• Asserted Claims: Independent method claim 1 is asserted (Compl. ¶165).
• Accused Features: The complaint alleges that Sheltered Harbor-compliant systems, which allow an enterprise to define, run, and modify existing policies to control data replication and vaulting, infringe the ’073 Patent (Compl. ¶¶181-182). A screenshot from a Dell instructional video shows a user interface for selecting and modifying filter options for reports, which Plaintiff presents as evidence of this capability (Compl. ¶182, p. 94).

U.S. Patent No. 10,250,639

• Patent Identification: U.S. Patent No. 10,250,639, "Information Infrastructure Management Data Processing Tools for Regulating Data Flow with Distribution Controls," issued April 2, 2019 (’639 Patent).
• Technology Synopsis: This patent relates to a method for "sanitizing" data processed in a distributed system. The method involves extracting sensitive content based on a plurality of sensitivity levels and security clearances, creating "sanitized" data from the non-extracted content, and then "inferencing" the sanitized data using content, contextual, and taxonomic filters (Compl. ¶¶193, 214, 217; ’639 Patent, Claim 16).
• Asserted Claims: Independent method claim 16 is asserted (Compl. ¶192).
• Accused Features: The accused features are systems that extract critical financial account data (the sensitive content) for storage in a secure vault, thereby creating a sanitized version of the data that can be used for recovery. The use of filters to identify the critical data for extraction is alleged to be the claimed "inferencing" step (Compl. ¶¶215, 217-218).

III. The Accused Instrumentality

Product Identification

• The Accused Instrumentalities are the data backup and disaster recovery systems and methods that Defendant Pinnacle Bank "makes, owns, operates, uses, or otherwise exercises control over" (Compl. ¶95). The complaint alleges these systems are compliant with the "Sheltered Harbor" specification or are functionally equivalent (Compl. ¶95).

Functionality and Market Context

• The complaint alleges the accused systems perform secure "data vaulting" to protect critical customer financial data from destructive cyberattacks (Compl. ¶62). The core functionality involves extracting this critical data, converting it into an industry-standard format, and transmitting it to a secure, isolated, and immutable "data vault" that is "air-gapped" from production and backup networks (Compl. ¶¶69, 76, 79). In the event of a catastrophic failure, this vaulted data can be used to restore basic customer services (Compl. ¶70). The complaint uses the Dell PowerProtect Cyber Recovery solution as an exemplary and endorsed implementation of the Sheltered Harbor standard (Compl. ¶71). A diagram from a Dell solution brief illustrates this architecture, showing a "Production Environment" where data is extracted and a separate, air-gapped "Data Vault Environment" where data is replicated and stored (Compl. ¶72, p. 32).
• Sheltered Harbor is described as an industry-driven initiative launched in 2015 to promote the stability of U.S. financial markets, with participation from institutions holding nearly three-quarters of U.S. deposit accounts (Compl. ¶¶62, 64-65).

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 "protection rules" utilized by the accused systems (Compl. ¶¶87, 109) meet the definition of "designated categorical filters" as claimed in the patent. The analysis may explore whether a high-level policy setting constitutes the type of active data filter contemplated by the patent.
  • Technical Questions: The complaint alleges that extracted data is "contextually or taxonomically associated" through the use of metadata tags (Compl. ¶¶88, 110). A point of contention may be what evidence exists that the accused systems perform this specific type of association as part of the filtering and extraction process required by the claim.

'169 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The claim requires a "cloud-based computing system." While the complaint alleges the systems can be deployed on cloud platforms (Compl. ¶132), the primary architecture described appears to be an on-premises vault. The construction of "cloud-based" will be critical to determining if all implementations of the accused systems infringe.
  • Technical Questions: The claim requires parsing and storing "remainder data" in "granular data stores." The complaint maps this function to the standard production and backup systems that exist outside the secure vault (Compl. ¶152). A potential dispute is whether these general-purpose production systems function as the claimed "granular data stores" that are part of the inventive method of organizing data.

V. Key Claim Terms for Construction

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

• Context and Importance: This term is foundational to the infringement theory against the '301 patent. The complaint equates this term with the "protection policies" and "protection rules" that govern the operation of the accused Sheltered Harbor systems (Compl. ¶¶87, 107). Practitioners may focus on this term because its scope will determine whether a high-level, user-defined policy for data backup qualifies as the specific type of data filter claimed by the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests "categorical filters" is a broad category, stating the sys-operator may activate one on "content, contextual or taxonomic classification" (’301 Patent, col. 14:7-9). The patent also describes enterprise-level policies influencing the filters, such as "customer privacy policy, supplier privacy policy, enterprise human resource privacy policy," which could support an interpretation inclusive of high-level business rules (’301 Patent, col. 4:15-21).
  • Evidence for a Narrower Interpretation: The detailed description often discusses filters in the context of specific data operations, such as identifying content based on "predetermined words, characters, images, data elements or data objects" (’301 Patent, col. 13:30-32). This could suggest a narrower interpretation where the "filter" must operate directly on the data content itself, rather than being a more abstract policy instruction.

• The Term: "distributed cloud-based computing system" (from ’169 Patent, Claim 1)

• Context and Importance: The applicability of Claim 1 hinges on this term. The complaint alleges the accused systems are optionally implemented on cloud platforms like AWS and Azure (Compl. ¶132), but the core architecture described is an isolated, air-gapped data vault that could be on-premises. Whether an on-premises private vault connected to a production network constitutes a "cloud-based" system will be a central issue.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not appear to provide a specific definition for "cloud-based." A party could argue for a broad meaning consistent with the NIST definition of a cloud, which includes private cloud deployments that are not necessarily hosted by a third party. The patent's focus on distributed storage and remote access could support this view.
  • Evidence for a Narrower Interpretation: A party could argue that, in the context of the patent, the term implies reliance on third-party, multi-tenant infrastructure, consistent with the common understanding of public cloud services. The lack of an explicit definition in the specification may lead a court to rely heavily on the plain and ordinary meaning of the term to a person of ordinary skill in the art at the time of the invention.

VI. Other Allegations

• Willful Infringement: The complaint includes a count for "Knowledge and Willfulness," alleging that Defendant has been on actual notice of the patents since at least the service of the complaint (Compl. ¶226). It further alleges constructive notice since at least November 21, 2023, based on "awareness of the patent infringement lawsuits filed by DigitalDoors against competitor financial institutions" (Compl. ¶226). Plaintiff also alleges Defendant maintains a policy of "willfully blind[ness] to the patent rights of Plaintiff" by instructing employees not to review patents of others (Compl. ¶227).

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

• A core issue will be one of definitional scope: Can the patent claim term "designated categorical filters" be construed broadly enough to read on the high-level "protection policies" that govern data backup and vaulting in the accused Sheltered Harbor-compliant systems? The outcome may depend on whether a policy is considered equivalent to a filter that actively processes a data input.
• A second key issue will be one of architectural mapping: Does the accused "production environment" and separate, air-gapped "data vault" architecture map onto the specific claim elements of "select content data stores" and "granular data stores" in the '169 patent, and does this architecture necessarily constitute a "cloud-based" system as required by that patent's asserted claim?
• Finally, a central evidentiary question may be one of system control and operation: Given that the accused systems may be implemented using technology from third-party vendors (like Dell) or hosted on third-party platforms, the case may explore what specific actions Defendant Pinnacle Bank takes to "use" or "operate" the systems and whether it performs every step of the asserted method claims.