DigitalDoors Inc v. Texas Capital Bank

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigitalDoors, Inc. (Florida)
  • Defendant: Texas Capital Bank (Texas)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 7:25-cv-108, W.D. Tex., 03/06/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established business presence within the Western District of Texas and specifically targets customers in the district.
• Core Dispute: Plaintiff alleges that Defendant’s data security and disaster recovery systems, which are asserted to be compliant with the financial industry's "Sheltered Harbor" standard, infringe four patents related to methods for granularly identifying, extracting, storing, and managing sensitive data in distributed computing systems.
• Technical Context: The technology at issue addresses secure data management, particularly for disaster recovery, by shifting focus from file-level protection to content-level analysis, extraction, and compartmentalized storage.
• Key Procedural History: The complaint asserts the patents-in-suit are pioneering and have been cited in hundreds of subsequent patent applications by major technology and financial companies. It also alleges that Defendant was on notice of potential infringement due to its awareness of other lawsuits filed by Plaintiff against competitor financial institutions.

Case Timeline

Date	Event
2007-01-05	Earliest Priority Date for all Asserted Patents
2015-01-01	Sheltered Harbor initiative launched
2015-04-21	U.S. Patent No. 9,015,301 Issued
2017-08-15	U.S. Patent No. 9,734,169 Issued
2019-01-15	U.S. Patent No. 10,182,073 Issued
2019-04-02	U.S. Patent No. 10,250,639 Issued
2023-11-21	Alleged alternative notice date of patents-in-suit
2025-03-06	Complaint Filing Date

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

The Invention Explained

• Problem Addressed: The patent’s background section describes the vulnerability of enterprises operating in open information ecosystems and the inefficiency of managing unstructured or sensitive data using conventional, file-based security protocols (Compl. ¶27; ’301 Patent, col. 1:31-2:27). Enterprises lacked effective methods to automatically categorize and manage sensitive information based on the content itself, rather than just the file it resided in (Compl. ¶27; ’301 Patent, col. 1:39-55).
• The Patented Solution: The invention proposes a method and system for organizing data within a distributed computing system. The core of the solution is the use of a plurality of "designated categorical filters" (e.g., content-based, contextual, and taxonomic filters) to process a data input, identify and obtain "select content," and store that aggregated content in corresponding data stores ('301 Patent, Abstract; col. 3:25-4:18). This approach allows data processes, such as copying or archiving, to be associated with specific types of content, thereby enabling more granular control over sensitive information (Compl. ¶29).
• Technical Importance: The technology provided a content-centric approach to data security, enabling automated management based on the data's substance rather than its container file (Compl. ¶27).

Key Claims at a Glance

• The complaint asserts 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 of the 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.
  • Wherein activating the filter includes automatic or manual activation, with automatic activation being time-based, condition-based, or event-based.

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

The Invention Explained

• Problem Addressed: The patent addresses the need for secure data processing and storage in distributed, cloud-based computing environments, where sensitive data must be protected from unauthorized access while allowing for authorized retrieval and reconstruction (’169 Patent, col. 1:15-2:66).
• The Patented Solution: The invention describes a method for a distributed, cloud-based system that processes data to separate it into "security designated data" (sensitive content) and "remainder data." The system provides distinct data stores for each: "select content data stores" for the sensitive information and "granular data stores" for the remainder ('169 Patent, Abstract). The select content data stores are protected by access controls, and the system allows for withdrawing data from both types of stores only when those controls are satisfied (Compl. ¶136, 157; ’169 Patent, col. 3:35-4:8).
• Technical Importance: The invention provides a specific architecture for data segregation in a cloud environment, enhancing security by physically or logically separating sensitive information from the bulk of the data (Compl. ¶130).

Key Claims at a Glance

• The complaint asserts 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.
  • Each select content data store having respective access controls.
  • Providing a communications network coupling the stores and the server.
  • Extracting and storing the security designated data in respective select content data stores.
  • Activating a data store to permit access based on applying access controls.
  • Parsing remainder data not extracted and storing it in respective granular data stores.
  • Withdrawing data from the stores only in the presence of applied access controls.

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

• Technology Synopsis: This patent focuses on an information infrastructure where the filters used to identify and process sensitive or select data are themselves configurable (’073 Patent, Abstract). The system allows an operator to alter the filters—by expanding, contracting, or changing their classification structure—and then generate modified filters to organize subsequent data throughput differently (Compl. ¶181, 184).
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶165).
• Accused Features: The complaint accuses the ability of the Defendant's systems, such as the Dell PowerProtect Cyber Recovery platform, to allow an enterprise to define, run, and modify policies that govern data replication and storage (Compl. ¶182, 185). The complaint includes a screenshot from an instructional video showing a user interface for selecting and applying different filters to generate a report, illustrating the alleged modification capability (Compl. ¶182, p. 94).

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

• Technology Synopsis: This invention relates to a method of "sanitizing" data by processing it through a distributed system with multiple sensitivity levels and security clearances (’639 Patent, Abstract). The method involves extracting sensitive content from a data input, storing it in a secure "extract store," and then inferencing the sanitized data using content, contextual, and taxonomic filters (Compl. ¶193, 217).
• Asserted Claims: Independent claim 16 is asserted (Compl. ¶192).
• Accused Features: The accused functionality includes the Sheltered Harbor-compliant systems' process of extracting critical account data based on predefined policies and security levels, storing that sensitive data in a secure vault, and separating it from non-extracted "remainder" data. The complaint alleges that the use of data analytics and content scans within the accused systems constitutes the claimed "inferencing" step (Compl. ¶211, 220).

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are the systems and methods used by Texas Capital Bank for data backup and disaster recovery, which are alleged to be compliant with the "Sheltered Harbor" industry standard or are functionally equivalent (Compl. ¶95). The complaint specifically identifies the Dell PowerProtect Cyber Recovery solution as an exemplary system that satisfies the Sheltered Harbor requirements (Compl. ¶71).

Functionality and Market Context

The accused systems are designed to protect critical financial data from catastrophic events like cyberattacks (Compl. ¶62). Their core function is to create secure, segmented backups by extracting critical customer account information from production systems, converting it into a standard format, and storing it in an isolated, immutable, and "air-gapped" data vault (Compl. ¶69, 76). The complaint includes a diagram from a Dell Solution Brief illustrating this process, which shows data moving from a "Production Environment" to a secure "Data Vault Environment" via "Secure Replication" across an "Air-gap" (Compl. ¶72, p. 32). The Sheltered Harbor standard is described as a critical, industry-wide initiative for maintaining public confidence in the U.S. financial system (Compl. ¶65, 94).

IV. Analysis of Infringement Allegations

9,015,301 Patent Infringement Allegations

Claim Element (from Independent Claim 25)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a method of organizing and processing data in a distributed computing system having select content important to an enterprise...	Defendant operates a distributed system to manage and protect critical customer financial account data, which is important to its enterprise.	¶99, ¶101	col. 13:25-29
providing, in said distributed computing system, a plurality of select content data stores operative with a plurality of designated categorical filters...	The Accused Instrumentalities provide a data vault (a plurality of data stores) that houses content derived from designated "protection policies" (categorical filters) established by the enterprise.	¶104, ¶106	col. 13:30-40
activating at least one of said designated categorical filters and processing a data input therethrough to obtain said select content and associated select content...	The system activates protection policies (filters) to extract critical financial account information (select content) from customer data (data input). This extracted data is contextually or taxonomically associated using tags and metadata.	¶108, ¶109, ¶110	col. 13:41-48
storing said aggregated select content for said at least one categorical filter in said corresponding select content data store;	The system stores the aggregated critical account data in a corresponding data vault or storage unit.	¶112, ¶113	col. 13:49-52
for the activated categorical filter, associating at least one data process from the group of data processes including a copy process, a data extract process, a data archive process...	The system associates data processes like backup (copy/archive) and vaulting with the selected content, as dictated by the enterprise's protection policies.	¶115, ¶116	col. 13:54-59
applying the associated data process to a further data input based upon a result of said further data being processed by said activated categorical filter...	Once a protection policy is established, all subsequent data inputs are processed in the same way, with backups automatically going to the designated storage unit.	¶118, ¶119	col. 14:1-6
activating a designated categorical filter, which encompasses an automatic activation... and said automatic activation is time-based, distributed computer system condition-based, or event-based.	Processing occurs automatically on a designated time interval (e.g., nightly), upon a condition (detection of new assets), or based on an event.	¶121, ¶122	col. 14:12-19

Identified Points of Contention

• Scope Questions: A central question may be whether the term "categorical filter" as defined in the patent can be construed to read on the "protection policies" and rules for identifying "critical account data" as described in the Sheltered Harbor standard. The analysis will likely focus on whether these high-level business rules perform the specific technical filtering function claimed in the patent.
• Technical Questions: The complaint alleges that once a policy is established, subsequent data is processed in the same way. A technical question is whether this automated application constitutes "applying the associated data process to a further data input based upon a result" of that processing, as the claim requires, or if it is merely a repeated, independent application of a static rule.

9,734,169 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method of organizing and processing data in a distributed cloud-based computing system...	Defendant's systems can be implemented in a cloud-based environment (e.g., AWS, Azure, Google Cloud) to process and vault customer financial data.	¶130, ¶132	col. 132:13-17
providing... (i) a plurality of select content data stores for respective ones of a plurality of security designated data; and (ii) a plurality of granular data stores; and (iii) a cloud-based server...	The system provides a "data vault" (select content stores) for critical data and uses production/backup systems as "granular data stores" for the remaining data, all managed via servers which can be cloud-based. The complaint references a diagram showing "Backup Workloads" as granular stores separate from the "Cyber Recovery Vault."	¶136, ¶137, ¶139, ¶152; Compl. p. 71	col. 132:18-23
each select content data store having respective access controls thereat;	The data vault is protected by strict access controls, including security credentials and multi-factor authentication.	¶136, ¶149	col. 132:24-25
(with respect to data processed by said cloud-based system) extracting and storing said security designated data in respective select content data stores;	The system extracts critical financial account data (security designated data) and stores it in the secure data vault.	¶143, ¶144	col. 132:29-32
parsing remainder data not extracted from data processed... and storing the parsed data in respective granular data stores;	Data not extracted for the vault (remainder data) is stored in production and backup systems (granular data stores). The complaint shows a diagram of production workloads separate from the vault.	¶151, ¶152; Compl. p. 78	col. 132:36-39
withdrawing some or all of said security designated data and said parsed data from said respective data stores only in the presence of said respective access controls applied thereto.	Data can be withdrawn from the vault for restoration only after satisfying strict security measures and access controls.	¶157, ¶158	col. 132:40-44

Identified Points of Contention

• Scope Questions: The interpretation of "granular data stores" will be critical. The complaint equates this term with standard production and backup systems. A potential dispute is whether the patent requires a more specialized type of storage for the "remainder data" rather than simply the original source systems.
• Technical Questions: The claim requires a "cloud-based" system. The complaint alleges the accused systems are optionally implemented in the cloud (Compl. ¶132). A key factual issue for trial will be the specific architecture Defendant actually uses and whether it meets the "cloud-based" limitation.

V. Key Claim Terms for Construction

"categorical filters" (’301 Patent, Claim 25)

• Context and Importance: This term is fundamental to the infringement allegation against the '301 Patent. Plaintiff’s theory requires equating the "protection policies" and rules for identifying "critical account data" in the Sheltered Harbor standard with the patent's "categorical filters." The case may turn on whether these high-level, business-driven rules are coextensive with the technical filtering mechanisms described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes filters as including "content-based filters, contextual filters and taxonomic classification filters" ('301 Patent, col. 13:31-36). This language suggests a broad definition that could encompass any system that selects data based on its content, context, or classification.
  • Evidence for a Narrower Interpretation: The specification provides specific examples, such as filters that identify and process data based on security levels like "Top Secret" or other specific labels and keywords ('301 Patent, col. 18:25-45). A defendant may argue that this context limits the term to more granular, security-classification-based filtering than the accused systems' identification of entire "critical account data" sets.

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

• Context and Importance: The claim requires not only extracting sensitive data but also "parsing" and storing the non-extracted "remainder data." The infringement allegation hinges on showing that the accused systems do more than just leave the original data in place; they must perform an affirmative act of "parsing" and "storing" this remainder. Practitioners may focus on this term because the accused process is described as "pulling data from backup storage on the production side" (Compl. ¶152), which raises the question of whether any action is taken on the "remainder" data at all.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not appear to provide a specific, narrow definition of "parsing remainder data." It could be argued that simply identifying what is not extracted and ensuring it is retained in its original storage location satisfies the requirement to "parse" and "store" it.
  • Evidence for a Narrower Interpretation: The term "parsing" typically implies an active process of analyzing and breaking down data. A defendant may argue that the claim requires an affirmative processing step on the remainder data itself, not just the act of leaving it behind after extracting the sensitive portions. The specification discusses splitting a data stream and creating granular pieces, which suggests a more active process than simple non-extraction ('169 Patent, col. 16:24-34).

VI. Other Allegations

Willful Infringement

The complaint alleges willful infringement based on both post-suit and pre-suit knowledge (Compl. Count V). The primary allegation is that Defendant has been on notice of the patents at least since the date of service of the complaint (Compl. ¶226). In the alternative, the complaint alleges Defendant should have known of the patents as of November 21, 2023, due to awareness of other patent infringement lawsuits filed by DigitalDoors against competitor financial institutions (Compl. ¶226). The complaint further alleges willful blindness, asserting that Defendant has a policy of not reviewing patents owned by others (Compl. ¶227).

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

• A core issue will be one of technical translation: can the business-level requirements of the "Sheltered Harbor" standard (e.g., "isolate critical account data," "create an air-gapped vault") be mapped directly onto the specific technical limitations recited in the patent claims (e.g., "categorical filters," "parsing remainder data," "granular data stores")? The dispute may focus on whether complying with an industry resiliency framework is legally equivalent to practicing the patented methods.
• A key evidentiary question will be one of architectural reality: what is the specific, technical implementation of the data security and recovery system used by Texas Capital Bank? While the complaint relies on public-facing documents for exemplary systems, the infringement analysis will ultimately depend on evidence from discovery detailing the defendant's actual hardware and software architecture, its data processing workflows, and whether its system is, in fact, "cloud-based" as required by one of the asserted claims.
• A third central question will be one of claim scope and modification: for the '073 patent, does the ability to create and "modify existing policies" within the accused systems' user interface equate to the claimed method of "altering... filters by... expanding... contracting... or imposing... a hierarchical or an orthogonal classification"? This will require a detailed comparison between the system's policy management features and the specific types of filter alteration described in the patent.