DCT
7:25-cv-00109
DigitalDoors Inc v. Vantage Bank Texas
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: DigitalDoors, Inc. (Florida)
- Defendant: Vantage Bank Texas (Texas)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 7:25-cv-00109, W.D. Tex., 03/06/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established business presence, including physical branch locations and employees, within the Western District of Texas and specifically targets customers in the district.
- Core Dispute: Plaintiff alleges that Defendant’s financial data backup and disaster recovery systems, particularly those compliant with the industry-wide "Sheltered Harbor" standard, infringe four patents related to secure, granular data processing, filtering, and storage.
- Technical Context: The technology concerns systems for identifying, extracting, and securely vaulting critical data to ensure business continuity after a catastrophic event, a key operational and regulatory concern in the financial services sector.
- Key Procedural History: The complaint states the patented technology was originally developed to provide data-security and survivability solutions for the U.S. government and military. It also notes the patents have been cited as relevant prior art in hundreds of subsequent patent applications by major technology and financial services companies.
Case Timeline
| Date | Event |
|---|---|
| 2007-01-05 | Earliest Priority Date for all Asserted Patents |
| 2015-04-21 | U.S. Patent No. 9,015,301 Issued |
| 2015 | Sheltered Harbor financial industry initiative launched |
| 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 date of Defendant's awareness of patents from prior lawsuits |
| 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, Analysis and Classification and Method Therefor"
- Patent Identification: U.S. Patent No. 9,015,301, "Information Infrastructure Management Tools with Extractor, Secure Storage, Analysis and Classification and Method Therefor," issued April 21, 2015 (the "’301 Patent").
The Invention Explained
- Problem Addressed: The patent describes a need to move beyond file-level security to manage sensitive information at the content level within large, open enterprise computing ecosystems. Conventional systems were allegedly unable to effectively manage the changing sensitivity of information over its lifecycle or apply granular security policies directly to the data itself (Compl. ¶27; ’301 Patent, col. 1:60-2:61).
- The Patented Solution: The invention is a method 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" from a data input. This extracted content is stored in designated data stores, and specific data processes—such as copying, archiving, or destruction—are associated with the content based on the activated filter. The activation of these filters can be automated based on time, system conditions, or events (’301 Patent, Abstract; col. 4:1-17).
- Technical Importance: The technology enabled a shift from managing data files to managing the sensitive content within those files, allowing for more granular and dynamic security and lifecycle management (Compl. ¶27).
Key Claims at a Glance
- The complaint asserts at least independent Claim 25 (’301 Patent, Compl. ¶98).
- Claim 25 of the ’301 Patent requires:
- 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 filter and processing a data input through it 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) for the activated filter.
- Applying the associated data process to a further data input processed by the filter.
- 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.
U.S. Patent No. 9,734,169 - "Digital Information Infrastructure and Method for Securing Designated Data and with Granular Data Stores"
- 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 "’169 Patent").
The Invention Explained
- Problem Addressed: The patent addresses the security risks of centralized data repositories by proposing a method to disperse data into smaller, more granular pieces across different storage locations, making it harder for an attacker to access the total content (’169 Patent, col. 17:25-34).
- The Patented Solution: The invention describes a method for a distributed, cloud-based system that processes data to separate it into "security designated data" and "remainder data." The sensitive, security-designated data is stored in a plurality of "select content data stores," each with its own access controls. The non-extracted remainder data is parsed (either randomly or algorithmically) and stored separately in a plurality of "granular data stores." Data can only be withdrawn from the secure stores when the proper access controls are applied (’169 Patent, Abstract; col. 4:26-44).
- Technical Importance: This architecture improves data security by physically and logically separating sensitive from non-sensitive data across distinct, access-controlled storage locations within a distributed or cloud-based environment (Compl. ¶¶52, 99-100).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (’169 Patent, Compl. ¶129).
- Claim 1 of the ’169 Patent requires:
- Providing a system with a plurality of select content data stores, a plurality of granular data stores, and a cloud-based server.
- Providing a communications network coupling the stores and the server.
- 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 step includes both random and algorithm-based parsing.
- Withdrawing data from the stores only in the presence of applied access controls.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 10,182,073 - "Information Infrastructure Management Tools with Variable and Reconfigurable Filters and Segmental Data Stores"
- Patent Identification: U.S. Patent No. 10,182,073, "Information Infrastructure Management Tools with Variable and Reconfigurable Filters and Segmental Data Stores," issued January 15, 2019 (the "’073 Patent").
- Technology Synopsis: This patent focuses on creating a data processing infrastructure where an enterprise can dynamically alter initially configured filters. The alterations can include expanding or contracting the scope of content being filtered, or changing its classification, which in turn generates modified filters for organizing subsequent data throughput (’073 Patent, Abstract).
- Asserted Claims: At least independent Claim 1 (Compl. ¶165).
- Accused Features: The complaint alleges infringement by systems that allow an enterprise to define, run, and modify data protection policies and their parameters, such as the Dell PowerProtect system's user interface for creating and modifying policies (Compl. ¶¶181-182).
U.S. Patent No. 10,250,639 - "Information Infrastructure Management Data Processing Tools for Regulated Data Flow with Distribution Controls"
- Patent Identification: U.S. Patent No. 10,250,639, "Information Infrastructure Management Data Processing Tools for Regulated Data Flow with Distribution Controls," issued April 2, 2019 (the "’639 Patent").
- Technology Synopsis: This patent claims a method for "sanitizing" data by extracting sensitive content based on a plurality of sensitivity levels and security clearances. The system creates sanitized data by separating extracted sensitive content from remainder data and then uses content, contextual, and taxonomic filters to "inference" the resulting sanitized data (’639 Patent, Abstract).
- Asserted Claims: At least independent Claim 16 (Compl. ¶192).
- Accused Features: The complaint alleges infringement by systems that extract critical account information based on predefined priority filters and store it in a secure data vault, thereby creating a sanitized version of the data for disaster recovery purposes (Compl. ¶¶197, 214-215).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant VBT’s systems and methods for processing and backing up data in a distributed system. The complaint specifically identifies systems that 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 for disaster recovery, a practice standardized by the Sheltered Harbor initiative for the U.S. financial sector (Compl. ¶¶62, 95). The core alleged functionality involves extracting critical customer account data from a production environment, replicating it, and storing it in a secure, immutable, and isolated "data vault" that is "air-gapped" from corporate networks (Compl. ¶¶72, 76). This ensures that a clean copy of essential data is available for restoration following a destructive cyberattack or other system failure (Compl. ¶65). A diagram in the complaint illustrates a compliant solution where data is extracted, replicated, and moved across an "Air-gap" to a "Data Vault Environment" for processing and locked storage (Compl. p. 32). This functionality is described as an industry-driven, and in some cases regulator-recognized, standard for maintaining public confidence in the financial system (Compl. ¶¶65, 94).
IV. Analysis of Infringement Allegations
U.S. Patent No. 9,015,301 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... said distributed computing system having select content important to an enterprise operating said distributed computing system... | Defendant VBT, the enterprise, operates a distributed computing system to manage and protect critical customer financial account data, which is the select content. | ¶¶99, 101 | col. 13:28-35 |
| 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" with multiple designated data stores (e.g., for backup, copy, analysis) that are operative with categorical filters established by the enterprise, such as "protection policies." | ¶¶104-106 | col. 13:36-41 |
| activating at least one of said designated categorical filters and processing a data input therethrough to obtain said select content and associated select content, which associated select content is at least one of contextually associated select content and taxonomically associated select content, as aggregated select content | The enterprise activates "protection policies" (filters) to extract critical financial account information. This data is contextually or taxonomically associated through the use of metadata and tags. | ¶¶108-110 | col. 13:50-58 |
| storing said aggregated select content for said at least one categorical filter in said corresponding select content data store | The extracted critical account data is aggregated and stored in corresponding data stores (storage units or trees) within the secure data vault. | ¶¶112-113 | col. 13:59-62 |
| and 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, a data distribution process and a data destruction process | The system associates data processes such as copying, extracting, and archiving data with the select content in order to move it to the data vault in accordance with Sheltered Harbor's technical requirements. | ¶¶115-116 | col. 14:1-11 |
| 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, subsequent data inputs are processed in the same way, with the system automatically applying the associated backup and vaulting processes. | ¶¶118, 119 | col. 14:12-17 |
| activating a designated categorical filter, which encompasses an automatic activation or a manual activation and said automatic activation is time-based, distributed computer system condition-based, or event-based | The processing takes place automatically based on a time interval (e.g., nightly backups), a condition (detection of new data), or manually ("on demand"). | ¶¶121-123 | col. 14:43-50 |
Identified Points of Contention
- Scope Questions: A central question may be whether the "protection policies" and "protection rules" described in the accused Sheltered Harbor systems (Compl. ¶¶87, 109) meet the definition of the "plurality of designated categorical filters" as required by the claim. The defense could argue that its backup policies are not the specific "content-based, contextual, and taxonomic" filters envisioned by the patent.
- Technical Questions: The complaint alleges the association of several distinct data processes (copy, extract, archive, distribution, destruction). A factual question will be what evidence demonstrates that the accused systems perform this specific range of processes and apply them to subsequent data inputs as claimed, rather than performing a more general backup or replication function.
U.S. Patent No. 9,734,169 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... | The accused systems are implemented in a distributed architecture and can be deployed on cloud platforms such as AWS, Azure, or Google Cloud. | ¶¶130, 132 | col. 132:15-18 |
| providing in said distributed cloud-based computing system: (i) a plurality of select content data stores... (ii) a plurality of granular data stores; and (iii) a cloud-based server... | The system provides a secure data vault (plurality of select content stores) and a production/backup environment (plurality of granular data stores), which can be implemented on cloud servers. | ¶¶136-139 | col. 132:19-27 |
| extracting and storing said security designated data in respective select content data stores... | Critical financial account information (security designated data) is extracted from the production environment and stored in the secure, air-gapped data vault (select content stores). | ¶¶143-144 | col. 132:31-34 |
| parsing remainder data not extracted from data processed... and storing the parsed data in respective granular data stores | Remainder data (non-extracted production and backup data) is stored in the production-side systems (granular data stores), separate from the vaulted data. A diagram in the complaint illustrates these separate "Production Workloads" (Compl. p. 78). | ¶¶151-152 | col. 132:41-44 |
| including both (i) randomly parsing and storing said remainder data, and (ii) parsing and storing said remainder data according to a predetermined algorithm... | Data traffic to and from the data vault, as well as data in the production environment, is encrypted, which the complaint equates to random parsing or parsing based on a predetermined algorithm. | ¶¶154-155 | col. 132:45-50 |
| 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 only be withdrawn from the secure vault for restoration after applying strict access controls, such as multi-factor authentication. | ¶¶157-158 | col. 132:51-55 |
Identified Points of Contention
- Scope Questions: The analysis may turn on whether the accused system’s architecture maps cleanly onto the patent’s terms. For instance, does the "production environment" where original data resides qualify as "granular data stores" for "remainder data," and does the secure "data vault" qualify as "select content data stores" for "security designated data"?
- Technical Questions: The claim requires both "randomly parsing" and "parsing... according to a predetermined algorithm." A key factual question will be whether the encryption methods used in the accused systems perform the function of "parsing" in the manner required by the claim.
V. Key Claim Terms for Construction
Term from the ’301 Patent: "categorical filters"
- The Term: "categorical filters"
- Context and Importance: This term is the core of the invention claimed in the ’301 Patent. The infringement case depends on whether the "protection policies" and "rules" used by the accused Sheltered Harbor systems (Compl. ¶¶87, 109) fall within the scope of this term. Practitioners may focus on this term because the defense may argue that generic backup rules are not the specific, multi-type filtering system described in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent summary states the system has "a plurality of enterprise designated categorical filters which include content-based filters, contextual filters and taxonomic classification filters" (’301 Patent, col. 3:37-41). This inclusive language ("include") may support an argument that the term is not limited to only these three types.
- Evidence for a Narrower Interpretation: The detailed description repeatedly and specifically defines the filters by these three types and explains their distinct technical functions, such as using a "Knowledge Expander" for taxonomic filters (’301 Patent, col. 10:22-32). This may support an argument that "categorical filters" requires the presence of these specific, technologically distinct filter types.
Term from the ’169 Patent: "granular data stores"
- The Term: "granular data stores"
- Context and Importance: The architectural separation of data is central to the ’169 Patent. The infringement theory maps this term to the production and backup systems where "remainder data" is stored (Compl. ¶152). Its construction will determine if the accused architecture infringes.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent abstract refers to "a plurality of granular data stores," suggesting any system with multiple storage locations for pieces of data could qualify (’169 Patent, Abstract).
- Evidence for a Narrower Interpretation: The specification describes the "granular" concept as a security feature where data is broken into "smaller and more granular pieces of data" using a dispersal algorithm to reduce the risk if any single store is compromised (’169 Patent, col. 15:52-59). This suggests the term may require more than just standard production storage; it may require an active process of granulation for security purposes.
VI. Other Allegations
Indirect Infringement
- The complaint does not plead separate counts for indirect infringement, focusing instead on allegations that VBT directly infringes by making, using, and controlling the accused systems within the United States (Compl. ¶¶98, 129).
Willful Infringement
- The complaint alleges that any post-notice infringement is willful and deliberate. It bases this allegation on Defendant having received actual notice upon service of the complaint, and alternatively on Defendant having been on notice of the patents since at least November 21, 2023, due to its awareness of similar lawsuits filed against competitor financial institutions. The complaint further alleges that Defendant has a policy or practice of not reviewing the patents of others, constituting willful blindness (Compl. ¶¶226-227).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the patent term "categorical filters," which is described in the specification with specific technical implementations like "taxonomic" and "contextual" filters, be construed broadly enough to read on the "protection policies" and "rules" that govern data backup and vaulting in the accused Sheltered Harbor systems?
- A second key issue will be one of architectural mapping: does the accused system's division between a "production environment" and a secure, air-gapped "data vault" correspond to the claimed architecture of "granular data stores" for remainder data and "select content data stores" for sensitive data, or is there a fundamental mismatch between the patent's specific structure and the industry-standard disaster recovery framework?
- An evidentiary question will be one of functional identity: what proof will be offered to show that the accused systems perform the specific, multi-step data processing methods recited in the claims—such as associating a range of distinct processes (copy, extract, archive, destroy) or performing specific types of "parsing"—beyond the general function of creating secure, isolated backups?