Focus Global Solutions LLC v. Marvell Semiconductor Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Focus Global Solutions LLC (Delaware)
  • Defendant: Marvell Semiconductor, Inc. (California)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00240, W.D. Tex., 05/21/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the district and committing alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that certain of Defendant's products infringe a patent related to methods and apparatuses for managing and recognizing the topology of Storage Area Networks (SANs).
• Technical Context: The technology relates to the management of large-scale, complex data storage systems, known as Storage Area Networks (SANs), which are a critical technology for enterprise computing and data centers.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 6,920,494 - "Storage area network methods and apparatus with virtual SAN recognition"

• Patent Identification: U.S. Patent No. 6,920,494, titled “Storage area network methods and apparatus with virtual SAN recognition,” issued July 19, 2005.

The Invention Explained

• Problem Addressed: The patent describes a challenge in managing the proliferation of hosts and storage devices in complex Storage Area Networks (SANs). Prior art solutions, such as configuring individual switches or interfaces to "block" access, were often specific to a single vendor's equipment and lacked a sophisticated, network-wide view of the topology ('494 Patent, col. 1:55-68).
• The Patented Solution: The invention proposes a system comprising a central "manager" and distributed "agents" that reside on host computers within the SAN. The agents employ "scanners" to collect information about the network components visible from their respective hosts. The manager then collects and "disambiguates" this information from multiple agents to construct a comprehensive topological map of the SAN, including identifying "virtual SANs" composed of elements that share common storage devices across different network zones ('494 Patent, Abstract; col. 2:35-51). Figure 1 illustrates this general architecture, showing a Manager (20) communicating with multiple Hosts (12a-c) that are connected to a SAN.
• Technical Importance: This technology provided a software-based, vendor-agnostic method for discovering and managing a SAN's topology, enabling more flexible and intelligent administration than was possible with hardware-centric "zoning" approaches ('494 Patent, col. 1:63-68).

Key Claims at a Glance

• The complaint does not specify which claims of the '494 Patent are asserted, instead referring to "Exemplary '494 Patent Claims" identified in an exhibit not provided with the complaint (Compl. ¶11, ¶13).
• Independent claim 10 is representative of the patent's apparatus claims and recites the following essential elements:
  • A storage area network (SAN) comprising a plurality of hosts, storage units, and an interconnect forming a plurality of regions.
  • A "manager digital data processor" that maintains a topological representation of the SAN.
  • One or more "scanners" that communicate with the hosts and the manager to determine the hosts and storage units in each region.
  • The manager determining a topology of a portion of the SAN as a function of the information collected by the scanners.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as the “Exemplary Defendant Products” (Compl. ¶11). These products are not named in the body of the complaint but are purportedly identified in claim charts in Exhibit 2, which was not filed with the complaint (Compl. ¶13).

Functionality and Market Context

• The complaint does not describe any specific features or functions of the accused products. It alleges in a conclusory manner that the products "practice the technology claimed by the '494 Patent" and "satisfy all elements of the Exemplary '494 Patent Claims" based on the non-provided claim charts (Compl. ¶13). The complaint makes no allegations regarding the products' commercial importance or market position.
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are contained entirely within references to claim charts in Exhibit 2, which was not provided with the publicly filed complaint (Compl. ¶13, ¶14). The complaint alleges that these charts demonstrate that the "Exemplary Defendant Products" practice the claimed technology and satisfy all elements of the asserted claims (Compl. ¶13). Without this exhibit, a detailed analysis of the infringement allegations is not possible. The narrative theory of infringement is limited to the assertion that the accused products infringe "literally or by the doctrine of equivalents" (Compl. ¶11).

• Identified Points of Contention:
  • Product vs. System Scope: The '494 Patent claims a system-level "storage area network" that includes a "manager digital data processor" and "scanners" ('494 Patent, Claim 10). A central question may be whether Defendant's semiconductor products can, by themselves, constitute the entire claimed system. The allegation of direct infringement raises the question of whether Plaintiff's theory is that Defendant’s products embody the entire claimed system or are merely a component of a larger infringing system made or used by others.
  • Evidentiary Questions: The complaint lacks any factual allegations detailing how the accused products operate. A primary point of contention will be the evidence Plaintiff offers to demonstrate that Defendant's products incorporate the functionalities of a "manager" and "scanners" as required by the claims and perform the function of determining SAN topology.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of specific infringement disputes. However, based on the technology and the nature of the parties, the following terms may be central to the case.

• The Term: "manager digital data processor"

• Context and Importance: This term is a core component of the claimed system. As Defendant is a semiconductor company, the parties will likely dispute whether this limitation can be met by a software module on a chip or if it requires a separate, standalone computer. Practitioners may focus on this term because its construction could determine whether the claims read on Defendant's products or only on larger end-user systems.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the manager as a "manager process, device or other functionality," suggesting it is not limited to a specific physical form ('494 Patent, col. 2:40-42).
  • Evidence for a Narrower Interpretation: Figures in the patent, such as Figure 1, depict the "Manager" (20) as a discrete computer, physically separate from the "Host" computers (12a-c), which could support an interpretation requiring a distinct device ('494 Patent, Fig. 1).

• The Term: "scanner"

• Context and Importance: This term defines the data-gathering element of the invention. The dispute will likely turn on whether any function within Defendant's products performs the specific actions of a "scanner" as described in the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The Abstract states that scanners are "operating within agents associated with the hosts," which may support an interpretation that a "scanner" is a software function ('494 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The specification discloses specific scanner executables, such as 'sandiscover', which performs "operating system queries to the managed host and SCSI queries to the endpoint devices" ('494 Patent, col. 25:27-30). This could support a narrower construction requiring specific query-and-discovery functionality, not merely any data-reporting process.

VI. Other Allegations

• Willful Infringement: The complaint’s prayer for relief requests that the case be declared "exceptional" and seeks an award of attorneys' fees, which is often associated with findings of willful infringement (Compl. ¶E(i)). However, the body of the complaint contains no factual allegations to support a claim for willfulness, such as any assertion of pre-suit or post-suit knowledge of the '494 Patent.

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

• A core issue will be one of infringement scope: can the claims, which describe a multi-component "storage area network" system, be read to cover the semiconductor products sold by Defendant? The viability of the direct infringement allegation may depend on whether a single accused product can be shown to embody all elements of the claimed system, including both the "manager" and "scanner" functionalities.
• A key challenge for the Plaintiff will be one of evidence: as the complaint provides no factual detail regarding the operation of the accused products, the case will turn on what specific technical evidence is brought forward to prove that Defendant’s products perform the claimed functions of collecting component data and determining a network topology from that data.