SanDisk Tech Inc v. Viasat Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sandisk Technologies, Inc. (Delaware) and SanDisk Storage Malaysia Sdn. Bhd. (Malaysia)
  • Defendant: Viasat, Inc. (Delaware) and Gigcasters, LLC (Delaware)
  • Plaintiff’s Counsel: Hueston Hennigan LLP
• Case Identification: 7:26-cv-00019, W.D. Tex., 01/21/2026
• Venue Allegations: Venue is alleged in the Western District of Texas based on Defendants' purported acts of infringement within the district and their maintenance of regular and established places of business in Midland and Austin (Viasat) and Austin (Gigcasters).
• Core Dispute: Plaintiff alleges that Defendants’ in-flight IPTV product infringes four patents related to secure digital content delivery, network-based buffering, and digital rights management.
• Technical Context: The technology addresses improving the quality and security of streaming media in bandwidth-constrained environments, such as on commercial aircraft, by using local network storage as a controlled buffer.
• Key Procedural History: The complaint notes prior litigation between the parties (or their predecessors) styled Sandisk I, where the ’400 and ’667 patents were asserted against different Viasat products. The complaint emphasizes a court ruling in Sandisk I that the IPTV product accused in the present case was not accused in that prior litigation. This history is cited as a basis for Plaintiff’s willfulness allegations, asserting that Viasat had pre-suit knowledge of its alleged infringement.

Case Timeline

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

U.S. Patent No. 11,757,854 - "Secure Stream Buffer on Network Attached Storage"

The Invention Explained

• Problem Addressed: The patent’s background section describes the deterioration of streaming quality (e.g., “hic-up or stall”) caused by network providers throttling bandwidth, which is compounded by display devices having limited internal buffers (’854 Patent, col. 1:26-38; Compl. ¶35).
• The Patented Solution: The invention proposes using a Network Attached Storage (NAS) device on a user’s local network to act as a large, secure buffer for streaming content. A remote content provider can control access to this secure region, allowing content to be pre-loaded or sent in large bursts. A user’s streaming device finds the local storage device, communicates with the remote provider to establish the secure buffer, receives an access key for pre-loaded content, and then obtains the content locally from the storage device, improving playback quality. (’854 Patent, Abstract; col. 2:36-48).
• Technical Importance: This architecture decouples real-time media playback from the vagaries of real-time wide-area network (WAN) delivery, which can improve Quality of Service (QoS) in bandwidth-constrained environments while preserving the content provider’s Digital Rights Management (DRM) control (Compl. ¶¶35-37).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶51).
• Claim 1 of the ’854 Patent recites a streaming device comprising a network interface and processors configured to perform the steps of:
  • finding a storage device on the local area network with an available secure region for storing digital content;
  • sending connection information for the storage device to the remote content provider to enable establishing a secure storage buffer in the storage device by the remote content provider, the secure storage buffer configured to enable the remote content provider to pre-load digital content on the storage device;
  • requesting a first digital content from the remote content provider;
  • receiving an access key to a pre-loaded copy of the first digital content stored on the storage device on the local area network; and
  • obtaining the first digital content from the storage device using the access key (Compl. ¶63; ’854 Patent, col. 11:1-12:9).
• The complaint reserves the right to assert other claims (Compl. ¶63 n.17).

U.S. Patent No. 12,273,330 - "Access-Controlled Delivery of Content to Network Attached Storage"

The Invention Explained

• Problem Addressed: Similar to the ’854 patent, this patent addresses degraded streaming quality resulting from ISP throttling and the small buffers in end-user display devices (’330 Patent, col. 1:26-38; Compl. ¶35).
• The Patented Solution: The invention describes a media streaming system (e.g., a remote provider) that interacts with a NAS on a user's local network. The NAS storage buffer is partitioned into a provider-controlled "secure region" and a "user accessible region." The system transmits content to the secure region and can later transmit instructions to the NAS to "reallocate a portion of the secure region to the user accessible region," which facilitates a transition from protected streaming to user ownership (e.g., after a purchase). (’330 Patent, Abstract; col. 5:11-42).
• Technical Importance: This system architecture allows a remote content provider to maintain fine-grained control over content buffered on a local user device, improving QoS while also managing the lifecycle of the content from secure stream to user-owned property (Compl. ¶¶36, 39).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶76).
• Claim 1 of the ’330 Patent recites a media streaming system comprising a network interface adapter and hardware processors configured to:
  • receive an indication of a NAS device comprising a buffer for streaming media, via the LAN, to a separate display device on the LAN, wherein the buffer comprises a secure region and a user accessible region;
  • transmit the digital content to the NAS device for playback by the separate display device from the buffer; and
  • transmit instructions to the NAS device to control streaming access to the digital content stored on the buffer and instructions to reallocate a portion of the secure region to the user accessible region (Compl. ¶88; ’330 Patent, col. 11:1-22).
• The complaint reserves the right to assert other claims (Compl. ¶25 n.17).

U.S. Patent No. 10,447,667 - "Secure Stream Buffer on Network Attached Storage"

• Technology Synopsis: The patent describes a media streaming system that addresses poor streaming quality by using a secure, remotely controlled buffer on a Network Attached Storage (NAS) device within a user's local network. The system transmits content to this secure region and sends instructions to the NAS to control streaming access, allowing for improved playback reliability even with limited bandwidth. (’667 Patent, Abstract; Compl. ¶¶35, 40).
• Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶98).
• Accused Features: The complaint alleges that Defendants’ ground segment and satellite network act as the claimed "media streaming system," transmitting IPTV content to the onboard S4 server, which functions as the claimed "NAS device" with a secure buffer for playback on passenger devices (Compl. ¶¶112-117).

U.S. Patent No. 9,424,400 - "Digital Rights Management System Transfer of Content and Distribution"

• Technology Synopsis: The patent is directed to solving problems in digital rights management (DRM) by tying content to a specific portable storage device using a unique, concealed identifier on that device. A remote trusted server authenticates the device using this identifier before provisioning encrypted content and an access key, which prevents unauthorized access from cloned media or copied keys. (’400 Patent, Abstract; Compl. ¶41).
• Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶121).
• Accused Features: The complaint alleges that the onboard aircraft server system (M3 Modem and S4 server) functions as the claimed "kiosk." This system is alleged to obtain a unique, concealed identifier from passenger devices ("portable data storage devices"), communicate with the ground segment ("remote trusted server") to authenticate the device, and then provide DRM-protected IPTV content in response. (Compl. ¶¶135-140).

III. The Accused Instrumentality

Product Identification

• The "Accused Product" is Viasat's IPTV product and system, which delivers live television via satellite to aircraft for viewing by passengers (Compl. ¶6). The system is alleged to comprise a "ground segment," responsible for ingesting and processing content, and an onboard segment with hardware and software (Compl. ¶¶6, 8). Defendant Gigcasters is alleged to provide portions of the ground segment (Compl. ¶8).

Functionality and Market Context

• The Accused Product enables passengers to watch live TV on seatback screens or personal electronic devices during a flight (Compl. ¶7). The onboard architecture is alleged to include an M3 modem for receiving satellite transmissions and an S4 server that caches and stores the live IPTV content for distribution on an onboard local area network (LAN) (Compl. ¶¶65, 90-91). A diagram in the complaint depicts the overall architecture, showing how content flows from a ground-based partner data center through high-capacity satellites to the aircraft's onboard modem and server for distribution to users (Compl. p. 27). The system allegedly uses a multi-device DRM service called VUDRM and AES encryption to protect content (Compl. ¶¶68, 94). The product is marketed as a way to provide live TV without impacting other critical, bandwidth-intensive communications on the aircraft (Compl. ¶7).

IV. Analysis of Infringement Allegations

’854 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The infringement theory may raise the question of whether the integrated onboard server (S4), modem (M3), and passenger displays collectively constitute the "streaming device" as recited in claim 1, which the patent specification often describes as a single user-side device.
  • Technical Questions: A key technical question may be whether the transient caching of a live television stream on the S4 server meets the claim limitation of receiving an access key to a "pre-loaded copy" of digital content, as the term "pre-load" may suggest content stored in advance of a user's specific, real-time request.

’330 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The analysis may turn on whether the specialized S4 in-flight server qualifies as a "Network Attached Storage (NAS) device" as that term is understood in the patent, which frequently provides the context of a user's home network.
  • Technical Questions: A central technical question may be whether providing temporary, DRM-controlled access to a live stream constitutes "reallocat[ing] a portion of the secure region to the user accessible region," a phrase the patent specification links to events like a user purchasing previously buffered content (’330 Patent, col. 5:11-16).

V. Key Claim Terms for Construction

The Term: "Network Attached Storage (NAS) device" (from ’330 Claim 1 and related family patents)

• Context and Importance: This term is foundational to the asserted claims. The infringement theory hinges on construing the accused in-flight S4 server as a "NAS device." Practitioners may focus on this term because the patent's specification repeatedly frames the invention within a consumer "home network" context, which may differ from the specialized, closed, and mobile environment of an aircraft's entertainment system.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The shared specification defines a NAS device functionally as comprising "one or more storage devices, a network interface, and one or more processors" (’667 Patent, col. 10:62-64). This general, component-based definition could support an argument that the S4 server, which possesses these components, falls within the term's scope regardless of its environment.
  • Evidence for a Narrower Interpretation: The specification consistently uses "a user's home network" as the exemplary environment for the NAS device (’330 Patent, col. 4:9-10). Figures depict a typical consumer setup with devices like smart TVs and tablets connected to the NAS in a home (’330 Patent, FIG. 3). This repeated contextual framing may be used to argue that the term is limited to devices intended for such environments.

The Term: "reallocate a portion of the secure region to the user accessible region" (from ’330 Claim 1)

• Context and Importance: This limitation defines a key control function of the claimed system. The complaint equates this "reallocation" with the act of granting a user temporary access to stream content (Compl. ¶94). The dispute may center on whether "reallocate" implies a more permanent change of status or ownership than temporary viewing access.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes moving a digital object to the user area "along with the appropriate keys for their account" (’330 Patent, col. 5:26-29), which could be argued to cover the temporary keys associated with a single viewing session.
  • Evidence for a Narrower Interpretation: The specification explicitly illustrates reallocation in the context of content that has been "purchased," where a "zone itself is protected and the entire zone is re-allocated to the user area when content is purchased" (’330 Patent, col. 5:32-42; FIG. 4B). This language suggests a change in ownership or storage designation, which may not map directly onto providing temporary access to a live TV stream.

VI. Other Allegations

Indirect Infringement

• The complaint alleges both induced and contributory infringement for all asserted patents. Induced infringement allegations are based on Defendants' promotion of the accused IPTV system to airline customers, provision of instructions and support, and encouragement of passengers to use the allegedly infringing features during flights (e.g., Compl. ¶¶55, 80, 103, 126).

Willful Infringement

• Willfulness is alleged based on Defendants’ purported knowledge of the patents. For the ’400 and ’667 patents, knowledge is alleged to stem from the prior Sandisk I litigation, where Plaintiffs claim to have put Viasat on notice of infringement by the IPTV product "as of at least early 2025" (Compl. ¶¶48, 100, 123). For the newer ’854 and ’330 patents, knowledge is alleged to arise from Viasat’s purported tracking of continuation applications during the prior litigation, as well as from the filing of the present complaint (Compl. ¶¶52-54, 77-79). The complaint provides a detailed diagram, allegedly from the prior litigation, showing the data flow and components of the accused system, including authentication and encryption modules, which may be used to support allegations of knowledge and intent (Compl. p. 54).

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

• A core issue will be one of definitional scope: can terms such as "Network Attached Storage (NAS) device" and "kiosk", which the patent specifications describe primarily within a terrestrial home or consumer context, be construed to cover the specialized, self-contained server architecture ("S4 server") operating on a closed local network inside an aircraft?

• A key evidentiary question will be one of functional mapping: does the accused IPTV system's method for providing temporary, DRM-controlled access to a live television stream perform the specific functions of "pre-loading" content and "reallocating" a secure storage region to a user, as those functions are described by the claims and specification, particularly where the specification links those functions to on-demand content and user purchase events?

• A central legal and factual question will be the impact of prior litigation: how will the procedural history of the Sandisk I case, including the specific ruling that the IPTV product was not accused therein, influence the court’s view of the willfulness allegations and the parties' litigation conduct?