VeriBase LLC v. Razer USA Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: VeriBase LLC (New Mexico)
  • Defendant: Razer USA Ltd. (Delaware)
  • Plaintiff's Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01236, E.D. Tex., 12/18/2025
• Venue Allegations: Venue is alleged to be proper based on the Defendant having an established place of business within the Eastern District of Texas and having committed alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant's Razer Blade 17 gaming laptops, which run the Windows operating system, infringe a patent related to securing computer systems by selectively controlling an application's ability to write data to a storage medium.
• Technical Context: The technology at issue involves a behavior-based computer security method designed to preemptively block malware by monitoring application write attempts and verifying them against a rules-based permission system.
• Key Procedural History: The complaint states that Plaintiff is the assignee of the patent-in-suit. No other significant procedural events, such as prior litigation or administrative proceedings involving the patent, are mentioned.

Case Timeline

Date	Event
2005-12-01	'661 Patent Priority Date
2017-03-21	'661 Patent Issue Date
2021-09-19	Date of Accused Product marketing materials referenced in complaint
2025-12-18	Complaint Filing Date

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

• Patent Identification: U.S. Patent No. 9,600,661, "System and method to secure a computer system by selective control of write access to a data storage medium," issued March 21, 2017.

U.S. Patent No. 9,600,661 - "System and method to secure a computer system by selective control of write access to a data storage medium"

The Invention Explained

• Problem Addressed: The patent's background section describes traditional anti-virus programs as often being reactive, addressing malicious software only after a system has already been infected, and notes their difficulty in keeping pace with the rapid emergence of new viruses '661 Patent, col. 1:12-23
• The Patented Solution: The patent proposes a proactive security method to prevent virus infections '661 Patent, col. 1:24-26 The invention uses an "interceptor" program, which runs in the background, to monitor attempts by applications to write data to a storage medium like a hard drive '661 Patent, col. 2:23-34 When a write attempt is detected, the interceptor consults a "rules database" to verify whether the specific application has permission to perform the write action '661 Patent, col. 2:30-34 Based on the rules, the write is either allowed or blocked, thereby aiming to stop malware from being saved to the system '661 Patent, Fig. 3
• Technical Importance: This approach reflects a method of providing system security through behavioral monitoring and access control, rather than relying solely on signature-based detection of known threats.

Key Claims at a Glance

• The complaint asserts at least independent claim 16 of the '661 Patent Compl. ¶16 Ex. 2
• The essential elements of independent claim 16 are:
  • detecting using a process operating in kernel mode monitoring file system access an attempt by the application to write data of a designated file type to said data storage device;
  • in response to said attempt, retrieving a permission value from a database comprised of data elements encoding at least one permission value associated with the application; and
  • controlling write access to the data storage device by the application in dependence on said permission value.
• The complaint notes that the asserted claims are "exemplary" and appears to reserve the right to assert additional claims '661 Patent, Compl. ¶11

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Razer Blade 17" gaming laptop as an exemplary accused product Compl. ¶16 Ex. 2, p. 2

Functionality and Market Context

• The complaint alleges the accused product is a computer that includes a mass data storage device, such as an SD card, and runs the Microsoft Windows operating system Ex. 2, p. 2 Ex. 2, p. 5 The complaint's infringement theory centers on the functionality of the Windows OS itself, alleging that its kernel includes processes for managing file system access by monitoring write attempts from applications and controlling those attempts based on configured permissions Ex. 2, p. 7 Ex. 2, p. 14 The complaint includes a diagram from Defendant's website highlighting the connectivity of the Razer Blade 17, which explicitly shows a "UHS-III SD CARD READER" as a feature Ex. 2, p. 5
• The complaint presents evidence positioning the Razer Blade 17 as a high-performance gaming laptop, marketed with the Windows 10 operating system Ex. 2, p. 3 Ex. 2, p. 4

IV. Analysis of Infringement Allegations

• Claim Chart Summary: The complaint incorporates by reference an exhibit that maps elements of claim 16 to the functionality of the accused Razer Blade 17 laptop, primarily focusing on features of its Windows operating system Compl. ¶16 Compl. ¶17

'661 Patent Infringement Allegations

Claim Element (from Independent Claim 16)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
detecting using a process operating in kernel mode monitoring file system access an attempt by the application to write data of a designated file type to said data storage device;	The accused product's Windows OS allegedly includes a kernel module that operates in kernel mode to monitor file system access attempts by applications to write data to storage devices like an SD card.	¶16	col. 7:30-34
in response to said attempt, retrieving a permission value from a database comprised of data elements encoding at least one permission value associated with the application;	In response to a write attempt, the Windows OS allegedly retrieves a configured permission value for the application from a database of permissions. The complaint cites Microsoft documentation on app permissions to support this.	¶16	col. 7:35-41
and controlling write access to the data storage device by the application in dependence on said permission value.	The accused product allegedly controls write access by denying or allowing the write attempt based on the retrieved permission value.	¶16	col. 7:42-45

• Identified Points of Contention:
  • Scope Questions: A primary question may be whether the claimed method can be practiced by a hardware manufacturer that sells a device containing a third-party, general-purpose operating system. The dispute may center on whether Razer "uses" the claimed method by selling a laptop with standard Windows OS functionality. Further, a question arises whether the claimed "process" and "database" can be construed to cover broad, multi-function components of a general-purpose OS, or if they are limited to the more specific, dedicated "interceptor" and "rules database" described in the patent's embodiments.
  • Technical Questions: The infringement analysis may turn on whether the general application permissions within Windows, as shown in the complaint's evidence, perform the specific function of monitoring write attempts for a "designated file type," as required by the claim. The complaint provides evidence of general file system access control, and the connection to the "designated file type" limitation may be a point of dispute. The complaint includes screenshots from Microsoft support pages explaining that the Windows kernel manages "file system management, device control and networking" Ex. 2, p. 12

V. Key Claim Terms for Construction

• "process operating in kernel mode monitoring file system access"

  • Context and Importance: This term's construction is critical, as the complaint identifies the Windows OS kernel as this "process." Practitioners may focus on this term because its scope will determine whether the claim can read on a general-purpose operating system kernel or is limited to a more specialized, add-on security application as depicted in the patent's figures.
  • Intrinsic Evidence for a Broader Interpretation: The specification states that the "interceptor program can run continuously in the background as a process, including as part of the computer operating system," which may support an interpretation that the process can be an integral OS component '661 Patent, col. 2:27-29
  • Intrinsic Evidence for a Narrower Interpretation: The specification also refers to the invention as a distinct "interceptor program 18," which is illustrated as a separate functional block in Figure 1 '661 Patent, Fig. 1 '661 Patent, col. 2:23-24 It is also described as a "kernel mode driver," which is a component within an OS but not the entirety of its file management system, potentially supporting a narrower definition '661 Patent, col. 4:40

• "database comprised of data elements encoding at least one permission value"

  • Context and Importance: The definition of "database" will be central to determining whether the standard Windows permission settings qualify. The outcome of this construction could decide if the accused product meets this limitation.
  • Intrinsic Evidence for a Broader Interpretation: The patent provides a broad definition, stating the "rule database is a set of entries or references in a data structure where the identity of an application is paired with one or more permission values" '661 Patent, col. 2:36-39 This could be argued to encompass any system that links applications to permissions.
  • Intrinsic Evidence for a Narrower Interpretation: The patent consistently refers to a specific "rules database" containing defined "levels" of access (e.g., Level 0, 1, 2) for specific applications and file extensions '661 Patent, col. 2:31 '661 Patent, col. 2:50-65 This could suggest a requirement for a purpose-built, structured database rather than the general permission settings of an OS.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that "at least since being served by this Complaint," the Defendant has knowingly induced infringement by distributing product literature and website materials that instruct end users on how to use the accused products Compl. ¶15 Compl. ¶14
• Willful Infringement: The allegation of willful infringement is based on post-suit conduct. The complaint posits that the service of the complaint provides Defendant with "actual knowledge" of infringement and that any subsequent infringing activities are therefore willful Compl. ¶13 Compl. ¶14

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

• A core issue will be one of definitional scope: can the claim terms "process operating in kernel mode" and "database," which are described in the patent's embodiments as parts of a dedicated security application, be construed broadly enough to read on the general-purpose, pre-existing kernel and permission-setting architecture of the Microsoft Windows operating system?
• A central question of liability will likely be whether a computer hardware vendor "practices" the claimed method by selling products that include a third-party operating system containing the allegedly infringing functionality, or whether the vendor's actions fall short of direct infringement.
• An key evidentiary question will be one of functional correspondence: does the evidence of the Windows OS's general file access controls, as presented in the complaint, demonstrate the more specific functions required by Claim 16, particularly the monitoring of write attempts for a "designated file type"?