Gaea LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Gaea, LLC (Colorado)
  • Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
  • Plaintiff's Counsel: Folio Law Group PLLC
• Case Identification: 2:26-cv-00264, E.D. Tex., 08/12/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant Samsung Electronics America, Inc. has regular and established places of business in the district and has committed acts of infringement there, and because Defendant Samsung Electronics Co., Ltd. is a foreign entity.
• Core Dispute: Plaintiff alleges that Defendant's enterprise Solid-State Drives (SSDs) that support the Flexible Data Placement (FDP) feature infringe three patents related to configurable, policy-based data storage management.
• Technical Context: The technology concerns methods for allowing a host system to provide policies that direct a storage device's internal controller on how and where to physically store data, a function traditionally managed exclusively by the device manufacturer.
• Key Procedural History: This First Amended Complaint follows an original complaint filed on March 31, 2026. Plaintiff alleges it put Defendant on notice of the asserted patents and infringement through the original complaint and subsequent service of preliminary infringement contentions on July 6, 2026, which may form the basis for a willfulness claim.

Case Timeline

Date	Event
2016-11-07	Priority Date for '023, '553, and '715 Patents
2020-09-15	U.S. Patent No. 10,776,023 Issued
2024-02-20	U.S. Patent No. 11,907,553 Issued
2025-04-01	U.S. Patent No. 12,265,715 Issued
2026-03-31	Original Complaint Filed
2026-04-02	Defendant Received Notice of Original Complaint
2026-07-06	Preliminary Infringement Contentions Served
2026-08-12	First Amended Complaint Filed

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

U.S. Patent No. 10,776,023 - "Data storage device with configurable policy-based storage device behavior"

The Invention Explained

• Problem Addressed: The patent's background describes that traditional data storage devices (like hard drives and SSDs) have fixed, manufacturer-defined trade-offs between performance, reliability, and storage capacity, giving end-users little or no ability to customize these behaviors for their specific needs ʼ023 Patent, col. 1:32-41
• The Patented Solution: The invention proposes a storage device with a controller that can receive a "storage device policy" from a host computer ʼ023 Patent, col. 3:9-12 This policy instructs the device on how to store and retrieve data, allowing the user to control operational details like data placement and error handling ʼ023 Patent, col. 3:5-21 The device controller uses this policy to manage content, records metadata about the stored content, and uses that metadata for subsequent retrieval ʼ023 Patent, abstract
• Technical Importance: This approach transfers significant control over low-level storage mechanics from the device manufacturer to the host system, enabling application-specific optimizations in environments like large-scale data centers Compl. ¶38

Key Claims at a Glance

• The complaint asserts independent claims 1 and 9 Compl. ¶46
• Essential elements of independent claim 1 include:
  • An apparatus with storage media and a device controller.
  • The device controller is configured to:
    • receive a "storage device policy" from a host indicating a "recording method";
    • receive a storage request with content;
    • store the content on the media using the indicated recording method;
    • record "storage information" (including a content identifier) in its memory;
    • subsequently receive a content request with the identifier;
    • retrieve the storage information from memory;
    • recover the content from the media using the storage information; and
    • return the content to the host.
• The complaint reserves the right to assert dependent claims, including at least claim 14 Compl. ¶46

U.S. Patent No. 11,907,553 - "Data storage device with configurable policy-based storage device behavior"

The Invention Explained

• Problem Addressed: As with the parent '023 Patent, the invention addresses the inability of end-users to influence the fixed operational trade-offs made by storage device manufacturers ʼ553 Patent, col. 1:26-41
• The Patented Solution: This patent discloses an apparatus architecture that includes not only a device controller for managing the physical storage media, but also a separate "programmable processor" ʼ553 Patent, col. 10:50-57 An application running on this programmable processor receives storage requests and policies, processes the content accordingly, and then transfers the processed content to the device controller for final storage, effectively decoupling the policy-execution logic from the media-control logic (ʼ553 Patent, abstract; '553 Patent, claim 9).
• Technical Importance: This architecture allows for greater modularity and flexibility in implementing policy-based storage control, as the host-facing application logic can be developed and updated on the programmable processor independently of the core device controller firmware ʼ553 Patent, col. 11:11-30

Key Claims at a Glance

• The complaint asserts independent claims 9 and 16, as well as dependent claims 1-4 and 10-12 Compl. ¶52
• Essential elements of independent claim 9 include:
  • An apparatus with solid-state memory, device memory, a programmable processor, and a device controller.
  • An application on the device memory with instructions for the programmable processor to:
    • retrieve a "storage device policy" in response to a storage request;
    • process content for storage based on the policy; and
    • transfer the content to the device controller.
  • The device controller is configured to receive the content from the programmable processor and store it on the solid-state memory.
• The complaint explicitly asserts dependent claims Compl. ¶52

U.S. Patent No. 12,265,715 - "Data storage device with configurable policy-based storage device behavior"

Technology Synopsis

This patent, a continuation of the '553 patent's application, also describes an apparatus with a programmable processor and a device controller ʼ715 Patent, abstract It details a process where, in response to a storage request, an application on the programmable processor retrieves a policy, processes the content according to that policy, and transfers it to the device controller, which then stores the content on solid-state memory ʼ715 Patent, claim 1

Asserted Claims

Independent claims 1 and 9 are asserted Compl. ¶59

Accused Features

The accused features are Samsung's SSDs that support FDP and/or NVMe 2.1, specifically including the PM9D3 and PM1763 models Compl. ¶59

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Samsung's enterprise and data-center Solid-State Drives (SSDs) that support Flexible Data Placement ("FDP") and/or the NVMe 2.1 Base Specification, including the PM9D3 and PM1763 SSDs Compl. ¶35

Functionality and Market Context

• The complaint alleges these SSDs contain non-volatile flash memory and a controller with firmware that manages read and write requests from a host system Compl. ¶36 The core accused functionality is the ability to receive "configuration information, storage directives, and/or placement information" from a host that indicates how content should be stored Compl. ¶37 The controller allegedly uses these "host-provided policies" to store content, record associated mapping information, and later retrieve the content upon request Compl. ¶37
• The complaint positions these SSDs for use in "server-based caching and storage systems," identifying their compatibility with Meta's "CacheLib" software as an example of their market application and importance Compl. ¶10 Compl. ¶38

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references but does not include detailed claim chart exhibits Compl. ¶47 Compl. ¶53 Compl. ¶60 The following summaries are based on the narrative allegations.

'023 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
receive, from a host, at least one storage device policy, wherein the at least one storage device policy indicates at least a recording method for writing content to the storage media	The accused SSDs allegedly receive "placement information indicating how content is to be recorded" from a host via their support for the FDP and NVMe 2.1 specifications.	¶37; ¶39	col. 33:48-52
receive a storage request, from the host, to store content	The accused SSDs' controller and firmware manage "write... requests received from a host."	¶36	col. 33:53-54
store the content on the storage media by utilizing the recording method indicated by the at least one storage device policy	The controller is allegedly "configured to use those host-provided policies and inputs to store content on the flash memory."	¶37	col. 33:55-58
record storage information for the content on a memory of the device controller, comprising at least a content identifier for the content	The controller allegedly records "storage information including identifiers and mappings for that content," such as storing a Logical Block Address (LBA) in the Flash Translation Layer (FTL).	¶37; ¶42	col. 33:59 - col. 34:2
subsequent to storing the content, receive a content request for the content, comprising at least the content identifier for the content	The accused SSDs allegedly receive "read requests...from a host" that include an LBA to identify the data.	¶36; ¶43	col. 34:3-6
retrieve from the memory of the device controller the storage information for the content	The accused SSDs allegedly identify the stored data in the FTL using a received LBA.	¶43	col. 34:7-9
recover the content from the storage media, at least in part according to the storage information; and respond to the content request at least by returning the content to the host	The controller is allegedly configured to "recover the content from the storage media" and "return the content to the host."	¶37	col. 34:10-15

'553 Patent Infringement Allegations

Claim Element (from Independent Claim 9)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
An apparatus comprising... a programmable processor... a device controller...	The accused SSDs include a "controller operatively coupled to that memory," which the complaint alleges performs the functions of the claimed processors.	¶36	col. 33:43-49
an application... direct the programmable processor to... in response to receiving a storage request comprising content, retrieve a storage device policy from the device memory	The controller and its firmware allegedly receive "write... requests" and "placement information indicating how content is to be recorded" from a host.	¶36; ¶37	col. 33:50-56
process the content for storage based on the storage device policy	The controller is allegedly "configured to use those host-provided policies and inputs to store content on the flash memory."	¶37	col. 33:57-58
and transfer the content to the device controller	The complaint does not provide sufficient detail for analysis of this internal data transfer step within the accused controller.		col. 33:59-60
and the device controller configured to: receive the content from the programmable processor and store the content on the solid-state memory	The controller and firmware "control the recording... of content on the SSD."	¶36	col. 34:1-5

Identified Points of Contention

• Scope Questions: A primary question for the '023 Patent will be whether the "placement information" associated with the NVMe FDP standard constitutes a "storage device policy" that indicates a "recording method" as those terms are used in the patent. The breadth of the term "recording method" suggests its construction will be a key issue.
• Technical Questions: For the '553 Patent, a central dispute may arise over the claimed architecture. The claim recites both a "programmable processor" and a "device controller", while the complaint describes the accused SSDs as having a single "controller and its firmware" Compl. ¶36 The case may turn on whether the single accused controller can be shown to contain distinct functional blocks that map onto the two separate claimed components, or if the claim requires physically or logically separate structures that are absent in the accused products.

V. Key Claim Terms for Construction

"storage device policy"

• Context and Importance: This term appears in the independent claims of all asserted patents and is foundational to the infringement case. Practitioners may focus on this term because the dispute centers on whether the "placement information" provided via the FDP/NVMe 2.1 standard Compl. ¶37 Compl. ¶39 qualifies as a "storage device policy". The definition will determine if the core functionality of the accused SSDs reads on the patents.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states a policy "may cover many or all aspects of operation, for example, controlling margin of error, allowing the user to make trade-offs between reliability of storage and volume of storage" ʼ023 Patent, col. 3:6-12 This broad, exemplary language may support an argument that any host-provided directive, including data placement hints, falls within the term's scope.
  • Evidence for a Narrower Interpretation: The patent frequently describes the policy in the context of a "collection of libraries" that control complex behaviors like "defect avoidance" and "read/write control" ʼ023 Patent, FIG. 7A '023 Patent, col. 12:21-30 This may support an argument that the term requires a more comprehensive set of rules than what is provided by the FDP standard.

"programmable processor"

• Context and Importance: This term is central to the infringement analysis for the '553 and '715 Patents. Practitioners may focus on this term because the claims require both a "programmable processor" and a "device controller". The complaint's infringement theory appears to map both claimed components onto a single controller in the accused SSDs Compl. ¶36 The viability of this mapping depends on the construction of "programmable processor" and whether it must be a structure distinct from the "device controller".
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims require the processor to be "operatively coupled" to the device controller, which does not facially preclude both functions residing on a single integrated circuit ('553 Patent, claim 9). An argument could be made that different functional units within a single chip satisfy this coupling.
  • Evidence for a Narrower Interpretation: The specification's figures and description consistently illustrate the "programmable logic device" (605) as a separate block from the "device controller" (130), suggesting a distinct architectural component ('553 Patent, FIG. 6). The description of it being "inserted directly into the data and/or control path" also suggests a separate, intervening element ('553 Patent, col. 11:20-22).

VI. Other Allegations

Indirect Infringement

The complaint alleges Samsung induces infringement by actively developing and promoting the FDP standard, including working directly with customers like Meta to implement the technology in their systems Compl. ¶78 It is also alleged that Samsung encourages infringement by providing customers with technical documentation, specifications, and user guides that instruct on the use of the accused FDP functionality Compl. ¶81 For contributory infringement, the complaint alleges the accused SSDs are material components specifically designed for the infringing use, are not staple articles of commerce, and that their intended purpose is incorporation into infringing systems Compl. ¶¶88-91

Willful Infringement

The willfulness claim is based on alleged knowledge of the patents as of at least April 2, 2026, the date Samsung allegedly received the original complaint Compl. ¶66 The complaint further alleges that serving preliminary infringement contentions on July 6, 2026, provided additional notice Compl. ¶67 Plaintiff alleges that Samsung's continued infringing activities despite this knowledge are willful Compl. ¶69

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

• A core issue will be one of definitional scope: can the "placement information" provided by the NVMe FDP standard be construed to meet the definition of a "storage device policy" that indicates a "recording method", as required by the patents? The outcome will likely depend on whether the term is interpreted broadly to cover any host-side placement directive or narrowly to require a more comprehensive set of operational rules.
• A second key question will be one of architectural equivalence: for the '553 and '715 Patents, does Samsung's single-controller SSD architecture infringe claims that recite both a "programmable processor" and a "device controller"? The resolution will depend on whether the court finds that the functions of the two claimed components are performed by distinct-enough modules within Samsung's controller, or if it determines the claims require a structural separation that is absent in the accused products.
• A third central question will concern intent for indirect infringement: what evidence will emerge regarding Samsung's role in developing, standardizing, and promoting FDP? The court will likely examine whether Samsung's collaboration with Meta and its creation of technical documentation demonstrate a specific intent to encourage customers to use the accused SSDs in a manner that directly infringes the patents.