DCT

2:26-cv-00581

Palisade Tech LLP v. Team Group Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00581, E.D. Tex., 07/13/2026
  • Venue Allegations: Venue is based on Defendant being a foreign corporation not resident in the United States, pursuant to 28 U.S.C. § 1391(c)(3).
  • Core Dispute: Plaintiff alleges that Defendant's non-volatile memory products, including solid-state drives (SSDs) and portable storage devices, infringe five U.S. patents related to data storage system operation, physical device structure, and semiconductor fabrication methods.
  • Technical Context: The lawsuit concerns technologies central to non-volatile memory, such as SSDs, which are foundational components in consumer electronics, enterprise computing, and data centers.
  • Key Procedural History: The complaint does not allege any prior litigation, inter partes review proceedings, or pre-suit licensing negotiations related to the asserted patents. Plaintiff alleges that Defendant had actual notice of the patents as of the filing of this complaint.

Case Timeline

Date Event
2007-11-20 '051 Patent Priority Date
2008-08-15 '846 Patent Priority Date
2011-11-08 '846 Patent Issue Date
2012-04-20 '716 Patent Priority Date
2012-12-04 '051 Patent Issue Date
2014-10-10 '314 Patent Priority Date
2015-07-22 '974 Patent Priority Date
2016-03-08 '314 Patent Issue Date
2016-12-20 '974 Patent Issue Date
2016-12-27 '716 Patent Issue Date
2026-07-13 Complaint Filing Date

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

U.S. Patent No. 8,055,846, "Data vaulting in emergency shutdown," issued November 8, 2011

The Invention Explained

  • Problem Addressed: The patent's background describes the risk of data loss in storage systems that use a volatile cache. While backing up write commands during a power failure is known, this is insufficient to seamlessly resume more complex, multi-step storage operations (e.g., "create volume") once power is restored, often forcing a full restart of the operation '846 Patent, col. 2:41-52
  • The Patented Solution: The invention proposes a method to protect against power loss by caching not only the write commands but also the "current execution status" of the storage operation in volatile memory '846 Patent, abstract In the event of a power interruption, both the commands and this execution status are backed up to a non-volatile memory '846 Patent, Fig. 3, step 86 Upon power restoration, the system uses the recovered execution status to resume the interrupted operation from the exact point of disruption, avoiding the need to roll back or restart the process '846 Patent, col. 2:61-65 '846 Patent, Fig. 3, step 94
  • Technical Importance: This technology enables more robust and reliable high-performance storage systems by ensuring data integrity and operational continuity even in the event of unexpected power shutdowns, a critical requirement for enterprise-grade data storage.

Key Claims at a Glance

  • The complaint asserts independent claim 15 Compl. ¶20
  • Essential elements of claim 15 include:
    • An interface for accepting write commands from a host.
    • A volatile cache memory for caching both the write commands and a "current execution status of the storage operation".
    • An auxiliary non-volatile memory.
    • A processor that, upon power interruption, backs up the cached write commands and the cached execution status to the non-volatile memory, and upon power resumption, recovers the backed-up execution status to resume the interrupted operation.
  • The complaint alleges infringement of at least claim 15 Compl. ¶33

U.S. Patent No. 8,327,051, "Portable handheld memory card and methods for use therewith," issued December 4, 2012

The Invention Explained

  • Problem Addressed: The patent background highlights the inconvenience of portable memory cards that require different physical interfaces for different host devices (e.g., an SD slot for a camera, but a USB adapter for a computer). It also notes that host devices often need specialized internal hardware or software to handle compressed or encrypted data stored on the card '051 Patent, col. 1:12-54
  • The Patented Solution: The patent describes a single portable memory card that includes two separate data ports, such as a USB port and an I/O port (e.g., an SD port), on the same physical end of the device '051 Patent, abstract The key structural feature is that the ports are positioned such that when one is connected to a host, at least one pin of the other port is not electrically connected, preventing interference '051 Patent, abstract The card can also contain its own circuitry for functions like decompression, reducing the burden on the host device '051 Patent, col. 3:9-15
  • Technical Importance: The invention enhances the versatility of portable storage by integrating multiple common interfaces into a single device, improving convenience and cross-device compatibility without the need for adapters.

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶39
  • Essential elements of claim 1 include:
    • A Universal Serial Bus (USB) port with a first set of pins and associated USB controller circuitry.
    • An input/output (I/O) port with a second set of pins and associated I/O controller circuitry.
    • A memory in communication with both ports.
    • A housing exposing both ports on the same end to allow for the same insertion direction.
    • A specific positional arrangement wherein connecting one port to a host device leaves at least one pin of the other port electrically disconnected.
  • The complaint alleges infringement of at least claim 1 Compl. ¶56

Multi-Patent Capsule: U.S. Patent No. 9,281,314, "Non-volatile storage having oxide/nitride sidewall," issued March 8, 2016

Technology Synopsis

This patent describes a specific physical structure for a non-volatile memory cell designed to mitigate issues like voltage breakdown and unwanted charge trapping that can degrade performance in high-density memory arrays. The solution involves forming a silicon nitride layer that covers the oxide on the sidewalls of the word lines but does not cover the oxide adjacent to the charge storage regions, which is intended to improve device current and operational reliability '314 Patent, abstract '314 Patent, col. 2:1-7

Asserted Claims

The complaint asserts independent claims 1 and 13, and dependent claims 3, 5, 6, 17, and 18 (Compl. ¶¶62-68).

Accused Features

The physical structure and manufacturing process of the NAND flash memory (identified as YMTC X3-9070) used in products such as the T-FORCE GE PRO PCIe 5.0 SSD are alleged to embody the claimed invention (Compl. ¶69; Compl. ¶70; Compl. ¶71; Compl. ¶72; Compl. ¶73; Compl. ¶74; Compl. ¶75; Compl. ¶76; Compl. ¶77; Compl. ¶78; Compl. ¶79; Compl. ¶80; Compl. ¶81; Compl. ¶82; Compl. ¶83; Compl. ¶84; Compl. ¶85; Compl. ¶86; Compl. ¶87; Compl. ¶88; Compl. ¶89; Compl. ¶90; Compl. ¶91; Compl. ¶92; Compl. ¶93; Compl. ¶94; Compl. ¶95; Compl. ¶96; Compl. ¶97; Compl. ¶98; Compl. ¶99; Compl. ¶100; Compl. ¶101; Compl. ¶102; Compl. ¶103; Compl. ¶104; Compl. ¶105; Compl. ¶106; Compl. ¶107; Compl. ¶108; Compl. ¶109; Compl. ¶110; Compl. ¶111; Compl. ¶112; Compl. ¶113; Compl. ¶114; Compl. ¶115; Compl. ¶116; Compl. ¶117; Compl. ¶118; Compl. ¶119; Compl. ¶120).

Multi-Patent Capsule: U.S. Patent No. 9,524,974, "Alternating sidewall assisted patterning," issued December 20, 2016

Technology Synopsis

This patent discloses a semiconductor manufacturing method known as sidewall-assisted patterning (SAP), used to create features smaller than what is achievable with conventional photolithography. The invention specifically describes a process that creates two alternating types of trenches with different cross-sectional profiles. This allows for the fabrication of two different types of conductive lines in a single process, which can be used to engineer features like integrated air gaps for insulation or to optimize connections to other layers '974 Patent, abstract '974 Patent, col. 2:9-27

Asserted Claims

The complaint asserts independent claim 17 and dependent claims 18 and 20 (Compl. ¶¶125-127).

Accused Features

The manufacturing process used for the NAND flash memory (identified as YMTC X3-9070) in Defendant's SSDs is alleged to utilize the claimed alternating sidewall-assisted patterning method (Compl. ¶128; Compl. ¶129; Compl. ¶130; Compl. ¶131; Compl. ¶132; Compl. ¶133; Compl. ¶134; Compl. ¶135; Compl. ¶136; Compl. ¶137; Compl. ¶138; Compl. ¶139; Compl. ¶140; Compl. ¶141; Compl. ¶142; Compl. ¶143; Compl. ¶144; Compl. ¶145; Compl. ¶146; Compl. ¶147; Compl. ¶148; Compl. ¶149; Compl. ¶150; Compl. ¶151; Compl. ¶152; Compl. ¶153; Compl. ¶154; Compl. ¶155; Compl. ¶156; Compl. ¶157; Compl. ¶158).

Multi-Patent Capsule: U.S. Patent No. 9,530,716, "Apparatus, system, and method for transferring heat from memory components," issued December 27, 2016

Technology Synopsis

This patent addresses thermal management in devices containing multiple non-volatile memory chips, which can operate at different temperatures. The invention comprises a heat-spreading material (e.g., a graphite sheet) in thermal contact with multiple memory components, and a controller that executes temperature-dependent management functions (e.g., adjusting garbage collection frequency or read voltage levels) in parallel across the different components. This allows the device to manage thermal loads dynamically, improving overall performance and reliability '716 Patent, abstract '716 Patent, col. 2:1-14

Asserted Claims

The complaint asserts independent claim 7 and dependent claims 8, 9, 10, 11, 12, 14, 15, 16, 17, and 18 (Compl. ¶¶163-173).

Accused Features

SSDs such as the TEAMGROUP NV5000 M.2 PCIe 4.0 SSD are accused of infringing. The allegations focus on the use of a "graphene heat-dissipation label" as the heat-spreading material and a controller that performs temperature-dependent management functions across multiple NAND packages (Compl. ¶174; Compl. ¶175; Compl. ¶176; Compl. ¶177; Compl. ¶178; Compl. ¶179; Compl. ¶180; Compl. ¶181; Compl. ¶182; Compl. ¶183; Compl. ¶184; Compl. ¶185; Compl. ¶186; Compl. ¶187; Compl. ¶188; Compl. ¶189; Compl. ¶190; Compl. ¶191; Compl. ¶192; Compl. ¶193; Compl. ¶194; Compl. ¶195; Compl. ¶196; Compl. ¶197; Compl. ¶198; Compl. ¶199; Compl. ¶200).

III. The Accused Instrumentality

Product Identification

The complaint collectively refers to the accused instrumentalities as "Accused Products," which encompass a wide range of Defendant's non-volatile memory products, including consumer, industrial, and enterprise solid-state drives (SSDs), portable storage devices, USB flash drives, and memory modules Compl. ¶3 Compl. ¶10 Specific exemplary products are identified for each asserted patent, including the T-FORCE GE PRO PCIe 5.0 SSD, the PD40 Mini External SSD, and the NV5000 M.2 PCIe 4.0 SSD Compl. ¶21 Compl. ¶40 Compl. ¶174

Functionality and Market Context

The complaint alleges that Defendant is a "dominant global participant in the high-speed storage market" and markets its products under brands like "TEAMGROUP," "T-FORCE," and "T-CREATE" Compl. ¶11 The accused products are alleged to be sold in the U.S. through major e-commerce platforms and distribution channels Compl. ¶13 The technical functionalities targeted by the lawsuit include power-loss protection in SSDs, dual-interface portable drives, specific NAND flash memory micro-architectures and fabrication processes, and advanced thermal management systems in high-performance SSDs (Compl. ¶20; Compl. ¶21; Compl. ¶22; Compl. ¶23; Compl. ¶24; Compl. ¶25; Compl. ¶26; Compl. ¶27; Compl. ¶28; Compl. ¶29; Compl. ¶30; Compl. ¶31; Compl. ¶32; Compl. ¶33; Compl. ¶34; Compl. ¶35; Compl. ¶36; Compl. ¶37; Compl. ¶38; Compl. ¶39; Compl. ¶40; Compl. ¶41; Compl. ¶42; Compl. ¶43; Compl. ¶44; Compl. ¶45; Compl. ¶46; Compl. ¶47; Compl. ¶48; Compl. ¶49; Compl. ¶50; Compl. ¶51; Compl. ¶52; Compl. ¶53; Compl. ¶54; Compl. ¶55; Compl. ¶56; Compl. ¶57; Compl. ¶58; Compl. ¶59; Compl. ¶60; Compl. ¶61; Compl. ¶62; Compl. ¶63; Compl. ¶64; Compl. ¶65; Compl. ¶66; Compl. ¶67; Compl. ¶68). A product photograph shows the T-FORCE GE PRO PCIe 5.0 SSD, an M.2 form factor drive with a graphene heat spreader Compl. ¶23

IV. Analysis of Infringement Allegations

'846 Patent Infringement Allegations

Claim Element (from Independent Claim 15) Alleged Infringing Functionality Complaint Citation Patent Citation
an interface, which is operative to accept write commands belonging to a storage operation invoked by a host computer The accused T-FORCE GE PRO PCIe 5.0 SSD includes a PCIe Gen5 x4 with NVMe interface. ¶25 col. 4:12-14
a volatile cache memory, which is powered by external electrical power and is coupled to cache the write commands and to cache a current execution status of the storage operation The product includes a DRAM cache that functions as a staging buffer for write commands and a "live ledger that caches the execution status of every storage operation," including FTL and L2P metadata. A product specifications table provided in the complaint confirms the presence of a DRAM cache Compl. ¶27 ¶27; ¶31 col. 6:31-36
an auxiliary non-volatile memory The product utilizes physical TLC NAND flash memory. ¶29 col. 4:48-49
a processor, which is coupled, responsively to an interruption of the external electrical power... to back-up the cached write commands and the cached execution status... and, upon resumption... to recover the backed-up execution status... so as to resume the interrupted storage operation The product's SSD controller (e.g., an InnoGrit IG5666) detects a power interruption, backs up the DRAM cache contents and L2P metadata to NAND flash, and upon power resumption, retrieves this data to reconstruct the state and seamlessly resume the interrupted operation. ¶31 col. 6:55-68
  • Identified Points of Contention: The central dispute may involve the claim term "current execution status of the storage operation". The patent's specification primarily discusses this in the context of high-level Storage Area Network (SAN) operations like "create volume" or "delete snapshot" '846 Patent, col. 5:15-30 The complaint alleges infringement based on the backup of lower-level SSD controller metadata, such as the Flash Translation Layer (FTL) and Logical-to-Physical (L2P) maps Compl. ¶31 This raises the question of whether the SSD controller's internal state management qualifies as the "execution status of the storage operation" as contemplated by the patent.

'051 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a Universal Serial Bus (USB) port comprising a first set of pins; USB controller circuitry electrically connected with the first set of pins... The PD40 Mini External SSD includes a USB Type-C receptacle and internal USB2.0 controller circuitry that uses a specific set of pins (A6, A7, B6, B7) to communicate via the USB2.0 protocol. ¶44 col. 4:45-48
an input/output (I/O) port comprising a second set of pins; I/O controller circuitry electrically connected with the second set of pins... The same USB Type-C receptacle is alleged to function as the I/O port, using a separate set of pins (A2, A3, A10, A11, etc.) and distinct internal USB4 controller circuitry to communicate via the USB4 protocol. ¶46 col. 4:63-66
a memory in communication with the USB port and the I/O port The product contains NAND flash memory that communicates with the host device via either the USB2.0 or USB4 protocols. ¶48 col. 3:19-22
a housing storing the memory and exposing the USB port and the I/O port The product has a housing made of plastic, rubber, and/or metal, as shown in a product photograph Compl. ¶42 ¶50 col. 2:1-4
wherein the USB port and the I/O port are positioned on a same end to allow a same card-insertion direction... The USB2.0 and USB4 functionalities are both accessed via the single USB-C connector on one end of the device. ¶52 col. 2:1-4
wherein the... port[s] are positioned such that when the I/O port is electrically connected... at least one of the first set of pins of the USB port is not electrically connected... and when the USB port is electrically connected... at least one of the second set of pins of the I/O port is not electrically connected... When the device communicates using the USB4 protocol, the pins designated for USB2.0 are not used, and when communicating via USB2.0, the pins for USB4 are not used. ¶54 col. 5:1-9
  • Identified Points of Contention: A primary issue may be whether a single physical connector (USB-C) that supports two different communication protocols (USB2.0 and USB4) using different sets of pins can satisfy the claim limitations of a "USB port" and a separate "input/output (I/O) port". The patent specification provides an SD card interface as an example of an "I/O port," which is physically distinct from a USB connector '051 Patent, Fig. 4 This raises the question of whether "port" refers to the physical connector itself or to the logical communication channel and its associated pins and controller.

V. Key Claim Terms for Construction

  • Patent: '846 Patent

    • The Term: "current execution status of the storage operation"
    • Context and Importance: This term is the central inventive concept distinguishing the patent from prior art that only backed up write commands. The definition will determine whether the type of state information saved by the accused SSDs (e.g., FTL/L2P maps) falls within the claim's scope.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent describes the term as including an "operation journal" and "state information of the storage operation" '846 Patent, col. 2:36-38 '846 Patent, col. 6:12 This language could be argued to encompass any metadata, including FTL/L2P maps, that records the state of an in-progress operation.
      • Evidence for a Narrower Interpretation: The specification's explicit examples of "storage operations" are high-level, logical functions common in SAN environments, such as "create volume," "delete volume," and "create snapshot" '846 Patent, col. 5:15-30 A party could argue the term is limited to the status of these specific types of logical management operations, not the internal, lower-level state of an SSD controller.

  • Patent: '051 Patent

    • The Term: "an input/output (I/O) port"
    • Context and Importance: The claim requires a "USB port" and a separate "I/O port." The complaint's infringement theory hinges on a single USB-C connector embodying both. Practitioners may focus on this term because its construction will determine whether the accused product's single-connector, dual-protocol design meets the structural requirements of the claim.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim defines the ports by their "set of pins" and associated "controller circuitry." An argument could be made that if distinct pin sets and distinct controller circuits are used for the USB4 protocol, this constitutes a functionally separate "I/O port," irrespective of its sharing a physical connector housing with the "USB port."
      • Evidence for a Narrower Interpretation: The specification repeatedly uses a Secure Digital (SD) port as the primary example of an "I/O port" '051 Patent, col. 4:63-64 The figures depict the SD port as having a physically separate structure and pin layout from the USB interface '051 Patent, Fig. 2 '051 Patent, Fig. 4 This could support an interpretation that the "I/O port" must be a physically distinct interface standard, not merely a different protocol mode on a single, multi-purpose connector.

VI. Other Allegations

  • Indirect Infringement: For all five asserted patents, the complaint alleges active inducement of infringement under 35 U.S.C. § 271(b). The basis for this allegation is that Defendant provides "user manuals, product specifications, marketing materials, and technical support" that allegedly instruct and encourage end-users and distributors to operate the Accused Products in an infringing manner Compl. ¶34 Compl. ¶57 Compl. ¶93 Compl. ¶156
  • Willful Infringement: The complaint alleges that Defendant's infringement has been and continues to be willful since at least the filing of the complaint, which provided actual notice of the asserted patents Compl. ¶16 Compl. ¶65(b) This forms the basis for a request for enhanced damages under 35 U.S.C. § 284.

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

  1. A core issue will be one of definitional scope across multiple patents. For the '846 patent, the key question is whether the term "execution status of the storage operation," which originated in the context of enterprise SANs, can be construed to cover the internal FTL/L2P metadata saved by a modern consumer SSD controller. For the '051 patent, the question is whether a single physical USB-C connector can constitute both a "USB port" and a separate "I/O port" as required by the claims.
  2. A second key issue will be one of evidentiary proof for the semiconductor patents ('314 and '974). The complaint relies heavily on Transmission Electron Microscope (TEM) images to allege that the internal structure and manufacturing process of third-party YMTC NAND flash chips meet the highly specific claim limitations (Compl. ¶¶74-91; Compl. ¶¶133-150). The case will likely turn on a battle of experts analyzing reverse-engineered chips to determine if the accused structures and methods are, in fact, practiced.
  3. A third question relates to the breadth of the accused instrumentalities. The complaint identifies a vast range of memory products. A significant case management challenge may involve narrowing the dispute to a representative set of products for infringement analysis, particularly given the detailed, product-specific allegations made for different patents.
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