DCT
2:19-cv-04886
Eureka Database Solutions LLC v. NFL Enterprises LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Eureka Database Solutions, LLC (Texas)
- Defendant: NFL Enterprises, LLC (Delaware)
- Plaintiff’s Counsel: SML AVVOCATI P.C.; Connor Lee Shumaker PLLC
- Case Identification: 2:19-cv-04886, C.D. Cal., 06/04/2019
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business within the district and has committed acts of infringement there. The complaint also notes that Defendant previously consented to venue in the district in a prior patent case.
- Core Dispute: Plaintiff alleges that Defendant’s NFL Game Pass streaming service infringes two patents related to methods for searching, indexing, and accessing specific segments within stored multimedia files.
- Technical Context: The technology addresses the challenge of efficiently locating and retrieving specific moments within large digital video libraries by using associated metadata, a foundational capability for modern on-demand video services.
- Key Procedural History: The complaint notes that the patents originated from Digital Equipment Corporation and Altavista Company, early pioneers in corporate computing and web search technology, respectively, situating the inventions in the context of the 1990s internet boom.
Case Timeline
| Date | Event |
|---|---|
| 1998-03-11 | Priority Date for '287 and '189 Patents |
| 2001-01-09 | U.S. Patent No. 6,173,287 Issued |
| 2001-10-30 | U.S. Patent No. 6,311,189 Issued |
| 2011-XX-XX | Accused NFL Game Pass begins offering archived games from the 2011 season |
| 2019-06-04 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,311,189, “Technique for Matching a Query to a Portion of Media,” issued October 30, 2001
The Invention Explained
- Problem Addressed: The patent’s background section identifies a lack of means for "searching inside streams of multimedia content (e.g., audio/video streams)" and "adding meta-information to multimedia content" for indexing purposes, which hindered efficient retrieval of specific content segments from large files (’189 Patent, col. 1:55-62).
- The Patented Solution: The invention provides a method where a system receives a user query, searches a plurality of "annotation values" (metadata tags) to find a value that matches the query, identifies the specific "start time" of the media stream segment corresponding to that annotation, and provides that start time in response to the user (’189 Patent, Abstract). This allows a user to directly access a relevant clip without needing to download or manually search through an entire media file (’189 Patent, col. 2:12-25).
- Technical Importance: The technology provided a "technique for matching a query to a slice of media," which was an important step in making large digital media archives navigable and useful in a networked environment (’189 Patent, col. 2:9-11).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 9-12 and 18-20 (Compl. ¶74).
- Independent Claim 1 recites a method with the following essential elements:
- Receiving a query relating to media of interest.
- Searching, based on the query, a plurality of annotation values to identify a matching annotation value, where each annotation value corresponds to a portion of available media.
- Identifying a start time of a media stream that forms a portion of the media corresponding to the identified annotation value.
- Providing the identified media stream start time in response to the query.
U.S. Patent No. 6,173,287, “Technique for Ranking Multimedia Annotations of Interest,” issued January 9, 2001
The Invention Explained
- Problem Addressed: The patent addresses the same problem as its continuation ('189 Patent): the difficulty in searching, organizing, and delivering specific portions of digitized multimedia content stored across distributed systems (’287 Patent, col. 1:55-65).
- The Patented Solution: This invention discloses a specific system architecture for accessing a media segment using a two-step lookup process. First, the system searches "annotations" to find an "annotation of interest" that has both a "data identifier" (a logical identifier for the content, like an object ID) and a "location identifier" (a timestamp within the content). Second, it searches a separate store of "data identifiers" to find an "address identifier" (a pointer to the file itself, like a URL). Finally, it uses the address identifier and the location identifier together to access the specific item of interest (’287 Patent, Abstract; Fig. 1A).
- Technical Importance: This architectural approach separates the indexing of content substance (annotations and data identifiers) from the management of file storage locations (address identifiers), providing a flexible method for accessing media in distributed datastores (’287 Patent, col. 2:21-28).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2-4, 6, 7, and 10 (Compl. ¶85).
- Independent Claim 1 recites a method with the following essential elements:
- Searching a plurality of stored annotations to locate an annotation of interest, which has an associated "data identifier" and an associated "location identifier."
- Searching a plurality of stored data identifiers to locate the associated data identifier and an associated "address identifier" corresponding to the address of the stored representation of data.
- Accessing the item of interest at the location of interest using the associated address identifier and the associated location identifier.
III. The Accused Instrumentality
- Product Identification: The NFL Game Pass service (Compl. ¶51).
- Functionality and Market Context: NFL Game Pass is a streaming service that allows users to watch archived NFL games on various platforms, including phones, tablets, and connected TVs (Compl. ¶¶53-54). A key feature of the service is its search functionality, which enables users to find and view specific highlights from games by applying filters such as player, team, down, and play type (e.g., "Big Plays," "Touchdowns") (Compl. ¶¶56-59). The complaint includes a screenshot of the "Player Search" interface, which displays filter options for curating a playlist of specific in-game situations (Compl. ¶57, p. 17). Upon selecting a search result, the user is taken directly to the corresponding video segment within the game (Compl. ¶60).
IV. Analysis of Infringement Allegations
'189 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) receiving a query relating to media of interest; | NFL Game Pass receives user input through its search interface, where a user can select criteria such as a specific player, play type, or down. | ¶78 | col. 7:42-45 |
| b) searching, based upon the query, a plurality of annotation values to identify an annotation value...which matches the query... | The system allegedly searches stored metadata (annotation values) corresponding to plays in recorded games to identify plays that match the user's query. For example, it identifies all plays matching "4th Down" and "Incomplete Passes" for a given player. | ¶62 | col. 8:35-50 |
| c) identifying a start time of a media stream...corresponding to the identified annotation value; and | For each play matching the search, the system identifies and provides a start time within the full game video. The complaint presents a screenshot of HTML code allegedly showing a timestamp associated with a play. | ¶63 | col. 2:19-22 |
| d) providing the identified media stream start time in response to the query. | The system uses the identified start time to begin playback of the media stream at the specific moment of the selected play, allowing the user to view the highlight directly. | ¶60, 63 | col. 2:23-25 |
'287 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) searching a plurality of stored annotations...to locate an annotation of interest...having an associated data identifier and an associated location identifier... | The complaint alleges that when a user searches, the system searches stored annotations (e.g., player, down) to locate an annotation of interest (a specific play). This play has an associated "data identifier" (the textual play-by-play description) and a "location identifier" (the timestamp). | ¶65, 66, 89 | col. 2:29-39 |
| b) searching a plurality of stored data identifiers...to locate the associated data identifier and an associated address identifier... | The system then allegedly searches a plurality of data identifiers (e.g., database object IDs for all plays) to locate the data identifier for the specific play and an associated address (e.g., a URL or file storage location) for the game in which the play occurred. | ¶67, 90 | col. 2:46-52 |
| c) accessing the item of interest...using the associated address identifier and the associated location identifier. | The system is alleged to access the specific play by using the game's file address (the URL) in combination with the play's timestamp (location identifier) to begin playback at the correct point. The complaint provides a diagram mapping these elements to the NFL Game Pass user interface and source code. | ¶68, p. 21 | col. 2:60-65 |
- Identified Points of Contention:
- Scope Questions: A central question for the ’287 Patent will be whether the terms "data identifier" and "address identifier", which in the patent describe elements of a specific database architecture (e.g., Figs. 8, 9), can be construed to read on the data elements and web-based architecture of the accused NFL Game Pass service as alleged in the complaint. For example, does a textual play-by-play description function as the unique "data identifier" contemplated by the patent?
- Technical Questions: The infringement theories for both patents appear to rely on the same underlying user action. This raises the technical question of whether the accused system performs the distinct, two-step lookup process required by claim 1 of the ’287 Patent (search annotations -> get data ID; search data IDs -> get address) or if it performs a more direct, single-lookup process that may more closely align with the method of the ’189 Patent.
V. Key Claim Terms for Construction
The Term: "annotation value" ('189 Patent, Claim 1)
- Context and Importance: The scope of this term is critical for the '189 Patent, as it defines the universe of searchable data. Practitioners may focus on this term because the infringement allegation depends on mapping it to the structured, multi-field play-by-play data (e.g., down, player, team) used by the accused service.
- Intrinsic Evidence for a Broader Interpretation: The specification of the parent '287 patent provides examples of annotations such as "transcript, speaker, or keyframe," suggesting the term covers various forms of metadata associated with media content (’287 Patent, col. 16:49-51).
- Intrinsic Evidence for a Narrower Interpretation: The exemplary Annotation Table in Figure 10 shows "ANNOTATION VALUE" as discrete data points like a single "WORD" or a "SPEAKERNAME," which could support an argument that the term does not cover the composite, multi-part search criteria alleged to be used by the accused product (’287 Patent, Fig. 10).
The Term: "data identifier" ('287 Patent, Claim 1)
- Context and Importance: The definition of this term is central to the ’287 Patent’s infringement theory, as it is the lynchpin of the claimed two-step search process. The case may turn on whether the accused product contains a corresponding element.
- Intrinsic Evidence for a Broader Interpretation: The specification describes the "data identifier" as corresponding to a particular representation of data, which could be argued to encompass any logical identifier that links an annotation to a media file (’287 Patent, col. 2:26-28). The complaint alleges this is met by the textual description of a play (Compl. ¶89).
- Intrinsic Evidence for a Narrower Interpretation: The patent’s detailed description and figures explicitly show the "data identifier" as a unique, assigned "OBJECT ID" (e.g., "00000001") stored in a specific "Object Table" structure, suggesting it refers to a formal database key rather than a descriptive text string (’287 Patent, Fig. 8; col. 16:15-20).
VI. Other Allegations
- Indirect Infringement: The complaint’s prayer for relief seeks a judgment of indirect infringement (Compl. p. 26, ¶a). However, the substantive counts for infringement only allege direct infringement (Compl. ¶¶75, 86), and the complaint does not plead specific facts to establish Defendant's knowledge of the patents and intent to induce infringement by third parties.
- Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or plead facts indicating Defendant had pre-suit knowledge of the asserted patents.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural scope: Can the claims, which arose from a 1990s client-server architecture with distinct meta, index, and media databases, be construed to cover the integrated, web-based architecture of the modern NFL Game Pass service?
- A key evidentiary question will be one of operational distinction: Does the accused service in fact perform the distinct two-step search process recited in the ’287 patent (first identifying a logical content ID, then using it to find a file address), or does its functionality align more closely with the more direct, single-lookup process of the ’189 patent, raising questions about whether both patents can be infringed by the same system.