DCT

2:24-cv-07209

Benson Avenue Co LLC v. Arri Americas Inc

Log In
Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-07209, C.D. Cal., 08/28/2025
  • Venue Allegations: Venue is alleged in the Central District of California based on Defendant maintaining a place of business in the district and the occurrence of infringing acts within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s ARRISCAN XT film scanner, which is used for film preservation and restoration, infringes a patent related to the lossless digitization of analog audio from physical media.
  • Technical Context: The technology addresses methods for creating high-fidelity digital archives of analog audio sources, such as film soundtracks or vinyl records, by capturing the physical characteristics of the media rather than sampling the audio waveform directly.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the asserted patent on May 18, 2023, and that Defendant acknowledged receipt on June 16, 2023, an event which may be relevant to the allegations of willful infringement.

Case Timeline

Date Event
2015-10-29 ’945 Patent Priority Date
2017-11-28 ’945 Patent Issued
2018-04-09 Alleged demonstration of accused product at NAB conference
2019-05-31 Alleged start of infringement period ends (approximate date)
2023-05-18 Plaintiff sent notice letter to Defendant
2023-06-16 Defendant acknowledged receipt of notice letter
2025-08-28 Complaint Filed

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

U.S. Patent No. 9,830,945 - *"ENCODING, DISTRIBUTION AND REPRODUCTION OF AUDIO MEDIA USING MECHANICAL IMAGE DIGITIZATION,"*

  • Patent Identification: U.S. Patent No. 9,830,945, “ENCODING, DISTRIBUTION AND REPRODUCTION OF AUDIO MEDIA USING MECHANICAL IMAGE DIGITIZATION,” issued November 28, 2017 (’945 Patent).

The Invention Explained

  • Problem Addressed: The patent’s background section identifies a problem with conventional digital audio encoding: it is described as a "lossy" process where "no original component of the original analog audio signal remains in the digitized signal," resulting in a lower-quality "estimated version" of the original audio. This creates a trade-off between the convenience of digital distribution and the fidelity of the original analog source media (e.g., vinyl records or master tapes) (’945 Patent, col. 1:20-30).
  • The Patented Solution: The invention proposes a method to digitize analog audio sources without this loss of quality. Instead of sampling the audio signal, the system first creates a "mechanical image" of the physical media itself—for example, a high-resolution image of a vinyl record's grooves or the magnetic flux patterns on a tape (’945 Patent, col. 2:32-35). This "mechanical image information" is then encoded into a digital file for storage or transmission. At the receiving end, the system decodes this digital file to recover the mechanical information and uses it to reproduce the original analog audio, thereby bypassing the losses associated with conventional audio digitization (’945 Patent, Abstract; Fig. 1).
  • Technical Importance: The claimed invention aims to provide the best of both worlds: the perfect fidelity of an original analog recording combined with the ease of storage and distribution of a digital file (Compl. ¶11).

Key Claims at a Glance

  • The complaint asserts independent Claim 1.
  • Essential elements of Claim 1 include:
    • An "original audio source media recording" containing analog audio.
    • A "mechanical production system for producing a mechanical image" of that media.
    • A "processing system for encoding the mechanical image information into a digital image file" with structure and control information.
    • A "processing system for recovering the mechanical image information" from the file.
    • "Audio processing circuitry" to produce the original audio from the recovered mechanical information "without standard losses associated with digital encoding of an analog source."
  • The complaint asserts infringement "literally or under the doctrine of equivalents" of at least Claim 1 (Compl. ¶¶19, 31).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is Defendant’s ARRISCAN XT film scanner, particularly when used with its “IMAGE TO SOUND TOOLS” (“ITST”) software (Compl. ¶¶13, 16).

Functionality and Market Context

  • The ARRISCAN XT is a device used by film archivists and restoration specialists to digitize and remaster motion picture film (Compl. ¶13). The complaint alleges that the ITST software is a "unique system" designed to "decode and digitize the optical soundtracks on films" and enables "real-time playback from image files" (Compl. ¶¶16, 18). The complaint alleges that these scanners are used by major studios, such as NBC Universal, for audio restoration and preservation services (Compl. ¶21).

IV. Analysis of Infringement Allegations

'945 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
wherein the audio recording is an original audio source media recording, containing original analog recording audio; The ARRISCAN XT is designed to operate on film containing an original analog optical soundtrack (Compl. p. 8, Image). ¶19 col. 2:62-67
a mechanical production system for producing a mechanical image of the original audio source media recording; The ARRISCAN XT’s optical scanner creates a visual representation of the audio soundtrack on the film, which the complaint alleges constitutes a "mechanical image" (Compl. p. 9, Image). ¶19 col. 2:32-35
a processing system for encoding the mechanical image information into a digital image file comprising an image structure and control information to enable audio reproduction of the original audio from the digital image file, the digital image file being capable... The ITST software processes the scanned optical soundtrack and stores it as a DPX or TIFF digital image file, which contains the waveform structure and control parameters such as amplitude and frequency (Compl. p. 10, Image). ¶19 col. 4:9-28
a processing system for recovering the mechanical image information in the digital image file; and The ITST software "decodes" the optical sound information from the DPX or TIFF image files. ¶19 col. 2:45-48
audio processing circuitry to produce the original analog recording audio from the recovered mechanical image information without standard losses associated with digital encoding of an analog source. The system provides "real-time sound playback directly from graphic files," which the complaint alleges produces the original analog audio without the losses of conventional digital encoding (Compl. p. 12, Image). ¶19 col. 2:54-58
  • Identified Points of Contention:
    • Scope Questions: A central dispute may concern the definition of "mechanical image." The complaint alleges that an optical scan of a film's soundtrack meets this limitation (Compl. ¶19, p. 9). This raises the question of whether the term, as used in the patent, is limited to images of physical geometries like record grooves, or if it can be construed more broadly to encompass optical representations of audio information.
    • Technical Questions: The analysis may focus on whether the ARRISCAN XT's process is technically distinct from the "lossy" conventional digitization the patent sought to improve upon. The complaint alleges the accused system produces audio "without standard losses" (Compl. ¶18), but the degree to which its optical scanning and digital file creation process differs functionally from high-resolution digital sampling may become a key point of technical debate.

V. Key Claim Terms for Construction

  • The Term: "mechanical image"
  • Context and Importance: This term is the technological core of the asserted claim. The entire infringement theory rests on the allegation that the ARRISCAN XT's optical scan of a film soundtrack creates a "mechanical image." Practitioners may focus on this term because its construction—whether broad enough to cover optical data or limited to physical topography—could be dispositive of infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification describes producing a "mechanical image" from various sources, including not only "vinyl... images" but also images representing the "flux density on the tape" (’945 Patent, col. 2:34-35, col. 4:1-2). Furthermore, the patent explicitly contemplates its application to film, showing an audio track on a film frame being "directly imaged" by a light source and detector (’945 Patent, Fig. 11, col. 5:8-21). This may support an interpretation that is not limited to physical grooves.
    • Evidence for a Narrower Interpretation: The specification repeatedly uses examples based on the physical geometry of media, such as the "actual track grooves of the vinyl master" and using a "3D printer system" to recreate the "groove image" for playback (’945 Patent, col. 3:31-33; col. 4:63-68). This emphasis on physical structure could be used to argue that a "mechanical image" requires capturing tangible, three-dimensional geometry, as opposed to the two-dimensional optical properties of a film soundtrack.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges active inducement, stating that ARRI provides advertising, technical documentation, and support that encourage customers to use the ARRISCAN XT in an infringing manner, and that ARRI did so with knowledge of the ’945 Patent after receiving a notice letter (Compl. ¶¶35-36). Contributory infringement is alleged based on the sale of an "Optical Sound Decoding System," which is claimed to be a non-staple component specially adapted for infringing use (Compl. ¶¶40-41).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant's continued infringing conduct after receiving notice of the ’945 Patent in May 2023 (Compl. ¶¶26-27). The complaint further alleges that Defendant has not provided a "good-faith or reasonably held defense" (Compl. ¶29).

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

  • A core issue will be one of definitional scope: can the term "mechanical image," which the patent illustrates with examples of physical vinyl grooves and magnetic tape flux, be construed to cover the optical data captured from a film's soundtrack by the accused ARRISCAN XT scanner?
  • A second key issue will be one of technical distinction: what evidence will be presented to establish that the accused process—creating a digital image file (DPX/TIFF) from an optical scan and then generating audio—is functionally the same as the patent's claimed method and successfully avoids the "standard losses associated with digital encoding of an analog source," as both the patent and the complaint require?