DCT

2:25-cv-00895

InterDigital Inc v. Walt Disney Co

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I. Executive Summary and Procedural Information

Case Timeline

Date Event
2002-05-14 ’297 Patent Priority Date
2002-07-15 ’301 Patent Priority Date
2007-04-03 ’268 Patent Priority Date
2010-05-14 ’610 Patent Priority Date
2010-06-10 ’818 Patent Priority Date
2011-12-27 ’297 Patent Issue Date
2013-03-26 ’301 Patent Issue Date
2015-11-10 ’268 Patent Issue Date
2020-10-13 ’610 Patent Issue Date
2022-07-05 ’818 Patent Issue Date
2022-07-01 Plaintiff allegedly contacts Defendant for licensing discussions
2025-02-02 Complaint Filing Date

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

U.S. Patent No. 8,406,301 - "Adaptive Weighting of Reference Pictures in Video Encoding"

The Invention Explained

  • Problem Addressed: The patent addresses inefficiencies in video compression, particularly for sequences with fading effects, where a picture is more strongly correlated to a "weighted" or scaled version of a reference picture than to the reference picture itself (Compl. ¶473; ’301 Patent, col. 2:42-46). Prior methods for transmitting the necessary "weighting factors" were inflexible or required excessive bandwidth (Compl. ¶473; ’301 Patent, col. 3:17-31).
  • The Patented Solution: The invention proposes a method where a weighting factor is associated with a specific reference picture index (Compl. ¶472). Because the reference picture index is already transmitted as part of the standard video bitstream, this allows the weighting factor to be adapted for individual motion blocks without requiring significant additional data overhead, thereby improving compression efficiency (Compl. ¶474; ’301 Patent, col. 8:62-65).
  • Technical Importance: This approach provided a more efficient mechanism for adapting prediction weighting in video codecs, which is a key tool for improving compression ratios without sacrificing visual quality.

Key Claims at a Glance

  • The complaint asserts method claims 8-12 (Compl. ¶483). Independent claim 8 includes the following essential elements:
    • Receiving a substantially uncompressed image block.
    • Assigning a weighting factor for the image block associated with a particular reference picture index.
    • Computing motion vectors corresponding to the difference between the image block and the particular reference picture.
    • Motion compensating the particular reference picture.
    • Modifying the motion compensated reference picture by the assigned weighting factor to form a weighted motion compensated reference picture.
    • Comparing the weighted motion compensated reference picture to the uncompressed image block.
    • Encoding a signal indicative of the difference.

U.S. Patent No. 10,805,610 - "Methods and Apparatus for Intra Coding a Block having Pixels Assigned to Groups"

The Invention Explained

  • Problem Addressed: In traditional intra-frame video coding, pixels in a block are predicted using previously coded pixels from neighboring blocks (e.g., above and to the left) (Compl. ¶491; ’610 Patent, col. 1:24-36). When predicting pixels at the bottom-right of a block, these neighboring predictors can be spatially distant, leading to low correlation, poor prediction accuracy, and reduced coding efficiency (Compl. ¶492; ’610 Patent, col. 1:36-39).
  • The Patented Solution: The patent proposes dividing the pixels within a single block into at least two groups. The first group is encoded, and then its reconstructed pixels—which are spatially much closer to the pixels in the second group—are used as predictors for encoding the second group. This use of closer predictors improves prediction accuracy and overall coding efficiency (Compl. ¶¶494-495; ’610 Patent, col. 8:19-29).
  • Technical Importance: This technique improves the efficiency of intra-prediction, a fundamental component of modern video codecs, by generating more accurate predictions from spatially proximate information within the same coding block.

Key Claims at a Glance

  • The complaint asserts method claims 6-10 (Compl. ¶503). Independent claim 6 includes the following essential elements:
    • Encoding a block in a picture using intra prediction.
    • Dividing pixels within the block into at least a first group and a second group.
    • Predicting pixels in the first group from neighboring pixels outside the block.
    • Encoding the pixels in the first group prior to encoding the pixels in the second group.
    • Obtaining an intra prediction for at least one of the pixels within the second group by using pixels from the first group and pixels outside the block.

U.S. Patent No. 11,381,818 - "Methods and Apparatus for Determining Quantization Parameter Predictors from a Plurality of Neighboring Quantization Parameters"

  • Technology Synopsis: The patent addresses the signaling of quantization parameters (QPs), which control video quality and bitrate. Prior art methods used a single neighboring block to predict the QP for a current block, which could be inaccurate and require sending a large "delta" value, increasing overhead (Compl. ¶512). The invention determines the QP predictor by using QPs from multiple neighboring blocks, resulting in a more accurate prediction and reducing the amount of data needed to signal QP adjustments (Compl. ¶513).
  • Asserted Claims: Claims 1-4 are asserted (Compl. ¶519).
  • Accused Features: The video encoding processes used for the Accused Instrumentalities' content are alleged to infringe (Compl. ¶519).

U.S. Patent No. 9,185,268 - "Methods and Systems for Displays with Chromatic Correction with Differing Chromatic Ranges"

  • Technology Synopsis: The patent addresses color inaccuracies that occur when content created for a standard reference color gamut (RCG) is viewed on a display with a different, often wider, color gamut (CG2), which can lead to clipped colors or hue shifts (Compl. ¶¶527, 533). The invention provides a workflow to create a "master" version of the content for CG2 displays and corresponding metadata that allows for the content to be accurately transformed for viewing on traditional RCG displays, ensuring predictable color reproduction across different screens (Compl. ¶535).
  • Asserted Claims: Claims 1-11 are asserted (Compl. ¶545).
  • Accused Features: The video encoding and content mastering processes for the Accused Instrumentalities are alleged to infringe (Compl. ¶545).

U.S. Patent No. 8,085,297 - "Method for Modifying a User Interface of a Consumer Electronic Apparatus, Corresponding Apparatus, Signal and Data Carrier"

  • Technology Synopsis: The patent addresses the limitation of static user interfaces (UIs) on consumer electronics, which are typically fixed at the factory (Compl. ¶554). The invention provides a method to modify a UI by embedding "side information" within a received data signal (e.g., a video stream). This side information can add new buttons, update UI functionality, or implement temporary, dedicated UI sub-domains based on validity information also contained in the signal (Compl. ¶555).
  • Asserted Claims: Claims 1-12 are asserted (Compl. ¶565).
  • Accused Features: The systems that provide the Accused Instrumentalities' content and user interfaces are alleged to infringe (Compl. ¶565).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are the Disney+, Hulu, Hulu Live, and ESPN+ video streaming services (Compl. ¶39).
  • Functionality and Market Context:
    • The complaint identifies the accused services as standalone platforms for streaming on-demand and live media content from a wide variety of sources, including Disney, Pixar, Marvel, and major broadcast networks (Compl. ¶¶40, 49, 56). These services are accessible on web browsers, mobile devices, smart TVs, and other platforms (Compl. ¶40).
    • Technically, the services are alleged to use Advanced Video Coding (AVC) and High Efficiency Video Coding (HEVC) to stream video (Compl. ¶¶41, 50). The complaint provides detailed evidence of the services' infrastructure, alleging the use of multiple third-party Content Delivery Networks (CDNs), including Amazon Web Services (AWS) CloudFront, Fastly, and Akamai, to deliver content to users (Compl. ¶¶42, 46, 47). A screenshot of an IP address lookup shows that a host involved in Disney+ playback, "disney.playback.edge.bamgrid.com," resolves to an Amazon network address, which Plaintiff may offer as evidence of the specific infrastructure used (Compl. ¶43, p. 21).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (A.2, B.2, C.2, D.2, E.2) that are not attached to the publicly filed document. Therefore, the narrative infringement theories are summarized below in prose.

  • ’301 Patent Infringement Allegations: The complaint alleges that Defendants infringe claims 8-12 of the ’301 Patent by encoding the content for the Accused Instrumentalities (Compl. ¶483). The infringement theory centers on the video encoding processes used by Disney, which allegedly practice the patented method of associating adaptive weighting factors with specific reference picture indices to improve compression efficiency (Compl. ¶472). The complaint includes a screenshot from network traffic analysis showing that a host name associated with Hulu video playback resolves to an IP address within the Amazon network, which may be used to argue that Defendants operate or control the servers performing the allegedly infringing encoding methods (Compl. ¶52, p. 29).

  • ’610 Patent Infringement Allegations: The complaint alleges that Defendants infringe claims 6-10 of the ’610 Patent by encoding content for the Accused Instrumentalities (Compl. ¶503). The infringement theory is that the video encoding technology used for Disney's streaming services, which utilize codecs such as HEVC (Compl. ¶50), implements the patented intra-prediction method of dividing pixels within a block into groups and using the reconstructed first group to predict the second (Compl. ¶494). The complaint provides technical data, such as HTTP headers captured during an ESPN+ live stream, that identify the use of the BAMTech Media platform and the AWS CloudFront CDN, which may serve as evidence of Defendants' use and control over the accused encoding and delivery infrastructure (Compl. ¶58, p. 33).

  • Identified Points of Contention:

    • Scope Questions: A central question for the video coding patents ('301, '610, '818) may be whether the specific algorithms implemented in the AVC and HEVC standards, as used by Defendants, fall within the scope of the asserted claims. For example, regarding the ’610 Patent, a dispute may arise over whether the accused codecs perform the claimed step of "dividing pixels within the block into at least a first group and a second group" for predictive purposes in the manner disclosed, or if they employ alternative, non-infringing intra-prediction modes permitted by the standards.
    • Technical Questions: For the ’268 Patent, a key technical question may be what evidence demonstrates that Disney's content creation and delivery workflow creates a "master for CG2 displays" and corresponding "metadata" for transforming that content to RCG displays, as required by the claims. The analysis may focus on the specific data structures and processing steps within Disney's content pipeline.
    • Control/Attribution Questions: The complaint details the use of third-party CDNs (Compl. ¶¶42-63). A potential point of contention may be the extent to which Disney directs or controls the actions of these third parties, and whether Disney's role constitutes "making" or "using" the allegedly infringing systems under 35 U.S.C. § 271(a).

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a full analysis, as it relies on unattached exhibits. However, based on the technology descriptions, certain terms may become central to the dispute.

  • Term ('301 Patent): "assigning a weighting factor . . . associated with a particular reference picture index"

    • Context and Importance: The invention's asserted novelty rests on this specific association. Practitioners may focus on this term because the definition of how a factor is "associated with" an "index" will determine whether the methods used in standard codecs like AVC/HEVC fall within the claim scope.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent specification may describe the "index" broadly as any identifier that points to a reference picture, potentially supporting an argument that any system linking a weight to a picture identifier infringes.
      • Evidence for a Narrower Interpretation: The patent's description of specific embodiments, potentially referencing particular syntax elements in a draft or final video standard, could be used to argue for a narrower construction limited to those specific implementations (e.g., ’301 Patent, col. 8:59-65).

  • Term ('610 Patent): "dividing pixels within the block into at least a first group and a second group"

    • Context and Importance: This step is the crux of the asserted improvement in intra-prediction. The dispute will likely hinge on what constitutes "dividing" for the purposes of the claim.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states that "the groups of pixels within the block may be divided in any manner desired and found to be effective," suggesting a broad, functional definition not limited to specific geometric patterns (Compl. ¶494, citing '610 Patent at col. 9:7-9).
      • Evidence for a Narrower Interpretation: Defendants may point to the specific examples shown in the patent's figures (e.g., partitioning a rightmost column or bottom row) to argue that the term should be limited to these disclosed physical arrangements (’610 Patent, col. 8:40-44).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that each Defendant "took the above actions intending to infringe and/or cause infringing acts by others" (Compl. ¶¶459-467). This language suggests a claim for induced infringement, potentially implicating the actions of third-party CDN providers or end-users who operate the streaming applications.
  • Willful Infringement: The complaint alleges that InterDigital contacted Disney in July 2022 to discuss licensing the asserted technologies (Compl. ¶3). Plaintiff's prayer for relief seeks a judgment that the infringement has been willful (Compl. p. 136, ¶B). This allegation of pre-suit notice, followed by continued alleged infringement, will likely be the primary basis for the willfulness claim.

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

  • A core issue will be one of algorithmic scope: Do the specific, standardized methods for video compression and color management implemented in the accused Disney+, Hulu, and ESPN+ services practice the particular steps recited in the asserted claims, or do they represent distinct, non-infringing alternatives available within the flexible frameworks of modern video standards?
  • A second key question will be one of infringing control: Given the services' reliance on a complex infrastructure involving third-party CDNs like AWS and Akamai, what evidence will establish that the Disney defendants direct or control the allegedly infringing encoding and content delivery operations to a degree sufficient to establish direct liability for infringement?
  • A final question will be one of technical implementation: For patents like the ’297 Patent on user interface modification, the case may turn on evidence showing that the accused services transmit "side information" embedded within the video stream that modifies the UI, as opposed to the UI being controlled by the client-side application code itself.