Nokia Tech Oy v. ASUSTeK Computer Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Nokia Technologies Oy (Finland)
  • Defendant: ASUSTek Computer Inc. (Taiwan); ASUS Global Pte Ltd. (Singapore); ASUS Computer International (California)
  • Plaintiff’s Counsel: McKool Smith, P.C.
• Case Identification: 2:25-cv-3053, C.D. Cal., 04/07/2025
• Venue Allegations: Venue is alleged to be proper in the Central District of California because Defendant ASUS Computer International maintains a regular and established place of business in the district and has committed acts of infringement there. For the foreign defendants, venue is alleged to be proper in any judicial district under 28 U.S.C. § 1391(c)(3).
• Core Dispute: Plaintiff alleges that Defendant’s laptops, desktop computers, and handheld gaming devices, which support H.264 and H.265 video standards, infringe five U.S. patents related to video coding technology.
• Technical Context: The technology at issue involves video compression and decompression methods essential to the widely adopted H.264 and H.265 video coding standards, which are fundamental to modern video streaming over the internet.
• Key Procedural History: The complaint asserts that some of the patents-in-suit are essential to the H.264 and H.265 standards, for which Plaintiff has committed to license on reasonable and non-discriminatory (RAND) terms. Plaintiff alleges that it has engaged in good-faith licensing negotiations with Defendant since 2017, but that these negotiations have failed, prompting the lawsuit.

Case Timeline

Date	Event
2002-01-23	’321 Patent Priority Date
2002-03-15	’808 Patent Priority Date
2009-05-12	’808 Patent Issue Date
2010-07-28	’701 Patent Priority Date
2011-01-07	’267 Patent Priority Date
2011-11-01	’321 Patent Issue Date
2011-11-04	’714 Patent Priority Date
2015-05-19	’701 Patent Issue Date
2020-01-14	’714 Patent Issue Date
2023-10-31	’267 Patent Issue Date
2025-04-07	Complaint Filing Date

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

U.S. Patent No. 10,536,714 - “Method for Coding and an apparatus”

• The Invention Explained:
  • Problem Addressed: The patent addresses inefficiencies in prior art video coding, where methods for generating a list of motion vector prediction candidates were computationally complex and created redundancy because some candidates contained identical motion information (Compl. ¶54; ’714 Patent, col. 3:66-4:3).
  • The Patented Solution: The invention claims to reduce computational complexity by creating a more efficient motion vector candidate list. The described method obtains spatial candidates from neighboring blocks and performs a limited, non-exhaustive number of comparisons to identify and remove redundant candidates before adding them to the final list, with the decision to compare candidates depending on the location of the block being processed (’714 Patent, col. 4:19-39). This avoids comparing every possible candidate pair, thereby reducing processing overhead (Compl. ¶55).
  • Technical Importance: This approach is described as improving prediction accuracy while reducing the computational complexity of video decoders, which in turn decreases the amount of data required to transmit and successfully play back video (Compl. ¶56).
• Key Claims at a Glance:
  • The complaint references a claim chart applying claim 9 to the Accused Products (Compl. ¶105).
  • Independent claim 9 is a method claim with the following essential elements:
    • selecting a first spatial motion vector prediction candidate from a set of candidates for a block of pixels;
    • determining a subset of spatial motion vector prediction candidates based on the location of the block associated with the first candidate;
    • comparing motion information of the first candidate with the motion information of candidates in the determined subset, without making a comparison of each possible pair from the full set;
    • determining to include or exclude the first candidate in a motion vector prediction list based on the comparison; and
    • causing information identifying one candidate from the list to be transmitted or stored.
  • The complaint reserves the right to assert additional claims (Compl. ¶99).

U.S. Patent No. 11,805,267 - “Motion Prediction in Video Coding”

• The Invention Explained:
  • Problem Addressed: In bi-directional prediction for video coding, forming a prediction signal by averaging two prediction blocks can introduce rounding errors. The patent states that the accumulation of these errors degrades overall coding efficiency, and prior solutions to this problem increased process complexity (’267 Patent, col. 3:56-65; Compl. ¶64).
  • The Patented Solution: The invention proposes a method that maintains prediction signals at a higher precision than the reference pixel values during the initial prediction calculation. After two or more of these higher-precision prediction signals are combined, the resulting combined prediction is reduced in precision (e.g., via bit-shifting) to match the original pixel precision. This approach avoids the accumulation of rounding errors at intermediate stages and eliminates the need to signal rounding direction information in the bitstream (’267 Patent, col. 4:29-35; Compl. ¶65).
  • Technical Importance: The solution is presented as reducing complexity and increasing coding efficiency, which results in a significant reduction in the amount of information that needs to be transmitted for video playback (Compl. ¶66).
• Key Claims at a Glance:
  • The complaint references claim charts applying claim 19 to the Accused Products (Compl. ¶115).
  • Independent claim 19 is a method claim with the following essential elements:
    • determining, for a current block, a first and second reference block based on first and second motion vectors, where pixels have a first precision;
    • using the first reference block to obtain a first prediction having a second precision, which is higher than the first precision;
    • using the second reference block to obtain a second prediction, also having the second precision;
    • obtaining a combined prediction based at least partly on the first and second predictions;
    • decreasing the precision of the combined prediction by shifting bits to the right; and
    • reconstructing the block of pixels based on the combined prediction.
  • The complaint reserves the right to assert additional claims (Compl. ¶109).

U.S. Patent No. 8,050,321 - “Grouping of Image Frames in Video Coding”

• Technology Synopsis: The patent addresses a problem that occurred when a user started streaming or browsing a video from a point other than the beginning (Compl. ¶74). The described solution involves inventing an independently decodable sequence of image frames that includes an explicit indication of the first picture, allowing a decoder to start decoding from that picture without needing prediction from any prior frames (Compl. ¶75).
• Asserted Claims: The complaint references claim charts applying claim 8 to the Accused Products (Compl. ¶124).
• Accused Features: The accused functionality is the decoding of video compliant with the H.264 and H.265 standards, which allegedly practice the claimed invention (Compl. ¶118, 124).

U.S. Patent No. 9,036,701 - “Method and Apparatus for Providing Complexity Balanced Entropy Coding”

• Technology Synopsis: The patent addresses the problem of high processing complexity and battery consumption in mobile devices when streaming video content (’701 Patent, col. 1:37-50). The solution is a "complexity balanced entropy coding" system that divides syntax elements into categories based on their expected frequency of occurrence and applies different coding techniques to each category—for example, using context adaptive coding for infrequent symbols and a less complex "bypass coding" for frequent symbols (Compl. ¶83-84).
• Asserted Claims: The complaint references a claim chart applying claim 1 to the Accused Products (Compl. ¶133).
• Accused Features: The accused functionality is the decoding of video compliant with the H.265 standard, which allegedly practices the claimed complexity-balancing invention (Compl. ¶127, 133).

U.S. Patent No. 7,532,808 - “Method for Coding Motion in a Video Sequence”

• Technology Synopsis: The patent addresses the inability of the conventional "SKIP" coding mode to efficiently handle global or regional motion in a video sequence, such as panning or zooming (’808 Patent, col. 12:41-47). The invention is an improved skip mode that can adapt to motion in the surrounding region by associating the macroblock with either a zero (non-active) motion vector or a non-zero (active) motion vector determined by analyzing the motion of neighboring blocks (Compl. ¶94).
• Asserted Claims: The complaint references a claim chart applying claim 7 to the Accused Products (Compl. ¶141).
• Accused Features: The accused functionality is the decoding of video compliant with the H.264 standard, which allegedly practices the claimed adaptive SKIP mode invention (Compl. ¶135, 141).

III. The Accused Instrumentality

Product Identification

• The Accused Products are identified as ASUS's laptops, desktop computers, and handheld gaming devices that support and implement H.264 and H.265 video decoding (Compl. ¶2).

Functionality and Market Context

• The relevant functionality of the Accused Products is their ability to decode video streams that conform to the H.264 Advanced Video Coding and H.265 High Efficiency Video Coding standards (Compl. ¶1). These standards are described as two of the most prominent video decoding standards in the world, enabling efficient streaming and playback of high-quality video with lower bandwidth requirements (Compl. ¶3, 25).
• The complaint alleges that ASUS benefits from Nokia's patented innovations, which enable ASUS products to stream, playback, and capture high quality video more efficiently (Compl. ¶4).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’714 Patent Infringement Allegations

Claim Element (from Independent Claim 9)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
selecting a first spatial motion vector prediction candidate from a set of spatial motion vector prediction candidates for a block of pixels...	ASUS products implementing H.265 decoding select spatial motion vector candidates from neighboring blocks to predict motion for a current block (Compl. ¶53, 55).	¶55	col. 4:19-21
determining a subset of spatial motion vector prediction candidates based on the location of the block associated with the first spatial motion vector prediction candidate	The decoding process allegedly determines a specific subset of the available neighboring candidates for comparison based on the location of the current block being processed (Compl. ¶55, 58).	¶58	col. 4:21-23
comparing motion information of the first spatial motion vector prediction candidate with motion information of the spatial motion vector prediction candidates in the determined subset...without making a comparison of each pair from the set of spatial motion vector prediction candidates	The H.265 decoding process allegedly performs a limited number of comparisons between candidate pairs to remove redundant candidates, rather than comparing every available pair (Compl. ¶55, 57).	¶57	col. 4:24-34
determining to include or exclude the first spatial motion vector prediction candidate in the motion vector prediction list based on the comparing	Based on the limited comparison, the decoding process determines whether to include or exclude a candidate from the final prediction list to reduce redundancy (Compl. ¶55, 59).	¶59	col. 4:35-39

• Identified Points of Contention:
  • Scope Questions: A central question may be how the claim term "without making a comparison of each pair" is construed. The analysis may turn on whether the accused H.265 implementation performs a comparison process that meets this negative limitation, or if its redundancy-check algorithm falls outside the claim's scope.
  • Technical Questions: The dispute may focus on whether the specific candidate-pruning logic implemented in the Accused Products for H.265 decoding is functionally identical to the specific method of determining a subset "based on the location of the block" and performing limited comparisons as required by the claim.

’267 Patent Infringement Allegations

Claim Element (from Independent Claim 19)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
determining, for a current block, a first reference block based on a first motion vector and a second reference block...wherein the pixels of the current block...have values with a first precision	ASUS products implementing H.265 bi-directional prediction determine reference blocks for a current block of pixels, where the pixels have a standard precision (e.g., 8-bit) (Compl. ¶62; ’267 Patent, col. 15:55-58).	¶62	col. 15:55-58
using said first reference block to obtain a first prediction, said first prediction having a second precision, which is higher than said first precision	The H.265 decoding process allegedly generates a first prediction signal from the first reference block that is maintained at a higher-than-standard precision during calculation (Compl. ¶65, 68).	¶68	col. 16:1-4
using said second reference block to obtain a second prediction, said second prediction having the second precision	The decoding process allegedly generates a second prediction signal from the second reference block that is also maintained at the same higher precision (Compl. ¶65, 68).	¶68	col. 16:5-8
obtaining a combined prediction based at least partly upon said first prediction and said second prediction	The two high-precision prediction signals are combined (e.g., averaged) to form a combined prediction signal that is also at the higher precision (Compl. ¶65, 69).	¶69	col. 16:9-11
decreasing a precision of said combined prediction by shifting bits of the combined prediction to the right	After combining, the precision of the combined prediction signal is reduced back to the standard "first precision" by a bit-shifting operation (Compl. ¶68-69).	¶68	col. 16:12-14
reconstructing the block of pixels based on the combined prediction	The final, precision-reduced combined prediction is used by the decoder to reconstruct the block of pixels for display (Compl. ¶65, 69).	¶69	col. 16:15-17

• Identified Points of Contention:
  • Scope Questions: The interpretation of "a second precision, which is higher than said first precision" will be critical. The case may hinge on whether the internal processing precision used in ASUS's decoders qualifies as this distinct "second precision" or is merely a conventional aspect of digital signal processing.
  • Technical Questions: A key evidentiary question will be whether the accused products' decoding process explicitly performs the claimed sequence of: generating two separate high-precision signals, then combining them, and then decreasing the precision via bit-shifting.

V. Key Claim Terms for Construction

For the ’714 Patent

• The Term: "a subset of spatial motion vector prediction candidates based on the location of the block"
• Context and Importance: This term is central to defining the novelty of the claimed method. The infringement analysis will depend on whether the H.265 standard as implemented by Defendant uses a candidate selection process that is driven by the "location of the block" in the specific manner covered by the patent, or if it uses a more generic or different logic for selecting which candidates to compare for redundancy.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The detailed description provides examples where the subset of candidates to be compared against changes depending on whether the current prediction unit is the second unit of a horizontally or vertically split coding unit, suggesting the "location" is relative to the coding unit structure (’714 Patent, Fig. 10a, 10b, col. 15:50-16:1). This could support a reading that covers various location-dependent logical checks.
  • Evidence for a Narrower Interpretation: The specific embodiments and flow charts (e.g., Fig. 5b, 8b) detail a very particular sequence of checks against neighboring blocks (A1, B1, B0, A0, B2). A defendant may argue that the term should be limited to these specific spatial arrangements and comparison rules, rather than any location-based logic.

For the ’267 Patent

• The Term: "a second precision, which is higher than said first precision"
• Context and Importance: This term defines the core technical mechanism for avoiding rounding errors. The dispute will likely focus on whether the internal processing arithmetic used in the Accused Products constitutes this claimed "higher" precision, or if it is a standard, unpatentable aspect of processor design. The viability of the infringement claim depends on this term being construed as a specific, unconventional processing state rather than a generic increase in bit depth during calculation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that the invention "maintains the prediction signals in a higher precision during the prediction calculation" and only reduces it after combination, distinguishing it from prior art that rounded at intermediate steps (’267 Patent, col. 3:66-4:12). This could support a broad interpretation covering any process that defers precision reduction until after combination.
  • Evidence for a Narrower Interpretation: The patent provides a specific example where an intermediate result is shifted "to the right so that the precision of the sum becomes M bits," where M>N (’267 Patent, col. 13:10-16). A defendant may argue that the claim requires this explicit creation of an intermediate, defined "second precision" of M bits, and is not met by general-purpose floating-point or extended-precision arithmetic inherent in modern processors.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant provides the Accused Products along with instructions, documentation, marketing, and technical support that encourage users to perform infringing acts, such as streaming video (Compl. ¶101, 111, 120). It further alleges contributory infringement on the grounds that the accused video decoding components are material to the inventions, are not staple articles of commerce, have no substantial non-infringing uses, and are known by ASUS to be especially adapted for use in infringement (Compl. ¶102, 112, 121).
• Willful Infringement: The complaint alleges willfulness based on both pre- and post-suit knowledge. Pre-suit knowledge is alleged based on licensing negotiations since 2017, and specific notice of patent lists and claim charts for related or asserted patents provided on multiple occasions between July 2020 and January 2025 (Compl. ¶98, 107, 117, 126, 134). Post-suit knowledge is based on the filing and service of the complaint itself.

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

• Standard-Essentiality vs. Infringement: A central issue will be whether compliance with the H.264 and H.265 standards necessarily requires practicing the specific methods claimed in the patents-in-suit. The case will likely involve detailed analysis of the standards to determine if non-infringing alternative implementations exist, a common point of contention in SEP litigation.
• Definitional Scope: The dispute may turn on questions of claim construction, such as whether the internal arithmetic of a modern processor meets the ’267 Patent’s requirement of a distinct "higher precision," or whether the H.265 standard’s method for building a motion vector list constitutes the specific location-based "subset" determination claimed by the ’714 Patent.
• Willfulness and Damages: Given the complaint’s detailed timeline of alleged pre-suit notice through licensing negotiations, a key question for damages will be when ASUS's alleged infringement became willful. The outcome of this question could substantially impact any potential damages award, particularly if enhanced damages are considered.