DCT
2:25-cv-10526
Control Synch Systems LLC v. E S Intl Enterprises Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Control Sync Systems, LLC (Wyoming)
- Defendant: E & S International Enterprises, Inc. dba ESI Enterprises, Inc. (California)
- Plaintiff’s Counsel: SML Avvocati P.C.
- Case Identification: 2:25-cv-10526, C.D. Cal., 11/02/2025
- Venue Allegations: Venue is based on Defendant being a California corporation with a regular and established place of business within the Central District of California, where acts of infringement are alleged to have occurred.
- Core Dispute: Plaintiff alleges that Defendant’s JVC-branded smart televisions, which utilize the HDMI-CEC standard, infringe a patent related to synchronously controlling a display device and a connected media play device using a single control system.
- Technical Context: The technology addresses the unified control of multiple home entertainment components, a common feature in modern consumer electronics designed to simplify user interaction with complex media systems.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2005-07-29 | ’889 Patent Priority Date |
| 2010-10-12 | ’889 Patent Issue Date |
| 2025-11-02 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,812,889 - "Control System for Synchronously Controlling Display Device and Play Device"
- Patent Identification: U.S. Patent No. 7,812,889, "Control System for Synchronously Controlling Display Device and Play Device," issued October 12, 2010.
The Invention Explained
- Problem Addressed: The patent's background describes the user inconvenience and frustration of managing separate control systems for interconnected media devices, such as a projector and a DVD player. A user wanting to adjust a parameter like volume might have to use two different remote controls, making the process "really inconvenient and troublesome." (’889 Patent, col. 1:40-54).
- The Patented Solution: The invention provides a control system where a command (an "OSD signal") received by a display device is encoded into a data signal and transmitted over a bus to a connected play device. This allows the play device to decode the signal and adjust its parameters in coordination with the display device, enabling synchronous control from a single point of input. (’889 Patent, Abstract; col. 2:2-37; Fig. 2). The system architecture is designed so that commands can flow in either direction, unifying the control experience. (’889 Patent, col. 4:36-50).
- Technical Importance: This approach sought to streamline the user interface for multi-component home theater systems by centralizing control functions that were traditionally isolated to individual devices. (Compl. ¶14).
Key Claims at a Glance
- The complaint asserts infringement of independent claim 1. (Compl. ¶15).
- The essential elements of Claim 1 are:
- An on screen display (OSD) system of the display device for receiving a first OSD signal from external of the display device;
- An encoding/decoding module of the display device for encoding the first OSD signal into a first data signal;
- A bus connected to the display device for sending the first data signal to the play device;
- Wherein the display device receives the first OSD signal to control its own parameters, and the play device decodes the first data signal from the bus to control its parameters.
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant’s 4K UHD HDR Roku Smart LED TVs, including the MAW595, MAR595, and MAW795 series. The 70” MAW795 model is used as an exemplary device. (Compl. ¶¶15-16).
Functionality and Market Context
- The complaint alleges that the accused TVs incorporate the HDMI-CEC (Consumer Electronics Control) standard, which enables a single remote control to manage multiple connected devices over HDMI cables. (Compl. ¶16). According to the complaint, the TV’s remote control can issue commands, such as play or pause, that are processed by the TV and relayed to a connected multimedia device (e.g., a DVD player or game console) to control its playback. (Compl. ¶18). The complaint includes a diagram from the product manual showing a "DVD Player/Set-Top Box" connected to the TV via an HDMI cable. (Compl. p. 10).
IV. Analysis of Infringement Allegations
’889 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an on screen display (OSD) system of the display device disposed in the display device for receiving a first OSD signal from external of the display device; | The accused TV includes an OSD system that receives control commands, such as play and pause signals ("first OSD signal"), from the TV's external remote control. | ¶17 | col. 5:6-9 |
| an encoding/decoding module of the display device disposed in the display device for encoding the first OSD signal received by the OSD system into a first data signal; | The accused TV allegedly includes a module that encodes the command received from the remote into a data signal (an HDMI-CEC command) for transmission to the connected multimedia device. | ¶18 | col. 5:1-5 |
| a bus connected to the display device for sending the first data signal out of the display device and transmitting the first data signal to the play device; | The HDMI cable connecting the TV to an external multimedia device, such as a DVD player, functions as the claimed "bus" to transmit the control commands. | ¶19 | col. 5:5-12 |
| wherein the display device receives the first OSD signal to control the video and audio parameters of the display device, the play device is decoding the first data signal received from the bus to control the video and audio parameters of the play device. | The TV receives the command from its remote, and the connected multimedia device allegedly decodes the command sent over the HDMI bus to control its playback parameters (e.g., play/pause). | ¶20 | col. 5:10-12 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the implementation of the industry-standard HDMI-CEC protocol falls within the scope of the patent's claims. The complaint alleges the TV's remote control and its functions satisfy the "first OSD signal" and "OSD system" limitations. (Compl. p. 14). A dispute could arise over whether the term "OSD system," as understood in the patent, refers to the IR receiver and command processing logic, or more narrowly to the graphical user interface generator.
- Technical Questions: The complaint alleges the existence of an "encoding/decoding module" based on the TV's ability to translate remote commands into HDMI-CEC signals, stating its existence "would be apparent for a person having ordinary skills in the art." (Compl. ¶¶17-18). The case may require evidence detailing how the accused TV's hardware and software architecture actually implements this function and whether it maps to the claimed "module" structure.
V. Key Claim Terms for Construction
The Term: "encoding/decoding module"
Context and Importance: This term is central to the claimed invention's mechanism. The infringement theory depends on establishing that the accused TV contains a distinct component or software function that "encodes" a signal from the remote into a "first data signal" for the bus. The definition of "module" will be critical.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the module in functional terms, without limiting it to a specific hardware implementation. For example, it is described as being "disposed in the display device for encoding the first OSD signal." (’889 Patent, col. 5:1-4). This functional language may support a construction that covers any combination of hardware or software that performs the claimed encoding function.
- Evidence for a Narrower Interpretation: The patent figures depict the "encoding/decoding module" as a discrete block in a system diagram (’889 Patent, Fig. 2, element 42). A defendant might argue this suggests a more specific structural requirement than is present in the highly integrated system-on-a-chip (SoC) architecture of a modern smart TV.
The Term: "on screen display (OSD) system"
Context and Importance: The claim requires this "system" to receive the external signal. Practitioners may focus on this term because its definition could determine whether the claim reads on the TV's entire input and control interface or only the part that generates on-screen graphics.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the "OSD system 40 is disposed in the display device 32 for receiving a first OSD signal from external of the display device 32." (’889 Patent, col. 3:21-23). This suggests the "system" is the component that directly interfaces with the external signal source. The complaint leverages this by showing the TV remote sending signals to the TV. (Compl. p. 14).
- Evidence for a Narrower Interpretation: In conventional technical usage, an OSD system is the component that generates text and graphics overlays on a video signal. A defendant could argue that the IR receiver that receives the remote signal is a separate component from the OSD graphics generator, and therefore the OSD system itself does not "receive" the external signal as required by the claim.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides customers with products and "online manuals describing how the control systems of the JVC TVs can be operated in a manner that infringes." (Compl. ¶21). This is alleged to demonstrate a specific intent to encourage the infringing use.
- Willful Infringement: The complaint alleges knowledge of the ’889 Patent "at least as of service of the Complaint." (Compl. ¶21). This provides a basis for post-suit willfulness but does not allege pre-suit knowledge of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical mapping: Can the functional block-diagram language of the 2005-priority patent claim, particularly the "encoding/decoding module," be mapped onto the integrated software and hardware architecture of a modern smart TV that implements the standardized HDMI-CEC protocol?
- A second key issue will be one of claim scope: Will the term "OSD system" be construed broadly to mean the TV's general control input interface, as the complaint's theory appears to require, or will it be limited to its more conventional meaning of a graphics-overlay generator, potentially creating a gap in the infringement narrative?
- A final question will be evidentiary: What factual evidence will be presented to demonstrate that the connected "play device" performs a "decoding" of a "data signal" from the bus, as required by the claim, versus simply executing a standardized command received through the HDMI-CEC interface?