8:25-cv-01404
Perceptix Tech LLC v. Meta Platforms Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Perceptix Technologies LLC (California)
- Defendant: Meta Platforms, Inc. (Delaware)
- Plaintiff’s Counsel: Orbit IP, LLP
- Case Identification: 8:25-cv-01404, C.D. Cal., 09/23/2025
- Venue Allegations: Plaintiff alleges venue is proper because Meta resides in the judicial district and maintains regular and established places of business, such as its Reality Labs office, where acts of infringement are alleged to have occurred.
- Core Dispute: Plaintiff, the exclusive licensee of a patent on context-aware audio headsets, alleges that Defendant’s virtual reality, augmented reality, and smart glass products infringe the patent by sensing user and environmental data to provide personalized audio services.
- Technical Context: The dispute centers on context-aware computing in wearable devices, a foundational technology for creating immersive and responsive user experiences in the virtual and augmented reality markets.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of infringement on or about June 26, 2025, prior to filing the initial complaint. This allegation may form the basis for a claim of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2007-07-20 | ’439 Patent Priority Date |
| 2013-07-30 | ’439 Patent Issue Date |
| 2014 | Meta (then Facebook) acquires Oculus VR, Inc. |
| 2019-05 | Launch of Meta XR Headsets (Oculus Quest) |
| 2023 | Launch of Ray-Ban Meta line of AI glasses |
| 2024 | Meta unveils Orion AR headset prototypes |
| 2025-06-26 | Plaintiff provides written notice of infringement to Meta |
| 2025-09-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,498,439 - "Headset for User Specific Audio Service and Method for User Specific Audio Service Using the Same," Issued July 30, 2013
The Invention Explained
- Problem Addressed: Conventional headsets require a user to manually select and play preferred music, which necessitates direct user intervention to match the audio to their current activity or environment (’439 Patent, col. 1:26-34).
- The Patented Solution: The invention is a headset system designed to automate audio selection. It includes a "sensing unit" to detect whether the headset is being worn, an "information collecting unit" to gather "current situation information" about the user, and an "information processing unit" that generates a "user profile" based on this situational data to control the audio output from a separate digital audio device (’439 Patent, Abstract; col. 2:1-5). The system aims to understand the user's context and surroundings to provide an "optimized specific audio service" automatically (’439 Patent, col. 2:46-52).
- Technical Importance: The patent describes an early architecture for context-aware personal audio, aiming to create a more seamless and intuitive user experience by eliminating the need for manual control of audio content based on the user's real-world state (Compl. ¶26).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 11 (Compl. ¶11).
- Independent Claim 1: A headset comprising:
- a sensing unit sensing whether or not the headset is put on;
- an information collecting unit determining whether or not the headset is put on by the sensing unit and collecting current situation information of a user when the headset is put on; and
- an information processing unit generating a user profile based on the current situation information of the user, and controlling an audio signal output of a digital audio device based on the generated user profile.
- Independent Claim 11: A headset with the same elements as claim 1, further specifying that the "current situation information" includes "information about the user's surroundings."
- The complaint notes that Plaintiff may assert additional claims (Compl. ¶58).
III. The Accused Instrumentality
Product Identification
The complaint collectively refers to three categories of products as the "Meta Headsets":
- Meta XR Headsets: Including Meta Quest, Quest 2, Quest 3, Quest 3S, and Quest Pro (Compl. ¶25).
- Meta AI Headsets: Including Ray-Ban and Oakley branded smart glasses (Compl. ¶33).
- Meta AR Headsets: Including the "Orion" augmented reality glasses prototypes (Compl. ¶40).
Functionality and Market Context
The accused products are head-worn computing devices equipped with various sensors (e.g., cameras, inertial measurement units) that gather data about the user and their environment (Compl. ¶44). This data enables features such as hand tracking, gesture support, passthrough mixed reality, and spatial audio (Compl. ¶62). The complaint alleges this sensor data is used to provide context-aware and personalized audio functionalities, which are central to the products' operation (Compl. ¶34, ¶42). A screenshot of a job posting for a "Software Engineer, Realtime Engine Technology – Reality Labs" is provided to support allegations of Meta's development activities related to these products within the judicial district (Compl. p. 5). The complaint alleges that sales of the infringing products have generated substantial revenue, exceeding $10 billion for the XR Headsets and $500 million for the AI Headsets (Compl. ¶27, ¶35).
IV. Analysis of Infringement Allegations
The complaint references claim chart exhibits that were not provided. The following analysis summarizes the narrative infringement theory presented in the complaint.
The complaint alleges that the Meta Headsets practice each element of claims 1 and 11 (Compl. ¶51). The core theory is that the devices use their built-in sensors to determine when they are being worn and to collect data about the user and their surroundings (Compl. ¶53-54, ¶56). This information is then allegedly processed to create a contextual understanding of the user, which is used to control and personalize audio output (Compl. ¶55, ¶57). For example, the complaint alleges that the ability of the Meta AR Headsets to provide relevant assistance based on what a user is looking at is "enabled by the headset's continuous sensing and profiling of the user's context" (Compl. ¶43). This combination of sensing, information collection, and adaptive audio output is alleged to be foundational to the accused products' functionality (Compl. ¶44).
Identified Points of Contention
- Scope Questions: A central dispute may concern whether the term "digital audio device" as used in the patent, which depicts a separate MP3 player-like device, can be read to cover the integrated processing and audio components within the accused headsets or the broader software ecosystem (e.g., the Meta Quest Store, associated smartphone apps) that provides content to them.
- Technical Questions: The complaint alleges the headsets generate a "user profile" to control audio output. A key technical question will be whether the accused devices perform this specific function as claimed—generating a profile from current situational data to control an audio signal—or if they employ a more generalized AI model that uses sensor data for a wide array of functions beyond immediate audio control, such as user interface adaptation, ad targeting, or avatar animation. The complaint's own allegations that the data is used for "physical AI" systems and "embodied AI training" may be used to frame this question (Compl. ¶38).
V. Key Claim Terms for Construction
The Term: "current situation information of a user"
- Context and Importance: This term is the lynchpin of the infringement allegation, as its scope defines what types of data collection fall within the claims. The dispute will likely center on whether this term is limited to the types of simple sensor data disclosed in the patent or extends to the rich, multi-modal data (e.g., video, spatial mapping) collected by modern AR/VR devices.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 11 itself broadens the term by explicitly including "information about the user's surroundings," suggesting the term is not limited to the user's personal physical state. The specification's use of "for example" when listing sensor types may support an argument that the list is illustrative, not exhaustive (’439 Patent, col. 5:9-11).
- Evidence for a Narrower Interpretation: The specification provides a specific list of exemplary sensor inputs, including "a temperature sensing unit, a light sensing unit, an acceleration sensing unit, a gyro sensing unit, a pressure sensing unit, a skin conductivity sensing unit, and a pulse sensing unit" (’439 Patent, col. 2:14-17). An argument could be made that the invention is limited to data from such sensors, rather than complex data streams like video from cameras.
The Term: "user profile"
- Context and Importance: The generation of a "user profile" is the crucial intermediate step between collecting data and controlling audio. The definition of this term will be critical to determining whether Meta's software architecture performs the claimed function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is generic, and one could argue it should be given its plain and ordinary meaning: any collection of data about a user used to tailor a service.
- Evidence for a Narrower Interpretation: The specification states that the user profile "may include types or lists of specific situation audio that the user prefers" and that "indexing related to the user profile is required for types of user's preferred audio at each specific situation" (’439 Patent, col. 2:18-19, col. 5:19-22). This language may support a narrower construction of the "user profile" as a lookup table or a set of predefined rules linking specific, detected situations to pre-selected audio content, rather than a dynamic, AI-driven model.
VI. Other Allegations
Indirect Infringement
The complaint alleges inducement of infringement by end-users and customers through Meta's provision of promotional materials, user guides, software updates, and access to the Meta Quest Store, which allegedly instruct and encourage users to operate the headsets in an infringing manner (Compl. ¶61, ¶64-65). Contributory infringement is alleged on the basis that the Meta Headsets are a material part of the invention, are not staple articles of commerce suitable for substantial non-infringing use, and are known by Meta to be especially adapted for infringement (Compl. ¶60).
Willful Infringement
Willfulness is alleged based on Meta’s continued infringing activities after receiving a written notice of infringement from Plaintiff on or about June 26, 2025, which allegedly provided Meta with full knowledge of the ’439 Patent and its infringement (Compl. ¶68, ¶71).
VII. Analyst’s Conclusion: Key Questions for the Case
This case will likely depend on the resolution of fundamental questions regarding claim scope and the technical operation of the accused systems.
- A core issue will be one of definitional scope: can claim terms like "current situation information" and "user profile," which were defined in the patent with reference to 2007-era sensor and software technology, be construed to encompass the sophisticated, AI-driven, multi-modal data processing architectures of Meta's contemporary XR and AR platforms?
- A key evidentiary question will be one of functional architecture: does the complaint provide sufficient evidence that Meta's devices perform the specific, sequential process recited in the claims—namely, generating a distinct "user profile" from immediate situational data for the express purpose of "controlling an audio signal output"—or do the accused systems operate on a fundamentally different technical principle where sensor data feeds a general-purpose AI model that influences a wide range of device behaviors, of which audio is only one component?