DCT
8:25-cv-02345
Tir Tech Ltd v. Meta Platforms Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: TIR Technologies Limited (Ireland)
- Defendant: Meta Platforms, Inc. (Delaware)
- Plaintiff’s Counsel: BC LAW GROUP, Group; Olson Stein LLP
- Case Identification: 8:25-cv-2345, C.D. Cal., 01/14/2026
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant maintains offices and conducts business in Orange and Los Angeles counties, including alleged acts of infringement.
- Core Dispute: Plaintiff alleges that Defendant’s video streaming services on its Facebook and Instagram social media platforms infringe two patents related to just-in-time distributed video caching.
- Technical Context: The technology concerns systems for efficiently transcoding and delivering video content across a large, distributed network, a critical function for social media platforms that handle immense volumes of user-generated and professionally produced video.
- Key Procedural History: The operative complaint is a First Amended Complaint. No other significant procedural events, such as prior litigation or administrative challenges involving the patents-in-suit, are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2012-07-18 | Earliest Priority Date for ’633 and ’442 Patents |
| 2017-10-24 | U.S. Patent No. 9,800,633 Issued |
| 2019-11-19 | U.S. Patent No. 10,484,442 Issued |
| 2026-01-14 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,800,633 - *"Just-in-time distributed video cache"*
The Invention Explained
- Problem Addressed: The patent describes the inefficiency of streaming video to mobile devices, which often involves on-the-fly transcoding that causes delays and consumes significant network bandwidth (’633 Patent, col. 1:26-56). The patent notes that conventional caching systems are often ineffective on a large scale because a user may be routed to a server (a "video optimizer") that does not have a previously transcoded version of the video, forcing a redundant transcoding operation while another server in the network may already have a cached copy (’633 Patent, col. 2:48-56).
- The Patented Solution: The invention proposes a distributed system where multiple video optimizers are linked by a central "cache database" (’633 Patent, Fig. 1). When a user requests a video, a "network controller" generates a unique key that identifies both the original video and the specific optimization parameters (e.g., for a mobile device screen). A video optimizer then queries the cache database with this key. If another optimizer has already created and cached this specific optimized version, the database returns its location, allowing the system to retrieve the existing file or redirect the user, thereby avoiding a resource-intensive re-transcoding process (’633 Patent, col. 2:57-col. 3:8).
- Technical Importance: This architecture seeks to reduce computational load and latency in a content delivery network by preventing redundant transcoding of the same source file for the same optimization parameters across different servers.
Key Claims at a Glance
- The complaint asserts independent claim 1 (’633 Patent, Compl. ¶9).
- Essential elements of claim 1 include:
- Receiving a request to optimize an original source file, where the request includes a key specifying optimization parameters and uniquely identifying the file.
- Identifying a "preview" of an optimized version of the file in a local cache.
- Generating a query to a cache database based on the key.
- Receiving a response from the database, including the address of another video optimizer that is storing a segment of the requested optimized version.
- "Stitching" the locally-cached portion with the segment from the other optimizer.
- Streaming the resulting stitched video to the client device.
- The complaint does not explicitly reserve the right to assert dependent claims, but infringement of "one or more claims" is alleged (Compl. ¶9).
U.S. Patent No. 10,484,442 - *"Just-in-time distributed video cache"*
The Invention Explained
- Problem Addressed: As a continuation of the application that led to the ’633 Patent, the ’442 Patent addresses the same technical problem of inefficient, redundant video transcoding in distributed networks for mobile device delivery (’442 Patent, col. 1:26-56).
- The Patented Solution: The patent describes the same solution architecture as the ’633 Patent, centered on a system of video optimizers that use a shared "cache database" to locate and reuse previously transcoded and cached video files, avoiding redundant processing (’442 Patent, col. 2:57-col. 3:8; Fig. 1).
- Technical Importance: The technology aims to improve the efficiency and user experience of large-scale video delivery systems.
Key Claims at a Glance
- The complaint asserts independent claim 1 (’442 Patent, Compl. ¶19).
- Essential elements of claim 1 include:
- Receiving a request to optimize an original source file, where the request includes a key specifying optimization parameters.
- Identifying a "first portion" of an optimized version of the file in a local cache of a video optimizer.
- Generating a query to a database based on the key.
- Receiving a response from the database, including the address of another video optimizer storing a segment of the requested optimized version.
- "Stitching" the "first portion" with the segment from the other video optimizer.
- Streaming the stitched optimized version for playback.
- The complaint alleges infringement of "one or more claims" (Compl. ¶19).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are the "video streaming services" offered through Defendant's "Facebook and Instagram social media platforms" (Compl. ¶9, ¶19).
Functionality and Market Context
The complaint alleges that Defendant "offers, provides, maintains, operates, and administers video streaming services" that perform the steps of the claimed methods (Compl. ¶9, ¶19). The functionality is described in the context of user actions such as watching live videos, viewing shows, and posting or editing videos on the platforms (Compl. ¶12, ¶22). The complaint asserts these services are central to Defendant's social media platforms, which are major global platforms for video content. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’633 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving a request to optimize an original source file from a client device, the request including a key specifying parameters for optimizing the original source file and uniquely identifying the original source file | Defendant's video streaming services on its Facebook and Instagram platforms are alleged to perform the steps of the claimed method. | ¶9, ¶10 | col. 3:25-33 |
| identifying, based on the key, a preview of an optimized version of the original source file in a local cache of a video optimization server... | Defendant's video streaming services are alleged to utilize a system of distributed caching to deliver video content. | ¶9, ¶10 | col. 17:21-26 |
| generating a query, based on the key, to a cache database... | Defendant's video streaming services are alleged to use a database or equivalent system to locate previously optimized video content within its network. | ¶9, ¶10 | col. 3:42-46 |
| receiving from the cache database... the address of another video optimizer storing a segment of the optimized version of the original source file | Defendant's video streaming services are alleged to retrieve content from different servers within its distributed network to fulfill a user request. | ¶9, ¶10 | col. 3:25-41 |
| stitching the first portion of the optimized version of the original source file with the segment of the optimized version of the original source file... | Defendant's video streaming services are alleged to combine video data from different internal sources to provide a seamless stream to the user. | ¶9, ¶10 | col. 17:1-16 |
| streaming the stitched optimized version of the original source file for playback on the client device | Defendant's video streaming services are alleged to stream the resulting video content to end-users on the Facebook and Instagram platforms. | ¶9, ¶10 | col. 3:5-8 |
’442 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving a request to optimize an original source file from a client computing device, the request including a key specifying parameters to optimize the original source file | Defendant's video streaming services on its Facebook and Instagram platforms are alleged to perform the steps of the claimed method. | ¶19, ¶20 | col. 11:58-67 |
| identifying, based on the key, a first portion of an optimized version of the original source file in a local cache of a video optimizer | Defendant's video streaming services are alleged to utilize a system of distributed caching to deliver video content. | ¶19, ¶20 | col. 17:21-26 |
| generating a query, based on the key, to a database... | Defendant's video streaming services are alleged to use a database or equivalent system to locate previously optimized video content within its network. | ¶19, ¶20 | col. 12:35-42 |
| receiving from the database... the address of another video optimizer storing a segment of the requested optimized version of the original source file | Defendant's video streaming services are alleged to retrieve content from different servers within its distributed network to fulfill a user request. | ¶19, ¶20 | col. 4:25-34 |
| stitching the first portion of the optimized version of the original source file with the segment of the optimized version of the original source file stored on the other video optimizer | Defendant's video streaming services are alleged to combine video data from different internal sources to provide a seamless stream to the user. | ¶19, ¶20 | col. 17:1-16 |
| streaming the stitched optimized version of the original source file for playback on the client computing device | Defendant's video streaming services are alleged to stream the resulting video content to end-users on the Facebook and Instagram platforms. | ¶19, ¶20 | col. 13:3-9 |
- Identified Points of Contention:
- Architectural Questions: A primary issue may be whether Defendant's highly complex and proprietary content delivery network maps onto the specific architectural components recited in the claims (e.g., "network controller", "video optimizer", "cache database"). The analysis will question whether Defendant's system contains discrete or logically separable components that perform the claimed functions in the claimed sequence.
- Technical Questions: The complaint does not provide specific technical facts explaining how Meta’s services allegedly perform the claimed steps. Key questions for discovery will include: (1) Does Meta's system generate and use a single "key" that incorporates both a unique file identifier and specific optimization parameters to query a cache? (2) Does Meta's system perform the claimed "stitching" of video segments retrieved from different servers to fulfill a single user request?
V. Key Claim Terms for Construction
The Term: "key specifying parameters for optimizing the original source file" (from Claim 1 of both patents)
- Context and Importance: This term is central to the invention's method of avoiding redundant work. The infringement analysis will depend on whether Defendant's system uses an identifier that contains not just information about the source video, but also the specific transcoding parameters (e.g., resolution, bitrate) for a particular viewing context.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states the key is "uniquely associated" with both the original and optimized file, which might support an argument that the parameters need only be logically linked to the file identifier, not necessarily contained in a single data structure (’442 Patent, col. 3:29-33).
- Evidence for a Narrower Interpretation: The description of a "network controller" that "may generate an identifier (ID) key... based on the specified optimization parameters" could support a narrower construction requiring a specific component to create a key that explicitly includes or is derived from these parameters (’442 Patent, col. 3:29-33).
The Term: "stitching" (from Claim 1 of both patents)
- Context and Importance: This term defines how video content from different sources (a local cache and another optimizer) is combined. Practitioners may focus on this term because the technical implementation of combining video streams can vary significantly. The dispute may turn on whether Defendant's alleged actions constitute the specific "stitching" claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The general description of assembling a seamless video stream could support a broad definition covering any method of sequential playback from different sources.
- Evidence for a Narrower Interpretation: The patent describes a process where an optimizer "stitches the received optimized video segment with the segment the video optimizer itself transcoded at the last key frame," suggesting an active process of joining distinct data streams at a specific technical point (’442 Patent, col. 17:13-16).
The Term: "preview" (’633 Patent, Claim 1) vs. "first portion" (’442 Patent, Claim 1)
- Context and Importance: The subtle difference between these terms in otherwise similar claims may become a focal point. The scope of "preview" could be construed more narrowly than "first portion," potentially affecting the infringement analysis for the ’633 Patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (of "first portion"): This term appears general and could be read to cover any initial segment of a video file.
- Evidence for a Narrower Interpretation (of "preview"): The patent discusses a "video preview cache" and storing a "1 minute portion of an optimized version" as a preview, which could support a construction requiring a specific, pre-defined segment intended for preview purposes, as opposed to any arbitrary beginning segment (’442 Patent, col. 17:21-33).
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for both patents. The basis for inducement is Defendant's alleged encouragement and instruction to users through online materials and guides on how to use the video streaming features (Compl. ¶11-12, ¶21-22). The basis for contributory infringement is the allegation that the accused services are a material part of the invention, are not staple articles of commerce, and are especially adapted for infringement (Compl. ¶13, ¶23). For both theories, knowledge is alleged to have begun, at the latest, upon service of the original complaint (Compl. ¶11, ¶13, ¶21, ¶23).
- Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or a request for enhanced damages under 35 U.S.C. § 284. However, it does allege continued infringement despite knowledge acquired from the filing of the lawsuit, which could form the basis for such a claim later in the proceedings (Compl. ¶12, ¶22).
VII. Analyst’s Conclusion: Key Questions for the Case
- Architectural Mapping: A core issue will be one of structural correspondence: can Plaintiff demonstrate that Meta’s complex, integrated content delivery network architecture maps onto the specific, discrete components recited in the claims, such as a "network controller", "video optimizer", and queryable "cache database"? Or does Meta’s system operate on a fundamentally different architectural principle for caching and delivering video?
- Functional Specificity: A key evidentiary question will be one of technical function: what evidence will discovery yield about the internal workings of Meta's services? Specifically, does the accused system use a "key" that incorporates both file identity and "optimization parameters" to query for cached content, and does it "stitch" video segments from different internal server caches as claimed, or does it achieve efficiency through alternative technical means?