DCT
8:25-cv-02352
Control Synch Systems LLC v. TTE Technologoy Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Control Sync Systems, LLC (Wyoming)
- Defendant: TTE Technology, Inc. dba TCL North America (Delaware)
- Plaintiff’s Counsel: SML Avvocati P.C.
- Case Identification: 8:25-cv-02352, C.D. Cal., 10/16/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district and has committed the alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s smart televisions incorporating the HDMI-CEC standard infringe a patent related to a system for synchronously controlling a display device and a connected media play device.
- Technical Context: The technology at issue addresses the unified control of separate home entertainment components, a central feature for usability in modern interconnected media systems.
- Key Procedural History: The complaint does not reference 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 |
| 2025-10-16 | 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 "inconvenient and troublesome" user experience of controlling interconnected but separate media devices, such as a projector and a DVD player, each with its own remote control and on-screen display (OSD) system. A user attempting to adjust a parameter like sound volume might have to perform separate actions on each device to achieve the desired result (Compl. ¶14; ’889 Patent, col. 1:40-54).
- The Patented Solution: The invention proposes a control system where a command (an "OSD signal") received by one device is encoded into a data signal, transmitted over a "bus" to the second device, and then decoded. This allows a single user input to synchronously control the parameters of both the display device and the play device, unifying the control process (’889 Patent, col. 2:1-40, Fig. 2).
- Technical Importance: The described solution sought to streamline the user interface for increasingly complex home theater setups by creating a single, consistent control pathway between components (’889 Patent, col. 1:55-58).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶15).
- Claim 1 requires:
- An on screen display (OSD) system in the display device for receiving a first OSD signal from an external source.
- An encoding/decoding module in 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 uses the first OSD signal to control its own parameters, and the play device decodes the first data signal received from the bus to control its parameters.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the TCL 55'' QM6K Series QD-Mini LED QLED 4K UHD Smart TV with Google TV as an exemplary accused product, along with other TCL products incorporating Consumer Electronic Control ("CEC") functionality (Compl. ¶¶15-16).
Functionality and Market Context
- The accused televisions feature HDMI-CEC, a standard-based control protocol that allows a single remote to control multiple devices connected via HDMI cables. This feature enables the TV to send control commands, such as play or pause, over the HDMI connection to a connected multimedia device like a DVD player or game console, thereby controlling its playback (Compl. ¶16, ¶18). A screenshot from a TCL instructional video shows the on-screen menu for enabling "Control Other Devices (CEC)" (Compl. p. 6).
IV. Analysis of Infringement Allegations
U.S. Patent No. 7,812,889 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 TCL TV includes an OSD system that receives control commands, such as play and pause, from the TV's remote control. | ¶17 | col. 2:6-9 |
| 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 complaint alleges that the TV contains a module that encodes the command received from the remote into a data signal formatted for transmission via the HDMI-CEC protocol. | ¶18 | col. 2:10-13 |
| 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 the external multimedia device allegedly functions as the claimed bus, transmitting the encoded control command. A diagram of the TV’s back panel provided in the complaint explicitly labels the group of HDMI ports with the term "Bus" (Compl. p. 22). | ¶19, ¶21 | col. 2:18-22 |
| 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 to control its own functions, and it also sends the command to the connected device (e.g., a DVD player), which then decodes the signal to control its own playback. | ¶20 | col. 5:8-13 |
- Identified Points of Contention:
- Scope Questions: The case may present a question of whether the patent's claims, which describe a "control system" in general terms, can be construed to cover the accused product's implementation of HDMI-CEC, a widely adopted industry standard. The complaint uses documentation from the HDMI standard itself to support its allegations (Compl. p. 9).
- Technical Questions: The complaint alleges the existence of an "encoding/decoding module" by stating it "would be apparent for a person having ordinary skills in the art" (Compl. ¶¶18, 25). This raises an evidentiary question as to whether the accused TV’s architecture includes a structure that meets the definition of this claimed module, or if the encoding function is performed by a more integrated system-on-a-chip in a way that is technically distinct from the claimed invention.
V. Key Claim Terms for Construction
The Term: "encoding/decoding module"
Context and Importance: The infringement analysis hinges on whether the accused TV’s internal systems contain a component or set of components that meet this definition. Practitioners may focus on this term because its construction will determine whether any system performing an encoding function infringes, or if a more specific, modular architecture is required.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent claims describe the module functionally, as being "for encoding the first OSD signal received by the OSD system into a first data signal" (’889 Patent, col. 5:1-4). This functional language may support a construction that covers any component that performs the specified task.
- Evidence for a Narrower Interpretation: The patent's Figure 2 depicts the "Displayer encoding/decoding module" (42) as a distinct block, separate from the "Displayer OSD system" (40) and "Display module" (202). This graphical representation of a discrete component could be used to argue for a narrower construction requiring a distinct modular structure.
The Term: "bus"
Context and Importance: Plaintiff's infringement theory depends on the HDMI cable being construed as the claimed "bus." The definition of this term is therefore critical.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes the bus in broad, functional terms as being "connected to both the display device and the play device" and "used for sending the first data signal" (’889 Patent, col. 2:18-22). This general description could support reading the term on a standard HDMI cable used for communication.
- Evidence for a Narrower Interpretation: The patent itself provides little intrinsic evidence to support a narrower construction. A party could potentially argue that the term, in the context of the 2005 priority date, implied a different type of parallel or serial connection common at the time, but the specification's general language does not explicitly limit it.
VI. Other Allegations
- Indirect Infringement: The prayer for relief seeks a judgment for indirect infringement (Compl. p. 28, ¶a). However, the body of the complaint does not allege specific facts to support the requisite elements of knowledge and intent for either induced or contributory infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of scope and standardization: Can the patent’s functionally-defined claims be construed to cover the implementation of HDMI-CEC, a ubiquitous industry standard, or does the patent describe a more specific architecture that is technically distinct from that standard? The outcome may depend on whether the court views the accused products as merely practicing a public standard or as implementing the specific solution taught and claimed by the patent.
- A key evidentiary question will concern structural correspondence: What level of proof will be required to demonstrate that the accused TV's integrated circuitry contains a distinct "encoding/decoding module" as claimed in the patent? The case will likely turn on whether performing the function of encoding is sufficient for infringement, or if the plaintiff must prove the existence of a specific hardware or software structure that corresponds to the "module" described in the patent's specification and figures.