DCT

3:23-cv-06151

X Corp v. Adeia Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:23-cv-06151, N.D. Cal., 11/28/2023
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant Adeia resides in the Northern District of California, maintains its principal place of business in San Jose, and a substantial part of the events giving rise to the claims occurred in the district.
  • Core Dispute: Plaintiff X Corp. seeks a declaratory judgment that its social media platform does not infringe four patents owned by Defendant Adeia related to dynamic video display, social media enhancement, content recommendation systems, and advertisement campaign management.
  • Technical Context: The technologies at issue involve core functionalities of modern digital media platforms, focusing on how content is displayed, recommended, and monetized in an interactive and algorithmically-driven environment.
  • Key Procedural History: The complaint states that the parties’ predecessors entered a patent license agreement (PLA) in 2019. In August 2023, Adeia sued X Corp. for breach of that agreement in California state court. In response, X Corp. provided notice of termination for the PLA and filed this federal declaratory judgment action, asserting that its products do not use Adeia’s patented technology and anticipating an imminent patent infringement lawsuit from Adeia. The complaint characterizes Adeia as an intellectual property licensing entity with a history of patent litigation.

Case Timeline

Date Event
2016-05-10 ’137 Patent Priority Date
2018-02-01 Patent license negotiations initiated between predecessors
2018-09-06 ’071 Patent Priority Date
2019-03-29 ’582 Patent Priority Date
2019-04-25 Patent License Agreement (PLA) executed
2019-06-27 ’563 Patent Priority Date
2020-06-23 ’137 Patent Issue Date
2021-03-16 ’563 Patent Issue Date
2022-03-29 ’582 Patent Issue Date
2023-08-07 Adeia sues X Corp. for breach of contract in state court
2023-09-12 ’071 Patent Issue Date
2023-11-28 Complaint for Declaratory Judgment Filed / PLA Terminated

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

U.S. Patent No. 10,694,137 - “Systems and Methods for Resizing Content Based on a Relative Importance of the Content”

  • Patent Identification: U.S. Patent No. 10,694,137, “Systems and Methods for Resizing Content Based on a Relative Importance of the Content,” issued June 23, 2020 (’137 Patent). (Compl. ¶41).

The Invention Explained

  • Problem Addressed: The patent addresses a scenario where a user views multiple video streams simultaneously, such as a live broadcast with a smaller picture-in-picture (PiP) window showing a replay. The user may be forced to watch important action (e.g., a goal replay) in the small window while less important content (e.g., a player substitution) occupies the main screen. (’137 Patent, col. 1:12-30).
  • The Patented Solution: The invention is a media guidance system that automatically monitors events in both the live and "catch-up" video streams, determines the "relative importance" of each event based on a user's profile (e.g., favorite teams, fantasy sports roster), and dynamically resizes the windows to make the more important content larger. (’137 Patent, Abstract; col. 2:31-54). For instance, if a replay shows a touchdown by a user's favorite team, the system would enlarge the replay window. (’137 Patent, col. 2:44-54).
  • Technical Importance: This technology aims to automate and optimize the viewing experience in multi-stream environments, shifting user focus to the most relevant content without requiring manual interaction. (’137 Patent, col. 2:51-54).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement of all claims. (Compl. ¶¶51-52). Independent claim 1 is representative.
  • Essential elements of Independent Claim 1 include:
    • Generating for simultaneous display live audio-visual media and catch-up audio-visual media in separate windows of different sizes, where the catch-up media is a previously broadcast segment of the live media.
    • Simultaneously monitoring a relative importance of concurrently-presented events from both the live and catch-up media.
    • Retrieving a user profile indicating attributes of important events.
    • Determining, based on the profile, that an event in the catch-up media is more important than a concurrent event in the live media.
    • Resizing the window of the catch-up media to a larger size based on a comparison of the events' importance.
  • The complaint notes that the contested limitations appear in all independent, and therefore dependent, claims. (Compl. ¶¶51-52).

U.S. Patent No. 10,951,563 - “Enhancing a Social Media Post with Content that is Relevant to the Audience of the Post”

  • Patent Identification: U.S. Patent No. 10,951,563, “Enhancing a Social Media Post with Content that is Relevant to the Audience of the Post,” issued March 16, 2021 (’563 Patent). (Compl. ¶43).

The Invention Explained

  • Problem Addressed: The patent identifies the underutilization of "non-focus portions" (e.g., background areas) in content shared on social media, which could otherwise be used to make posts more engaging. (’563 Patent, col. 1:17-25).
  • The Patented Solution: The invention describes a method to automatically enhance a social media post by first identifying a "non-focus portion" within a primary content item (like a photo). It then selects a second content item that matches the audience's preferences and fits within that non-focus area, and overlays it to create an "enhanced social media post." The selection also considers the estimated time the audience will view the post. (’563 Patent, Abstract; col. 2:44-64).
  • Technical Importance: This technology provides a method for programmatically increasing the density of relevant information in a social media feed, potentially increasing user engagement and creating new advertising opportunities. (’563 Patent, col. 2:23-35).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement of all claims. (Compl. ¶56). Independent claim 1 is representative.
  • Essential elements of Independent Claim 1 include:
    • Receiving a social media post and extracting a first content item from it.
    • Identifying a "non-focus portion" in a frame of the first content item.
    • Identifying a plurality of content items that can fit within that non-focus portion.
    • Identifying a content preference of the post's audience.
    • Determining an estimated length of time the audience will view the post.
    • Selecting a second content item from the plurality that matches the audience's preference and has a duration not exceeding the estimated time.
    • Generating an enhanced post by overlaying the second content item onto the non-focus portion.
    • Generating the enhanced post for display.
  • The complaint asserts that the contested limitations appear in all independent, and therefore dependent, claims. (Compl. ¶56).

U.S. Patent No. 11,288,582 - “Systems and Methods for Providing Media Content Recommendations”

  • Patent Identification: U.S. Patent No. 11,288,582, “Systems and Methods for Providing Media Content Recommendations,” issued March 29, 2022 (’582 Patent). (Compl. ¶45).
  • Technology Synopsis: The patent addresses the challenge of selecting the optimal set of algorithms for providing media content recommendations. (’582 Patent, col. 1:25-37). It discloses an evolutionary method that assigns weights to a plurality of different prediction algorithms, generates various candidate weight combinations, and iteratively tests them against actual user requests to empirically determine the combination that yields the most accurate recommendations. (’582 Patent, Abstract).
  • Asserted Claims: All independent claims, which include claims 1 and 10. (Compl. ¶¶60-62).
  • Accused Features: The complaint alleges that X’s platform does not infringe because it uses a single recommendation algorithm, not a weighted plurality, and does not use the claimed iterative process to generate recommendations. (Compl. ¶¶60-62).

U.S. Patent No. 11,756,071 - “Managing Impressions of an Advertisement Campaign”

  • Patent Identification: U.S. Patent No. 11,756,071, “Managing Impressions of an Advertisement Campaign,” issued September 12, 2023 (’071 Patent). (Compl. ¶47).
  • Technology Synopsis: The patent addresses inefficiencies in digital advertising, where impression budgets for campaigns can be misallocated. (’071 Patent, col. 1:22-38). The invention provides a system for managing multiple simultaneous ad campaigns by calculating the "rate of impression generation" for each and dynamically reallocating budgeted impressions from low-performing campaigns to high-performing ones to optimize overall effectiveness. (’071 Patent, Abstract).
  • Asserted Claims: All independent claims. (Compl. ¶66).
  • Accused Features: The complaint alleges X's platform does not have a feature for dynamically reallocating advertisement budgets across different campaigns based on performance metrics as claimed. (Compl. ¶66).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is the X social media platform, including its associated products and services. (Compl. ¶¶1, 23).

Functionality and Market Context

  • The complaint describes X as a "leading social media platform for open communication," which has expanded from its origins in microblogging to incorporate audio, video, messaging, and payments/banking functionalities. (Compl. ¶23). The specific features relevant to the non-infringement allegations include the platform's handling of live video, its tools for posting media content like GIFs and videos, its content recommendation engine, and its advertisement campaign dashboard. (Compl. ¶¶51, 56, 60, 66).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

’137 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
generating for simultaneous display... live audio-visual media... and catch-up audio-visual media... The X platform does not provide for the "simultaneous" display of "live" and "catch-up" video as a feature. ¶51 col. 42:8-16
simultaneously monitoring a relative importance of concurrently-presented events from the live... and from the catch-up audio-visual media... Because the platform does not simultaneously provide the two required video types, there is no relative importance of concurrent events to monitor or determine. ¶52 col. 42:17-23
resizing... the window of the catch-up audio-visual media to a third size larger... based on a comparison... of the importance of the first event with respect to the importance of the second event. Video resizing functionalities on the X platform, such as entering a full-screen or picture-in-picture mode, are initiated manually by the user, not performed automatically based on a comparison of event importance. ¶52 col. 42:31-40

Identified Points of Contention

  • Technical/Factual Question: The primary dispute appears to be factual: does the X platform technically provide simultaneous live and "catch-up" video streams as contemplated by the patent? X Corp.’s position is that it does not, rendering the subsequent monitoring and resizing steps inapplicable.
  • Scope Question: A key issue for the court may be to define "catch-up audio-visual media." The complaint suggests a narrow interpretation is required, which X's platform does not meet, raising the question of whether other video-on-demand features could fall within the claim scope.

’563 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
identifying, in a frame of the first content item, a portion of the frame that is a non-focus portion The X platform's social media posting features do not include functionality for identifying "non-focus" portions of a content item for enhancement. ¶56 col. 10:5-7
selecting a second content item... that matches the content preference of the audience... The platform does not offer functionality to select and overlay secondary content based on audience preference and viewing time. ¶56 col. 10:13-17
generating an enhanced social media post by overlaying the second content item onto the non-focus portion... The platform does not generate enhanced posts by overlaying content onto non-focus portions as recited in the claim. ¶56 col. 10:18-22

Identified Points of Contention

  • Technical/Factual Question: The dispute centers on whether the X platform offers the specific "enhancement functionality" claimed. X Corp. alleges a complete absence of this feature, framing the issue as a direct mismatch between the patent's claims and the product's operation.

V. Key Claim Terms for Construction

For the ’137 Patent

  • The Term: "catch-up audio-visual media"
  • Context and Importance: X Corp.'s non-infringement argument relies heavily on its assertion that it does not provide this feature. The construction of this term is therefore central to determining whether the patent's core premise is applicable to X's platform. Practitioners may focus on this term because its definition will dictate whether any of X's video playback features meet the claim limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the term functionally as "a replay of an event in the live audio-visual media" and notes it can be implemented by playing back "a buffered portion of the live audio-visual media." (’137 Patent, col. 2:15-18). This language could potentially be argued to cover a range of replay functionalities beyond a simple time-shift.
    • Evidence for a Narrower Interpretation: The claim language specifies that the catch-up media "corresponds to a previously broadcast segment of the live audio-visual media." (’137 Patent, col. 42:14-16). The patent's figures and primary embodiment consistently depict a direct, time-shifted replay of the exact same event (a soccer match) shown on the live feed, suggesting a tightly coupled relationship is required. (’137 Patent, Fig. 2).

For the ’563 Patent

  • The Term: "non-focus portion"
  • Context and Importance: The entire inventive concept of the '563 patent revolves around identifying and utilizing this specific area of a media item. The definition of this term will determine what type of technical capability is required for infringement, which X Corp. claims its platform lacks.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a functional definition: "the portion(s) of the content that does not include the subject and/or includes the background or other objects that are not intended to draw the audience's attention." (’563 Patent, col. 1:21-25). This could be interpreted broadly to mean any background area of an image.
    • Evidence for a Narrower Interpretation: The detailed description suggests a more specific process of first identifying a "focus portion" and then selecting what is not obscured by it as the "non-focus portion." (’563 Patent, col. 2:1-4). This implies an active, analytical step of subject-background segmentation, which may support a narrower construction requiring more than just identifying generic empty space.

VI. Other Allegations

Indirect Infringement

  • The complaint seeks a declaratory judgment of non-infringement "directly, contributorily, or by inducement." (Compl. p. 14, ¶1). However, the factual allegations in the body of the complaint focus exclusively on demonstrating the absence of direct infringement by asserting that X Corp.'s platform does not practice the claimed methods. The complaint does not provide sufficient detail for analysis of any specific theory of indirect non-infringement.

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

This declaratory judgment action appears poised to center on the following core questions:

  • A primary issue will be one of technical and factual reality: Does the X social media platform, as it currently operates, contain the specific functionalities at the heart of the asserted patents? For the ’137 and ’563 patents, the case may turn on evidence demonstrating the presence or complete absence of features for simultaneous live/catch-up video resizing and for programmatic "non-focus portion" enhancement.
  • A second issue will be one of definitional scope and claim construction: For the ’582 patent on recommendation systems, can the patentee’s claimed "plurality of weight values to each prediction algorithm" be construed to read on X Corp.'s alleged use of a "single recommendation algorithm" that is a "parameter neural network"? This raises a critical question of whether distinct conceptual models for machine learning can be considered equivalent under the patent's claims.
  • A third question concerns the commercial context: As this dispute arises from a terminated license, the litigation will likely serve as a test case for the reach of Adeia's patent portfolio into the architecture of a major social media platform. The outcome may signal whether X Corp.'s technology is fundamentally distinct from the licensed art or if this action is primarily a dispute over licensing terms.