Artificial Intelligence Industry Association Inc v. Ceres Ai Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Artificial Intelligence Industry Association, Inc. (Florida)
  • Defendant: Ceres AI, Inc. (Delaware)
  • Plaintiff’s Counsel: Fry Law Corporation
• Case Identification: 3:25-cv-07924, N.D. Cal., 12/04/2025
• 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 AI-powered aerial imaging and agricultural data analytics platforms infringe a patent related to the real-time embedding of calibration metadata into stereoscopic video files.
• Technical Context: The technology at issue addresses methods for synchronizing sensor and camera calibration data with video frames, which is significant for ensuring the accurate processing and playback of 3D video content.
• Key Procedural History: The complaint states that prior to filing suit, Plaintiff sent Defendant a formal demand letter that identified the patent-in-suit and alleged infringement, which may form the basis for a subsequent claim of willful infringement.

Case Timeline

Date	Event
2015-04-29	U.S. Patent No. 10,075,693 Priority Date
2018-09-11	U.S. Patent No. 10,075,693 Issues
2025-12-04	Complaint Filed

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

U.S. Patent No. 10,075,693 - “Embedding Calibration Metadata Into Stereoscopic Video Files”

• Patent Identification: U.S. Patent No. 10,075,693, titled “Embedding Calibration Metadata Into Stereoscopic Video Files,” issued September 11, 2018 (the “’693 Patent”).

The Invention Explained

• Problem Addressed: The patent’s background section describes the difficulty in properly rendering stereoscopic 3D video because playback systems often lack the specific camera parameters (e.g., lens distortion, sensor size) associated with the device that captured the video (Compl. ¶15; ’693 Patent, col. 1:46-54). This problem is compounded when video from different cameras is combined, as each device has unique calibration parameters that must be associated with the correct video segments (’693 Patent, col. 1:59-65).
• The Patented Solution: The invention proposes a system that captures not just the stereoscopic video feed but also contemporaneous metadata from the camera’s sensors (e.g., calibration, gyroscope, GPS data) and embeds this data directly into the video file in real-time as it is recorded (’693 Patent, Abstract). To ensure the metadata remains synchronized with the corresponding video frames during playback, the system can encode it into the subtitle or closed-captioning fields of the video file format (’693 Patent, col. 10:11-21; Fig. 11).
• Technical Importance: This approach creates a self-contained video file that simplifies downstream processing and enables more accurate playback on various devices, such as virtual reality headsets, without requiring separate, out-of-sync parameter files (’693 Patent, col. 2:41-54).

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 of the ’693 Patent (Compl. ¶25).
• Independent Claim 1 recites a computerized system for recording stereoscopic 3D video, comprising:
  • A computer store containing a stereoscopic video feed and contemporaneous metadata feeds.
  • A computer processor programmed to obtain both the video and metadata feeds.
  • The processor is further programmed for embedding the metadata into the video feed in real-time during recording.
  • The metadata is embedded by encoding it into the subtitle or closed captioning fields of the video file format, such that the timing of the metadata is preserved relative to the video frames.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant’s “aerial imaging systems, AI-powered data analytics platforms, computer vision technologies, and machine learning models used for precision agriculture and crop health monitoring” (Compl. ¶¶1, 18).

Functionality and Market Context

• The complaint alleges that Defendant’s platform captures aerial images of farmland using multispectral stereoscopic cameras and processes that imagery using sensor and environmental metadata to create calibrated data layers (Compl. ¶¶18, 20).
• These calibrated data layers are then allegedly analyzed by machine learning models to generate predictive analytics on crop health, yield, and irrigation efficiency (Compl. ¶18). The complaint alleges these services are marketed to major agricultural entities in California and globally (Compl. ¶7).

IV. Analysis of Infringement Allegations

Claim Chart Summary

Exhibit B of the complaint provides a chart outlining the Plaintiff's infringement theory. The complaint’s allegations for Claim 1 of the ’693 Patent are summarized below.

’693 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
(a) a computer store containing data, wherein the data comprises: a stereoscopic video feed... and a plurality of contemporaneous metadata feeds...	Defendant's systems allegedly capture image data using "multispectral stereoscopic or 3D imaging technologies" and simultaneously generate associated "calibrated data layers" from sensor-derived information.	¶¶21, 52; Ex. B	col. 9:55-61
(b) a computer processor... programmed to... obtain the stereoscopic video feed and the... metadata feeds, and embedding, in real-time... the stereoscopic video feed with the... metadata feeds...	Defendant's processing pipelines allegedly incorporate "image augmentation and calibration processes" that embed sensor and environmental data into imagery layers during "real-time or near-real-time" capture-based workflows.	¶¶20, 53; Ex. B	col. 10:1-7
...wherein the plurality of contemporaneous metadata feeds is embedded into the stereoscopic video feed by encoding the contemporaneous metadata feeds into the subtitles or closed captioning metadata fields of the video file format, such that the timing of the subtitle or closed captioning metadata conveys the timing of the metadata feeds.	Defendant's imaging systems allegedly embed calibrated data within the imaging output, which corresponds to the claim requirement of encoding metadata into video file fields to maintain alignment with the underlying imagery. The complaint includes a claim chart in Exhibit B that visually maps this asserted correspondence (Compl. Ex. B).	¶¶53-54; Ex. B	col. 10:11-21

Identified Points of Contention

• Scope Questions: The ’693 Patent specification frequently describes the invention in the context of video playback for a human viewer, particularly in virtual reality environments (’693 Patent, col. 2:41-45). A potential point of contention is whether the term "stereoscopic video feed," as used in the patent, can be construed to read on the aerial imaging data allegedly collected by Defendant primarily for algorithmic analysis by machine learning models rather than for direct human viewing.
• Technical Questions: A central technical question will be whether Defendant’s platform performs the specific step of "encoding the contemporaneous metadata feeds into the subtitles or closed captioning metadata fields of the video file format." The complaint alleges this functionality but does not provide specific evidence (e.g., an analysis of the accused video file structure). The case may turn on whether Defendant's method for associating metadata with its imagery meets this precise technical limitation.

V. Key Claim Terms for Construction

• The Term: "encoding... into the subtitles or closed captioning metadata fields"
  • Context and Importance: This term defines a specific technical mechanism for embedding and synchronizing the metadata. The infringement analysis will likely depend heavily on whether Defendant’s accused method of storing metadata falls within the scope of this language. Practitioners may focus on this term because it appears to be a highly specific limitation distinguishing the invention from other methods of associating metadata with video (e.g., separate "sidecar" files).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent’s overall objective is to ensure metadata is timed with video frames (’693 Patent, col. 10:18-21). A party might argue that any mechanism that embeds time-coded data into a track within a video container file to achieve this synchronization serves the same function and should be covered.
    • Evidence for a Narrower Interpretation: The claim language explicitly identifies two standard mechanisms: "subtitles or closed captioning." A party could argue that this term should be limited to its plain and ordinary meaning, covering standardized subtitle formats (like SRT) or closed captioning data streams (like CEA-608/708) and excluding other forms of data tracks within a video file.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement based on Defendant’s provision of "detailed technical documentation, tutorials, and customer support services" that allegedly instruct customers on how to use the accused products in an infringing manner (Compl. ¶2). Contributory infringement is alleged on the basis that Defendant sells software components that are material to the invention and are not suitable for a substantial non-infringing use (Compl. ¶3).
• Willful Infringement: The complaint alleges that Defendant had pre-suit knowledge of the ’693 Patent and its infringement based on a formal demand letter sent by Plaintiff. The allegation of continued and expanded sales after receiving this notice forms the basis of the willfulness claim (Compl. ¶¶4, 24).

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

The resolution of this dispute may depend on the court’s determination of several key issues:

• A primary issue will be one of definitional scope: whether the term "stereoscopic video feed," described in the patent in the context of playback for human viewing, can be construed to encompass the type of aerial imaging data allegedly collected by the accused agricultural analytics platform for machine learning analysis.
• A second critical issue will be one of technical implementation: what evidence will emerge to show whether the accused products perform the specific function of "encoding" metadata "into the subtitles or closed captioning metadata fields" as required by Claim 1, or if this limitation creates a fundamental mismatch in technical operation that precludes a finding of literal infringement.