DCT

3:25-cv-11048

DirecTV LLC v. Adeia Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:25-cv-11048, N.D. Cal., 12/29/2025
  • Venue Allegations: Venue is alleged to be proper in the Northern District of California because Defendants' principal place of business is located in San Jose, within the district.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its media products and services do not infringe ten of Defendants' patents, and that three of those patents are invalid, in anticipation of the expiration of a long-standing license agreement.
  • Technical Context: The patents relate to digital media technology, including adaptive bitrate streaming, interactive user interface features, digital video recording (DVR), and targeted advertising, which are foundational technologies in the modern streaming and broadcast television industries.
  • Key Procedural History: The parties' predecessors have a licensing relationship dating back to 1994. The current license agreement, entered into by DIRECTV's former parent AT&T, is set to expire on December 31, 2025. Plaintiff alleges that Defendants have demanded a new license agreement, prompting this preemptive action to resolve the dispute over infringement of the asserted patents. The complaint also notes Defendants' history of litigating its patent portfolio against other major media companies.

Case Timeline

Date Event
2002-03-21 U.S. Patent No. 8,156,528 Priority Date
2007-07-31 U.S. Patent No. 8,640,165 Priority Date
2008-06-23 U.S. Patent No. 8,601,526 Priority Date
2008-08-13 U.S. Patent No. 11,778,245 Priority Date
2008-12-23 U.S. Patent No. 8,234,668 Priority Date
2010-09-30 U.S. Patent No. 10,506,010 Priority Date
2011-12-23 U.S. Patent No. 8,805,418 Priority Date
2012-04-10 U.S. Patent No. 8,156,528 Issued
2012-07-31 U.S. Patent No. 8,234,668 Issued
2013-12-03 U.S. Patent No. 8,601,526 Issued
2014-01-28 U.S. Patent No. 8,640,165 Issued
2014-02-26 U.S. Patent No. 10,110,961 Priority Date
2014-06-16 U.S. Patent No. 9,715,334 Priority Date
2014-08-12 U.S. Patent No. 8,805,418 Issued
2016-01-01 AT&T License Agreement Effective Date
2017-07-25 U.S. Patent No. 9,715,334 Issued
2018-10-23 U.S. Patent No. 10,110,961 Issued
2019-12-10 U.S. Patent No. 10,506,010 Issued
2023-10-03 U.S. Patent No. 11,778,245 Issued
2024-01-10 U.S. Patent No. 12,301,922 Priority Date
2024-11-01 Adeia files suit against The Walt Disney Company (approx. date)
2025-05-13 U.S. Patent No. 12,301,922 Issued
2025-11-03 Adeia files suit against Advanced Micro Devices, Inc.
2025-12-29 Complaint Filed
2025-12-31 AT&T License Agreement Expiration Date

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

U.S. Patent No. 10,506,010 - “Delivering Content in Multiple Formats,” Issued 12/10/2019

The Invention Explained

  • Problem Addressed: The patent describes the inefficiency of traditional content delivery networks where the same content (e.g., a movie) must be sent multiple times over a distribution network to accommodate end-user terminals with varying capabilities and formats (’010 Patent, col. 1:16-30).
  • The Patented Solution: The invention proposes an "edge server" that receives content in a single format and transcodes it into multiple different formats (e.g., different resolutions). A key aspect is "aligning" the transcoded video streams, specifically ensuring that key frames (i-frames) in the different format versions correspond to the same point in the content. The content is then stored as individually accessible "fragments," each beginning with an i-frame, which allows a user's device to seamlessly switch between formats during playback without re-transmitting data. (’010 Patent, Abstract; col. 2:1-14; Fig. 6).
  • Technical Importance: This method facilitates Adaptive Bitrate Streaming (ABS), which improves network efficiency and user experience by allowing a video player to dynamically switch between different quality streams to match changing network bandwidth conditions without interrupting playback (’010 Patent, col. 3:56-62).

Key Claims at a Glance

  • The complaint asserts non-infringement of independent claim 1 (Compl. ¶66).
  • Essential elements of Claim 1 include:
    • Receiving a content item.
    • Transcoding the content item into a first video stream (first format) and a second video stream (second format).
    • Fragmenting both video streams into a plurality of fragments.
    • Aligning the first fragment (from the first stream) with the second fragment (from the second stream) based on a point in the content item that corresponds to the beginning of both fragments.
    • Storing the fragments as individually accessible fragments.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,110,961 - “Methods and Systems for Supplementing Media Assets During Fast-Access Playback Operations,” Issued 10/23/2018

The Invention Explained

  • Problem Addressed: The patent background states that during "fast-access playback operations" such as fast-forwarding or rewinding, viewers often miss important details or find it difficult to locate a desired stopping point (’961 Patent, col. 1:17-23).
  • The Patented Solution: The invention proposes a system that, in response to a user input received while a media asset is undergoing a fast-access playback operation, determines the "progression point" (e.g., the timestamp) in the media. It then cross-references this point with a database to retrieve and generate "supplemental content" for display. This supplemental content can include a picture-in-picture (PIP) display playing at normal speed, a textual summary, or highlights, all while the main playback continues in the fast-access mode. (’961 Patent, Abstract; col. 2:32-51; Fig. 6).
  • Technical Importance: This technology aims to enhance the user experience of "trick play" modes by providing contextual information that would otherwise be lost, thereby making content navigation more intuitive and informative (’961 Patent, col. 1:24-32).

Key Claims at a Glance

  • The complaint asserts non-infringement of independent claim 1 (Compl. ¶90).
  • Essential elements of Claim 1 include:
    • Receiving a user input while a media asset is subject to a fast-access playback operation.
    • Determining a progression point in the media asset when the user input was received.
    • Determining supplemental content by comparing the progression point to a database of progression points.
    • Retrieving the determined supplemental content.
    • Generating the supplemental content for presentation while the fast-access playback operation continues.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,778,245 - “Interrupting Presentation of Content Data to Present Additional Content in Response to Reaching a Timepoint Relating to the Content Data and Notifying a Server Over the Internet,” Issued 10/03/2023

  • Technology Synopsis: The patent describes a system where a device receives content data and a set of "timepoints" prior to display. Upon reaching a designated timepoint during playback, the device interrupts the primary content to present additional content (such as an advertisement) and notifies a server. (’245 Patent, Abstract; col. 20:29-40). (Compl. ¶41).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶82).
  • Accused Features: The complaint states that Adeia will contend that DIRECTV’s Stream services infringe by displaying mid-stream advertisements to users (Compl. ¶23).

U.S. Patent No. 8,805,418 - “Methods and Systems for Performing Actions Based on Location-Based Rules,” Issued 08/12/2014

  • Technology Synopsis: The patent relates to systems that perform actions based on a user's location. The system determines that a user has entered a predefined location range and, based on a location-based rule, selects and performs an action. (’418 Patent, Abstract). (Compl. ¶38).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶74).
  • Accused Features: The complaint anticipates that Adeia will allege infringement by DIRECTV’s Stream services providing location-based programs to users (Compl. ¶23).

U.S. Patent No. 9,715,334 - “Personalized Timeline Presentation,” Issued 07/25/2017

  • Technology Synopsis: The patent describes a method for resuming playback of content at a specific pause point associated with a user profile. The system can store multiple pause points for different users or devices linked to the same content item and present an interface for selecting which pause point to resume from. (’334 Patent, Abstract). (Compl. ¶47).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶98).
  • Accused Features: The complaint anticipates infringement allegations against the “Continue Watching” feature offered to DIRECTV Stream users (Compl. ¶23).

U.S. Patent No. 8,156,528 - “Personal Video Recorder Systems and Methods,” Issued 04/10/2012

  • Technology Synopsis: The patent describes a personal video recorder (PVR) system comprising a primary device with a "first interactive television program guide" coupled to a compliant device with a "second interactive television program guide." The claims require the two program guides to be "distinctly implemented." (’528 Patent, Abstract; col. 27:3-12). (Compl. ¶50).
  • Asserted Claims: Independent claim 32 is asserted (Compl. ¶106).
  • Accused Features: The complaint anticipates infringement allegations against the DVR feature provided via DIRECTV's set-top box receiver systems, including its Genie and Genie Mini devices (Compl. ¶24).

U.S. Patent No. 8,601,526 - “Systems and Methods for Displaying Media Content and Media Guidance Information,” Issued 12/03/2013

  • Technology Synopsis: The patent describes a system where media guidance information from a portable electronic device is simultaneously displayed on a larger screen (e.g., a television) along with other media content. The system also involves the portable device receiving an indication that the information displayed on the larger screen has been manipulated. (’526 Patent, Abstract). (Compl. ¶53).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶114).
  • Accused Features: The complaint anticipates infringement allegations against the DIRECTV App in connection with a set-top box system, which allegedly allows for modification of a user's recorded programs (Compl. ¶24).

III. The Accused Instrumentality

Product Identification

The complaint identifies two categories of accused instrumentalities: the “DIRECTV Stream Products and Services,” which are over-the-top (OTT) streaming offerings, and the “DIRECTV MVPD Products and Services,” which encompass traditional satellite set-top box receiver systems (Compl. ¶¶23-25).

Functionality and Market Context

The complaint alleges on "information and belief" the specific features that Adeia will contend infringe the Patents-in-Suit. For the DIRECTV Stream (OTT) products, these features include storing and delivering content in multiple resolution fragments, providing location-based programming, displaying mid-stream ads, showing picture-in-picture content, and offering a "Continue Watching" feature (Compl. ¶23). For the MVPD (set-top box) products, accused features include digital video recording (DVR), modifying recorded programs via an app, providing an interactive sports scoreboard, and delivering content in both standard and high definition (Compl. ¶24). DIRECTV is a major provider in both the established MVPD market and the growing OTT market, the latter of which Adeia has noted is a strategic focus for its licensing efforts (Compl. ¶18).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

U.S. Patent No. 10,506,010 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
aligning, by the computing device, and based on a point in the content item that corresponds to a beginning of the first fragment and a beginning of the second fragment, the first fragment with the second fragment The DIRECTV Stream server's process of storing video content as fragments of different resolutions and providing those fragments to users for adaptive bitrate streaming. ¶23, ¶69 col. 13:19-23
storing, by the computing device, as individually accessible fragments, the first fragment and the second fragment The storage of different resolution video fragments on DIRECTV's servers for on-demand delivery to streaming users. ¶23 col. 13:24-26

Identified Points of Contention

  • Technical Question: The core of DIRECTV’s non-infringement argument is a factual denial that its system performs the specific "aligning" method required by claim 1 (Compl. ¶69). The central question for the court will be whether DIRECTV's method for generating and serving different-resolution fragments for adaptive streaming constitutes "aligning... based on a point... that corresponds to a beginning of the first fragment and a beginning of the second fragment," or if it uses a technically distinct method that falls outside the claim's scope.

U.S. Patent No. 10,110,961 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving, by control circuitry, a user input while a media asset is subject to a fast-access playback operation The functionality within DIRECTV Stream that displays picture-in-picture content to users. ¶23, ¶93 col. 29:53-56
determining, by the control circuitry, a progression point in the media asset when the user input was received The system's identification of a specific point in the media timeline in response to the user's interaction. ¶93 col. 29:57-59
generating for presentation the supplemental content while the media asset continues to be subject to the fast-access playback operation The display of picture-in-picture content while a primary media stream is potentially undergoing trick-play operations. ¶23, ¶93 col. 30:1-4

Identified Points of Contention

  • Scope & Timing Question: DIRECTV's primary non-infringement argument is that no user input is received "while a media asset is subject to a fast-access playback operation" (Compl. ¶93). This raises a critical question of claim scope and timing: does the accused picture-in-picture feature require user input during an operation like fast-forward or rewind, as specified by the claim, or is it triggered in a different context that falls outside the claimed sequence of events?

V. Key Claim Terms for Construction

For the ’010 Patent

  • The Term: "aligning"
  • Context and Importance: This term is central to DIRECTV's non-infringement position. The construction of "aligning" will determine whether DIRECTV's method for implementing adaptive bitrate streaming is covered by the patent. Practitioners may focus on this term because it appears to describe a specific technical step, not merely a desired outcome.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's summary states the goal is to allow a terminal to switch between formats "mid-viewing without receiving frames that were already transmitted" ('010 Patent, col. 3:56-62). Adeia could argue that any technical method that achieves this result by coordinating fragments is a form of "aligning."
    • Evidence for a Narrower Interpretation: Claim 1 requires aligning "based on a point in the content item that corresponds to a beginning of the first fragment and a beginning of the second fragment." This language, along with Figure 6 depicting i-frames synchronized at specific time points (t0, t1, t2), suggests a specific implementation where fragments from different streams are made to start at the exact same content moment.

For the ’961 Patent

  • The Term: "fast-access playback operation"
  • Context and Importance: The claim requires a user input to be received while this operation is occurring. DIRECTV denies this condition is met. The definition of the "operation" and its temporal boundaries are therefore critical to the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides an explicit definition: "any operation that pertains to playing back a non-linear media asset at faster than normal playback speed or in a different order than the media asset is designed to be played, such as a fast-forward, rewind, skip, chapter selection," and distinguishes it from a normal "play" operation (’961 Patent, col. 5:1-12). Adeia may argue this covers any user interaction state other than standard playback.
    • Evidence for a Narrower Interpretation: The problem statement and examples in the patent repeatedly frame the invention in the specific context of mitigating the downsides of fast-forwarding and rewinding (’961 Patent, col. 1:17-23). DIRECTV may argue that the term should be limited to these specific, continuous "trick play" modes, and that the accused feature is initiated outside of such a state.

VI. Other Allegations

  • Indirect Infringement: As a declaratory judgment plaintiff, DIRECTV does not allege indirect infringement. Instead, its prayer for relief seeks a declaration from the court that it does not induce or contributorily infringe the Patents-in-Suit (Compl., Prayer for Relief ¶¶ C, D).
  • Willful Infringement: The complaint makes no allegations related to willfulness.
  • Invalidity under 35 U.S.C. § 101: DIRECTV alleges that U.S. Patent Nos. 8,640,165; 8,234,668; and 12,301,922 are invalid as being directed to patent-ineligible abstract ideas (Compl. ¶¶ 124, 132, 140).
    • The complaint argues the ’165 Patent is directed to the abstract idea of "displaying an interactive scoreboard during a sporting event" using conventional hardware (Compl. ¶¶ 124-125).
    • It argues the ’668 Patent is directed to the abstract idea of "providing a higher-quality product in place of a lower-quality product when said higher-quality product is available" (i.e., de-duplicating standard and high-definition channels in a program guide) (Compl. ¶¶ 132-133).
    • It argues the ’922 Patent is directed to the abstract idea of "identifying a subset of users and outputting targeted content to said subset of users," a long-standing practice in advertising (Compl. ¶¶ 140-141).

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

  1. A core issue will be one of functional operation: Does DIRECTV’s adaptive streaming system perform the specific "aligning" of content fragments based on a common starting point, as required by Claim 1 of the ’010 Patent, or does it employ a technically distinct method for managing multi-resolution video streams?
  2. A second issue will be one of temporal scope: Does the functionality accused of infringing the ’961 Patent involve receiving a user input while a "fast-access playback operation" (such as a fast-forward or rewind) is in progress, or is the feature triggered under different temporal conditions that fall outside the claim language?
  3. A third major question will be one of subject matter eligibility: For the patents challenged under 35 U.S.C. § 101, do the claims recite more than the abstract ideas of an interactive scoreboard, de-duplicating content listings, or targeted advertising, respectively, implemented with generic computer components, or do they contain a sufficient inventive concept to be patent-eligible?