DCT
5:25-cv-07924
Artificial Intelligence Industry Association Inc v. Ceres Ai Inc
Key Events
Amended Complaint
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., 12/10/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in Emeryville, California, within the district, and has committed alleged acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s AI-powered aerial imaging and data analytics platforms for precision agriculture infringe a patent related to embedding calibration metadata into stereoscopic video files.
- Technical Context: The technology at issue involves synchronizing sensor and calibration data with stereoscopic video frames, which is significant for accurate 3D rendering in virtual reality and for processing data-rich imagery in fields like agricultural analytics.
- Key Procedural History: The complaint alleges that prior to filing suit, Plaintiff sent Defendant a formal demand letter identifying the patent-in-suit, asserting infringement, and offering a license, which Defendant allegedly ignored.
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 |
| 2025-12-10 | 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, “Embedding Calibration Metadata Into Stereoscopic Video Files,” issued September 11, 2018 (’693 Patent).
The Invention Explained
- Problem Addressed: When playing back stereoscopic 3D video, the player requires camera parameters (e.g., lens distortion, sensor size) to properly render the images. These parameters may be fixed or may change during recording. Further, if video from different cameras is combined, each segment may have different parameters. The patent addresses the need for a system to embed these parameters directly and time-sequentially into the video file itself to ensure accurate playback. (’693 Patent, col. 1:41-67).
- The Patented Solution: The invention describes a system within a stereoscopic video capture device that obtains both the video feed and contemporaneous metadata feeds (e.g., calibration, IMU, location data). A computer processor is programmed to embed this metadata into the video feed in real time as it is recorded. The system specifically utilizes subtitle or closed-captioning fields within the video file format to encode the metadata, ensuring that the timing of the metadata remains aligned with the corresponding video frames. (’693 Patent, Abstract; col. 2:16-34).
- Technical Importance: This approach allows a playback device to decode camera and sensor parameters on a per-frame basis, enabling accurate, real-time calibration and display, which is particularly important for immersive virtual reality experiences. (’693 Patent, col. 2:8-14).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 of the ’693 Patent (Compl. ¶25).
- The essential elements of Claim 1, a computerized system, include:
- 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 to embed the metadata into the video feed in real time.
- The embedding is performed by encoding the metadata into the subtitles or closed captioning fields of the video file format to preserve timing alignment.
- The complaint’s reference to "one or more claims" may suggest it reserves the right to assert additional dependent claims (Compl. ¶19).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant’s software products, including its aerial imaging systems, AI-powered data analytics platforms, computer vision technologies, and machine learning models (Compl. ¶1).
Functionality and Market Context
- The complaint alleges Defendant’s platform captures high-resolution aerial imagery using multispectral stereoscopic cameras and sensors, processes the imagery into calibrated data layers (e.g., water-stress indices), and applies machine learning to generate predictive analytics for crop health (Compl. ¶1, ¶19).
- The described workflows allegedly involve image capture, "rigorous calibration of imagery (using sensor metadata and environmental data)," and algorithmic transformations to produce enhanced datasets for machine learning models (Compl. ¶20, ¶21).
- These products are marketed for precision agriculture and crop health monitoring to customers that include major farming and agricultural entities (Compl. ¶1, ¶7).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
- Claim Chart Summary: The following table summarizes the infringement allegations for Claim 1 as detailed in the complaint and its Exhibit B (Compl. ¶16, Ex. B).
’693 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a computer store containing stereoscopic video feeds and contemporaneous metadata feeds, including calibration metadata | Defendant's accused systems allegedly capture image data using multispectral stereoscopic or 3D imaging technologies while simultaneously generating associated calibrated data layers and other sensor-derived information. | ¶21; Ex. B | col. 2:18-24 |
| a computer processor programmed to obtain the stereoscopic video feed and the contemporaneous metadata feeds, and to embed the metadata into the stereoscopic video feed in real time | Defendant's processing pipelines allegedly apply "image augmentation and calibration processes" and "rigorous calibration of imagery" using sensor and environmental data, which involves embedding this calibrated data into imagery layers in real-time or near-real-time. | ¶20; Ex. B | col. 2:25-30 |
| encoding the contemporaneous metadata feed... into subtitle or closed-captioning fields of the video file such that timing alignment is preserved | The complaint alleges that Defendant's workflows embed calibrated data within the imaging output, including "embedding calibration metadata in video files" in a manner where data layers are "aligned with the underlying stereoscopic or multispectral imagery." | Ex. B | col. 2:30-34 |
- Identified Points of Contention:
- Scope Questions: The infringement analysis may raise the question of whether a data analytics platform for agriculture falls within the scope of a patent focused on 3D video playback for human viewing in VR. For instance, can the accused "calibrated data layers" be considered a "stereoscopic video feed" within the meaning of the patent, which emphasizes display on a "virtual-reality headset"? (’693 Patent, col. 10:48-50).
- Technical Questions: A central technical question may be whether the accused products' alleged method of "embedding calibrated data into the imagery layers" meets the specific limitation of "encoding the contemporaneous metadata feeds into the subtitles or closed captioning metadata fields of the video file format." The complaint does not specify the exact technical mechanism used by Defendant for embedding data, creating a potential point of dispute over whether the implementation matches the claim language.
V. Key Claim Terms for Construction
The Term: "encoding... into the subtitles or closed captioning metadata fields"
Context and Importance: This term defines the specific technical mechanism for embedding metadata. The infringement case may depend on whether Defendant’s alleged "embedding" uses this precise method. Practitioners may focus on this term because it appears to be a highly specific limitation that distinguishes the invention from other methods of associating metadata with video.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The parties may argue that the core of the invention is the time-synchronized embedding of metadata, and the reference to subtitle/CC fields is merely one exemplary way to achieve it. The patent’s summary describes the invention more broadly as a system for embedding parameters "directly into the video file... at the time of capture" (’693 Patent, col. 1:54-56).
- Evidence for a Narrower Interpretation: The plain language of Claim 1 explicitly recites this specific encoding method. The specification reinforces this by describing how metadata "can be encoded into the stereoscopic video sequence using subtitle metadata or a table in the metadata header" (’693 Patent, col. 8:10-13) and how a player can "decode metadata from each frame that has been previously encoded into the subtitle or closed captioning fields" (’693 Patent, Fig. 11, step 1104). This may support a construction limiting the claim to this specific implementation.
The Term: "stereoscopic video feed"
Context and Importance: The definition of this term is critical because the patent's context is primarily 3D video for human perception, while the accused product generates data for machine analysis. The dispute may turn on whether a data stream for agricultural analytics constitutes a "stereoscopic video feed."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent defines the term broadly as a feed of "two or more stereoscopic images from a stereoscopic video capture device" (’693 Patent, Claim 1), a technical definition that may not require a specific end-use.
- Evidence for a Narrower Interpretation: The patent’s background and summary repeatedly frame the invention’s purpose as enabling playback on a "virtual reality ('VR') headset or a mobile phone fitted with a stereoscopic display adapter" (’693 Patent, col. 1:41-44). This context may support an argument that the term is implicitly limited to video intended for human 3D viewing.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant actively promotes and instructs its customers to use the accused products in an infringing manner through "detailed technical documentation, tutorials, and customer support services" (Compl. ¶2). It also alleges contributory infringement, asserting that Defendant’s software products are material components of the invention, are especially made for infringing use, and have no substantial non-infringing uses (Compl. ¶3).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged pre-suit knowledge of the ’693 Patent. It states that Plaintiff sent a "formal demand letter" asserting infringement and that Defendant continued and expanded its allegedly infringing activities despite this notice and an offer to license (Compl. ¶4).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical implementation: what evidence does the complaint or subsequent discovery provide that Defendant’s method of creating "calibrated data layers" for its analytics platform uses the specific mechanism of "encoding... metadata into the subtitles or closed captioning... fields" as explicitly required by Claim 1?
- A second key issue will be one of definitional scope: can the term "stereoscopic video feed," described in the patent’s context of 3D display for human VR experiences, be construed to read on the multispectral imaging data generated by the accused platform for the purpose of machine-learning-based agricultural analysis?