DCT

5:25-cv-11048

DirecTV LLC v. Adeia Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
    • Plaintiff: DIRECTV, LLC (California)
    • Defendant: Adeia, Inc. and its subsidiaries (collectively "Adeia") (Delaware / California)
    • Plaintiff’s Counsel: O'Melveny & Myers LLP
  • 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 Defendant Adeia's principal place of business is in the district, and a substantial part of the events giving rise to the claim occurred there.
  • Core Dispute: Plaintiff DIRECTV seeks a declaratory judgment that it does not infringe ten patents owned by Defendant Adeia related to media delivery and that three of those patents are invalid, arising from a dispute over the renewal of a long-standing license agreement.
  • Technical Context: The patents-in-suit cover technologies foundational to modern media services, including adaptive bitrate streaming, interactive program guides, digital video recording (DVR), and targeted advertising.
  • Key Procedural History: The parties have a licensing relationship dating back to 1994. The current license agreement, which covers DIRECTV as a subsidiary of AT&T, is set to expire on December 31, 2025. This declaratory judgment action was filed by DIRECTV in response to Adeia's demands that it enter a new license agreement, and in light of Adeia's history of litigating its patent portfolio.

Case Timeline

Date Event
2001-03-22 ’528 Patent Priority Date
2006-07-31 ’165 Patent Priority Date
2008-06-13 ’526 Patent Priority Date
2008-08-13 ’245 Patent Priority Date
2008-12-23 ’668 Patent Priority Date
2010-09-30 ’010 Patent Priority Date
2011-12-23 ’418 Patent Priority Date
2012-04-10 ’528 Patent Issue Date
2012-07-31 ’668 Patent Issue Date
2013-12-03 ’526 Patent Issue Date
2014-01-28 ’165 Patent Issue Date
2014-02-26 ’961 Patent Priority Date
2014-06-16 ’334 Patent Priority Date
2014-08-12 ’418 Patent Issue Date
2015-12-15 AT&T license agreement signed
2016-01-01 AT&T license agreement effective date
2017-07-25 ’334 Patent Issue Date
2018-06-29 ’922 Patent Priority Date
2018-10-23 ’961 Patent Issue Date
2019-12-10 ’010 Patent Issue Date
2023-10-03 ’245 Patent Issue Date
2025-05-13 ’922 Patent Issue Date
2025-12-29 Complaint Filing Date
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"

  • Patent Identification: U.S. Patent No. 10,506,010, titled “Delivering Content in Multiple Formats,” issued December 10, 2019 (the "’010 Patent"). (Compl. ¶35).

The Invention Explained

  • Problem Addressed: The patent addresses the inefficiency of delivering the same media content (e.g., a movie) over a distribution network multiple times in different formats to accommodate the varying capabilities of end-user terminals. ('010 Patent, col. 1:16-30).
  • The Patented Solution: The invention proposes a system at an "edge location" of a network that receives content once, transcodes it into multiple formats (e.g., different resolutions or bitrates), and stores these versions as aligned, individually accessible fragments. The alignment of fragments, particularly their initial i-frames, allows a user's device to switch between formats mid-stream without interruption or re-transmission of already-viewed frames. ('010 Patent, Abstract; col. 3:56-62; Fig. 6).
  • Technical Importance: This method provides a technical foundation for adaptive bitrate (ABR) streaming, which enables smooth video playback for users by dynamically adjusting stream quality in response to changing network conditions. ('010 Patent, col. 12:51-67).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement of at least claim 1. (Compl. ¶66).
  • Independent claim 1 of the ’010 Patent includes the following essential elements:
    • Receiving a content item at a computing device.
    • Transcoding the content into a first video stream (first format) and a second video stream (second format).
    • Fragmenting each video stream into a plurality of fragments.
    • Aligning the first fragment from the first stream with the second fragment from the second stream, based on a corresponding point in the original content item.
    • Storing the first and second fragments as individually accessible fragments. ('010 Patent, col. 13:5-31).

U.S. Patent No. 8,805,418 - "Methods and Systems for Performing Actions Based on Location-Based Rules"

  • Patent Identification: U.S. Patent No. 8,805,418, titled “Methods and Systems for Performing Actions Based on Location-Based Rules,” issued August 12, 2014 (the "’418 Patent"). (Compl. ¶38).

The Invention Explained

  • Problem Addressed: The complaint does not provide the patent document, preventing a direct analysis of the problem described in the patent's background section. The patent's title suggests the invention relates to triggering device actions based on geographic location.
  • The Patented Solution: Based on the limited claim language in the complaint, the invention appears to be a method where a system determines a user has entered a "predetermined range of a location" and then, based on a pre-defined "location-based rule," "select[s] one of a plurality of actions" to perform. (Compl. ¶77). The complaint does not provide sufficient detail for a full analysis of the patented technology.
  • Technical Importance: The complaint does not provide the patent specification, precluding an analysis of the invention's stated technical importance.

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement of at least claim 1. (Compl. ¶74).
  • Independent claim 1 of the ’418 Patent, as quoted in the complaint, requires at least:
    • "determining that the user entered a predetermined range of a location." (Compl. ¶77).
    • "selecting one of a plurality of actions based on the location and the location-based rule." (Compl. ¶77).

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"

  • Patent Identification: U.S. Patent No. 11,778,245, titled “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 October 3, 2023 (the "’245 Patent"). (Compl. ¶41).
  • Technology Synopsis: The patent title and infringement allegations suggest a system for inserting content, such as advertisements, into a media stream. The technology appears to involve a client device receiving a "set of timepoints" related to the primary content, which trigger an interruption for displaying the additional content and a notification back to a server. (Compl. ¶¶ 23, 85).
  • Asserted Claims: Claim 1. (Compl. ¶82).
  • Accused Features: The functionality for "displaying mid-stream advertisements to DIRECTV Stream users." (Compl. ¶23).

U.S. Patent No. 10,110,961 - "Methods and Systems for Supplementing Media Assets During Fast-Access Playback Operations"

  • Patent Identification: U.S. Patent No. 10,110,961, titled “Methods and Systems for Supplementing Media Assets During Fast-Access Playback Operations,” issued October 23, 2018 (the "’961 Patent"). (Compl. ¶44).
  • Technology Synopsis: The patent's abstract describes a system for enhancing the user experience during "fast-access playback operations" like fast-forward or rewind. The technology solves the problem of missing important details during such operations by generating supplemental content (e.g., a picture-in-picture display) related to the progression point in the media asset when a user input is received. (’961 Patent, Abstract).
  • Asserted Claims: Claim 1. (Compl. ¶90).
  • Accused Features: The feature for "displaying picture-in-picture content to DIRECTV Stream users," which DIRECTV alleges does not infringe because it is not triggered by a user input received "while a media asset is subject to a fast-access playback operation." (Compl. ¶¶ 23, 93).

U.S. Patent No. 9,715,334 - "Personalized Timeline Presentation"

  • Patent Identification: U.S. Patent No. 9,715,334, titled “Personalized Timeline Presentation,” issued July 25, 2017 (the "’334 Patent"). (Compl. ¶47).
  • Technology Synopsis: The patent title and infringement allegations suggest a system for creating a personalized interface for resuming paused content. The technology appears to involve designating a "pause event" and later transmitting an "instruction to a client device to initiate playback" from that designated point. (Compl. ¶101).
  • Asserted Claims: Claim 1. (Compl. ¶98).
  • Accused Features: The "Continue Watching" feature provided to DIRECTV Stream users. (Compl. ¶1).

U.S. Patent No. 8,156,528 - "Personal Video Recorder Systems and Methods"

  • Patent Identification: U.S. Patent No. 8,156,528, titled “Personal Video Recorder Systems and Methods,” issued April 10, 2012 (the "’528 Patent"). (Compl. ¶50).
  • Technology Synopsis: The patent abstract describes an interactive television system for recording programming, integrating Personal Video Recorder (PVR) functionality with an Interactive Program Guide (IPG). The infringement allegations center on a claim requiring a "first interactive television program guide" and a "second interactive television program guide" that are "distinctly implemented," suggesting a distributed system architecture where guide functions are split between different devices. (’528 Patent, Abstract; Compl. ¶109).
  • Asserted Claims: Claim 32. (Compl. ¶106).
  • Accused Features: The Digital Video Recording (DVR) feature provided via DIRECTV's set-top box receiver systems, including the 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"

  • Patent Identification: U.S. Patent No. 8,601,526, titled “Systems and Methods for Displaying Media Content and Media Guidance Information,” issued December 3, 2013 (the "’526 Patent"). (Compl. ¶53).
  • Technology Synopsis: The patent's abstract describes a system where users of portable electronic devices can transmit media guidance data to a television for display. The technology allows for the simultaneous display on the television of guidance information from the portable device along with other media content. (’526 Patent, Abstract).
  • Asserted Claims: Claim 1. (Compl. ¶114).
  • Accused Features: The functionality of the DIRECTV App that allows for displaying and modifying a user's recorded programs in connection with a DIRECTV set-top box system. (Compl. ¶24).

U.S. Patent No. 8,640,165 - "Systems and methods for providing enhanced sports watching media guidance"

  • Patent Identification: U.S. Patent No. 8,640,165, titled “Systems and methods for providing enhanced sports watching media guidance,” issued January 28, 2014 (the "’165 Patent"). (Compl. ¶56).
  • Technology Synopsis: The patent abstract describes an "interactive 'sports watcher' application" for providing enhanced access to sports-related media content. The complaint characterizes the invention as being directed to the abstract idea of "displaying an interactive scoreboard during a sporting event" using conventional hardware. (’165 Patent, Abstract; Compl. ¶124).
  • Asserted Claims: Claim 1. (Compl. ¶122).
  • Accused Features: The feature for "providing an interactive scoreboard to users during a sports event via broadcast to a DIRECTV set-top box receiver system." (Compl. ¶24).

U.S. Patent No. 8,234,668 - "Content access"

  • Patent Identification: U.S. Patent No. 8,234,668, titled “Content access,” issued July 31, 2012 (the "’668 Patent"). (Compl. ¶59).
  • Technology Synopsis: The complaint describes the patent as being directed to the abstract idea of de-duplicating an electronic program guide (EPG) by providing access to high-definition channels when available, instead of also showing corresponding standard-definition channels. The technology aims to substitute a higher-quality product for a lower-quality one when available. (Compl. ¶132).
  • Asserted Claims: Claim 1. (Compl. ¶130).
  • Accused Features: The functionality for "providing standard-definition and high-definition content to users via broadcast to a DIRECTV set-top box receiver system." (Compl. ¶24).

U.S. Patent No. 12,301,922 - "Systems and methods for providing synchronized supplemental content to a subset of users that are disinterested in live content"

  • Patent Identification: U.S. Patent No. 12,301,922, titled “Systems and methods for providing synchronized supplemental content to a subset of users that are disinterested in live content,” issued May 13, 2025 (the "’922 Patent"). (Compl. ¶62).
  • Technology Synopsis: The patent's abstract describes a system that replaces a segment of live content with supplemental, non-live content for a subset of users who are disinterested, while other users continue to view the live stream. This appears to be a technology for targeted content substitution within a live broadcast, such as for ad replacement or alternative content during game breaks. (’922 Patent, Abstract).
  • Asserted Claims: Claim 1. (Compl. ¶138).
  • Accused Features: The system for "identifying and broadcasting advertisements to users based on user data." (Compl. ¶24).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two categories of accused instrumentalities, collectively referred to as the "DIRECTV Products and Services." (Compl. ¶25).
    • DIRECTV Stream Products and Services: This category includes DIRECTV's over-the-top streaming service, targeting features such as adaptive resolution streaming, mid-stream ad insertion, picture-in-picture display, and the "Continue Watching" feature. (Compl. ¶¶ 1, 23).
    • DIRECTV MVPD Products and Services: This category includes DIRECTV's traditional satellite and set-top box offerings, such as the Genie and Genie Mini devices. Accused features include DVR functionality, the DIRECTV App for managing recorded programs, interactive scoreboards, and targeted advertising. (Compl. ¶¶ 24, 13).

Functionality and Market Context

  • The accused products and services represent DIRECTV's core offerings in both the streaming (OTT) and traditional multichannel video programming distributor (MVPD) markets. The complaint positions these services as central to DIRECTV's business, noting that without a renewed license from Adeia, it would be "at risk of accruing possible damages" for continuing to sell them. (Compl. ¶27). The complaint does not provide detailed technical descriptions of how the accused features operate.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’010 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving, by a computing device, a content item The DIRECTV Stream server receives a content item for streaming. ¶23 col. 13:5-7
transcoding... into a first video stream;... transcoding... into a second video stream The server is alleged to transcode content into different resolution fragments for adaptive streaming. ¶23 col. 13:8-13
fragmenting... the first video stream;... fragmenting... the second video stream The server is alleged to create and store fragments for the different resolution streams. ¶23 col. 13:14-20
aligning... 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 Adeia is expected to contend that the fragments for different resolutions are aligned to enable seamless stream switching. ¶23, ¶69 col. 13:21-27
storing... as individually accessible fragments, the first fragment and the second fragment The server stores these fragments for delivery to DIRECTV Stream users. ¶23 col. 13:28-31
  • Identified Points of Contention:
    • Technical Question: DIRECTV's complaint centers its non-infringement argument on the "aligning" step, stating its system "does not perform aligning as required by claim 1." (Compl. ¶69). A central factual question will be whether the technical process used by the DIRECTV Stream server to prepare content for adaptive bitrate streaming meets the specific definition of "aligning" recited in the claim.
    • Scope Question: The dispute may raise the question of the proper construction for the term "aligning." The patent specification describes aligning i-frames at the start of fragments to allow seamless switching ('010 Patent, col. 3:56-62; Fig. 6). The scope of the claim may depend on whether it is limited to this specific embodiment or can be read more broadly on other technical methods for enabling stream switching.

’418 Patent Infringement Allegations

The complaint does not provide a claim chart exhibit for the ’418 Patent or sufficient detail to construct one. Adeia is expected to allege that DIRECTV's "providing location-based programs to DIRECTV Stream users" infringes claim 1. (Compl. ¶23). DIRECTV asserts non-infringement by arguing its products do not "‘select[] one of a plurality of actions based on the location and the location-based rule’ as required by the claim." (Compl. ¶77).

  • Identified Points of Contention:
    • Evidentiary Question: The complaint provides no description of what the accused "location-based programs" feature is or how it functions. A primary issue will be establishing the existence and technical operation of this accused functionality within the DIRECTV Stream services.
    • Functional Question: The dispute raises the question of whether the accused feature, if identified, operates by "selecting" an "action" based on a "location-based rule." DIRECTV’s argument suggests a potential mismatch between the logic of its system and the specific sequence of steps required by the claim.

V. Key Claim Terms for Construction

  • The Term: "aligning... the first fragment with the second fragment" (’010 Patent, Claim 1)
  • Context and Importance: This term is the explicit basis for DIRECTV’s non-infringement argument regarding the ’010 Patent. (Compl. ¶69). The outcome of the infringement analysis for this patent may depend entirely on whether DIRECTV's method for preparing adaptive bitrate streaming files falls within the court's construction of this term.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain language of the claim recites "aligning... based on a point in the content item," which could be argued to cover any technical method that ensures fragments from different bitrate streams correspond to the same point in the underlying content to permit seamless switching. ('010 Patent, col. 13:21-27).
    • Evidence for a Narrower Interpretation: The specification provides a specific example of alignment, stating that "some or all of the i-frames of each copy of the content are aligned with one another." ('010 Patent, col. 3:56-59). Figure 6 further illustrates this concept by showing three streams (610, 620, 630) with i-frames aligned at specific time points (t0, t1, t2). This may support a narrower construction that requires alignment of specific frame types at fragment boundaries.
  • The Term: "selecting one of a plurality of actions based on... the location-based rule" (’418 Patent, Claim 1)
  • Context and Importance: This is the core limitation upon which DIRECTV bases its non-infringement argument for the ’418 Patent. (Compl. ¶77). The dispute will likely focus on whether the accused DIRECTV feature, once identified, performs a "selection" based on a "rule," or operates via a different mechanism.
  • Intrinsic Evidence for Interpretation: The complaint does not provide the patent-in-suit, precluding an analysis of intrinsic evidence for claim construction.

VI. Other Allegations

  • Indirect Infringement: The complaint seeks a declaratory judgment that DIRECTV does not induce or contributorily infringe the patents-in-suit, but it does not specify the factual basis Adeia might assert for such claims. (Prayer for Relief ¶C, D).
  • Willful Infringement: Willful infringement is not alleged in this declaratory judgment action. However, the complaint establishes that the dispute arises in the context of license renewal negotiations where Adeia has asserted its portfolio against DIRECTV, which could provide a basis for a future willfulness claim by Adeia. (Compl. ¶¶ 3, 19).

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

  1. Technical and Definitional Scope: For the seven patents subject to a non-infringement defense, the case raises a core question of technical and definitional scope: does the actual operation of DIRECTV's adaptive streaming, DVR, and multi-device features meet the specific, and potentially narrow, sequence of technical steps recited in the asserted claims (e.g., '010 Patent's "aligning" step, '961 Patent's "user input...while...fast-access" step)?
  2. Patent-Eligible Subject Matter: For the ’165, ’668, and ’922 Patents, a central issue will be patent eligibility under 35 U.S.C. § 101. The court will need to determine whether the claims directed to an interactive scoreboard, a de-duplicated program guide, and targeted content substitution in a live stream are patent-ineligible abstract ideas implemented with conventional technology, or if they claim a specific technological improvement that is patent-eligible.
  3. Evidentiary Foundation: The complaint is notably sparse on technical details describing the operation of the accused DIRECTV features. A threshold issue for the dispute will be evidentiary: what technical evidence will be presented to establish how DIRECTV's services function and to map that functionality (or lack thereof) to the specific limitations of the ten diverse patents-in-suit?