Cedar Lane Tech Inc v. WideOpenWest Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: WideOpenWest, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-00327, D. Colo., 01/30/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the District of Colorado and having committed alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s products, which are not specifically identified in the complaint, infringe a patent related to universal remote controls adapted to receive and process voice input.
• Technical Context: The technology addresses methods for using voice to control consumer electronics and, more specifically, to enter alphanumeric data for functions like internet browsing or online shopping.
• Key Procedural History: The complaint states that Plaintiff is the assignee of the patent-in-suit with the right to sue for infringement. No other procedural history, such as prior litigation or administrative proceedings, is mentioned.

Case Timeline

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

U.S. Patent No. 6,629,077, "Universal remote control adapted to receive voice input," Issued September 30, 2003

The Invention Explained

• Problem Addressed: The patent identifies the growing need for users to enter alphanumeric "keystroke data" (e.g., website URLs, credit card information) into consumer electronics that are part of a home entertainment network ('077 Patent, col. 1:25-34). It describes existing solutions like physical keyboards as "large, unwieldy, and more costly," and stylus-based "graffiti" input on touch screens as suffering from "disadvantages affecting user acceptability" ('077 Patent, col. 1:46-64).
• The Patented Solution: The invention proposes a universal remote control that uses voice recognition to overcome these problems. The remote is designed to receive voice input and distinguish between two types of commands: operational commands (e.g., "play," "stop") and alphanumeric data entry (e.g., spelling a word) ('077 Patent, col. 2:11-24). It achieves this through distinct operating modes, including a "keyboard mode," allowing a single device to serve both as a traditional remote and a data entry tool ('077 Patent, col. 5:7-24). The remote processes the voice input by comparing it to templates stored in its local memory and transmits the appropriate command or data codes to an electronic device ('077 Patent, Abstract).
• Technical Importance: This approach sought to provide a more intuitive user interface for interacting with internet-enabled consumer electronics, which were becoming more prevalent at the time of the invention ('077 Patent, col. 1:25-34).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims of the ’077 Patent," including "method claims," but does not identify specific claims (Compl. ¶11). Independent claim 1 is a representative method claim.
• The essential elements of independent claim 1 include:
  • determining if an input is a voice input or a button input;
  • if the input is voice, determining if the remote is in a "first mode" or a "second mode";
  • in the first mode, selecting and transmitting "alphanumeric symbol codes" based on the voice input to support "network communication functions";
  • in the second mode, selecting and transmitting "command codes" based on the voice input to cause a device "to perform an operation";
  • if the input is from a button, selecting and transmitting a command code based on the button activated.
• The complaint reserves the right to assert other claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" but does not name them in the body of the document (Compl. ¶11). It states these products are identified in charts contained in an "Exhibit 2," which was not filed with the public complaint (Compl. ¶13).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context. It makes the conclusory allegation that the products "practice the technology claimed by the '077 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement and states that claim charts comparing the patent claims to the accused products are contained in Exhibit 2, which is incorporated by reference but was not publicly filed (Compl. ¶13-14). In the absence of the charts, the infringement theory must be summarized from the complaint's narrative.

The complaint alleges that Defendant directly infringes the '077 Patent by "making, using, offering to sell, selling and/or importing" the accused products (Compl. ¶11). A specific allegation is made that infringement occurs through the actions of Defendant's employees who "internally test and use these Exemplary Products" (Compl. ¶12). The core of the infringement theory appears to be that the accused products embody the method of receiving voice input and, based on that input, transmitting either command codes or alphanumeric data codes, thereby satisfying the elements of the asserted method claims (Compl. ¶13).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Architectural Questions: A potential issue is whether the accused products use the specific architecture described in the patent, which involves a remote control with local memory storing command and symbol codes ('077 Patent, Fig. 2; col. 4:1-9). The analysis may question whether modern systems, which might rely on cloud-based speech processing and dynamic command generation, meet the claim limitation of "selecting" a code from a "plurality of...codes stored in the memory."
• Scope Questions: The distinction between the "first mode" (for alphanumeric data) and "second mode" (for operational commands) in claim 1 raises the question of how the accused products make this determination. The case may turn on whether the accused functionality maps onto this specific two-mode framework or operates via a different logic that falls outside the claim's scope.

V. Key Claim Terms for Construction

The Term: "first mode" / "second mode"

• Context and Importance: This pair of terms is central to the structure of independent claim 1, which requires the remote control to determine which of these two modes it is in before processing a voice input. The infringement analysis will depend heavily on whether the accused products can be shown to operate under this specific dual-mode paradigm for handling data entry versus device commands.
• Intrinsic Evidence for a Broader Interpretation: A party could argue that these terms do not require a formal, user-initiated switch, but rather describe any internal state logic where the device contextually distinguishes between a request for data entry and a request for an operational command.
• Intrinsic Evidence for a Narrower Interpretation: The specification explicitly describes a "keyboard button 78" for "placing the remote control 20 in a keyboard mode," which corresponds to the "first mode" for data entry ('077 Patent, col. 3:21-23; col. 5:14-18). This could support a narrower construction requiring a distinct, selectable mode rather than an implicit, contextual determination.

The Term: "selecting at least one... code from the plurality of... codes stored in the memory"

• Context and Importance: Practitioners may focus on this term because its construction could determine whether the claim reads on modern voice-control systems. The infringement outcome may depend on whether the accused system's method of converting speech to a command signal is equivalent to "selecting" a "code" from a pre-existing, "stored" library.
• Intrinsic Evidence for a Broader Interpretation: The patent does not narrowly define "code" or "memory," which could support an argument that the terms encompass any system where a voice input is mapped to a digital output signal, regardless of the underlying hardware or software architecture.
• Intrinsic Evidence for a Narrower Interpretation: The specification and figures describe a system with on-board memory (35, 45) containing an "operational command code library" and an "alphanumeric symbols library" ('077 Patent, col. 3:44-48, Fig. 2). This may support a construction limited to devices that retrieve commands from a finite, pre-loaded list stored locally on the remote control, potentially excluding systems that rely on cloud-based, real-time speech-to-text processing.

VI. Other Allegations

Willful Infringement

The complaint does not contain an explicit allegation of willful infringement. However, the prayer for relief requests that the case be declared "exceptional within the meaning of 35 U.S.C. § 285" and seeks an award of attorneys' fees (Compl. p. 4). No specific facts to support pre- or post-suit knowledge of the patent are alleged in the complaint.

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

• A central issue will be one of architectural scope: does the claim language requiring the "selecting" of "codes stored in the memory" of the remote control read on the architecture of the accused products? The case may depend on whether Defendant's systems, potentially leveraging modern cloud-based voice processing, can be proven to operate in the manner described by the patent's 2000-era disclosure.
• The outcome will also likely turn on a key functional question: can the Plaintiff provide evidence that the accused products operate by "determining if the remote control is in a first mode or a second mode," as required by claim 1? The dispute may focus on whether the accused systems use this specific dual-mode logic for differentiating between data entry and device commands, or if they use a different, non-infringing method to achieve a similar result.