DCT
1:17-cv-01627
Rothschild Broadcast Distribution Systems LLC v. Ring Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Rothschild Broadcast Distribution Systems, LLC (Texas)
- Defendant: Ring Inc. (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
- Case Identification: 1:17-cv-01627, D. Del., 11/09/2017
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant, Ring Inc., is a Delaware corporation and is therefore deemed to reside in the district.
- Core Dispute: Plaintiff alleges that Defendant’s security camera systems, which allow users to store and stream video content via a cloud-based service, infringe a patent related to on-demand media content storage and delivery.
- Technical Context: The technology at issue involves a server-based system for managing user requests to either store media content for a period of time or to stream (deliver) already-stored content.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit. The patent-in-suit is a continuation of a prior application that issued as a U.S. patent.
Case Timeline
| Date | Event |
|---|---|
| 2011-08-29 | ’221 Patent Priority Date |
| 2014-10-07 | ’221 Patent Issue Date |
| 2017-11-09 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,856,221 - "System and Method for Storing Broadcast Content in a Cloud-based Computing Environment"
- Patent Identification: U.S. Patent No. 8,856,221, "System and Method for Storing Broadcast Content in a Cloud-based Computing Environment," issued October 7, 2014 (’221 Patent).
The Invention Explained
- Problem Addressed: The patent's background section describes inefficiencies in on-demand media services, where providers must bear the high cost of storing vast libraries of content (e.g., all broadcast television shows), and consumers often pay flat fees for content they do not watch or face long waits for requested content to be added to the library (’221 Patent, col. 1:36-2:12).
- The Patented Solution: The invention describes a system centered on a remote server that receives specific requests from a user's device. The server's processor authenticates the user and distinguishes between two types of requests: a "storage request message" to save specific media content for a defined period, and a "content request message" to stream or download that content. This allows for a more granular, user-directed approach to media storage and delivery, as depicted in the system's process flowchart (’221 Patent, Abstract; FIG. 2).
- Technical Importance: This technical approach sought to create a more flexible and cost-effective on-demand media system by tailoring storage and associated costs to individual consumer requests rather than a monolithic, provider-maintained library model (’221 Patent, col. 2:12-18).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (’221 Patent, Compl. ¶13).
- The essential elements of Claim 1 include:
- A first server with a receiver and a processor.
- The receiver is configured to receive a "request message" containing "media data" (identifying the content) and a "consumer device identifier."
- The processor first determines if the "consumer device identifier" corresponds to a "registered consumer device."
- If registered, the processor then determines if the request is a "storage request message" or a "content request message."
- For a storage request, the processor determines if the content is "available for storage."
- For a content request, the processor "initiates delivery" of the content to the device.
- The complaint states that Plaintiff may assert other claims of the ’221 Patent (Compl. ¶13).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the "Ring security camera system and its components," including various camera models (e.g., "Stick Up Cam"), the Ring mobile and desktop applications, and associated cloud-based services (collectively, the "Product") (Compl. ¶¶14-15).
Functionality and Market Context
- The accused Product is a system for media content storage and delivery where videos captured by security cameras can be stored on a cloud server and delivered to a user's smartphone or other computing device (Compl. ¶15). The complaint alleges the Product includes at least one cloud server for storing these videos (Compl. ¶16).
- The system allegedly differentiates between a user's request to store video (e.g., by subscribing to a recording plan) and a request to stream live or recorded content (Compl. ¶19). A promotional screenshot included in the complaint advertises "Ring Video Recording Plans" that allow users to "[s]ave all your videos for up to 60 days," illustrating the storage function (Compl. p. 5). Another screenshot highlights the ability to "[l]ive [v]iew on-demand video and audio," illustrating the delivery function (Compl. p. 4).
IV. Analysis of Infringement Allegations
’221 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first server, the first server including: a first receiver... and a first processor... | The Product includes at least one server (e.g., a cloud server) for hosting and storing media content, which necessarily includes a receiver for requests and a processor. | ¶16 | col. 4:41-47 |
| a first receiver... configured to receive a request message including media data indicating requested media content and a consumer device identifier corresponding to a consumer device; | The server has infrastructure to receive requests to store or stream video. The request identifies the video and includes user credentials that tie the request to a specific user account, smartphone, and cameras. A user sign-in screen is provided as an example of this authentication gateway. | ¶17, p. 6 | col. 5:6-14 |
| a first processor... configured to determine whether the consumer device identifier corresponds to a registered consumer device; | The server's processor must authenticate a user's credentials to ensure they match a registered user and provide access to the correct security camera feeds. | ¶18 | col. 5:7-10 |
| if... registered... determine whether the request message is one of a storage request message and a content request message; | A processor in the Product necessarily differentiates between a user's request to store videos (a storage request) and a request to stream live or recorded content (a content request). | ¶19 | col. 5:20-22 |
| if the request message is the storage request message, then the processor is further configured to determine whether the requested media content is available for storage; | The server verifies that content is available for storage by, for example, checking that the camera is connected to the internet or that the user has not exceeded their subscription's memory limit. | ¶20 | col. 5:46-55 |
| if the request message is the content request message, then the processor is further configure to initiate delivery of the requested media content to the consumer device. | If a customer requests content (e.g., live streaming), a processor initiates delivery of that content, such as a live camera feed, to the customer's device (e.g., a smartphone). | ¶21 | col. 6:35-41 |
- Identified Points of Contention:
- Scope Questions: The patent is titled "Storing Broadcast Content" and its background focuses on television shows and movies (’221 Patent, Title; col. 1:36-66). A central question may be whether the term "media content", as used in the claims, can be construed to cover user-generated security camera footage, or if its scope is limited by the specification's focus on pre-existing, commercially broadcast content.
- Technical Questions: The complaint alleges that checking camera connectivity or user subscription limits satisfies the "available for storage" limitation (Compl. ¶20). It may be disputed whether this function is technically equivalent to the function described in the patent, which appears to contemplate a server checking whether a specific piece of third-party content exists and is available for download from a source like a broadcast server (’221 Patent, col. 5:46-61).
V. Key Claim Terms for Construction
The Term: "storage request message"
- Context and Importance: The claim requires the system to differentiate between a "storage request message" and a "content request message". The definition of this term is critical to determining if the accused system performs this claimed function. Practitioners may focus on this term because infringement depends on whether a user's action, such as subscribing to a "Ring Video Recording Plan" (Compl. p. 5), constitutes the transmission of a "storage request message" as contemplated by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the message in general terms as indicating a request for the "remote server 16 [to] store specific media content for an amount of time" (’221 Patent, col. 5:22-26). This could support a reading that covers setting up a recurring recording plan.
- Evidence for a Narrower Interpretation: The patent’s background discusses a consumer actively requesting a specific program (e.g., a particular TV episode) to be stored (’221 Patent, col. 2:3-6). This could support a narrower construction requiring the message to identify a discrete, pre-existing media item, rather than establishing a general rule for future recording of user-generated content.
The Term: "media content"
- Context and Importance: This term's scope is fundamental to the case. If construed narrowly to mean only "broadcast content," the infringement case may fail, as the accused product deals with user-generated security video.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a broad definition, stating that "the stored media content may be video, audio, graphical images and the like" without any explicit limitation to broadcast sources (’221 Patent, col. 4:31-33). The claim language itself is not limited.
- Evidence for a Narrower Interpretation: The patent is titled "System and Method for Storing Broadcast Content..." and the Background of the Invention exclusively uses examples from broadcast television to frame the problem being solved (’221 Patent, Title; col. 1:36-44). This context may be used to argue that "media content" should be implicitly limited to that domain.
VI. Other Allegations
- Indirect Infringement: The complaint makes a general allegation of infringement under 35 U.S.C. § 271, et seq., but does not plead specific facts to support claims of induced or contributory infringement (Compl. ¶9).
- Willful Infringement: The complaint does not contain an explicit allegation of willful infringement and does not plead facts related to Defendant's pre- or post-suit knowledge of the ’221 Patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the patent's claims, which arose from a technical context of managing "broadcast content" like television shows, be construed to cover a system for storing and streaming user-generated video from a personal security camera? The outcome will likely depend on the construction of key terms such as "media content" and "storage request message".
- A key evidentiary question will be one of functional equivalence: does the accused Ring system's process of checking for camera connectivity or subscription storage limits meet the claim limitation of determining if "media content is available for storage," or is there a fundamental mismatch with the patent's apparent contemplation of a server verifying the existence of third-party content?