DCT
1:18-cv-00283
Location Based Services LLC v. Sony Electronics Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Location Based Services, LLC (Texas)
- Defendant: Sony Electronics Inc. (Delaware)
- Plaintiff’s Counsel: Bayard, P.A.
- Case Identification: 1:18-cv-00283, D. Del., 02/19/2018
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business and has committed acts of patent infringement in the District of Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s PlayMemories software for organizing photos and videos infringes a patent related to systems that map images to geographic locations and display them in coordination with an interactive timeline.
- Technical Context: The technology addresses the organization and visualization of geo-tagged digital media, a key feature in consumer photo management software that became more prevalent with the integration of GPS into cameras and smartphones.
- Key Procedural History: The complaint asserts that the patented invention was unconventional at the time of filing, noting that cameras with the requisite built-in GPS hardware did not become widely available until years later. No prior litigation, licensing, or post-grant proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2005-02-15 | '733 Patent Priority Date |
| 2008-08-01 | Context: Nikon releases Coolpix P6000 with built-in GPS (approximate date) |
| 2012-11-13 | '733 Patent Issue Date |
| 2018-02-19 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,311,733 - "Interactive Key Frame Image Mapping System and Method"
- Patent Identification: U.S. Patent No. 8,311,733, issued November 13, 2012.
The Invention Explained
- Problem Addressed: As digital image collections grow, organizing and visualizing photos based on when and where they were taken becomes a challenge. The patent addresses the need for a system to manage and intuitively display images that are associated with specific times and geographic locations (Compl. ¶10; ’733 Patent, col. 1:11-16).
- The Patented Solution: The invention is a computer system that organizes images on a map and links them to a timeline. The system uses a "data store" to hold the images organized by map location and a separate "table" to associate metadata (like time, location, and image history) for those images with an interactive timeline. A user can then interact with the timeline (e.g., by positioning a cursor) to call up and display images corresponding to a specific time and its associated location on the map (’733 Patent, Abstract; Fig. 3).
- Technical Importance: The technology provides a method for creating a personalized, interactive "iconographic map" that integrates a user's photographic journey with a geographical and temporal context, moving beyond simple chronological or folder-based organization (’733 Patent, col. 5:50-60).
Key Claims at a Glance
- The complaint asserts independent claim 1 ('733 Patent, Compl. ¶11).
- The essential elements of independent claim 1 are:
- A computer system comprising a processor, a memory, and a mapping module.
- The mapping module includes a data store to organize multiple images by map location.
- The mapping module also includes a table, coupled to the data store, to associate metadata for the images with a time line, an image history, and a location.
- This association enables the display of time-related images on the map when a user positions a cursor at different locations along the timeline.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Sony’s software products: “PlayMemories Home for PC and Mac and PlayMemories Studio for PS3” (Compl. ¶11).
Functionality and Market Context
- The complaint alleges these software products are used to manage and view digital photos and videos. Their accused functionality involves correlating video or image information with map data (e.g., GPS information), organizing the media based on this map data, and associating metadata with a timeline. This allows a user to interact with the timeline to display a corresponding video frame or image along with its map data (Compl. ¶13).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
’733 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a computer system comprising: a processor; a memory coupled to the processor; and a mapping module coupled to the memory... | The accused software operates on computer systems (PC, Mac, PlayStation 3) that include processors and memory, and the software itself acts as the mapping module. | ¶13 | col. 10:11-15 |
| a data store configurable to organize multiple images according to one or more locations on a map, and | The accused software organizes video frames based on correlated map data derived from GPS information. | ¶13 | col. 10:16-18 |
| a table coupled to the data store, the table configurable to associate metadata for the multiple images with a time line, an image history and a location, | The software allegedly uses a table to associate metadata from video frames with a time line, image history, and location. | ¶13 | col. 10:18-21 |
| the association to enable an instantiation of time-related images from the multiple images at the one or more locations on the map in response to an instantiation of a curser positioned at different locations along an instantiation of the time line. | When a user clicks on a location on the timeline, the software displays the corresponding video frame along with map data. | ¶13 | col. 10:21-24 |
Identified Points of Contention
- Structural Questions: The claim recites a "data store" and a "table coupled to the data store." A central question may be whether the accused software's architecture contains two distinct, coupled components corresponding to these limitations, or if it uses a more integrated database structure that does not map onto the claimed architecture.
- Scope Questions: The term "image history" is recited as a required piece of metadata. Discovery will likely focus on whether the accused software associates metadata that meets the definition of "image history" as contemplated by the patent.
- Technical Questions: The final limitation requires displaying an image in response to an "instantiation of a curser positioned at different locations along an instantiation of the time line." The complaint alleges this is met by a user "click[ing] on a location on the time line" (Compl. ¶13). The court may need to determine if a "click" is encompassed by the claim's more complex language regarding cursor positioning.
V. Key Claim Terms for Construction
The Term: "table coupled to the data store"
- Context and Importance: This term is central to the claimed system architecture. The infringement analysis depends on whether the accused software's data management system embodies this specific two-part structure. Practitioners may focus on this term to dispute whether a single, integrated database can meet a limitation that explicitly recites two distinct, coupled components.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not narrowly define "table," which could support an argument that any data structure that logically associates metadata with images satisfies the limitation, regardless of its specific implementation.
- Evidence for a Narrower Interpretation: Figure 3 explicitly depicts the "DATA STORE" (312) and the "TABLE" (314) as separate blocks within the system architecture. The claim language "coupled to" further suggests two distinct but connected entities, which could support a narrower construction requiring a separable table structure. (’733 Patent, Fig. 3; col. 10:18).
The Term: "image history"
- Context and Importance: This is one of three required metadata types (along with "time line" and "location") that the "table" must associate with the images. A narrow definition could render the claim not infringed if the accused software does not track or associate this specific type of data.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term is not explicitly defined, leaving room to argue it covers any historical data about an image, such as creation date, modification date, or file properties, which are commonly stored as metadata.
- Evidence for a Narrower Interpretation: The specification summary discusses organizing images as a function of "a time, a location and/or an image history parameter" (’733 Patent, col. 1:13-15). This phrasing, separating it from time and location, suggests it is a distinct parameter. A defendant might argue it refers to a specific, curated history (e.g., a sequence of images in a "trip") not present in the accused system.
VI. Other Allegations
Indirect Infringement
- The complaint alleges induced infringement under 35 U.S.C. § 271(b) (Compl. ¶¶ 16-23). The factual basis for inducement is Defendant’s alleged provision of "instruction manuals, advertisement of the infringing features, and support" that instruct and encourage end-users to operate the accused software in a manner that directly infringes claim 1 (Compl. ¶¶ 20, 22). The complaint provides a URL to a Sony support page as an example of such instructions (Compl. ¶22).
Willful Infringement
- The complaint alleges that Defendant "has had knowledge of the ’733 Patent since at least the filing of this complaint" (Compl. ¶21). This allegation appears aimed at establishing a basis for post-filing willful infringement and enhanced damages, rather than asserting pre-suit knowledge of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural equivalence: does the data management system within Sony's PlayMemories software meet the claim limitation of a "data store" that is "coupled to" a separate "table," or does its potentially more integrated design fall outside the literal scope of the claim?
- A second key issue will be one of definitional scope: can the term "image history," as used in the patent, be construed broadly to cover standard image metadata, or does it require a more specific type of historical data that the accused software may not generate or use?
- Finally, the case may turn on a functional question of claim construction: does the user action of "click[ing]" on the accused product's timeline constitute an "instantiation of a curser positioned at different locations along an instantiation of the time line" as required by the specific language of claim 1?