Dynamic Data Tech LLC v. Intel Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dynamic Data Technologies, LLC (Delaware)
  • Defendant: Intel Corporation (Delaware)
  • Plaintiff’s Counsel: Bayard, P.A.; Berger & Hipskind LLP
• Case Identification: 1:18-cv-01977, D. Del., 12/13/2018
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant Intel Corporation is incorporated in Delaware, has transacted business in the state, and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that a wide range of Defendant’s processors, cameras, and related software infringes eleven patents concerning core technologies in video and image processing, including contrast control, motion estimation and compensation, and artifact reduction.
• Technical Context: The patents relate to fundamental techniques in digital video processing, a technology domain critical to modern computing, media streaming, and consumer electronics.
• Key Procedural History: The complaint states that the patents-in-suit originated from research and development by Koninklijke Philips N.V. The complaint also notes that many of the patents-in-suit have been cited as relevant prior art in patents issued to numerous technology companies, including Defendant Intel. For several of the asserted patents, the complaint alleges pre-suit knowledge of the patent by Intel based on these citations in Intel's own patent portfolio.

Case Timeline

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

U.S. Patent No. 7,050,114 - Picture Signal Contrast Control

Issued May 23, 2006

The Invention Explained

• Problem Addressed: The patent addresses the problem that amplifying a video signal's contrast to achieve a brighter picture can cause signal peaks to exceed the maximum level permitted by a display or D/A converter, leading to "clipping" and a loss of detail in bright areas (’114 Patent, col. 1:16-32).
• The Patented Solution: The invention proposes a multi-step method for controlling contrast to maximize light output while mitigating harsh clipping. The method involves first splitting the signal into components representing luminance and chrominance (e.g., YUV) and then, if any color component exceeds a predefined threshold, first reducing the saturation (the chrominance information, e.g., U and V signals) before reducing the overall contrast of all basic colors ('114 Patent, Abstract; col. 3:33-47). This sequential approach allows for a more nuanced adjustment than simply clipping the entire signal.
• Technical Importance: This technique provided a more sophisticated method for dynamic range management in video processing, aiming to enhance perceived brightness without the severe visual artifacts associated with simple signal clipping (Compl. ¶20, ¶29).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶132).
• Claim 1 requires a method with the essential elements of:
  • increasing contrast by increasing the amplitudes of all basic colors in a selected sub signal;
  • determining if an amplitude of one of the basic colors exceeds a predefined value; and
  • reducing saturation of the color information if an amplitude of one of the basic colors exceeds the predefined value.

U.S. Patent No. 8,385,426 - Method For A Mosaic Program Guide

Issued February 26, 2013

The Invention Explained

• Problem Addressed: The patent's background describes the significant computational resources required for a receiver (such as a set-top box) to generate a "mosaic" program guide, which traditionally involved decoding multiple video streams simultaneously (’426 Patent, col. 1:18-47). The complaint characterizes the invention as a way to "save significant resources by streamlining" this process (Compl. ¶34).
• The Patented Solution: The patented method enables a receiver to efficiently generate a mosaic guide by using only the intra-coded frames (I-frames) from multiple compressed video streams. Because I-frames are self-contained and can be decoded without reference to other frames, the receiver's video decoder can selectively extract and decode only these key frames, place them into mosaic windows, and combine them into a single mosaic video frame for display, thereby avoiding the need to fully decode every stream ('426 Patent, Abstract; col. 2:50-59).
• Technical Importance: This invention offered a resource-efficient method for client-side generation of video program guides, reducing the processing load on the receiver and conserving network bandwidth compared to receiving a pre-composed mosaic stream from a headend (Compl. ¶34).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶151).
• Claim 1 requires a method with the essential elements of:
  • generating I frames from a coded video bit stream by a video decoder of a receiver;
  • placing each I frame into one of a multiplicity of mosaic windows by the receiver; and
  • combining in the receiver the multiplicity of mosaic windows into a mosaic video frame.

U.S. Patent No. 6,760,376 - Motion Compensated Upconversion For Video Scan Rate Conversion

Issued July 6, 2004

• Technology Synopsis: This patent addresses improving image quality in video scan rate conversion (e.g., converting 50 Hz video to 100 Hz). The invention proposes a method for generating interpolated video fields by calculating correlation values between pixels in a new field and pixels in previous and next fields, comparing these values to a threshold, and selecting the best-matching pixel to create a sharper interpolated image (Compl. ¶40-42, ¶44-46).
• Asserted Claims: At least claim 4 (Compl. ¶172).
• Accused Features: Intel processors containing Intel Quick Sync Video (versions 5 and later) and various graphics processing units are accused of performing the patented method (Compl. ¶160).

U.S. Patent No. 6,782,054 - Method And Apparatus For Motion Vector Estimation

Issued August 24, 2004

• Technology Synopsis: The patent describes a method to enhance motion estimation in video processing by improving the speed of convergence of motion vectors. The method involves selecting a best motion vector from a plurality of candidates by applying an error function that includes penalty terms dependent on both the type of the candidate vector and its position and size (Compl. ¶49-52).
• Asserted Claims: At least claim 13 (Compl. ¶189).
• Accused Features: Intel processors containing Intel Quick Sync Video (versions 5 and later) and various graphics processing units are accused of using the patented error function (Compl. ¶180).

U.S. Patent No. 7,929,609 - Motion Estimation And/Or Compensation

Issued April 19, 2011

• Technology Synopsis: This patent discloses a method for estimating or compensating for motion in video by using a video processor to define an "asymmetric search area" around an image segment. The asymmetry is defined by an offset from the center of the image segment, which is statistically determined from an average of previous motion vectors, thereby improving video signal processing (Compl. ¶55-60).
• Asserted Claims: At least claim 1 (Compl. ¶209).
• Accused Features: Intel processors containing Intel Quick Sync Video (versions 5 and later) and various graphics processing units are accused of using an asymmetric search area for motion estimation (Compl. ¶198).

U.S. Patent No. 7,982,799 - Method And Device For Interpolation Of An Image Information Value For Pixel Of An Interline

Issued July 19, 2011

• Technology Synopsis: The patent addresses a method for interpolating image data for pixels situated between original image lines, for example, in de-interlacing. The invention aims to reduce ambiguities in determining the optimal direction of an edge by ascertaining a "direction quality value" for an image direction based on aggregating single direction values from a group of adjacent pixels (Compl. ¶63-65, ¶67).
• Asserted Claims: At least claim 1 (Compl. ¶236).
• Accused Features: Intel processors containing Intel Quick Sync Video (versions 5 and later) and various graphics processing units are accused of performing the patented interpolation method (Compl. ¶224).

U.S. Patent No. 7,995,793 - Occlusion Detector For And Method Of Detecting Occlusion Areas

Issued August 9, 2011

• Technology Synopsis: The patent describes a system for detecting occlusion areas (where objects cover or uncover background) in an image based on a set of motion vectors. An occlusion is detected by selecting two motion vectors with a substantial difference, comparing pixel value differences along those vectors, and deciding a pixel belongs to an occlusion area if both differences exceed predetermined thresholds, enabling better halo reduction in up-conversion (Compl. ¶72-73, ¶75-77).
• Asserted Claims: At least claim 1 (Compl. ¶257).
• Accused Features: Intel RealSense Depth Cameras (D435i, D435, D415) are accused of containing functionality for detecting occlusion areas based on motion vectors (Compl. ¶246).

U.S. Patent No. 8,155,459 - Video Processing Device With Low Memory Bandwidth Requirements

Issued April 10, 2012

• Technology Synopsis: This patent aims to reduce memory bandwidth and cost in video processing devices that use predictive block-based encoding. The invention discloses a device that uses a cache memory to temporarily store a "prediction area" read from external memory, divides that data into zones, and retrieves only the subset of zones needed for decoding, reducing bandwidth by not retrieving zones that do not contain the required pixels (Compl. ¶80-82, ¶86, ¶88-90).
• Asserted Claims: At least claim 1 (Compl. ¶283).
• Accused Features: Intel processors containing Intel Quick Sync Video (versions 5 and later) and various graphics processing units are accused of being a video processing device with the claimed features (Compl. ¶267).

U.S. Patent No. 8,335,392 - Method For Reducing Image Artifacts

Issued December 18, 2012

• Technology Synopsis: The patent describes a method to reduce image artifacts from block-based video compression. The method involves generating filter coefficients for pixels, detecting artifact regions, modifying the filter coefficients for pixels within those regions, and then synthesizing the final video information values using the modified coefficients (Compl. ¶93-97).
• Asserted Claims: At least claim 1 (Compl. ¶302).
• Accused Features: Intel field-programmable gate array (FPGA) Video Image Processing (VIP) Suite IP cores in various device families (e.g., Intel Arria 10, Cyclone 10) are accused of implementing the patented artifact reduction method (Compl. ¶292).

U.S. Patent No. 8,442,118 - Calculating Transformation Parameters For Image Processing

Issued May 14, 2013

• Technology Synopsis: This patent discloses a method to reduce the processing capacity needed to obtain transformation parameters (e.g., for camera motion) from a vector field. The method involves obtaining a vector field from a video image, projecting the vector field onto at least one axis, and deriving the transformation parameters from that projection, which are then used to compress the video image (Compl. ¶100-106).
• Asserted Claims: At least claim 1 (Compl. ¶324).
• Accused Features: Intel processors containing Intel Quick Sync Video (versions 5 and later) and various graphics processing units are accused of performing this method (Compl. ¶311).

U.S. Patent No. 8,526,502 - Method And Apparatus For Line Based Vertical Motion Estimation And Compensation

Issued September 3, 2013

• Technology Synopsis: The patent discloses a computer program product for line-based vertical motion estimation between consecutive video frames. The method involves summing luminance values for each horizontal line in previous and current frames to create "accumulation profiles." A vertical motion vector is then derived by matching a subprofile of the current accumulation profile with the previous accumulation profile (Compl. ¶111-114).
• Asserted Claims: At least claim 8 (Compl. ¶343).
• Accused Features: Intel processors containing Intel Quick Sync Video (versions 5 and later) and various graphics processing units are accused of providing this functionality (Compl. ¶333).

III. The Accused Instrumentality

Product Identification

The complaint accuses a wide range of Intel products across eleven distinct infringement counts. These include:

• Specific processor models (e.g., Pentium Silver J5005, Celeron N4000 series) that allegedly implement "Localized Adaptive Contrast Control" ('114 Patent) (Compl. ¶118).
• Intel software, specifically Intel Multi-Media Samples ("MMS") Version 1.3, for generating mosaic program guides ('426 Patent) (Compl. ¶141).
• A vast catalogue of Intel processors that contain "Intel Quick Sync Video versions 5 and later" and various integrated graphics processing units (e.g., UHD Graphics 600, Iris Plus Graphics 640) (’376, '2054, ’609, ’799, ’459, ’118, ’502 Patents) (Compl. ¶160, ¶180, ¶198, ¶224, ¶267, ¶311, ¶333).
• Intel RealSense Depth Cameras, including the D435i, D435, and D415 models (’793 Patent) (Compl. ¶246).
• Intel field-programmable gate array (FPGA) products containing Video Image Processing (VIP) Suite IP cores (’392 Patent) (Compl. ¶292).

Functionality and Market Context

The accused instrumentalities are central components of modern computing devices. The complaint alleges that these products incorporate patented technologies to perform fundamental video and image processing tasks, including real-time contrast enhancement, motion estimation for video compression and format conversion, efficient program guide generation, interpolation for de-interlacing, and the reduction of visual artifacts (Compl. ¶7, ¶117, ¶140, ¶159). These functionalities are alleged to be critical for video streaming and other media applications on devices using Intel hardware (Compl. ¶7). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

'7,050,114 Infringement Allegations

Identified Points of Contention

• Technical Questions: A central question will be whether Intel's "Localized Adaptive Contrast Control" technology performs the specific, sequential method required by claim 1. The claim implies a process where saturation is reduced in response to an amplitude exceeding a limit. The complaint does not detail the specific algorithm used by Intel's products, raising the evidentiary question of whether there is a direct operational match or if Intel's technology achieves a similar outcome through a different, non-infringing process.

'8,385,426 Infringement Allegations

Identified Points of Contention

• Scope Questions: The infringement allegation targets "Intel Multi-Media Samples," which may be software development tools or sample code rather than a final end-user product. This raises the question of whether use of this software constitutes performance of the claimed method "by a video decoder of a receiver." The definition of "receiver" could become a point of contention, specifically whether it reads on a general-purpose computer executing the accused software.
• Technical Questions: The complaint alleges the accused products "perform a method," suggesting direct infringement. The evidence will need to show that the accused software, when operated as intended, executes all steps of the claimed method.

V. Key Claim Terms for Construction

For the ’114 Patent

• The Term: "reducing saturation of said color information"
• Context and Importance: This term is central to the invention's purported novelty. The infringement analysis will likely depend on whether this term is construed to require a specific sequence of operations—namely, altering only the chrominance components of a video signal as a first step—or if it can broadly cover any algorithm that results in less colorful pixels when contrast is being limited. Practitioners may focus on this term because the patent's specification provides a specific implementation (operating on U and V signals before Y), which could be used to argue for a narrower construction than the plain words might suggest.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is functional, describing the result ("reducing saturation") rather than specifying the mechanism.
  • Evidence for a Narrower Interpretation: The detailed description explains the process by separating the signal into luminance (Y) and chrominance (UV) and operating first on the UV part, stating this "separates the contributions" and makes it "possible to control the saturation separately" ('114 Patent, col. 3:60-65; col. 4:19-25). An accused infringer may argue this embodiment limits the claim scope to that specific sequence.

For the ’426 Patent

• The Term: "receiver"
• Context and Importance: The claims consistently locate the infringing activity "in the receiver" or "by a video decoder of a receiver." The accused instrumentality is "Intel Multi-Media Samples," which is likely software run on a computer. The dispute may turn on whether a general-purpose computer running software constitutes a "receiver" in the context of the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term is not explicitly defined in the patent, potentially allowing it its plain and ordinary meaning, which could encompass any device capable of receiving and processing a coded video bit stream.
  • Evidence for a Narrower Interpretation: The patent's context is digital television and program guides, which at the time of invention were primarily associated with dedicated hardware like set-top boxes. An accused infringer may argue that the context implies a more limited definition than a general-purpose PC. The patent's figures depict components like a "tuner and demodulator" which are typical of traditional receivers ('426 Patent, Fig. 4).

VI. Other Allegations

Indirect Infringement

For each of the eleven patents-in-suit, the complaint alleges induced infringement under 35 U.S.C. § 271(b). The allegations follow a consistent pattern, asserting that Intel provides products with the capability to operate in an infringing manner and encourages this infringement by providing "documentation and training materials that cause customers and end users" to utilize the products in a way that directly infringes the claims (e.g., Compl. ¶135, ¶154, ¶175, ¶193).

Willful Infringement

The complaint alleges willful infringement for all asserted patents. The basis for willfulness is primarily post-suit knowledge, alleging that "Intel has had knowledge of the [asserted] patent since at least service of this Complaint or shortly thereafter" (e.g., Compl. ¶134, ¶153, ¶174). For several patents ('2054, '609, '799, and '793), the complaint makes an alternative allegation of pre-suit knowledge, based on the fact that patents owned by Intel cite the patent-in-suit as relevant prior art (Compl. ¶192, ¶212-217, ¶239, ¶260).

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

• A primary issue will be one of technical proof and specificity: The complaint asserts eleven distinct patents against a vast and varied portfolio of Intel's hardware and software products, often with generalized infringement allegations. A key challenge for the plaintiff will be to produce evidence demonstrating that the specific algorithms implemented in products like "Intel Quick Sync Video" or "Localized Adaptive Contrast Control" perform the precise, multi-step methods recited in the claims, rather than achieving similar outcomes through technically distinct and non-infringing means.
• A second core issue will concern willfulness and pre-suit knowledge: For the patents where pre-suit knowledge is alleged based on citations within Intel’s own patent portfolio, a central legal question will be whether these citations, on their own, are sufficient to establish that Intel possessed the specific intent required to induce infringement or was willfully blind, a notably high evidentiary standard.
• A third question will be one of claim scope and the accused environment: For claims directed at methods performed in a "receiver" or "video processing device," the case may turn on whether these terms, in the context of the patents, can be construed to cover general-purpose computers executing the accused Intel software (e.g., "Multi-Media Samples") or if their scope is limited to more specialized hardware like set-top boxes, as suggested by the patents' context and figures.