Charles Smith Enterprises LLC v. Catapult Sports Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Charles Smith Enterprises, LLC (New Jersey)
  • Defendant: Catapult Sports, Inc. (Delaware)
  • Plaintiff’s Counsel: Devlin Law Firm LLC
• Case Identification: 1:21-cv-01278, D. Del., 02/15/2022
• Venue Allegations: Venue is alleged to be proper as Defendant is a Delaware corporation, incorporated in the judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s sports video analysis software infringes two patents related to the computer-assisted, customizable logging and indexing of time-based media.
• Technical Context: The technology addresses systems for tagging, searching, and retrieving specific events from video recordings, a key function in sports analytics, broadcasting, and archival management.
• Key Procedural History: This First Amended Complaint adds U.S. Patent No. 7,756,876 to the suit. It also reflects that the original defendant, XOS Technologies, Inc., changed its name to Catapult Sports, Inc. The complaint notes that Defendant has filed counterclaims asserting invalidity of the '010 patent, and Plaintiff's answer to those counterclaims states the '010 patent was reinstated by the USPTO in 2021 following a petition.

Case Timeline

Date	Event
1999-11-30	Priority Date for U.S. Patent Nos. 6,877,010 and 7,756,876
2005-04-05	U.S. Patent No. 6,877,010 Issued
2010-07-13	U.S. Patent No. 7,756,876 Issued
2020-10-27	Accused Product "Live-Capture" Documentation Accessed by Plaintiff
2021	U.S. Patent No. 6,877,010 Reinstated by USPTO
2021-07-22	Accused Product "Baseball" Documentation Accessed by Plaintiff
2021-09-08	Original Complaint Filed
2022-02-15	First Amended Complaint Filed

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

U.S. Patent No. 6,877,010 - "System and Method for Computer-assisted Manual and Automatic Logging of Time-based Media," issued April 5, 2005

The Invention Explained

• Problem Addressed: The patent describes prior art media logging methods as either manual, paper-based processes that were "time consuming and inefficient," or reliant on sophisticated video editing software that was expensive and required a skilled video engineer to operate (Compl. ¶¶14, 22; ’010 Patent, col. 1:63-2:3, col. 2:36-41).
• The Patented Solution: The invention is a computer-based system that simplifies media logging. It provides a user-friendly graphical user interface (GUI) with predefined, customizable on-screen objects (e.g., buttons) corresponding to specific events, such as a "2-point shot" in basketball. A user ("logger") clicks these objects to create a time-stamped index of events in a database, making later search and retrieval of the corresponding media segments efficient and straightforward (Compl. ¶¶15-16; ’010 Patent, col. 2:50-3:6).
• Technical Importance: The system aimed to make media indexing less expensive and more accessible to non-technical users, particularly for logging live events where speed and ease of use are critical (Compl. ¶15; ’010 Patent, col. 2:42-49).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 4-5 and 8-10 (Compl. ¶31).
• Independent Claim 1 requires:
  • A customizable media logging system for indexing media, comprising a timer object and a logger object.
  • The logger object includes a graphical user interface (GUI) with selectable user interface objects having labels corresponding to predetermined events.
  • The GUI is customizable to correspond to types of events that occur in the particular media being logged.
  • The system includes a "graphical user interface generator" that uses "information entered by a user" to generate a custom GUI for the logging application.
• The complaint reserves the right to amend its infringement contentions (Compl. ¶33).

U.S. Patent No. 7,756,876 - "System and Method for Computer-assisted Manual and Automatic Logging of Time-based Media," issued July 13, 2010

The Invention Explained

• Problem Addressed: As a continuation of the '010 patent, the '876 patent addresses the same problems of inefficient manual logging and the high cost and complexity of professional editing software (Compl. ¶12; ’876 Patent, col. 2:26-45).
• The Patented Solution: This invention builds on the earlier system by introducing "events administrator programmed logic circuitry." This component allows a user to not only use predefined events but also to define new "custom events" and "custom terminology" applicable to the media being logged. The system is explicitly designed to be customizable by the user based on the type of media being indexed, making it flexible and "database driven" (Compl. ¶19; ’876 Patent, Claim 1; ’876 Patent, col. 12:9-17).
• Technical Importance: The invention provided a more flexible and powerful framework for media logging, moving beyond predefined templates to allow applications to be customized "on the fly" without hard-coded modifications (Compl. ¶19; ’876 Patent, col. 12:9-17).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-6, 9-11, 13, and 14 (Compl. ¶39).
• Independent Claim 1 requires:
  • A computer-implemented media logging system, comprising an "events administrator programmed logic circuitry," a timer object, and a logger object.
  • The "events administrator programmed logic circuitry" is configured to define a "custom event" and "custom terminology" applicable to that event.
  • The logger object logs these user-defined events against time references.
  • The "events administrator programmed logic circuitry" is "customizable by a user based in part on the type of media being indexed."
• The complaint reserves the right to amend its infringement contentions (Compl. ¶41).

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are identified as the "XOS Digital software package," which includes products such as Thunder HD, ThunderCloud, Thunder Basketball, Thunder Hockey, Thunder Football, and Thunder Baseball (Compl. ¶¶31, 39).

Functionality and Market Context

The complaint alleges these are "customizable media logging systems for indexing media" (Compl. ¶¶31, 39). It further alleges that Defendant provides these products to numerous professional sports teams in the MLB, NFL, NBA, and NHL for their use in logging and analyzing game footage (Compl. ¶¶21, 32, 40). A screenshot from the patent, described in the complaint, shows a user interface for logging a basketball game by selecting buttons for players and events like a "2-point" shot (Compl. ¶16). Another screenshot description from the patent illustrates a "Game Wizard" for setting up a new logging session for a live or taped game (Compl. ¶19).

IV. Analysis of Infringement Allegations

The complaint references but does not include claim chart exhibits. The narrative infringement theories are summarized below.

’010 Patent Infringement Allegations

• Narrative Summary: The complaint alleges that the Accused Instrumentalities directly infringe at least claim 1 of the ’010 patent. The theory is that the Defendant's software systems constitute "customizable media logging systems" that provide a graphical interface with selectable objects for logging events (the "logger object"), associate these events with time references (the "timer object"), and include a feature for creating custom interfaces based on user input (the "graphical user interface generator") (Compl. ¶¶31, 34). The allegations are based on information and belief, supported by links to Defendant's product web pages (Compl. ¶31).
• Identified Points of Contention:
  • Scope Question: A central issue may be whether the customization features in Defendant's software meet the claim limitation of a "graphical user interface generator that generates a custom graphical user interface... us[ing] information entered by a user." The dispute will likely focus on whether the accused functionality rises to the level of a "generator" as described in the patent, or if it is merely a configurable system with pre-set options.
  • Technical Question: What is the specific mechanism by which the Accused Instrumentalities create customized logging interfaces? The complaint relies on general product descriptions, and the case may turn on evidence from discovery revealing whether the software's operation aligns with the functional requirements of the claimed "generator."

’876 Patent Infringement Allegations

• Narrative Summary: The complaint alleges the Accused Instrumentalities directly infringe at least claim 1 of the ’876 patent. The infringement theory posits that the software provides "events administrator programmed logic circuitry" that allows users at sports teams to "define a custom event" and "define custom terminology" relevant to their sport. The software is then allegedly used to log these custom-defined events against time references, with the customization being based on user input and the type of media (e.g., football vs. baseball) being logged (Compl. ¶¶39, 42).
• Identified Points of Contention:
  • Scope Question: The construction of the term "events administrator programmed logic circuitry" will be critical. Does this term, in the context of the patent, read on the functionality within the accused software for creating custom event tags or labels, or does it require a more specific, structured administrative module as depicted in the patent's "Game Wizard" and "Admin" figures?
  • Technical Question: What evidence does the complaint provide that the accused products contain the claimed "programmed logic circuitry"? The analysis will require a factual determination of how users of the Thunder software define, name, and manage event types, and whether that process is equivalent to the system claimed in the patent.

V. Key Claim Terms for Construction

Term from '010 Patent: "graphical user interface generator"

• Context and Importance: This term is the central feature of the asserted independent claim. The infringement case for the ’010 patent hinges on whether the accused software's customization capabilities can be characterized as a "generator." Practitioners may focus on this term because its scope will likely be a primary point of non-infringement argument.
• Intrinsic Evidence for a Broader Interpretation: The specification states that "a user interface generator is provided to facilitate the creation of customized, HTML- or XML-based user interfaces" ('010 Patent, col. 3:49-52). This language could support an interpretation covering any tool that helps create a custom UI.
• Intrinsic Evidence for a Narrower Interpretation: The specification also describes the feature as enabling interfaces to be "customized automatically... based on entered information by the user, thereby avoiding the need to hard code the interfaces," noting the system is "database driven" ('010 Patent, col. 12:9-17). This could support a narrower construction requiring a specific type of automated, database-driven generation process.

Term from '876 Patent: "events administrator programmed logic circuitry"

• Context and Importance: This term appears to be the main point of novelty in the asserted independent claim of the ’876 patent over the prior art, including the '010 patent. The definition of this term will likely determine whether the accused software, which presumably allows some form of custom tagging, infringes.
• Intrinsic Evidence for a Broader Interpretation: The term is not explicitly defined, which could support giving it a broad, plain, and ordinary meaning that covers any software module or set of functions for managing the definition of custom events.
• Intrinsic Evidence for a Narrower Interpretation: The shared specification illustrates this concept through specific "Game Wizard" and "Administration" interfaces (e.g., ’010 Patent, FIG. 19, FIG. 36). A defendant may argue these embodiments limit the term to a structured, wizard-based administrative toolset rather than a simple text-based tagging system.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant provides the Accused Instrumentalities to numerous professional sports teams "for their use, and caused them to used," which directly infringes the patents (Compl. ¶¶32, 40). These allegations form the basis for a potential claim of induced infringement, asserting Defendant provides the tools and causes its customers to perform the infringing logging methods.
• Willful Infringement: The complaint does not contain an explicit allegation of "willful infringement." However, it does request a declaration that the case is "exceptional under 35 U.S.C. § 285" and seeks an award of attorneys' fees, which can be awarded for willful infringement or other litigation misconduct (Compl., p. 18, ¶C). The complaint does not specify the factual basis for this request beyond the infringement itself.

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

• A core issue will be one of definitional scope: Will the claim terms "graphical user interface generator" ('010 patent) and "events administrator programmed logic circuitry" ('876 patent) be construed broadly enough to encompass the methods for creating custom layouts and event tags in modern sports-analytics software, or will they be narrowly construed and limited to the specific database-driven, wizard-style embodiments described in the patent specification?
• A second key question will be one of evidentiary proof: As the complaint relies on high-level product descriptions, the case will likely turn on the factual evidence produced during discovery. Specifically, can the Plaintiff demonstrate a technical match between the precise operational steps of the accused "Thunder" software and the functional requirements of the key claim limitations as construed by the court?
• Finally, the procedural posture, including Defendant's counterclaims of invalidity and the patent's pre-suit reinstatement by the USPTO, indicates that patent validity and enforceability will be a central battleground, running parallel to the court's infringement analysis.