DCT
1:24-cv-00170
Sportradar US LLC v. SportsCastr
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sportradar US LLC, Sportradar Solutions LLC, and Sportradar AG (Delaware & Switzerland)
- Defendant: Sportscastr, Inc. d/b/a PANDA Interactive (Delaware)
- Plaintiff’s Counsel: Young Conaway Stargatt & Taylor, LLP (Lead); Bryan Cave Leighton Paisner LLP (Of Counsel)
- Case Identification: 1:24-cv-00170, D. Del., 02/08/2024
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant PANDA Interactive is a Delaware corporation and therefore "resides" in the district.
- Core Dispute: Plaintiffs seek a declaratory judgment that their sports data and streaming products do not infringe three of Defendant’s patents, which relate to systems for delivering live-streamed digital content synchronized with separate streams of event-related data.
- Technical Context: The technology for synchronizing live video with real-time data, such as scores or gaming information, is a critical component of the modern sports media, entertainment, and online betting industries.
- Key Procedural History: This declaratory judgment action follows a prior lawsuit filed by PANDA Interactive against Sportradar Group AG (a non-party holding company) in the U.S. District Court for the Eastern District of Texas on October 5, 2023. The complaint notes that Sportradar Group AG intends to challenge personal jurisdiction in the Texas action, positioning this Delaware filing as a proactive measure to litigate the dispute in a different forum.
Case Timeline
| Date | Event |
|---|---|
| 2016-08-05 | Earliest Priority Date for ’687, ’218, and ’697 Patents |
| 2019-09-24 | U.S. Patent No. 10,425,697 Issued |
| 2020-10-13 | U.S. Patent No. 10,805,687 Issued |
| 2021-06-15 | U.S. Patent No. 11,039,218 Issued |
| 2023-10-05 | PANDA files complaint against Sportradar Group AG in E.D. Tex. |
| 2024-02-08 | Sportradar files Complaint for Declaratory Judgment in D. Del. |
II. Technology and Patent(s)-in-Suit Analysis
No probative visual evidence provided in complaint.
U.S. Patent No. 10,805,687 - "Systems, Apparatus, And Methods For Rendering Digital Content Relating To A Sporting Event With Online Gaming Information" (Issued Oct. 13, 2020)
The Invention Explained
- Problem Addressed: The patent specification describes the technical problem of viewer "latency"—the delay between a live event occurring and a viewer seeing it streamed online—and the associated difficulty of synchronizing event information (like scores or statistics) with the video stream (’697 Patent, col. 2:21-48). This is particularly problematic for "second screen" experiences where a viewer may watch an event on television while consuming related data on a mobile device.
- The Patented Solution: The invention proposes a system architecture that separates the delivery of video content from the delivery of event information. A "control server" retrieves event data from an external provider, and a "socket server" transmits this data to viewer devices over dedicated Internet channels, separate from the video channels used by "media sources" to deliver the live stream. This architecture is designed to handle multiple live streams for multiple sporting events simultaneously (’687 Patent, Abstract; col. 9:45-66).
- Technical Importance: This architectural separation of data and video streams aims to ensure that event information can be updated in near real-time and synchronized across all viewers, a critical requirement for interactive applications such as in-game sports betting.
Key Claims at a Glance
- The complaint identifies Claim 19 as an asserted independent claim (Compl. ¶9, ¶22).
- Claim 19 requires a system comprising three core components:
- A) a plurality of media sources to receive and provide copies of multiple live streams for multiple sporting events.
- B) a control server to periodically retrieve first and second event information germane to first and second live sporting events.
- C) at least one socket server, coupled to the control server, to receive the event information and transmit it to viewer devices via dedicated Internet communication channels using event-specific sockets.
- The complaint notes that dependent Claim 20 is also asserted (Compl. ¶9, ¶23).
U.S. Patent No. 11,039,218 - "Systems, Apparatus And Methods For Rendering Digital Content Relating To A Sporting Event With Online Gaming Information" (Issued Jun. 15, 2021)
The Invention Explained
- Problem Addressed: Like its related patents, the ’218 Patent addresses the technical challenge of latency in live streaming and the need to synchronize event data, specifically including "online gaming information," with the corresponding video content (’218 Patent, col. 2:21-48).
- The Patented Solution: This patent claims a system that adds a "webserver" component to the architecture. The webserver is responsible for transmitting network addresses to the viewer's client device: one address for the media source (to establish a video channel) and another for the socket server (to establish an event information channel). This allows the client device to initiate and maintain the separate connections required to receive synchronized video and data, including online gaming information (’218 Patent, Abstract; col. 8:20-32).
- Technical Importance: The introduction of a coordinating webserver provides a structured method for establishing the parallel data and video communication channels, which could be a key element for building a scalable and reliable platform for sports data and gaming applications.
Key Claims at a Glance
- The complaint identifies Claim 1 as an asserted independent claim (Compl. ¶9, ¶29).
- Claim 1 requires a system comprising:
- A) a control server to periodically retrieve event information.
- B) at least one socket server, coupled to the control server, to receive and transmit the event information (including online gaming information) to a viewer device via a dedicated channel.
- C) at least one webserver, coupled to the socket server, to transmit to the viewer device a first Internet address for a media source and a first socket address for the event socket.
- The complaint notes that dependent Claim 4 is also asserted (Compl. ¶9, ¶30).
U.S. Patent No. 10,425,697 - "Systems, Apparatus, And Methods For Scalable Low-Latency Viewing Of Broadcast Digital Content Streams Of Live Events, And Synchronization Of Event Information With Viewed Streams, Via Multiple Internet Channels" (Issued Sep. 24, 2019)
- Technology Synopsis: This patent addresses low-latency streaming and data synchronization through a system architecture comprising a plurality of media sources, a control server that retrieves event information from a provider, and a socket server that transmits specific data, such as "score information," to viewer devices over separate communication channels. The claims also recite that the live stream includes "video-based commentary" from a broadcaster (’697 Patent, Abstract; col. 10:15-44).
- Asserted Claims: Claims 19 (independent) and 20 are asserted (Compl. ¶9, ¶36, ¶37).
- Accused Features: The complaint denies infringement by alleging that the accused products are not used to provide "video-based commentary" and do not employ the claimed "plurality of media sources," "control server," or "socket server" architecture as recited in the claims (Compl. ¶38).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Sportradar's branded products emBET, OTT, and Live Channel Trading ("LCT") (Compl. ¶1).
Functionality and Market Context
- The complaint describes Plaintiffs' business as the "provision of sports data, content, engagement tools, live streaming, and gaming products" (Compl. ¶8). The complaint does not provide sufficient detail for a technical analysis of how the accused products operate. It focuses instead on asserting that the products do not incorporate the specific architectural components required by the asserted patents (Compl. ¶24, ¶31, ¶38). The products are positioned in the global sports information, data, and technology market (Compl. ¶8).
IV. Analysis of Infringement Allegations
’687 Patent Infringement Allegations
| Claim Element (from Independent Claim 19) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A) a plurality of media sources to: receive the first live stream... and provide a first copy... | The accused products do not employ, incorporate, or otherwise make use of "a plurality of media sources." | ¶24 | col. 9:26-31 |
| B) a control server to periodically retrieve... first event information... | The accused products do not employ, incorporate, or otherwise make use of "a control server." | ¶24 | col. 9:45-51 |
| C) at least one socket server communicatively coupled to the control server to: receive from the control server... and transmit... | The accused products do not employ, incorporate, or otherwise make use of a "socket server communicatively coupled to the control server." | ¶24 | col. 9:52-66 |
’218 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A) a control server to periodically retrieve... the first event information... | The accused products do not employ, incorporate, or otherwise make use of "a control server." | ¶31 | col. 8:1-3 |
| B) at least one socket server communicatively coupled to the control server to: receive... and transmit... | The accused products do not employ, incorporate, or otherwise make use of a "socket server communicatively coupled to the control server." | ¶31 | col. 8:4-6 |
| C) at least one webserver communicatively coupled to the at least one socket server to transmit... | The accused products do not employ, incorporate, or otherwise make use of a "webserver communicatively coupled to the at least one socket server." | ¶31 | col. 8:20-22 |
- Identified Points of Contention:
- Scope Questions: The dispute appears to center on architectural mapping. A primary question will be whether the components of Sportradar's system architecture, which delivers sports data and streaming content, meet the specific claim definitions of a "control server," a "socket server," and a "webserver." The case may depend on whether Sportradar's potentially integrated system can be shown to contain distinct or logically separable components that map onto the patent's delineated server architecture. A further question for the ’697 Patent is whether Sportradar’s content constitutes "video-based commentary" as required by the claims (Compl. ¶38).
- Technical Questions: The complaint's denials raise a key technical question: what is the specific mechanism by which the accused products retrieve and transmit event data to end-users? The court will need to determine if this mechanism is functionally equivalent to the claimed architecture of retrieving data via a control server and transmitting it via a dedicated socket server channel, separate from the primary video stream.
V. Key Claim Terms for Construction
The Term: "control server"
Context and Importance: This term appears in the independent claims of all three asserted patents and forms a cornerstone of the claimed invention. Sportradar’s declaratory judgment action is premised on its assertion that its products do not use such a server (Compl. ¶24, ¶31, ¶38). The construction of this term will be critical in determining whether any component of Sportradar's infrastructure performs the function required by the claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims provide a functional definition, requiring the server to "periodically retrieve, via the Internet... event information" (’687 Patent, Claim 19). Parties favoring a broader scope may argue this language reads on any server component that fetches external data for use with a live stream.
- Evidence for a Narrower Interpretation: The patent figures depict the "Control Server" 500 as a distinct architectural block that retrieves information from an external "Event Info Provider" 55 and provides it to the "Socket Server(s)" 600 (’697 Patent, Fig. 2). Parties favoring a narrower scope may argue this specific structural relationship and separation of functions is required.
The Term: "socket server"
Context and Importance: This term is another central architectural element that Sportradar explicitly denies employing in its products (Compl. ¶24, ¶31, ¶38). Its claimed function is to transmit event information over a separate channel from the video stream, and its construction will be vital to the infringement analysis.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims define the socket server functionally as being "communicatively coupled to the control server to: receive... event information... and transmit" it to viewer devices via a dedicated channel (’687 Patent, Claim 19). This could be interpreted to cover any server that pushes pre-processed event data to clients.
- Evidence for a Narrower Interpretation: The specification suggests that connections to the socket server are "persistent authenticated connections" (’697 Patent, col. 20:49-50). Parties may argue that this implies a requirement for a specific type of long-lived connection, potentially distinguishing it from systems that deliver data via other mechanisms like repeated HTTP polling.
VI. Other Allegations
- Indirect Infringement: The complaint requests a declaration that Plaintiffs do not "directly or indirectly infringe" any of the asserted patent claims (Compl. ¶26, ¶33, ¶40; Prayer for Relief ¶A). As a complaint for non-infringement, it does not allege facts related to knowledge or intent but seeks to preemptively resolve any such claims.
- Willful Infringement: Willfulness is not alleged by Plaintiffs. The complaint establishes that an "actual controversy" exists based on PANDA's filing of the Texas lawsuit, which created a "real and immediate threat" of an infringement suit against Plaintiffs (Compl. ¶14). Any potential willfulness claim would arise from that controversy, but no specific facts supporting or refuting willfulness are pleaded in this complaint.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of architectural equivalence: Does Sportradar's system, however integrated, contain distinct or logically separable components that perform the specific functions of the claimed "control server," "socket server," and "webserver," or is its architecture fundamentally different from the multi-server, multi-channel system described in the patents?
- A key evidentiary question will be one of functional operation: By what technical mechanism do the accused products deliver event data to clients? Does this mechanism meet the claim requirements of transmission "via a... channel between at least one... socket... and the... viewer client device," or does it utilize a different, non-infringing data transport method?
- Finally, the case's development will be influenced by a procedural question: The outcome of the jurisdictional dispute between this declaratory judgment action in Delaware and PANDA's prior-filed infringement suit in the Eastern District of Texas will determine the forum and could significantly shape the strategic course of the litigation.