DigiMedia Tech LLC v. eHarmony Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigiMedia Tech, LLC (Georgia)
  • Defendant: eHarmony Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
• Case Identification: 1:25-cv-00314, D. Del., 03/12/2025
• Venue Allegations: Venue is alleged to be proper in the District of Delaware on the grounds that Defendant is a Delaware corporation and therefore resides in the state.
• Core Dispute: Plaintiff alleges that Defendant’s online dating service, which includes photo management features, infringes four patents related to methods for reducing bandwidth and storage requirements during the transmission of digital images between a device and a server.
• Technical Context: The technology addresses the challenge of efficiently handling large digital image files in network environments, a problem that grew in significance with the rise of internet-connected cameras and online photo sharing platforms.
• Key Procedural History: The complaint notes that during the prosecution of the '088 patent, the applicant distinguished prior art by arguing the invention's novelty lay in transmitting only an image identifier and a requested action for subsequent operations on an already-uploaded image. The complaint also highlights that the '778 patent issued after the Supreme Court's decision in Alice Corp. v. CLS Bank, suggesting the patent overcame patent-eligibility scrutiny under that framework.

Case Timeline

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

U.S. Patent No. 7,287,088 - "Transmission Bandwidth and Memory Requirements Reduction in a Portable Image Capture Device by Eliminating Duplicate Image Transmissions," issued October 23, 2007

• The Invention Explained:
  • Problem Addressed: The patent identifies the technical problem of excessive network bandwidth consumption and on-device storage use caused by transmitting large digital image files over the internet, particularly when the same image is sent to multiple destinations or for multiple purposes (Compl. ¶25; ’088 Patent, col. 1:65-2:8). Conventional solutions like heavy image compression were deemed insufficient as they degrade image quality (Compl. ¶26; ’088 Patent, col. 2:9-18).
  • The Patented Solution: The invention proposes a client-server system where a portable device uploads a full-resolution image to a server only once. The server stores the image and assigns it a unique "image identifier." For any subsequent operations involving that image (e.g., sending, printing, sharing), the device transmits only the small image identifier and the requested action to the server, which then acts on the full image it already has stored. This eliminates redundant transmission of the large image file, thereby saving bandwidth (Compl. ¶28, ¶35; ’088 Patent, col. 3:21-30, col. 5:31-50). The device can also then replace its local high-resolution copy with a smaller version to free up storage space (’088 Patent, col. 5:6-14).
  • Technical Importance: This method provided a technical solution for managing increasingly large image files from newly emerging "web-enabled" devices, like digital cameras with direct internet connectivity, without overwhelming the limited bandwidth and storage of that era (Compl. ¶24; ’088 Patent, col. 1:29-38).
• Key Claims at a Glance:
  • The complaint asserts independent claims 14 and 22 (Compl. ¶55).
  • Independent Claim 14 recites a method comprising:
    • Uploading captured images to a server for the first time, where the server assigns each image an identifier.
    • Receiving the image identifiers and "action information" from the server.
    • Presenting an "action control" based on the action information.
    • In response to a user selection, transmitting the action and the corresponding image identifier, rather than the image itself, to the server.
  • Independent Claim 22 recites a method comprising:
    • Receiving images uploaded from an image capture device to a server.
    • The server assigning an image identifier to the images.
    • Downloading the identifiers and "action information" to the device.
    • Receiving a request from the device to apply an action, where the request includes only the identifier and the action, thereby eliminating the need to retransmit the image.

U.S. Patent No. 7,587,514 - "Transmission Bandwidth and Memory Requirements Reduction in a Portable Image Capture Device by Eliminating Duplicate Image Transmissions," issued September 8, 2009

• The Invention Explained:

  • Problem Addressed: As a continuation of the '088 patent, the '514 patent addresses the same technical challenge of reducing bandwidth and storage burdens associated with transmitting digital images from a portable device to a network server (’514 Patent, col. 2:25-29).
  • The Patented Solution: The patented solution is functionally identical to that of the '088 patent. It describes a method where captured images are uploaded to a hardware server, which assigns identifiers and provides them back to the device. The device can then request actions on the stored images by sending only the identifier and the requested action, thus "eliminating the need to retransmit the image and reducing transmission bandwidth" (’514 Patent, Claim 1). This process is illustrated in flowcharts showing the exchange between the device and server (see, e.g., ’514 Patent, Fig. 4, Fig. 7A).
  • Technical Importance: The invention provided a refined framework for a client-server interaction model specifically aimed at efficient management of user-generated images.

• Key Claims at a Glance:

  • The complaint asserts independent claim 1 (Compl. ¶62).
  • Independent Claim 1 recites a method comprising:
    • Receiving captured images uploaded from a portable image capture device to a hardware server.
    • The hardware server assigning an image identifier to the uploaded images.
    • Downloading the image identifiers to the device for association with the images.
    • Downloading "action information" to the device including actions the server can perform.
    • Receiving a request from the device to apply an action, where the request includes the identifier and action "rather than the image itself."

• Multi-Patent Capsule: U.S. Patent No. 8,073,965

  • Patent Identification: U.S. Patent No. 8,073,965, "Transmission Bandwidth and Memory Requirements Reduction in a Portable Image Capture Device by Eliminating Duplicate Image Transmissions," issued December 6, 2011.
  • Technology Synopsis: This patent, part of the same family, also discloses a method to reduce network bandwidth use in image sharing. It describes a photo-sharing service that receives an image from a device, provides an identifier for that image back to the device, and then receives subsequent requests that reference the image via its identifier instead of requiring the image to be re-sent (’965 Patent, Abstract).
  • Asserted Claims: Independent claims 1 and 13 (Compl. ¶69).
  • Accused Features: The complaint alleges infringement by Defendant's "systems and processes for managing photos of Defendant's customers" (Compl. ¶69).

• Multi-Patent Capsule: U.S. Patent No. 8,868,778

  • Patent Identification: U.S. Patent No. 8,868,778, "Transmission Bandwidth and Memory Requirements Reduction in a Portable Image Capture Device by Eliminating Duplicate Image Transmissions," issued October 21, 2014.
  • Technology Synopsis: Continuing the same technical theme, this patent describes an online service that interacts with an image capture device. The service provides action information, receives an uploaded image, stores it in an image set, and provides back a unique image identifier, which is then used for future action requests on that image (’778 Patent, Abstract).
  • Asserted Claims: Independent claim 1 (Compl. ¶76).
  • Accused Features: The complaint alleges infringement by Defendant's "systems and processes for managing photos of Defendant's customers" (Compl. ¶76).

III. The Accused Instrumentality

• Product Identification: The accused instrumentalities are Defendant eHarmony's "systems and processes for managing photos of Defendant's customers," which are integral to its online dating service (Compl. ¶¶55, 62, 69, 76).
• Functionality and Market Context: The complaint alleges that the accused functionality involves "uploading and managing images" in a manner that reduces bandwidth requirements (Compl. ¶¶56, 63). However, the complaint does not provide specific technical details about how Defendant's systems operate. Instead, it incorporates by reference a series of exhibits (E, F, G, and H), described as preliminary claim charts, which were not filed with the complaint (Compl. ¶¶55, 62, 69, 76). The complaint therefore does not contain sufficient detail for a public-facing analysis of the accused system's specific functionality. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of all four patents-in-suit but asserts that the details of this infringement are contained in preliminary claim chart exhibits that were not publicly filed (Compl. ¶¶ 55, 62, 69, 76). The complaint’s narrative theory is that Defendant’s photo management systems, used by its customers, practice the patented methods for reducing bandwidth by using image identifiers for subsequent actions on uploaded photos (Compl. ¶56). Without the exhibits, a detailed element-by-element analysis is not possible based on the complaint alone.

• Identified Points of Contention:
  • Factual Question: A primary point of contention will be factual: does the eHarmony platform actually operate as claimed? The core question is whether discovery will show that after a user uploads an image, subsequent actions (e.g., making it a profile picture, sending it in a message) are handled by transmitting only an identifier and an action command from the user's device to eHarmony's servers, rather than by re-uploading or re-processing the full image data.
  • Scope Question: A potential dispute may arise over the scope of the term "portable image capture device." The patents' specifications focus heavily on the architecture of a digital camera or similar device (’088 Patent, Fig. 2; col. 4:15-22). The infringement analysis raises the question of whether a user's general-purpose computer or smartphone, when interacting with the eHarmony website or app, meets this claim limitation as it is described and enabled in the patent.

V. Key Claim Terms for Construction

• The Term: "portable image capture device" (’088 Patent, Claim 14 preamble)

• Context and Importance: This term appears in the asserted claims of all four patents and is central to defining the scope of the invention. The patents were filed when dedicated "web-enabled" digital cameras were an emerging technology. Practitioners may focus on whether this term is limited to such devices or broadly covers modern smartphones and computers running a web browser or app that interacts with the accused eHarmony service.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that "any portable device capable of capturing images could be used, such as a cellphone or PDA equipped with a lens attachment, for instance" (’088 Patent, col. 3:38-41). This language may support an interpretation that includes modern smartphones.
  • Evidence for a Narrower Interpretation: The detailed description and figures, such as the architectural diagram in Figure 2 of the patents, describe a device where the "communication manager," "protocol stack," and "operating system" are integral components controlling the hardware (’088 Patent, Fig. 2; col. 4:26-62). This could support an argument that the claim requires a device with this specific integrated architecture, rather than a general-purpose device merely accessing a remote service.

• The Term: "action information" (’088 Patent, Claim 14)

• Context and Importance: The claims require the server to provide, and the device to download, "action information" that corresponds to actions the server can perform. The construction of this term is important for determining whether the interaction on the accused service meets this limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: This term could be construed broadly to mean any data from the server (e.g., HTML, Javascript) that enables a user to select an action on the client side.
  • Evidence for a Narrower Interpretation: The specification provides a specific example of an "action list 48" that is "down-loaded to the user's camera 14" and includes items like "Print Images," "Save in MyShoeBox," and "Send to Mom" (’088 Patent, Fig. 6; col. 4:3-6). This may support a narrower construction requiring a distinct, downloadable list of server-side functions, as opposed to standard interactive elements of a web page.

VI. Other Allegations

• Indirect Infringement: The complaint appears to plead a theory of divided infringement, asserting that to the extent users (third parties) perform some steps, "Defendant conditioned the third party's use of the functionality... on the performance of that step" and "controlled the manner and/or timing" of the functionality (Compl. ¶¶ 56, 63, 70, 77). This alleges that Defendant is liable for inducement of infringement because its service requires users to act in an infringing manner to obtain the offered benefit.
• Willful Infringement: The complaint does not explicitly allege "willful infringement." It does, however, request a determination that the case is "exceptional" and an award of attorney's fees in its prayer for relief (Compl., p. 20, ¶F). The body of the complaint does not plead specific facts typically used to support willfulness, such as allegations of pre-suit knowledge of the patents.

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

• A central issue will be one of definitional scope: can the term "portable image capture device," which is rooted in the patent's disclosure of a digital camera's internal architecture, be construed to cover a modern smartphone or computer interacting with Defendant's web-based service?
• A key evidentiary and technical question will be one of functional operation: does discovery reveal that the eHarmony platform avoids image re-transmission by using server-assigned identifiers for subsequent user actions, or does it employ a different technical method for managing user photos? The answer appears to lie in claim chart exhibits that are not yet public.
• The case will likely involve a significant dispute over divided infringement: can Plaintiff establish that eHarmony directs or controls its users' actions with the specificity required to hold it liable for performing every step of the claimed methods, which are split between the user's device and Defendant's servers?