DigiMedia Tech LLC v. CarGurus Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigiMedia Tech, LLC (Georgia)
  • Defendant: CarGurus, Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
• Case Identification: 1:25-cv-00315, D. Del., 03/12/2025
• Venue Allegations: Venue is based on Defendant's incorporation and residence in the State of Delaware.
• Core Dispute: Plaintiff alleges that Defendant’s systems for managing vehicle listing photographs infringe patents related to reducing network bandwidth and device storage requirements by eliminating duplicate image transmissions.
• Technical Context: The technology addresses the efficient management of digital images transmitted between a user's device and a network server, a key consideration for online platforms handling large volumes of user-generated content.
• Key Procedural History: The complaint notes that during the prosecution of the parent '088 patent, the applicant distinguished prior art by highlighting the invention's specific method of using an image identifier to request server-side actions on an already-uploaded image. The complaint also points to the post-Alice allowance of a related patent ('778) as evidence of the subject matter's patent eligibility.

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's background describes the technical problem of excessive network bandwidth consumption that occurs when users transmit the same high-resolution digital image from a portable device to a server multiple times for different purposes (e.g., sending to various recipients) (Compl. ¶21; ’088 Patent, col. 1:65-2:8). It notes that while image compression can reduce file size, high compression rates degrade image quality, which runs counter to consumer demand for higher-quality images (’088 Patent, col. 2:9-18).
• The Patented Solution: The invention proposes a method where a portable device uploads a captured image to a server only once (Compl. ¶24). The server stores the full-resolution image and assigns it a unique "image identifier" (’088 Patent, Abstract). For any subsequent operations on that image (e.g., printing, sharing, deleting), the device transmits only the small image identifier and the requested action to the server. The server then performs the action using the stored image, thereby "eliminating the need to retransmit the image" and significantly reducing bandwidth usage (Compl. ¶31; ’088 Patent, col. 5:31-50). The system also allows for the on-device image file to be reduced in size or deleted after the initial upload to conserve local storage (’088 Patent, col. 2:37-40).
• Technical Importance: This client-server architecture was designed to mitigate the growing data transfer and storage burdens associated with the increasing resolution of digital cameras and the rise of online photo-sharing platforms (Compl. ¶¶ 20-21).

Key Claims at a Glance

• The complaint asserts independent claims 14 and 22 (Compl. ¶50).
• Independent Claim 14 requires a method comprising:
  • Uploading captured images for a first time to a server, where the server assigns a respective image identifier to each image.
  • Receiving, from the server, the image identifiers and "action information" that includes at least one action that the server can apply.
  • Presenting an "action control" based on the received action information.
  • In response to a selection of the action control, transmitting the action and the corresponding image identifier, rather than the image itself, from the portable image capture device to the server.
• Independent Claim 22 requires a method comprising:
  • Receiving captured images at a server from the image capture device.
  • Assigning an image identifier to the images by the server.
  • Downloading the image identifiers from the server to the image capture device.
  • Downloading "action information" to the image capture device.
  • Receiving a request from the device to apply an action, where the request includes only the image identifier and the requested action.

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

The Invention Explained

• Problem Addressed: As a continuation of the '088 patent, the '514 patent addresses the same technical challenge: reducing the redundant transmission of large digital image files from a portable device and conserving the device's limited memory (Compl. ¶¶ 19, 23).
• The Patented Solution: The '514 patent claims a similar method centered on a "hardware server" that manages images uploaded from a portable device (’514 Patent, Abstract). The server receives an image, assigns it an identifier, and downloads both the identifier and "action information" to the device. Subsequent user-initiated actions are communicated to the server by sending the identifier and the action, not by re-transmitting the image itself (’514 Patent, col. 8:50-67). This offloads both permanent storage and data-intensive processing to the server.
• Technical Importance: The invention provides a specific client-server protocol to manage the lifecycle of a digital image in a network-efficient manner (Compl. ¶35).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶57).
• Independent Claim 1 requires a method comprising:
  • Receiving captured images at a hardware server from an image capture device.
  • Assigning an image identifier to the images by the hardware server.
  • Downloading the image identifiers to the image capture device for association with the corresponding image.
  • Downloading "action information" to the device, including at least one action the server can perform.
  • Receiving a request from the device to apply an action to an image, where the request includes the image identifier and the 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," Issued December 6, 2011.
• Technology Synopsis: This patent, also in the same family, discloses a method to reduce network transmission bandwidth for a portable image capture device interacting with a "photo-sharing service" (Compl. ¶¶ 19, 36). The service receives an uploaded image, assigns it an identifier, and provides that identifier back to the device. The device can then request the service to perform an action on the stored image by sending the identifier and action information, avoiding the need to re-upload the image file (’965 Patent, Abstract).
• Asserted Claims: The complaint asserts independent claims 1 and 13 (Compl. ¶64).
• Accused Features: The infringement allegations target Defendant's "systems and processes for managing photos of vehicle listings," which allegedly utilize the patented method of uploading an image once and subsequently referencing it via an identifier for management actions (Compl. ¶64).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's "systems and processes for managing photos of vehicle listings" (Compl. ¶50).

Functionality and Market Context

• The complaint alleges that Defendant’s systems, used for uploading and managing photographs on its online automotive marketplace, operate in a manner that reduces bandwidth requirements (Compl. ¶51). The core accused functionality is a process where images are uploaded to Defendant's servers and subsequently managed by users through an interface that, Plaintiff alleges, sends commands referencing the images rather than re-transmitting the image data for each action (Compl. ¶¶ 51, 58, 65).
• The complaint does not provide specific details about the architecture of the accused systems or their market position. The infringement allegations rely on "preliminary claim chart[s]" attached as exhibits, which are incorporated by reference but not included in the provided complaint document (Compl. ¶¶ 50, 57, 64).

IV. Analysis of Infringement Allegations

The complaint does not provide detailed factual allegations mapping specific product features to claim elements in the body of the complaint, instead incorporating by reference preliminary claim charts (Exhibits D, E, F) which are not included in the provided document. The analysis below is based on the general infringement theory presented in the complaint.

’088 Patent Infringement Allegations

’514 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A primary issue may be whether Defendant's web-based platform, accessed by users via general-purpose computers and smartphones, constitutes the "portable image capture device" recited in the claims. The patent specification heavily emphasizes "digital cameras" and "cellphone[s]" as the operative device, raising the question of whether the claims are limited to the device that both captures and transmits the image (Compl. ¶¶ 20, 24, 28).
• Technical Questions: The infringement theory hinges on whether the accused system performs the specific sequence of claimed steps, such as the server "downloading action information" to the client device. The court may need to determine if the dynamic, state-managed nature of a modern web application is technically equivalent to the more discrete, procedural steps described in the patent's specification and flowcharts (’088 Patent, Fig. 7A).
• Evidentiary Questions: As the complaint relies on "information and belief" and external exhibits not provided, the actual architecture and operation of the accused system will be a central factual question for discovery.

V. Key Claim Terms for Construction

The Term: "portable image capture device"

• Context and Importance: This term appears in the preamble and body of the asserted claims and is foundational to the scope of the patents. Its construction is critical because the patents’ disclosure is centered on devices like digital cameras, while the accused instrumentality is a web-based software platform used to manage photos that may have been captured on separate devices. Practitioners may focus on this term because its interpretation could determine whether the patents apply to Defendant's system at all.
• Intrinsic Evidence for a Broader Interpretation: A party could argue that the term should be interpreted functionally to encompass any system where a user employs a portable device (like a smartphone or laptop) to perform the claimed method steps, regardless of where the image was originally captured. The claims are directed to a "method for reducing... requirements of a" device, which may not strictly require the device itself to perform every action, including capture.
• Intrinsic Evidence for a Narrower Interpretation: The specification repeatedly and consistently refers to "digital cameras 14," "hand-held electronic devices," and devices with "built-in cellphone-like wireless communication" as the invention's context (Compl. ¶¶ 20, 24, 28; ’088 Patent, col. 4:37-44). This consistent focus on the image-capturing hardware itself may support a narrower construction that excludes general-purpose computers running web browsers.

The Term: "downloading action information to the image capture device"

• Context and Importance: This step, recited in claims like '514 Claim 1, requires the server to actively send information about possible actions to the user's device. The interpretation of "downloading" is important in the context of modern web applications, where such information might be rendered dynamically as part of a webpage rather than being "downloaded" as a discrete data package as contemplated by the patent's flowcharts.
• Intrinsic Evidence for a Broader Interpretation: A broader reading could construe this step as being satisfied by the server sending HTML, CSS, and JavaScript that renders the user interface with its action controls, which is technically data sent from the server to the client.
• Intrinsic Evidence for a Narrower Interpretation: The patent specification describes a more structured process where an "action list 48" is created by the photo-sharing service and can be "downloaded to the user's camera 14" (’088 Patent, col. 4:3-7). This language, along with the flowcharts, may support an interpretation requiring a more distinct and formal data transfer event than the routine rendering of a web page.

VI. Other Allegations

Indirect Infringement

The complaint includes allegations that if any claimed steps are performed by third parties (e.g., users of the platform), Defendant is liable for infringement because it "conditioned the third party's use" on performance of those steps and "controlled the manner and/or timing" of the functionality (Compl. ¶¶ 51, 58, 65). These allegations appear to be boilerplate assertions intended to address potential divided infringement defenses.

Willful Infringement

The complaint does not contain specific allegations of willful infringement or pre-suit knowledge of the patents. The prayer for relief includes a request for a finding that the case is "exceptional" to support an award of attorney's fees, but does not explicitly request enhanced damages for willfulness (Compl. p. 17).

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

• A core issue will be one of definitional scope: can the term "portable image capture device", which the patent specification grounds in the context of digital cameras, be construed broadly enough to read on a system where users interact with Defendant's web platform via general-purpose computers and smartphones?
• A central evidentiary question will be one of technical implementation: does the architecture of Defendant's accused system, once detailed in discovery, perform the specific, sequential method steps recited in the claims—particularly the "downloading" of identifiers and "action information" from the server to the client—or is its functionality based on a technically distinct process, such as modern, dynamic web application state management?
• The litigation may also turn on the question of divided infringement: does Defendant directly perform all steps of the asserted method claims, or are some steps performed by its users? If the latter, the court will have to analyze whether Plaintiff's allegations that Defendant "directs or controls" its users are sufficient to hold Defendant liable for the actions of those users.