DCT

1:25-cv-00505

DigiMedia Tech LLC v. Pinterest Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00505, D. Del., 04/24/2025
  • Venue Allegations: Venue is asserted on the basis that Defendant is a Delaware corporation and therefore resides in the state for purposes of patent venue.
  • Core Dispute: Plaintiff alleges that Defendant’s social media platform and chatbot functionality infringe five patents related to reducing data transmission bandwidth and automating information exchange.
  • Technical Context: The patents address methods for efficiently managing and transmitting digital images over networks and for automating data processing to generate server responses.
  • Key Procedural History: The complaint alleges multiple attempts to contact Defendant regarding a potential license, beginning in May 2020. The complaint also notes that the related U.S. Patent No. 8,868,778 was examined and issued by the USPTO after the Supreme Court's decision in Alice Corp. v. CLS Bank, an event Plaintiff presents as evidence of the patent family's subject matter eligibility.

Case Timeline

Date Event
2000-09-20 Priority Date for U.S. Patent No. 6,684,220
2000-10-06 Priority Date for '088, '514, '965, and '778 Patents
2004-01-27 U.S. Patent No. 6684220 Issues
2007-10-23 U.S. Patent No. 7,287,088 Issues
2009-09-08 U.S. Patent No. 7,587,514 Issues
2011-12-06 U.S. Patent No. 8,073,965 Issues
2014-10-21 U.S. Patent No. 8868778 Issues
2020-05-27 Plaintiff alleges first pre-suit contact with Defendant
2020-07-29 Plaintiff alleges second pre-suit contact with Defendant
2021-08-24 Plaintiff alleges third pre-suit contact with Defendant
2023-10-24 Plaintiff alleges fourth pre-suit contact with Defendant
2023-11-09 Plaintiff alleges fifth pre-suit contact with Defendant
2024-05-15 Plaintiff alleges sixth pre-suit contact with Defendant
2024-06-19 Plaintiff alleges seventh pre-suit contact with Defendant
2025-04-24 Complaint Filed

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

U.S. Patent No. 7,287,088 - “Transmission Bandwidth and Memory Requirements Reduction in Portable Image Capture Device by Eliminating Duplicate Image Transmissions”

  • Issued: October 23, 2007

The Invention Explained

  • Problem Addressed: At the time of the invention, the increasing popularity of digital cameras and online photo-sharing websites was creating significant network bandwidth consumption, as large image files were often transmitted over the internet multiple times to different destinations ('088 Patent, col. 1:29-31, 1:65-2:8). The patent notes that while image compression could reduce file size, it often did so at the cost of image quality (Compl. ¶35; '088 Patent, col. 2:9-18).
  • The Patented Solution: The invention proposes a system where a portable image capture device transmits an image to a server only once for permanent storage. The server assigns the image a unique identifier. For any subsequent server communication regarding that image (e.g., sharing, printing), the device transmits only the image identifier and the requested action, not the full image file, thereby "eliminating redundancy in image transmission" ('088 Patent, col. 3:21-30). The device can then reduce the size of the locally stored image file to free up memory (Compl. ¶44; '088 Patent, col. 5:31-50).
  • Technical Importance: This approach aimed to conserve bandwidth and on-device storage for emerging web-enabled portable devices, a critical consideration as image resolutions increased ('088 Patent, col. 2:19-22).

Key Claims at a Glance

  • The complaint asserts independent claims 14 and 22 (Compl. ¶79).
  • Independent Claim 14 recites a method for reducing transmission bandwidth, including the steps of:
    • Uploading captured images to a server for the first time.
    • The server assigning a respective image identifier to each image.
    • The device receiving the image identifiers and action information from the server.
    • Presenting an action control based on the action information.
    • In response to a selection, transmitting the action and the image identifier, rather than the image itself, from the device to the server.
  • Independent Claim 22 recites a method for reducing storage and transmission bandwidth, including the steps of:
    • A server receiving captured images from an image capture device.
    • The server assigning an image identifier to the images.
    • The device downloading the image identifiers for association with the images.
    • The device downloading action information.
    • Receiving a request from the device that includes only the image identifier and the requested 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”

  • Issued: September 8, 2009

The Invention Explained

  • Problem Addressed: As a continuation of the application leading to the '088 Patent, this patent addresses the same technical problem of reducing bandwidth and storage requirements for portable devices that transmit images over a network (Compl. ¶30; ’514 Patent, col. 1:21-28).
  • The Patented Solution: The '514 Patent discloses the same solution as the '088 Patent, centered on a "transmit-once" model where subsequent actions are performed by referencing a server-assigned image identifier instead of retransmitting the image file ('514 Patent, col. 2:30-41). The common specification describes the architecture involving a portable device, a network, and an online photo-sharing service with a server and database (Compl. ¶¶37-39).
  • Technical Importance: This patent continues the technical theme of optimizing data transfer for the emerging class of internet-connected imaging devices ('514 Patent, col. 2:25-29).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶86).
  • Independent Claim 1 recites a method for reducing storage and transmission bandwidth, including the steps of:
    • A hardware server receiving captured images uploaded from an image capture device.
    • The hardware server assigning an image identifier to the uploaded images.
    • The image capture device downloading the image identifiers for association with the images.
    • The image capture device downloading action information.
    • Receiving a request from the device that includes the image identifier and the requested action, rather than the image itself.

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 is part of the '088 Patent family and shares the same specification (Compl. ¶30). It discloses a method for reducing network bandwidth by having a photo-sharing service receive an image, provide an identifier back to the device, and then receive subsequent action requests that reference the identifier rather than the full image, thus avoiding retransmission (Compl. ¶49; ’965 Patent, col. 9:1-12).
  • Asserted Claims: Independent claims 1 and 13 are asserted (Compl. ¶93).
  • Accused Features: The accused features are Defendant's systems and processes for managing photos uploaded by users of its app (Compl. ¶93).

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: Also part of the '088 Patent family, this patent discloses a method where an online service provides action information to an image capture device, receives an uploaded image, stores it in a set, and transmits a unique identifier for that image back to the device in response to a request to perform an action (Compl. ¶50; ’778 Patent, col. 12:1-13).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶100).
  • Accused Features: The accused features are Defendant's systems and processes for managing photos uploaded by users of its app (Compl. ¶100).

U.S. Patent No. 6,684,220 - “Method and System for Automatic Information Exchange”

  • Issued: January 27, 2004
  • Technology Synopsis: This patent addresses the technical problem of automating information exchanges within a computer system to enable server-generated responses without requiring human support representatives (Compl. ¶68). The invention describes a "loading engine" that retrieves a data model composed of objects, each with input and output variables, and then "automatically creat[es] object links between the corresponding input variables and output variables" to facilitate automated processing (’220 Patent, Abstract; col. 2:1-10).
  • Asserted Claims: Independent claim 10 is asserted (Compl. ¶106).
  • Accused Features: The accused feature is Defendant's chatbot functionality (Compl. ¶106).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses two main instrumentalities: (1) Defendant's systems and processes for managing photos uploaded by users of the Pinterest app, which are accused of infringing the '088 family of patents, and (2) Defendant's chatbot, which is accused of infringing the '220 Patent (Compl. ¶¶79, 106).

Functionality and Market Context

  • The complaint alleges that the accused photo management functionality involves users uploading images to Defendant's servers, where they are stored and managed (Compl. ¶79). The core accused function is the subsequent handling of these images, where the system allegedly avoids retransmitting full image files for actions like saving or sharing, thereby reducing bandwidth requirements (Compl. ¶80).
  • The accused chatbot functionality is alleged to provide automated responses to user inquiries (Compl. ¶¶68, 106).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates preliminary claim charts by reference as Exhibits I, J, K, L, and M, but these exhibits are not attached to the filed document (Compl. ¶¶79, 86, 93, 100, 106). The infringement theory is therefore summarized from the narrative allegations.

’088 and ’514 Patent Infringement Allegations (Summarized)

The core of the infringement allegation is that Defendant's systems practice the claimed methods for reducing bandwidth and storage. The complaint alleges that when a user uploads an image to Pinterest, it is sent to Defendant's servers a first time (Compl. ¶79). The servers allegedly assign an identifier to the image. For subsequent actions on that image performed by the user, the complaint alleges that Defendant’s system transmits a request containing the action and the image identifier, rather than retransmitting the image itself, thereby mapping to the steps of the asserted method claims (Compl. ¶¶80, 87).

Identified Points of Contention

  • Scope Questions: A central question may be whether the term "portable image capture device" from the 2000-era patents, which describe digital cameras and early cellphones, can be construed to read on the modern ecosystem of user devices (e.g., smartphones, PCs) interacting with Defendant's server-based social media platform.
  • Technical Questions: The complaint alleges on "information and belief" that Defendant's system avoids retransmitting images for subsequent actions. A key evidentiary question will be whether this is technically accurate in all instances or if there are modes of operation where image data, or derivatives thereof, are retransmitted, potentially creating a mismatch with the claim limitation "rather than the image itself" (Compl. ¶48).

V. Key Claim Terms for Construction

The Term: "portable image capture device" (e.g., ’088 Patent, claim 14)

  • Context and Importance: This term appears in the preamble of the asserted method claims of the '088 patent family. Its construction is critical because infringement depends on whether the accused system, which involves user smartphones/computers and Defendant's servers, performs the steps of a method related to such a device. Practitioners may focus on this term to dispute whether the patent's scope, rooted in early 2000s technology, covers a modern, distributed social media platform.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the term is not limited to a traditional camera, stating that "a cellphone may be used to provide the digital camera 14 with wireless capability" or that the device could have "built-in cellphone-like wireless communication" (’088 Patent, col. 4:37-44).
    • Evidence for a Narrower Interpretation: The patent’s background and summary repeatedly frame the invention in the context of a "digital camera" (’088 Patent, col. 1:29-31, 3:21-25). A party could argue that the term is limited to the physical device that performs the initial image capture, not the entire client-server system that subsequently manages it.

The Term: "automatically creating object links" (’220 Patent, claim 10)

  • Context and Importance: This step is a central element of the asserted claim of the '220 Patent. The dispute will likely turn on whether the accused chatbot technology performs this specific function.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not detail the mechanism for creating links, which may support an argument that it covers any automated process that logically connects inputs and outputs.
    • Evidence for a Narrower Interpretation: The specification describes a specific "loading engine" that "automatically links corresponding input variables and output variables of the objects of a model" (’220 Patent, col. 2:1-6). The patent also includes detailed flow diagrams illustrating this process (e.g., ’220 Patent, Figs. 4A-4B). This may support a narrower construction limited to the specific architecture disclosed, rather than any generic automated response system.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges that to the extent a third party (i.e., a user) performs any of the claimed method steps, Defendant is liable for indirect infringement. This is based on the allegation that Defendant "conditioned the third party's use of the functionality" on the performance of those steps and "controlled the manner and/or timing of the functionality" (Compl. ¶¶80, 87, 94, 101).

Willful Infringement

  • The complaint alleges that Defendant had knowledge of the patents-in-suit at least as early as May 27, 2020, due to a series of letters and emails sent by Plaintiff (Compl. ¶¶6-13). The alleged failure to respond to these communications forms the basis for the willfulness allegation. Plaintiff also seeks a determination that the case is exceptional and an award of attorney's fees (Compl. p. 25, ¶G).

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," rooted in the 2000-era context of digital cameras, be construed to cover the modern, distributed social media ecosystem of Pinterest, which involves user smartphones, PCs, and a sophisticated server backend?
  • A second central question will address technical operation: Does Defendant's chatbot technology function by "automatically creating object links" between defined inputs and outputs as specified in the '220 patent, or does it rely on a fundamentally different architecture (e.g., large language models, natural language processing) for generating responses?
  • Finally, a key evidentiary question will be one of proof: Given the complaint’s reliance on "information and belief," what technical evidence will be brought forward to demonstrate that Defendant's systems perform each step of the claimed methods, particularly the alleged avoidance of re-transmitting image data for all subsequent user actions?