CDN Innovations LLC v. Iheartmedia Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CDN Innovations, LLC (Georgia)
  • Defendant: iHeartMedia, Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Kent & Risley LLC
• Case Identification: 1:25-cv-00852, D. Del., 07/09/2025
• Venue Allegations: Venue is asserted on the grounds that Defendant is a Delaware corporation and therefore resides in the District of Delaware.
• Core Dispute: Plaintiff alleges that Defendant’s iHeartRadio service infringes two patents, one related to fault-tolerant management of remote computing devices and another related to recognizing spoken commands using predefined grammars.
• Technical Context: The patents address technologies for ensuring the reliability of networked client devices and improving the accuracy of voice-command interfaces.
• Key Procedural History: The complaint asserts that the patents resulted from "pioneering efforts." No prior litigation, licensing history, or other procedural events are mentioned in the complaint.

Case Timeline

Date	Event
2000-12-12	’487 Patent Priority Date
2001-09-19	’532 Patent Filing Date
2005-03-08	’532 Patent Issue Date
2007-12-11	’487 Patent Issue Date
2025-07-09	Complaint Filing Date

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

U.S. Patent No. 7,308,487 - System and method for providing fault-tolerant remote controlled computing devices, Issued December 11, 2007

The Invention Explained

• Problem Addressed: The patent describes a problem where remote computing devices, such as kiosks or digital billboards, are prone to software faults or errors that can render them inoperable, leaving users with an "undesirable interface" (Compl. ¶10; ’487 Patent, col. 1:21-30). These devices often operate over unreliable or slow network connections, complicating remote management and updates (’487 Patent, col. 2:26-29).
• The Patented Solution: The invention provides a "self-healing" system where a "monitor process" runs on the remote device to supervise one or more "primary processes" (e.g., the main application) (’487 Patent, Abstract). If the monitor process detects that a primary process has entered a "fault state" (e.g., crashed or hung), it automatically takes steps to resolve the fault, such as restarting the failed process, to ensure high availability without manual intervention (’487 Patent, col. 3:62-col. 4:8).
• Technical Importance: This technology aims to provide robust, autonomous operation for unmanned, networked devices, reducing downtime and the need for on-site technical support (’487 Patent, col. 1:40-49).

Key Claims at a Glance

• The complaint asserts independent Claim 1 (Compl. ¶18).
• Essential elements of Claim 1 include:
  • Storing a local copy of a configuration file and multimedia content on an autonomous multimedia computing device.
  • Polling a server at pre-determined time intervals for updates.
  • In response to available updates, downloading one or more updates from the server without user input.
  • Playing the multimedia content based on instructions in the configuration file, which defines a program with media files, priority, and timing information.

U.S. Patent No. 6,865,532 - Method for recognizing spoken identifiers having predefined grammars, Issued March 8, 2005

The Invention Explained

• Problem Addressed: The patent identifies the difficulty conventional systems have in correctly recognizing spoken numbers, particularly long sequences like account codes or telephone numbers, which are prone to interpretation errors (’532 Patent, col. 1:41-49).
• The Patented Solution: The invention proposes a method for creating and recognizing spoken identifiers that are more robust than simple digit strings. It defines a phrase structure with multiple "word slots" arranged in a "predetermined grammatical structure" (e.g., adjective-noun-verb) (’532 Patent, col. 2:50-57, col. 5:1-7). Each slot is populated from a unique, limited set of words, so a phrase like "four green dogs flew" can uniquely map to a numeric identifier (e.g., "4.2.1.2"), making it easier for a machine to recognize correctly (’532 Patent, Abstract; col. 5:13-17).
• Technical Importance: This approach sought to improve the reliability and user-friendliness of voice-operated devices by structuring voice commands in a way that reduces recognition ambiguity (’532 Patent, col. 5:35-41).

Key Claims at a Glance

• The complaint asserts independent Claims 1 and 7 (Compl. ¶25).
• Essential elements of Claim 1 include:
  • Defining a phrase having a plurality of word slots.
  • Arranging the word slots in a predetermined order and according to a predetermined grammatical structure of a target language.
  • Associating a set of unique words with each word slot.
  • Generating a unique identifier by selecting one word from each set for each slot, such that concatenating the words forms the identifier.

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Defendant's "iHeartRadio service" (Compl. ¶18, ¶25).

Functionality and Market Context

The complaint does not provide any specific technical details regarding the architecture or operation of the iHeartRadio service. It is identified as the product that allegedly infringes the patents-in-suit, but its specific features corresponding to the claimed inventions are not described in the body of the complaint (Compl. ¶18, ¶25). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of the ’487 and ’532 patents but states that the details are provided in preliminary claim charts attached as Exhibits C and D, respectively (Compl. ¶18, ¶25). As these exhibits were not provided with the complaint, a detailed element-by-element analysis is not possible. The complaint’s narrative theory is limited to the general assertion that the iHeartRadio service incorporates the inventions claimed in the patents (Compl. ¶17, ¶24).

• Identified Points of Contention:
  • Evidentiary Questions: A primary issue will be what evidence Plaintiff can produce to demonstrate that the iHeartRadio service performs each of the steps recited in the asserted method claims. The complaint itself does not articulate a factual basis for these allegations.
  • ’487 Patent - Technical Questions: The infringement analysis will question whether the iHeartRadio service, which is primarily a media streaming platform, utilizes a "fault-tolerant" architecture with distinct "monitor" and "primary" processes as described in the patent, or if it handles errors and updates through different mechanisms.
  • ’532 Patent - Technical Questions: The analysis will focus on whether the voice command functionality within the iHeartRadio service operates by recognizing identifiers composed of words selected from different "word slots" arranged in a "predetermined grammatical structure," or if it uses more conventional speech-to-text or natural language processing techniques that do not map to the specific structure claimed.

V. Key Claim Terms for Construction

For the ’487 Patent:

• The Term: "fault state" (Claim 1 is not asserted, but this concept from the specification is central to the patent's purpose and likely relevant to asserted dependent claims or equivalents arguments for other claims like the asserted Claim 1, which focuses on updating and playing content). Correction: The complaint asserts claim 1. The concept of fault tolerance is described in the specification as the context for the invention. A key term from asserted Claim 1 is "autonomous multimedia computing device".
• The Term: "autonomous multimedia computing device" (Claim 1)
  • Context and Importance: The nature of the "device" is central. Plaintiff will likely argue this term broadly covers the client-side iHeartRadio application, while Defendant may argue its service architecture does not constitute an "autonomous" device in the manner contemplated by the patent, which focuses on standalone kiosks.
  • Intrinsic Evidence for a Broader Interpretation: The specification discusses "client-server computing devices" generally and applications working across the web, which could support reading the term on software clients (’487 Patent, col. 1:16-17).
  • Intrinsic Evidence for a Narrower Interpretation: The background repeatedly references physical devices like an "attractive billboard, kiosk, or marketing device," suggesting the invention was directed at unmanned, standalone hardware installations (’487 Patent, col. 1:30-35).

For the ’532 Patent:

• The Term: "predetermined grammatical structure" (Claim 1)
  • Context and Importance: This term is the core of the invention. Its construction will determine whether modern, flexible voice recognition systems fall within the scope of the claims. Practitioners may focus on this term because the patent’s examples suggest a rigid, multi-category structure.
  • Intrinsic Evidence for a Broader Interpretation: The claim language is not explicitly limited to the specific grammar examples given. Plaintiff may argue any system that parses commands into structured components meets this limitation.
  • Intrinsic Evidence for a Narrower Interpretation: The specification provides a specific example of "number:adjective:noun:verb:preposition:proper-noun" and states the words can be "further constrained" (e.g., nouns are animals, adjectives are colors), suggesting a highly defined, categorical structure is required (’532 Patent, col. 5:1-7).

VI. Other Allegations

• Indirect Infringement: The complaint includes allegations that appear to lay the groundwork for a divided infringement theory under an inducement standard. It states that to the extent a third party (e.g., an end-user) performs a claimed step, 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. ¶19, ¶26).
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement in the counts. However, the prayer for relief requests a determination that the case is "exceptional" and an award of attorney's fees, which often accompanies such a claim (Compl., Prayer for Relief ¶D).

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

1. Evidentiary Sufficiency: The central threshold question will be whether Plaintiff can substantiate the bare allegations of infringement, which are currently unsupported by any factual detail or the referenced exhibits in the public-facing complaint. The case's viability depends on the evidence presented to link the iHeartRadio service's specific functions to the patent claims.
2. Definitional Scope: The dispute will likely involve a significant claim construction battle. For the ’487 patent, a key issue is whether a modern software application like iHeartRadio constitutes an "autonomous multimedia computing device" as envisioned in the patent. For the ’532 patent, the core question is whether the iHeartRadio voice interface uses a "predetermined grammatical structure" with "word slots," or if its technology is fundamentally different from the rigid, phrase-based system claimed.
3. Divided Infringement: Given that the asserted claims are method claims potentially performed by both Defendant's servers and end-users' devices, a critical legal question will be whether Plaintiff can prove that Defendant directs or controls its users to perform the claimed steps in a manner sufficient to establish liability for divided infringement.