DCT

1:25-cv-01036

DigiMedia Tech LLC v. Craigslist Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01036, D. Del., 08/18/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware on the basis that Defendant is a Delaware corporation and therefore resides in the state.
  • Core Dispute: Plaintiff alleges that Defendant’s online platform for uploading and managing user-submitted images infringes four patents related to reducing bandwidth and memory requirements in data transmissions.
  • Technical Context: The patents address methods for minimizing data transmission between a client device and a server by uploading a full image file only once and thereafter using a smaller, unique "image identifier" to manage or request actions related to that stored image.
  • Key Procedural History: The complaint highlights aspects of the patent prosecution history, noting that the Examiner for the most recently issued patent (’778 Patent) allowed the claims post- Alice, which Plaintiff suggests is evidence of the patent-eligible nature of the claimed subject matter across the entire patent family.

Case Timeline

Date Event
2000-10-06 Earliest Priority Date for all Asserted Patents
2007-10-23 U.S. Patent No. 7,287,088 Issued
2009-09-08 U.S. Patent No. 7,587,514 Issued
2011-12-06 U.S. Patent No. 8,073,965 Issued
2014-10-21 U.S. Patent No. 8,868,778 Issued
2025-08-18 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"

  • Patent Identification: U.S. Patent No. 7,287,088, entitled “Transmission Bandwidth and Memory Requirements Reduction in Portable Image Capture Device by Eliminating Duplicate Image Transmissions,” issued October 23, 2007 (’088 Patent).

The Invention Explained

  • Problem Addressed: The patent’s background section describes the problem of high bandwidth consumption and cost associated with transmitting digital images from a capture device to an online service, particularly when the same image is sent multiple times for different purposes (e.g., to different email groups) (’088 Patent, col. 1:65-2:8; Compl. ¶25).
  • The Patented Solution: The invention proposes a method where a portable device uploads a captured image to a server only once. The server stores the image and assigns it a unique identifier (’088 Patent, col. 3:21-25). For any subsequent operations on that image (such as sending it to another destination), the device transmits only the small image identifier and the requested action, not the full image file again, "thereby eliminating redundancy in image transmission" (’088 Patent, col. 3:27-30; Compl. ¶28). The system is illustrated in Figure 1, showing web-enabled cameras (14) connecting to a photo-sharing service (16) (’088 Patent, Fig. 1).
  • Technical Importance: At the time of the invention, this approach aimed to make internet-based photo sharing more efficient and affordable by conserving limited and expensive network bandwidth and freeing up storage on memory-constrained portable devices (Compl. ¶24-25, 27).

Key Claims at a Glance

  • The complaint asserts independent claims 14 and 22 (Compl. ¶55).
  • Independent Claim 14 requires a method comprising:
    • Uploading captured images to a server for the first time, where the server assigns a respective image identifier to each image.
    • Receiving, from the server, the image identifiers and action information (e.g., a list of possible actions).
    • Presenting an action control based on the received action information.
    • In response to a user selection, transmitting the action and the image identifier, rather than the image itself, to the server to perform the action.
  • Independent Claim 22 requires a method comprising:
    • Receiving captured images uploaded from an image capture device to a server.
    • Assigning an image identifier to the uploaded images by the server.
    • Downloading the image identifiers to the image capture device.
    • Downloading action information to the image capture device.
    • 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 Portable Image Capture Device by Eliminating Duplicate Image Transmissions"

  • Patent Identification: U.S. Patent No. 7,587,514, entitled “Transmission Bandwidth and Memory Requirements Reduction in Portable Image Capture Device by Eliminating Duplicate Image Transmissions,” issued September 8, 2009 (’514 Patent).

The Invention Explained

  • Problem Addressed: As a continuation of the application leading to the ’088 Patent, this patent addresses the same technical problem of inefficient bandwidth and storage usage in digital image transmissions (’514 Patent, col. 2:4-13).
  • The Patented Solution: The solution is functionally identical to that described in the ’088 Patent: a one-time upload of an image from a device to a hardware server, followed by the use of a server-assigned identifier for all subsequent actions to avoid re-transmission (’514 Patent, Abstract; col. 2:30-41). The specification describes the same system architecture, including a portable device communicating with an online photo-sharing service (’514 Patent, col. 3:32-51).
  • Technical Importance: This patent continues the technical approach of its parent, aimed at improving the efficiency of web-enabled portable devices during an era of constrained network resources (Compl. ¶24-25).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶62).
  • Independent Claim 1 requires a method comprising:
    • Receiving captured images uploaded from an image capture device to a hardware server.
    • Assigning an image identifier to the images by the hardware server.
    • Downloading the image identifiers to the image capture device.
    • Downloading action information (including at least one action) to the device.
    • Receiving a request from the device to apply an action, where the request includes the identifier and action rather than the image itself, thereby reducing transmission bandwidth.

U.S. Patent No. 8,073,965 - "Transmission Bandwidth and Memory Requirements Reduction in Portable Image Capture Device by Eliminating Duplicate Image Transmissions"

  • Patent Identification: U.S. Patent No. 8,073,965, entitled “Transmission Bandwidth and Memory Requirements Reduction in Portable Image Capture Device by Eliminating Duplicate Image Transmissions,” issued December 6, 2011 (’965 Patent).
  • Technology Synopsis: This patent, part of the same family, describes a method for reducing network transmission bandwidth where a "photo-sharing service" receives an image from a capture device, provides an image identifier back to the device, and then receives requests from the device that use the identifier—rather than the full image—to specify an action to be performed on the image (’965 Patent, Abstract).
  • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶69).
  • Accused Features: Defendant's systems and processes for uploading and managing images from its users are accused of infringement (Compl. ¶69).

U.S. Patent No. 8,868,778 - "Transmission Bandwidth and Memory Requirements Reduction in Portable Image Capture Device by Eliminating Duplicate Image Transmissions"

  • Patent Identification: U.S. Patent No. 8,868,778, entitled “Transmission Bandwidth and Memory Requirements Reduction in Portable Image Capture Device by Eliminating Duplicate Image Transmissions,” issued October 21, 2014 (’778 Patent).
  • Technology Synopsis: This patent describes a method where an "online service" receives an image from a capture device, stores it in an "image set," and in response to receiving a request to perform an action on the image, transmits an image identifier back to the device that uniquely identifies the image within the set (’778 Patent, Abstract).
  • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶76).
  • Accused Features: Defendant's systems and processes for uploading and managing images from its users are accused of infringement (Compl. ¶76).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are Defendant Craigslist's "systems and processes for uploading and managing images of Defendant's customers/users" (Compl. ¶55, 62, 69, 76).
  • Functionality and Market Context: The complaint alleges that the accused functionality concerns the method by which users upload images to the Craigslist platform for inclusion in online classified advertisements (Compl. ¶55-56). The accused processes are alleged to manage these images in a manner that reduces bandwidth requirements, consistent with the methods claimed in the patents-in-suit (Compl. ¶56). The complaint does not provide specific technical details about the architecture or operation of Craigslist's back-end systems.

IV. Analysis of Infringement Allegations

The complaint references preliminary claim charts (Exhibits E, F, G, H) that are incorporated by reference but not attached to the filed document (Compl. ¶55, 62, 69, 76). The infringement theory is therefore summarized based on the complaint's narrative allegations.

For both the ’088 and ’514 Patents, the complaint alleges that Defendant’s systems perform all steps of the asserted method claims (Compl. ¶56, 63). The narrative theory suggests that when a user uploads an image to Craigslist, Defendant's servers receive the image, assign it an internal identifier, and store it. Subsequent actions related to that image, such as displaying it in an advertisement, are allegedly managed using this identifier, thus avoiding the need for the user to re-upload the original image file from their device. This process is alleged to meet the claim limitations of receiving an image, assigning an identifier, and using that identifier for subsequent actions to reduce bandwidth (Compl. ¶56, 63).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A central dispute may arise over whether the term "portable image capture device," central to the patents' claims and context, can be construed to cover modern general-purpose computers and smartphones using a web browser to access the Craigslist service. The patent specification heavily focuses on the architecture and limitations of early-2000s digital cameras (’088 Patent, col. 4:15-22).
    • Technical Questions: The asserted claims in both the ’088 and ’514 Patents require the server to send, and the device to receive, "action information" that is then presented to the user (’088 Patent, cl. 14, 22; ’514 Patent, cl. 1). A key technical question will be whether the standard transmission of HTML and scripts from Craigslist's web server to a user's browser constitutes the specific step of "downloading action information to the image capture device" as contemplated by the patent, which describes a discrete "action list" (’088 Patent, Fig. 6).

V. Key Claim Terms for Construction

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

  • Context and Importance: The applicability of the patents to Defendant’s service hinges on whether a modern smartphone or PC running a web browser falls within the scope of this term. Practitioners may focus on this term because the patents' problem-solution narrative is rooted in the technical limitations of devices from a much earlier technological era.

  • 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. 3:39-43), which may support extending the term to modern smartphones.
    • Evidence for a Narrower Interpretation: The primary embodiment described is a "digital camera" with a specific software architecture, including a "communication manager 74" and "operating system 70" (’088 Patent, col. 4:15-30, Fig. 2). Defendant may argue the term is limited to such dedicated devices for which the claimed bandwidth-saving methods provided a specific solution to on-device memory and transmission constraints.

  • The Term: "downloading action information to the image capture device" (e.g., ’088 Patent, Claim 22)

  • Context and Importance: This term is a critical active step in the claimed methods. The infringement analysis will depend on whether routine web communications meet this limitation.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: Plaintiff may argue that any data sent from the server that renders actionable options (e.g., buttons for "edit" or "delete") in a user's browser constitutes "action information."
    • Evidence for a Narrower Interpretation: The specification explicitly discloses an "action list 48" that is downloaded to the user's camera and "stored on the camera 14" (’088 Patent, col. 4:5-7). Figure 6 shows this as a discrete menu of options like "Print Images" and "Save in MyShoeBox" (’088 Patent, Fig. 6). This may support a narrower construction requiring a distinct, storable list of server-side actions to be transmitted to the client device, rather than transient user interface elements in a webpage.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that to the extent any steps are performed by a third party (i.e., the user), Defendant "conditioned the third party's use" and "controlled the manner and/or timing" of the functionality (Compl. ¶56, 63). These allegations appear to be directed at theories of divided infringement and inducement, though no specific facts (such as user instructions) are detailed to support intent.
  • Willful Infringement: The complaint does not explicitly allege willful infringement or pre-suit knowledge of the patents. However, the Prayer for Relief requests a determination that the case is "exceptional" and an award of attorney's fees, which is the relief typically sought in cases of willful or egregious infringement (Compl. Prayer for Relief ¶F).

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 is described in the context of a 2000-era digital camera with specific on-device software, be construed to cover the modern client-server architecture where a user's PC or smartphone accesses the accused Craigslist service via a web browser?
  • A key evidentiary question will be one of functional mismatch: does the standard interaction between Craigslist's web servers and a user's browser perform the specific, ordered method steps recited in the claims—particularly the "downloading [of] action information" to the device—or does the accused system operate in a fundamentally different manner than the device-centric process disclosed in the patents?