DCT

1:25-cv-01054

Nokia Tech Oy v. Paramount Skydance Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01054, D. Del., 08/21/2025
  • Venue Allegations: Venue is based on Defendants’ incorporation in Delaware, their regular conduct of business in the district, and the offering of their services to customers in Delaware.
  • Core Dispute: Plaintiff alleges that Defendant’s backend video processing services, used for streaming platforms like Paramount+, infringe thirteen patents related to video encoding and compression technology.
  • Technical Context: The patents relate to fundamental techniques in digital video compression, which is essential for efficiently streaming high-quality video over bandwidth-constrained networks like the internet.
  • Key Procedural History: The complaint alleges that licensing negotiations began in September 2022. A central point of dispute appears to be whether Nokia’s encoding patents are essential to the H.264/H.265 video standards and therefore subject to fair, reasonable, and non-discriminatory (RAND) licensing obligations; Nokia seeks a declaratory judgment that they are not.

Case Timeline

Date Event
2000-01-20 Priority Date for U.S. Patent No. 9,800,891
2000-05-08 Priority Date for U.S. Patent No. 6,711,211
2000-05-15 Priority Date for U.S. Patent No. 6,968,005
2000-08-11 Priority Date for U.S. Patent No. 8,005,145
2001-08-30 Priority Date for U.S. Patent No. 7,082,450
2001-09-14 Priority Date for U.S. Patent No. 6,856,701
2001-09-17 Priority Date for U.S. Patent No. 6,950,469
2002-01-23 Priority Date for U.S. Patent No. 8,050,321
2002-03-15 Priority Date for U.S. Patent No. 7,532,808
2002-04-23 Priority Date for U.S. Patent No. 8,175,148
2002-06-11 Priority Date for U.S. Patent No. 7,289,674
2002-11-06 Priority Date for U.S. Patent No. 8,107,744
2003-06-10 Priority Date for U.S. Patent No. 8,776,204
2004-03-23 U.S. Patent No. 6,711,211 Issues
2005-02-15 U.S. Patent No. 6,856,701 Issues
2005-09-27 U.S. Patent No. 6,950,469 Issues
2005-11-22 U.S. Patent No. 6,968,005 Issues
2006-07-25 U.S. Patent No. 7,082,450 Issues
2007-10-30 U.S. Patent No. 7,289,674 Issues
2009-05-12 U.S. Patent No. 7,532,808 Issues
2011-08-23 U.S. Patent No. 8,005,145 Issues
2011-11-01 U.S. Patent No. 8,050,321 Issues
2012-01-31 U.S. Patent No. 8,107,744 Issues
2012-05-08 U.S. Patent No. 8,175,148 Issues
2014-07-08 U.S. Patent No. 8,776,204 Issues
2017-10-24 U.S. Patent No. 9,800,891 Issues
2022-09-29 Nokia first informs Paramount of its patent portfolio
2022-12-07 Nokia provides notice of twelve specific patents to Paramount
2024-11-23 Nokia provides notice of U.S. Patent No. 8,776,204 to Paramount
2025-08-21 Complaint Filed

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

U.S. Patent No. 7,532,808 - Method for Coding Motion in a Video Sequence

The Invention Explained

  • Problem Addressed: The patent addresses inefficiencies in prior art video compression techniques related to the "SKIP" coding mode ('808 Patent, col. 10:64-67). This mode, used for image regions (macroblocks) with no change, was assumed to be the most frequently occurring mode but could not effectively handle global or regional motion, such as camera pans or zooms, forcing encoders to use more computationally intensive methods (Compl. ¶¶55-57; ’808 Patent, col. 12:41-47).
  • The Patented Solution: The invention proposes an improved skip coding mode that can adapt to motion in the surrounding scene. The encoder analyzes the motion of neighboring macroblocks to determine if the current macroblock is part of a global or regional motion. If so, it associates the skip mode with an "active" (non-zero) motion vector that reflects this broader motion; otherwise, it uses a "zero" motion vector. This allows the encoder to efficiently represent common motion patterns without transmitting additional motion data for that macroblock (Compl. ¶58; ’808 Patent, col. 14:23-32).
  • Technical Importance: This approach improves coding efficiency by allowing a low-bitrate coding mode (SKIP) to be used for a wider variety of motion scenarios, reducing computational load and data overhead (Compl. ¶61).

Key Claims at a Glance

  • Independent claim 1 is asserted in the complaint (Compl. ¶197).
  • Claim 1 of the ’808 Patent includes the following essential elements:
    • Analyzing motion of a region surrounding a segment of an image to be coded.
    • Determining, based on the analysis, if the motion is characteristic of zero motion or non-zero motion.
    • In response, associating a skip coding mode with either a zero motion vector or a non-zero motion vector that describes global or regional motion.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 6,950,469 - Method for Sub-Pixel Value Interpolation

The Invention Explained

  • Problem Addressed: Motion in real-life video does not align perfectly with the grid of pixels in a digital frame. To model this motion accurately, encoders must calculate values for "sub-pixel" locations. The patent states that conventional methods for this "sub-pixel value interpolation" were computationally complex, required significant memory, and suffered from reduced precision due to intermediate rounding and storage steps ('469 Patent, col. 11:15-32; Compl. ¶68).
  • The Patented Solution: The patent discloses a more flexible and efficient method for sub-pixel interpolation. A key aspect is the ability to calculate values for certain sub-pixels (e.g., those at diagonal quarter-pixel locations) directly from a weighted average of diagonally-located full pixels or other sub-pixels ('469 Patent, col. 13:66-14:9). This approach avoids relying on intermediate interpolated values, which reduces the number of calculations and eliminates precision loss from intermediate rounding, thereby decreasing computational complexity and memory requirements (Compl. ¶¶69-70).
  • Technical Importance: The invention provides a specific technological improvement by increasing the efficiency of video coding, which is critical for real-time compression and for devices with limited processing power and memory (Compl. ¶71).

Key Claims at a Glance

  • Independent claim 1 is asserted in the complaint (Compl. ¶203).
  • Claim 1 of the ’469 Patent includes the following essential element:
    • When a value for a sub-pixel at a specific fractional location is required, interpolating that value by taking a weighted average of the values of a first sub-pixel/pixel and a second sub-pixel/pixel that are located diagonally with respect to the target sub-pixel.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 8,175,148 - Method and Device for Indicating Quantizer Parameters in a Video Coding System

  • Technology Synopsis: The patent addresses the problem that transmitting the quantization parameter (QP), which controls compression levels, for every picture or slice of a video stream consumes significant bandwidth ('148 Patent, col. 10:35-43; Compl. ¶80). The invention provides for a default or reference QP level that applies to multiple pictures, with encoders only needing to transmit the difference from this default level, thereby reducing bit-rate (Compl. ¶81).
  • Asserted Claims: Claim 1 (Compl. ¶209).
  • Accused Features: The Accused Services’ backend encoding processes are alleged to infringe (Compl. ¶206).

U.S. Patent No. 8,050,321 - Grouping of Image Frames in Video Coding

  • Technology Synopsis: The patent addresses a problem that occurs when a user begins streaming a video from the middle; prior systems could misinterpret this as data loss and attempt unnecessary error correction ('321 Patent, col. 11:11-25; Compl. ¶91). The invention provides for encoding an indication of a first picture in an independently decodable group of pictures, allowing a decoder to begin playback from a random point in the stream without prediction from prior pictures (Compl. ¶92).
  • Asserted Claims: Claim 1 (Compl. ¶215).
  • Accused Features: The Accused Services’ backend encoding processes are alleged to infringe (Compl. ¶212).

U.S. Patent No. 7,289,674 - Spatial Prediction Based Intra Coding

  • Technology Synopsis: The patent addresses the high memory requirements of prior art intra-mode prediction, where large tables were needed to store the probable prediction modes for a current block based on every possible combination of modes of its neighboring blocks ('674 Patent, col. 5:37-48; Compl. ¶102). The invention proposes a method that divides possible prediction modes into two groups—most probable and remaining—which reduces the amount of information that needs to be transmitted and stored to determine the correct mode (Compl. ¶103). The complaint includes a visual from the patent to illustrate the relationship between the current block (C) and its upper (U) and left (L) neighbors (Compl. ¶100, Fig. 3).
  • Asserted Claims: Claim 1 (Compl. ¶221).
  • Accused Features: The Accused Services’ backend encoding processes are alleged to infringe (Compl. ¶218).

U.S. Patent No. 6,968,005 - Video Coding

  • Technology Synopsis: The patent addresses the inability of prior systems to distinguish between the loss of a critical "reference picture" (which propagates errors) and a non-reference picture ('005 Patent, col. 3:35-39; Compl. ¶111). The invention introduces a sequence indicator with an independent numbering scheme that applies only to reference pictures, allowing a decoder to differentiate between the two types of loss and take appropriate action, improving error resiliency (Compl. ¶112).
  • Asserted Claims: Claim 1 (Compl. ¶228).
  • Accused Features: The Accused Services’ backend encoding processes are alleged to infringe (Compl. ¶224).

U.S. Patent No. 7,082,450 - Implementation of a Transform and of a Subsequent Quantization

  • Technology Synopsis: The patent addresses the computational expense of the discrete cosine transform (DCT) operation in video compression, which traditionally required many multiplications with irrational numbers ('450 Patent, col. 1:20-45; Compl. ¶120). The invention proposes a method that simplifies the transform by approximating irrational coefficients with rational values (enabling use of faster bit-shift operations) and compensates for any resulting errors in the subsequent quantization step, increasing speed and efficiency (Compl. ¶¶122-123).
  • Asserted Claims: Claim 31 (Compl. ¶234).
  • Accused Features: The Accused Services’ backend encoding processes are alleged to infringe (Compl. ¶231).

U.S. Patent No. 6,711,211 - Method for Encoding and Decoding Video Information

  • Technology Synopsis: Prior video coding systems required encoders to perform exhaustive calculations to evaluate all possible prediction candidates for a given macroblock ('211 Patent, col. 6:1-5; Compl. ¶133). The invention improves efficiency by restricting the number of possible prediction methods per macroblock segmentation, which enables the decoder to infer the prediction method from the segmentation information alone, reducing computational complexity and bandwidth requirements (Compl. ¶134).
  • Asserted Claims: Claim 1 (Compl. ¶240).
  • Accused Features: The Accused Services’ backend encoding processes are alleged to infringe (Compl. ¶237).

U.S. Patent No. 8,005,145 - Method and Apparatus for Transferring Video Frame in Telecommunication System

  • Technology Synopsis: The patent addresses inefficiencies in motion vector prediction when a block to be coded uses a different reference frame than its neighbors. Prior art methods were not capable of handling this scenario efficiently ('145 Patent, col. 7:31-35; Compl. ¶146). The invention provides a method where, in such a situation, the encoder predicts the motion data for the current block using only the motion data from neighboring blocks that share the same reference frame, saving calculation time and capacity (Compl. ¶¶143-144).
  • Asserted Claims: Claim 1 (Compl. ¶246).
  • Accused Features: The Accused Services’ backend encoding processes are alleged to infringe (Compl. ¶243).

U.S. Patent No. 9,800,891 - Method and Associated Device for Filtering Digital Video Images

  • Technology Synopsis: The patent addresses "blocking artefacts," visible edges that appear at the boundaries of blocks in compressed video ('891 Patent, col. 3:25-29; Compl. ¶153). Prior art filtering methods to remove these artefacts were indiscriminate and could remove real features of the image ('891 Patent, col. 3:54-57; Compl. ¶154). The invention provides an adaptive filter that adjusts its parameters based on the coding type of the blocks on either side of the boundary, allowing it to remove more artefacts without weakening real image edges (Compl. ¶155).
  • Asserted Claims: Claim 23 (Compl. ¶252).
  • Accused Features: The Accused Services’ backend encoding processes are alleged to infringe (Compl. ¶249).

U.S. Patent No. 6,856,701 - Method and System for Context-Based Adaptive Binary Arithmetic Coding

  • Technology Synopsis: The patent relates to Context-based Adaptive Binary Arithmetic Coding (CABAC), a form of entropy coding. It notes that prior CABAC methods were not optimal because they failed to account for relationships between the "run" and "level" values of transform coefficients ('701 Patent, col. 15:55-62; Compl. ¶166). The invention proposes an improved context model that considers the context assigned to a previously coded level value when assigning a context to the current level value, improving bitrate savings (Compl. ¶167).
  • Asserted Claims: Claim 1 (Compl. ¶258).
  • Accused Features: The Accused Services’ backend encoding processes are alleged to infringe (Compl. ¶255).

U.S. Patent No. 8,107,744 - Picture Buffering for Prediction References and Display

  • Technology Synopsis: The patent addresses buffering issues created by modern video standards that decouple the decoding order of pictures from their display order. Prior solutions proposed separate buffers for reference pictures and for display reordering, which was inefficient and stored pictures twice ('744 Patent, col. 3:32-36; Compl. ¶178). The invention provides for a unified buffer that holds both reference pictures and pictures awaiting display, reducing memory requirements (Compl. ¶179).
  • Asserted Claims: Claim 12 (Compl. ¶264).
  • Accused Features: The Accused Services’ backend encoding processes are alleged to infringe (Compl. ¶261).

U.S. Patent No. 8,776,204 - Secure Dynamic Authority Delegation

  • Technology Synopsis: This patent is in a different technical field from the others. It addresses problems with authority delegation protocols like OAuth, which were tied to HTTP, vulnerable to phishing, and required multiple round trips ('204 Patent, col. 1:32-44; Compl. ¶188). The invention provides a method for a resource requestor to dynamically obtain an authorization token from a resource owner in a single round trip via a request-response mechanism that can be bound to existing application protocols, not just HTTP (Compl. ¶189).
  • Asserted Claims: Claim 1 (Compl. ¶270).
  • Accused Features: The Accused Services’ user authentication processes are alleged to infringe (Compl. ¶3, ¶267).

III. The Accused Instrumentality

Product Identification

The "Accused Services" are identified as backend processes, including transcoding and encoding, used to provide videos to users and for user authentication (Compl. ¶3). These services support Paramount's streaming offerings, including Paramount+, Pluto TV, and BET+ (Compl. ¶4).

Functionality and Market Context

The complaint alleges that the Accused Services perform video compression to enable efficient delivery of high-quality video over the internet and cellular networks (Compl. ¶1, ¶4). This functionality is described as important to Paramount's ad-supported and subscription business models (Compl. ¶4). The complaint also implicates user authentication processes as part of the Accused Services (Compl. ¶3).

IV. Analysis of Infringement Allegations

The complaint states that claim charts are attached as exhibits but does not provide them. The following tables summarize the infringement theories for the lead patents based on the narrative allegations in the complaint and language from the patents themselves.

7,532,808 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
analyzing motion of a region surrounding a segment of an image to be coded... Paramount's Accused Services analyze the motion of macroblocks surrounding a current macroblock to determine the most efficient coding mode. ¶58 col. 14:23-28
determining, based on said analyzing, if said motion is characteristic of one of a zero motion and a non-zero motion; Based on the analysis of surrounding motion, the Accused Services determine whether to apply a skip mode with a zero motion vector or a non-zero motion vector that accounts for regional or global motion. ¶58 col. 14:28-32
and in response to said determining, associating a skip coding mode and one of a zero motion vector and a non-zero motion vector with said segment... The Accused Services assign the determined skip coding mode and its corresponding motion vector (zero or non-zero) to the macroblock being encoded in the video bitstream. ¶59 col. 14:48-51
  • Identified Points of Contention:
    • Scope Questions: A potential issue is whether the term "skip coding mode" as used in the patent, which involves a specific adaptive decision-making process based on surrounding motion, can be read to cover any mode in the Accused Services that results in not transmitting an explicit motion vector for a macroblock, regardless of the underlying decision process.
    • Technical Questions: A key question for the court may be what evidence exists that Paramount's encoders perform the explicit step of "analyzing motion of a region surrounding a segment" for the specific purpose of selecting a skip mode vector, as opposed to this outcome being the result of a more general rate-distortion optimization algorithm that is technically distinct from the claimed method.

6,950,469 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
when a value for a sub-pixel situated at a 1/2^N unit horizontal and 1/2^N unit vertical location is required, interpolating such a value by taking a weighted average of the value of a first sub-pixel or pixel...and the value of a second sub-pixel or pixel...located diagonally... The Accused Services, in performing motion-compensated prediction, must calculate sub-pixel values. This allegedly includes interpolating values for quarter-resolution sub-pixels by calculating a weighted average of values from diagonally located pixels and/or other sub-pixels. ¶69 col. 13:66-14:9
  • Identified Points of Contention:
    • Scope Questions: The construction of "weighted average" will be critical. The dispute may turn on whether this term requires a specific mathematical formula disclosed in the patent's embodiments or if it can be construed more broadly to cover any interpolation formula used by the Accused Services that combines values from diagonal locations.
    • Technical Questions: An evidentiary question may be whether the specific interpolation filters and algorithms used in Paramount's modern, standard-compliant encoders for calculating quarter-pixel values perform the function of taking a "weighted average" of two diagonally-situated points as required by the claim, or if they operate on a different technical principle (e.g., using a larger set of non-diagonal points).

V. Key Claim Terms for Construction

U.S. Patent No. 7,532,808

  • The Term: "analyzing motion of a region"
  • Context and Importance: This term is central to the novelty of the claimed invention. Infringement will depend on whether the Accused Services perform an explicit analysis of surrounding motion to make the skip-mode decision, or if they arrive at a similar result through a different computational method, such as a generalized cost-function analysis that does not isolate "analyzing motion" as a discrete step. Practitioners may focus on this term because it defines the core adaptive mechanism of the invention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Language describing the overall goal of adapting to motion could support a broader reading, where any process that results in an adaptive skip mode implicitly performs an "analysis" (Compl. ¶58).
    • Evidence for a Narrower Interpretation: The specification's description of making the decision by "analyzing the motion of other macroblocks or sub-blocks in a region surrounding the macroblock to be coded" suggests a specific, directed process rather than a general optimization ('808 Patent, col. 14:28-32).

U.S. Patent No. 6,950,469

  • The Term: "interpolating such a value by taking a weighted average of the value of a first sub-pixel or pixel ... and the value of a second sub-pixel or pixel ... located diagonally"
  • Context and Importance: This lengthy phrase constitutes the core technical step of claim 1. The infringement case for this patent likely rests on whether the accused encoders perform this specific type of diagonal interpolation. Practitioners may focus on this term because modern video standards (like H.264/H.265) use highly complex, standardized interpolation filters, and the dispute will be whether those standardized processes meet this claim limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim uses the general term "weighted average," which could be argued to cover a wide range of mathematical combinations, not just a simple arithmetic mean, potentially capturing various filter implementations (Compl. ¶73).
    • Evidence for a Narrower Interpretation: The specification provides specific examples and contexts, such as interpolating quarter-resolution sub-pixels from "a diagonally located pixel and sub-pixel or two diagonally located sub-pixels," which could be used to argue that the claim is limited to these specific scenarios or formulas ('469 Patent, col. 13:66-14:9).

VI. Other Allegations

Indirect Infringement

The complaint makes general allegations of indirect infringement but does not plead specific facts to support induced or contributory infringement beyond Paramount operating the Accused Services and deriving revenue from them (Compl. ¶195).

Willful Infringement

Willfulness is alleged based on pre-suit knowledge. The complaint asserts that Paramount had knowledge and notice of twelve of the asserted patents no later than December 7, 2022, and of the thirteenth patent no later than November 23, 2024 (Compl. ¶193, ¶266).

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

  • A central legal issue will be one of contractual obligation: are Nokia’s patents covering encoding techniques "essential" to the H.264/H.265 standards, and therefore subject to RAND licensing obligations as Paramount may argue, or are they non-essential implementation improvements as Nokia contends? The resolution of the declaratory judgment count will significantly impact the scope and potential damages in the case.
  • A key technical question will be one of functional correspondence: do Paramount’s modern, standards-compliant backend encoding and transcoding systems, which are the product of decades of industry-wide development, perform the specific, discrete steps recited in the asserted patents, many of which date to the early 2000s? The case will likely involve a deep technical dive into whether the accused processes operate in a manner that is merely equivalent in result or identical in method to what is claimed.
  • A significant procedural question will be one of case management: given that thirteen patents covering a wide range of distinct video processing technologies are asserted, the court will likely need to establish a process for narrowing the case to a manageable number of representative patents and claims for discovery and trial.