DCT
1:25-cv-01065
Lenovo United States Inc v. General Video LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lenovo (United States) Inc. (Delaware)
- Defendant: General Video, LLC (Delaware)
- Plaintiff’s Counsel: Morris, Nichols, Arsht & Tunnell LLP
- Case Identification: 1:25-cv-01065, D. Del., 08/22/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant General Video, LLC is a Delaware entity that resides in the district.
- Core Dispute: Plaintiff Lenovo seeks a declaratory judgment that its products do not infringe six patents owned by Defendant General Video and that the patents are invalid, following a prior lawsuit where General Video accused Lenovo products of infringement.
- Technical Context: The patents-in-suit relate to the encoding, transmission, and processing of digital video and audio data, technologies that are foundational to modern high-speed display interfaces such as DisplayPort.
- Key Procedural History: This action follows a lawsuit filed by General Video against Lenovo Group Limited (an affiliate of the Plaintiff) in the Eastern District of Texas, which was dismissed for lack of personal jurisdiction. Although not a party to that case, Plaintiff Lenovo (United States) Inc.'s products were accused of infringement. The current complaint incorporates by reference the invalidity contentions Lenovo served in the prior Texas litigation.
Case Timeline
| Date | Event |
|---|---|
| 1999-04-23 | Earliest Priority Date for ’443 and ’224 Patents |
| 2001-12-24 | Earliest Priority Date for ’437 Patent |
| 2002-06-13 | Earliest Priority Date for ’282 Patent |
| 2003-06-24 | ’443 Patent Issued |
| 2006-06-27 | ’224 Patent Issued |
| 2007-05-29 | ’282 Patent Issued |
| 2007-12-18 | Earliest Priority Date for ’010 and ’786 Patents |
| 2008-04-15 | ’437 Patent Issued |
| 2015-05-19 | ’010 Patent Issued |
| 2017-12-12 | ’786 Patent Issued |
| 2024-08-30 | General Video files E.D. Tex. Lawsuit |
| 2025-06-23 | Lenovo serves Invalidity Contentions in E.D. Tex. Lawsuit |
| 2025-08-11 | E.D. Tex. Lawsuit dismissed |
| 2025-08-22 | Complaint for Declaratory Judgment filed in D. Del. |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,359,437 - "Encoding method and system for reducing inter-symbol interference effects in transmission over a serial link," Issued 04/15/2008
The Invention Explained
- Problem Addressed: The patent describes transmitting encoded data over a serial link and addresses the problem of inter-symbol interference ("ISI"), a form of signal distortion where symbols interfere with subsequent symbols, which can increase bit error rates, particularly in high-speed transmissions ('437 Patent, Abstract).
- The Patented Solution: The invention proposes encoding data using a "robust subset" of the full set of available code words. This selected subset is chosen such that the resulting sequence of bits is less susceptible to ISI than a sequence encoded using the full set ('437 Patent, Abstract). The patent also describes a system where bursts of video data, auxiliary data (encoded with the robust subset), and control words are transmitted in a specific interleaved sequence over the serial link ('437 Patent, col. 22:5-21).
- Technical Importance: This encoding strategy aims to improve the reliability of high-speed digital video interfaces, such as DVI and HDMI, by reducing signal degradation during transmission ('437 Patent, col. 2:5-12).
Key Claims at a Glance
- The complaint specifically references independent claim 41 as not infringed (Compl. ¶12).
- Claim 41 recites a communication system including:
- Circuitry configured to receive input data and generate a "sequence of selected code words" by encoding the data.
- Each selected code word is a member of a "robust subset" of a full code word set.
- The sequence of selected code words is "less susceptible to inter-symbol interference" than a conventional sequence.
- A transmitter configured to transmit over a link a specific interleaved structure: a "first burst of the encoded control words between a first burst of the video code words and the burst of the selected code words, and a second burst of the encoded control words between the burst of the selected code words and a second burst of the video code words."
- The complaint seeks a declaratory judgment of non-infringement of any claim of the patent (Compl. ¶13).
U.S. Patent No. 9,036,010 - "Transport of stereoscopic image data over a display interface," Issued 05/19/2015
The Invention Explained
- Problem Addressed: The patent addresses the challenge of transmitting stereoscopic (3D) image data over existing digital display interfaces that were primarily designed for conventional 2D images, without requiring new hardware or sacrificing significant image resolution ('010 Patent, col. 1:47-55).
- The Patented Solution: The invention discloses a device with a "formatter" that can operate in at least two modes. In a second mode for stereoscopic content, the formatter generates a stream of data elements containing a "multiplexed combination of components of a stereoscopic image" (e.g., left-eye and right-eye data). This method is designed to fit within the "known data carrying capacity" of the existing interface, potentially by repurposing high-capacity 2D modes like "deep color" for 3D transport ('010 Patent, Abstract; col. 2:1-12).
- Technical Importance: This approach provided a pathway for delivering 3D video content to consumer devices like televisions and monitors using established interface standards, thereby supporting the market for 3D home entertainment ('010 Patent, col. 2:56-62).
Key Claims at a Glance
- The complaint specifically references independent claims 1 and 12 as not infringed (Compl. ¶17).
- Claim 1 recites a digital display interface part (transmitter side) comprising:
- A "formatter" operable in a "second mode" to generate a stream of "second data elements" carrying a "multiplexed combination of components of a stereoscopic image."
- These components are transmitted in a "first portion" and a "second portion" of the interface.
- Each portion has a "lesser data carrying capacity" than the interface's "known data carrying capacity," and their "combined data carrying capacity" is "no greater than" the known capacity.
- Claim 12 recites a corresponding interface part (receiver side) with a processor that "demultiplexes components of a stereoscopic image" from a stream of data elements with the same transmission and capacity constraints.
- The complaint seeks a declaratory judgment of non-infringement of any claim of the patent (Compl. ¶18).
U.S. Patent No. 9,843,786 - "Transport of stereoscopic image data over a display interface," Issued 12/12/2017
- Technology Synopsis: Related to the ’010 Patent, this patent describes a system for transporting stereoscopic image data over a display interface using a formatter that operates in different modes for 2D and 3D content. In the 3D mode, the formatter generates a stream of data elements containing a multiplexed combination of stereoscopic image components at different times than the 2D mode ('786 Patent, Abstract; Compl. ¶20).
- Asserted Claims: The complaint explicitly references independent claims 1 and 13 (Compl. ¶22).
- Accused Features: The complaint alleges that Lenovo products complying with DisplayPort standards are accused of infringement (Compl. ¶21).
U.S. Patent No. 7,225,282 - "Method and apparatus for a two-wire serial command bus interface," Issued 05/29/2007
- Technology Synopsis: This patent describes a method for transmitting data over a two-wire interface by "re-mapping" a data signal and a clock signal from a local bus protocol (like I²C) into a "different protocol signal." This new protocol is transmitted over the interface and then re-mapped back to the original local bus protocol at the receiver, a technique intended to overcome limitations like distance and speed inherent in the local bus standard ('282 Patent, Abstract).
- Asserted Claims: The complaint explicitly references independent claim 1 (Compl. ¶27).
- Accused Features: The complaint alleges that Lenovo products complying with DisplayPort standards are accused of infringement (Compl. ¶26).
U.S. Patent No. 6,584,443 - "Apparatus and method for audio data/audio-related information transfer," Issued 06/24/2003
- Technology Synopsis: This patent addresses transferring audio data that has been modified (e.g., sample rate converted) from its original format. The invention involves transmitting "audio-related information" alongside the audio data, where this information includes details about the original audio (such as its sampling frequency) as well as "monitor information" that indicates to the receiver whether the transmitted audio data is capable of being monitored (i.e., played back) (’443 Patent, Abstract; col. 2:36-44).
- Asserted Claims: The complaint explicitly references claims 7 and 9 (Compl. ¶32).
- Accused Features: The complaint alleges that Lenovo products complying with DisplayPort standards are accused of infringement (Compl. ¶31).
U.S. Patent No. 7,069,224 - "Receiver for receiving audio data and audio-related information," Issued 06/27/2006
- Technology Synopsis: This patent, related to the ’443 Patent, focuses on the receiver. It describes a receiver with an "analysis section" that determines from received "monitor information" whether the audio data is capable of being monitored. This allows the receiver to appropriately handle audio that may have been transmitted at a speed or in a format it cannot directly reproduce, for example by muting the output (’224 Patent, Abstract; col. 4:15-22).
- Asserted Claims: The complaint explicitly references claims 3 and 5 (Compl. ¶37).
- Accused Features: The complaint alleges that Lenovo products complying with DisplayPort standards are accused of infringement (Compl. ¶36).
III. The Accused Instrumentality
Product Identification
The complaint identifies the accused instrumentalities as a broad category of Lenovo-branded consumer electronics, including "desktop computers," "laptop computers," "computer monitors," and "video/graphics cards" (Compl. ¶11).
Functionality and Market Context
The central technical functionality at issue is the products' alleged compliance with, implementation of, or embodiment of DisplayPort standards for transmitting video and audio data (Compl. ¶11, ¶16). The complaint does not detail the specific operation of the accused products beyond this standards-based allegation. It notes that General Video's accusations in the prior Texas lawsuit encompassed "hundreds of Lenovo US products," suggesting a broad commercial scope for the dispute (Compl. ¶11).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
'437 Patent Infringement Allegations
| Claim Element (from Independent Claim 41) | Alleged Infringing Functionality (as denied by Lenovo) | Complaint Citation | Patent Citation |
|---|---|---|---|
| generat[e] a sequence of selected code words by encoding the input data, wherein each of the selected code words is a member of a robust subset of the full code word set, and the sequence of selected code words is less susceptible to inter-symbol interference... | The complaint asserts that the accused products do not generate code words using a "robust subset" of a full code set that is specifically selected to be less susceptible to inter-symbol interference as required by the claim (Compl. ¶12). | ¶12 | col. 22:4-10 |
| transmi[t] over the link a first burst of the encoded control words between a first burst of the video code words and the burst of the selected code words, and a second burst of the encoded control words between the burst of the selected code words and a second burst... | The complaint asserts that the accused products do not transmit data in the specific interleaved sequence required by the claim, where bursts of control words are placed between bursts of video code words and bursts of the specifically "selected code words" (Compl. ¶12). | ¶12 | col. 22:12-21 |
'010 Patent Infringement Allegations
| Claim Element (from Independent Claims 1 & 12) | Alleged Infringing Functionality (as denied by Lenovo) | Complaint Citation | Patent Citation |
|---|---|---|---|
| a second mode to generate a stream of second data elements which carry a multiplexed combination of components of a stereoscopic image...transmitted in a first portion...and in a second portion...each...having a lesser data carrying capacity...and a combined data carrying capacity no greater than said known data carrying capacity (Claim 1). | The complaint asserts that the accused products do not include a "formatter" (for transmitting) or a "processor" (for receiving) that operates in the claimed "second mode" to multiplex or demultiplex stereoscopic image components under the specific data capacity constraints recited for the "first portion" and "second portion" of the interface (Compl. ¶17). | ¶17 | col. 10:9-25 |
| in a second mode, the processor demultiplexes components of a stereoscopic image from a stream of second data elements... (Claim 12). | See above. | ¶17 | col. 11:1-17 |
Identified Points of Contention
- Technical Operation vs. Claim Scope: For the ’437 Patent, a central question is whether the encoding and data-packetizing schemes defined by the DisplayPort standard fall within the scope of the claim limitations "robust subset" and the specific interleaved burst structure. The analysis will depend on the technical evidence of how DisplayPort operates and the court's interpretation of the claim language.
- Definitional Scope: For the ’010 Patent, the dispute may turn on the construction of "multiplexed combination of components of a stereoscopic image" and the associated data capacity limitations for different "portions" of the interface. The question for the court will be whether the methods for handling 3D data in the DisplayPort standard meet these specific structural and functional requirements as defined in the patent.
V. Key Claim Terms for Construction
Patent: U.S. Patent No. 7,359,437
- The Term: "robust subset"
- Context and Importance: This term is central to the inventive concept of reducing ISI. Its construction will be critical to determining infringement. If construed broadly to mean any encoding that improves signal integrity, it may be more likely to read on the accused standard. If construed narrowly to require the specific selection criteria disclosed in the specification, infringement may be more difficult to establish.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent abstract describes the subset as one where the resulting bit pattern is "less susceptible to inter-symbol interference" than a conventional encoding, which could be argued as a functional definition ('437 Patent, Abstract).
- Evidence for a Narrower Interpretation: The abstract also suggests a structural basis, noting the selected words have "fewer contiguous zeros and ones" than non-selected words. A defendant may argue the term is limited to code words selected based on this specific property ('437 Patent, Abstract).
Patent: U.S. Patent No. 9,036,010
- The Term: "a first portion of said interface and...a second portion of said interface"
- Context and Importance: This language, which appears in claim 1, defines the structure over which the "multiplexed" stereoscopic data is transmitted. Practitioners may focus on this term because the infringement analysis will require mapping the architecture of the DisplayPort interface onto this "first portion" and "second portion" structure, which has specific data capacity limitations tied to it. The definition will determine if the physical or logical structure of DisplayPort matches the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to limit the "portions" to specific physical wires, which may support an argument that they can be logical divisions of a data stream.
- Evidence for a Narrower Interpretation: The detailed description and claims consistently tie these portions to specific data rate limitations relative to the interface's overall "known data carrying capacity," suggesting the terms are not arbitrary divisions but have specific, defined technical characteristics that must be met ('010 Patent, col. 10:18-25).
VI. Other Allegations
The complaint seeks a declaratory judgment of non-infringement and invalidity and does not contain allegations of indirect or willful infringement against the defendant.
VII. Analyst’s Conclusion: Key Questions for the Case
- Standards Compliance as Infringement: A core issue will be whether implementing the public DisplayPort standard necessarily results in infringement of the patents-in-suit. This will require a technical deep dive comparing the mandatory and optional features of the standard against the specific limitations of the asserted patent claims.
- Definitional Scope: The case will likely turn on claim construction. A primary question for the court will be one of technical definition: can the term "robust subset" in the ’437 patent, described in the context of reducing ISI, be construed to cover the standard encoding schemes used in DisplayPort? Similarly, does the specific "multiplexed" transport structure claimed in the ’010 patent read on the methods for handling 3D data within the DisplayPort standard?
- Invalidity and Prior Art: Lenovo’s declaratory judgment action includes a claim of invalidity and incorporates prior invalidity contentions. A key battleground will be the strength of the asserted patents against the backdrop of a crowded field of prior art related to digital video transmission and interface standards that existed before the patents' priority dates.