Intent Iq LLC v. Samba TV Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Intent IQ, LLC (Delaware)
  • Defendant: Samba TV, Inc. (Delaware)
  • Plaintiff’s Counsel: Farnan LLP
• Case Identification: 1:25-cv-01084, D. Del., 08/28/2025
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is incorporated under the laws of the State of Delaware.
• Core Dispute: Plaintiff alleges that Defendant’s cross-device advertising and attribution platform infringes patents related to methods for linking user activity across different network-connected devices for targeted advertising and measurement.
• Technical Context: The dispute centers on cross-device identity resolution, a technology domain critical to the digital advertising industry for identifying a single user across their various devices (e.g., television, smartphone, laptop) to enable coherent ad campaigns and measure their effectiveness.
• Key Procedural History: The front pages of the asserted patents indicate they are part of an extensive family of continuing applications and are subject to terminal disclaimers, a factor that may be relevant to potential validity or damages analyses by limiting the patents' effective term.

Case Timeline

Date	Event
2007-04-17	U.S. Patent No. 8,677,398 Priority Date
2007-12-31	U.S. Patent No. 10,321,198 Priority Date
2011-08-03	U.S. Patent No. 11,949,962 Priority Date
2014-03-18	U.S. Patent No. 8677398 Issues
2019-06-11	U.S. Patent No. 10321198 Issues
2024-04-02	U.S. Patent No. 11949962 Issues
2025-08-28	Complaint Filed

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

U.S. Patent No. 8,677,398 - systems and methods for taking action with respect to one network-connected device based on activity on another device connected to the same network

The Invention Explained

• Problem Addressed: The patent's background section describes the technical challenge of targeting television advertisements based on a user's observed online behavior, particularly without employing personally identifiable information (PII) to link the user's disparate devices, such as a computer and a television set-top box (’398 Patent, col. 1:16-22, col. 7:19-27).
• The Patented Solution: The invention claims a method for electronically associating the IP addresses of online access devices (e.g., modems for computers) with the IP addresses of television set-top boxes (STBs) (’398 Patent, Abstract). This association is based on recognizing when the two devices are connected to a "common local area network" (’398 Patent, cl. 1). Based on this link, profile information derived from online activity on the first device is used to select and direct a television advertisement to the second device (the STB) (’398 Patent, Abstract).
• Technical Importance: The described technology provides a method for cross-device advertising that can operate using network-level identifiers (IP addresses) rather than personal user data, addressing a key privacy and technical hurdle in the ad-tech industry (’398 Patent, col. 8:8-12).

Key Claims at a Glance

• The complaint asserts independent method claim 1 of the ’398 Patent (Compl. ¶13).
• The essential elements of independent claim 1 include:
  • Receiving an electronic identifier of a first device.
  • Automatically generating and storing an association between the first device's identifier and a second device's identifier based on recognizing that both devices were connected to a common local area network.
  • Based on that association, sending a transmission that causes an action to be taken with respect to the second device, where the action is based on profile data from the first device.
• The complaint reserves the right to assert other "one or more method claims" (Compl. ¶10).

U.S. Patent No. 10,321,198 - systems and methods for dealing with online activity based on delivery of a television advertisement

The Invention Explained

• Problem Addressed: The patent addresses the challenge of measuring the impact of a television advertisement by tracking a viewer's subsequent online behavior, a process known as attribution, especially when different devices are used for each activity and PII is to be avoided (’198 Patent, col. 1:15-21).
• The Patented Solution: The invention describes a method where a computer system receives a "notification" that a television advertisement was presented on a specific set-top box (identified by an STB identifier) (’198 Patent, cl. 1). Based on this notification, the system then takes an action (such as directing a targeted ad or tracking activity) with respect to an online device that is associated with that STB identifier, but without using PII to make the link (’198 Patent, cl. 1, Abstract).
• Technical Importance: This technology provides a framework for advertisers to measure the return on investment of television ad campaigns by connecting them to specific online actions, a crucial capability in modern media analytics (’198 Patent, col. 9:16-24).

Key Claims at a Glance

• The complaint asserts independent method claim 1 of the ’198 Patent (Compl. ¶23).
• The essential elements of independent claim 1 include:
  • Receiving a notification at a computer system that includes or references a first set-top box identifier and signifies that a television ad was presented on that set-top box.
  • Using the notification to automatically cause an action to be taken with respect to online activity on a first online user interface device.
  • The online device identifier and the set-top box identifier are associated without using personally identifiable information.
• The complaint reserves the right to assert other "one or more method claims" (Compl. ¶20).

U.S. Patent No. 11,949,962 - method and computer system using proxy IP addresses and PII in measuring ad effectiveness across devices

• Patent Identification: U.S. Patent No. 11,949,962, "method and computer system using proxy IP addresses and PII in measuring ad effectiveness across devices," issued April 2, 2024 (Compl. ¶29).
• Technology Synopsis: This patent discloses a method for measuring ad effectiveness by associating a primary online device (OD1) with a set-top box (STB) and using the location of OD1 as a "proxy location" for the STB. Other secondary online devices (OD2s) observed near this proxy location are then also associated with the STB, enabling TV ad selection for the STB to be based on profile information from any of the associated online devices (’962 Patent, Abstract; col. 10:1-14).
• Asserted Claims: The complaint asserts independent method claim 1 (Compl. ¶33).
• Accused Features: The complaint accuses components of the Samba TV platform, such as its identity graph, cross-device graph, and attribution services, of infringing the ’962 patent (Compl. ¶30).

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Instrumentalities" as the "Samba TV platform" and its components, including "Samba TV Identity, Samba TV Advertising ID and/or SambaID, Content Viewership and Ad Exposure Information, household identity graph, Screen6 cross-device graph, Samba Automatic Content Recognition, Samba TV Identity graph, and Omniscreen attribution" (Compl. ¶¶10, 20, 30).

Functionality and Market Context

The complaint alleges that the Accused Instrumentalities constitute a platform for "cross-device-based ad targeting, retargeting, audience extension, and attribution" (Compl. ¶3). This platform is alleged to identify a given user across multiple device types, including televisions and online devices, to aggregate profile data and deliver targeted ads (Compl. ¶3). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits comparing the asserted independent claims to the Accused Instrumentalities but does not include these exhibits in the provided documents (Compl. ¶¶13, 23, 33). The narrative infringement theory is that the Accused Instrumentalities, by creating a "Dynamic Device Map" to identify users across devices for targeted advertising and attribution, perform all the steps of the asserted method claims (Compl. ¶¶3, 13, 23, 33). The complaint does not, however, provide specific factual allegations detailing how the accused Samba TV platform components are alleged to meet each element of the asserted claims.

• Identified Points of Contention:
  • Scope Questions: A central question for the ’398 Patent will be the construction of "common local area network." The infringement analysis may turn on whether Samba TV’s method of associating devices through its "household identity graph" meets this claim limitation, which the patent often exemplifies with devices sharing a single public IP address (Compl. ¶10; ’398 Patent, Fig. 3).
  • Technical Questions: For the ’198 Patent, the dispute may focus on the "notification... [that] signifies a... television advertisement presented" element. The case will require evidence on the technical operation of Samba TV's "Automatic Content Recognition" and "Content Viewership" data products to determine if the data they generate constitutes the specific type of notification required by the claim (Compl. ¶20).

V. Key Claim Terms for Construction

• The Term: "common local area network" (’398 Patent, cl. 1).

• Context and Importance: This term is the basis for associating the two devices in the ’398 Patent. Its definition is critical because it determines what types of technical connections between devices fall within the claim scope. Practitioners may focus on this term because modern cross-device graphs may use signals beyond a shared IP address to associate devices within a household.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes a system where television and internet services may be provided by separate entities, which may suggest that the invention is not strictly limited to environments where devices are physically wired together (’398 Patent, Fig. 7).
  • Evidence for a Narrower Interpretation: Claim 1 requires devices be "connected to" the network. Figures in the patent depict a direct connection between a modem and a set-top box, and the specification frequently uses the sharing of a single "common IP address" as the mechanism for recognition, which could support a narrower construction limited to devices on the same physical LAN (’398 Patent, Fig. 3, col. 13:9-12).

• The Term: "notification... [that] results from and signifies a first television advertisement presented" (’198 Patent, cl. 1).

• Context and Importance: This term defines the causal trigger for the claimed attribution method. The dispute will likely center on what kind of data signal qualifies as a "notification" that both "results from" and "signifies" an ad presentation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The abstract describes the underlying data as being "automatically collected data related to user behavior with respect to" a TV ad, which could support an argument that general viewership data collected via technologies like Automatic Content Recognition qualifies as the claimed "notification" (’198 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The claim language "results from and signifies" suggests a direct causal link and a specific meaning. This could support a narrower interpretation requiring a purpose-built signal generated by the set-top box specifically to report that a particular ad was shown, rather than raw viewership data from which an ad presentation might be inferred.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant "directs and controls use of the Accused Instrumentalities to perform acts that result in infringement," which supports a claim for induced infringement (Compl. ¶¶11, 21, 31).
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the Asserted Patents and the alleged infringement continuing "at least as a result of the filing and service of this Complaint" (Compl. ¶¶12, 22, 32). The prayer for relief requests a finding of "post-suit willful infringement" (Compl. p. 8).

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

• A core issue will be one of definitional scope: can the term "common local area network" from the ’398 Patent, which is rooted in the context of shared network hardware, be construed to cover modern device associations made by a probabilistic or deterministic "identity graph" using a variety of signals?
• A key evidentiary question will be one of technical mechanism: what evidence will be presented to show that Samba TV's data collection methods generate a specific "notification" that "results from and signifies" a TV ad presentation as required by the ’198 Patent, or is there a fundamental mismatch in the alleged and actual technical operation of its attribution platform?