DCT

1:25-cv-01084

Intent Iq LLC v. Samba TV Inc

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01084, D. Del., 12/31/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s cross-device advertising and attribution platform infringes four patents related to network-based advertising systems and methods that link user activity across different devices.
  • Technical Context: The technology at issue involves identifying a single user across multiple devices (e.g., smart TVs, laptops, smartphones) to enable cross-device advertising, a practice central to the modern digital advertising market for measuring ad effectiveness and delivering targeted content.
  • Key Procedural History: The complaint is a First Amended Complaint. No other significant procedural events, such as prior litigation or administrative challenges to the patents, are mentioned.

Case Timeline

Date Event
2007-12-31 Earliest Priority Date for U.S. Patent Nos. 10,321,198 and 12,457,388
2011-08-03 Earliest Priority Date for U.S. Patent No. 11,949,962
2014-03-18 U.S. Patent No. 8,677,398 Issued
2019-06-11 U.S. Patent No. 10,321,198 Issued
2024-04-02 U.S. Patent No. 11,949,962 Issued
2024-04-02 U.S. Patent No. 12,457,388 Issued
2025-12-31 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,* issued March 18, 2014

The Invention Explained

  • Problem Addressed: The patent addresses the technical challenge of targeting advertisements across different media (e.g., from an internet device to a television) without relying on personally identifiable information (PII) to link the devices (’398 Patent, col. 1:15-22).
  • The Patented Solution: The invention proposes a method where a computer system automatically recognizes when two different devices (e.g., a computer and a set-top box) are connected to the same "common local area network." This network-based association allows an action, such as delivering a targeted advertisement, to be taken on the second device based on a user's activity on the first device (’398 Patent, col. 10:2-15).
  • Technical Importance: This approach provided a method for cross-device advertising that could function in environments with dynamic IP addresses and potentially avoid the privacy concerns associated with using PII to track users across devices (’398 Patent, col. 1:49-55).

Key Claims at a Glance

  • The complaint asserts independent method claim 1 (Compl. ¶12).
  • Essential elements of independent claim 1 include:
    • Automatically generating and storing electronic indicia of an association between a first device identifier and a second device identifier based on automatically recognizing that each device was connected to a common local area network.
    • The computer system performing this recognition is not itself on the local area network.
    • Based on this association, sending an electronic transmission that causes an action to be taken on the second device, where the action is based on profile data from the first device.
  • The complaint does not explicitly reserve the right to assert dependent claims for the ’398 Patent.

U.S. Patent No. 10,321,198 - *systems and methods for dealing with online activity based on delivery of a television advertisement,* issued June 11, 2019

The Invention Explained

  • Problem Addressed: The patent addresses the technological impediments to cross-media ad targeting created by the prevalent use of dynamic device addresses, which makes it difficult to link a user's television and online activities over time (’198 Patent, col. 9:8-14).
  • The Patented Solution: The invention describes a method where a notification is received signifying that a television advertisement was presented on a device associated with a "first set-top box identifier." Based on that notification, an action (such as tracking online activity or delivering a targeted online ad) is taken on a user's "online user interface device" (e.g., a computer). The core of the solution is the association between the "set-top box identifier" and the "online user interface device identifier" without using PII (’198 Patent, Abstract; col. 9:31-48). Figure 1 illustrates a system architecture with an ISP, a TVP, a user's computer, and a set-top box (STB) connected to a TV (’198 Patent, Fig. 1).
  • Technical Importance: The technology enables advertisers to measure the effectiveness of television ads by observing subsequent online activity or to reinforce a TV ad campaign with follow-up online ads, bridging two distinct advertising ecosystems (’198 Patent, col. 16:20-31).

Key Claims at a Glance

  • The complaint asserts independent method claim 1 (Compl. ¶21).

  • Essential elements of independent claim 1 include:

    • Receiving a notification that includes or references a "first set-top box identifier" and signifies a television advertisement was presented using that set-top box.
    • Using the notification to automatically cause a "first action" (e.g., delivering an ad or tracking activity) with respect to an online user interface device.
    • The association between the online user interface device identifier and the set-top box identifier is performed "without using personally identifiable information."

  • The complaint does not explicitly reserve the right to assert dependent claims for the ’198 Patent.
    Multi-Patent Capsule: U.S. Patent No. 11,949,962

  • 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. ¶27).

  • Technology Synopsis: The patent describes a method for associating multiple online devices with a single set-top box (STB). A primary online device is first associated with the STB, establishing a "proxy location" for the STB. Secondary online devices observed near this proxy location are then also associated with the STB, allowing a television advertisement to be selected for the STB based on profile information linked to one of these secondary devices (’962 Patent, Abstract).

  • Asserted Claims: The complaint asserts independent method claim 1 (Compl. ¶30).

  • Accused Features: The complaint accuses the Samba TV platform and its related components, such as its identity graph and attribution services, of infringement (Compl. ¶28).
    Multi-Patent Capsule: U.S. Patent No. 12,457,388

  • Patent Identification: U.S. Patent No. 12,457,388, recording online activity based on viewing or interacting with television advertisements, issued April 2, 2024 (Compl. ¶36).

  • Technology Synopsis: The patent discloses a method for tracking a user's online activity following the viewing of, or interaction with, a television advertisement. A computer system receives a notification referencing a "set-top box identifier" that signifies a TV ad was presented, and based on this, it records online activity from an associated online device without using PII to link the two (’388 Patent, Abstract).

  • Asserted Claims: The complaint asserts independent method claim 1 (Compl. ¶39).

  • Accused Features: The complaint accuses Samba TV's equipment and platform components, including its identity graph and content recognition technology, of infringement (Compl. ¶37).

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Instrumentalities" as the Samba TV platform and its related components (Compl. ¶10). These components include, but are not limited to, Samba TV Identity, Samba TV Advertising ID, 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, ¶19, ¶28, ¶37).

Functionality and Market Context

The complaint alleges these components collectively form a platform for cross-device ad targeting, retargeting, and attribution (Compl. ¶3, ¶10). This functionality allows for identifying a user across multiple devices, including televisions and online devices, to deliver targeted advertising and measure its impact. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement allegations (Compl. ¶12, ¶21, ¶30, ¶39). The narrative infringement theory is summarized below.

’398 Patent Infringement Allegations
The complaint alleges that the Accused Instrumentalities directly infringe one or more method claims of the ’398 patent (Compl. ¶10, ¶12). The theory suggests that the Samba TV platform performs the claimed method of identifying different devices (such as a smart TV and a mobile phone) on a common local area network, creates an association between them, and uses this association to take an action (such as delivering a targeted ad) on one device based on activity observed on the other.

’198 Patent Infringement Allegations
The complaint alleges that the Accused Instrumentalities perform all limitations of one or more method claims, including claim 1, of the ’198 patent (Compl. ¶19, ¶21). The narrative suggests that the Samba TV platform receives data indicating a television advertisement was viewed on a device (e.g., a smart TV running Samba's software), and uses this information to cause an action, such as tracking or advertising, on an associated online device without using PII for the linkage.

  • Identified Points of Contention:
    • Scope Questions: A central question for the ’198 and ’388 patents may be whether an identifier for integrated software on a smart TV, such as Samba TV's Automatic Content Recognition technology, qualifies as a "set-top box identifier" as the term is used in the claims. A similar question for the ’398 patent may be what constitutes a "common local area network" and whether the accused system's method of recognition meets the claim requirements.
    • Technical Questions: A key evidentiary question may be what proof demonstrates that the Accused Instrumentalities perform the claimed associations "without using personally identifiable information" (’198 Patent, Claim 1). The complaint alleges this functionality but does not provide public-facing technical details on how the Samba TV platform achieves this separation.

V. Key Claim Terms for Construction

  • The Term: "set-top box identifier" (’198 Patent, Claim 1)

    • Context and Importance: This term is critical because the accused platform primarily operates through software integrated into smart TVs, not necessarily separate physical boxes. The defendant may argue that its system therefore does not use a "set-top box" or its identifier, while the plaintiff may argue for a broader, functional definition.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The ’198 patent specification provides an explicit, broad definition, stating, "Nor is it necessary that the STB be a box, literally. Rather, a STB might be implemented, for example, as a circuit board, integrated circuit, set of integrated circuits, or software that is physically integrated with another 'box,' such as the television..." (’198 Patent, col. 2:23-29).
      • Evidence for a Narrower Interpretation: Parties seeking a narrower construction could point to the plain meaning of "set-top box" as a separate physical device or to patent figures that depict the STB (36) as a distinct component from the TV (38) (’198 Patent, Fig. 1).

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

    • Context and Importance: The infringement reading of the ’398 patent depends on the accused system's ability to recognize that two devices are on the same local network. The definition of this term will determine whether the claim covers modern home networking environments, which may include mesh systems, multiple access points, or guest networks that complicate the notion of a single "common" network. Practitioners may focus on this term because the method of "recognizing" this connection is a core element of the asserted claim.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The complaint does not cite specific portions of the ’398 patent specification, but a party could argue that the patent's goal of enabling cross-device communication implies a functional definition that includes any configuration allowing devices in a single location to communicate via a shared internet connection point.
      • Evidence for a Narrower Interpretation: A party could point to embodiments or figures in the patent that illustrate a simple, single-router setup as evidence that the claim scope is limited to such basic network architectures.

VI. Other Allegations

  • Willful Infringement: The complaint alleges willful infringement for all four asserted patents. The basis for this allegation is knowledge of the patents and the alleged infringement obtained "at least the filing and service of this Complaint" (Compl. ¶11, ¶20, ¶29, ¶38). The allegation is based on alleged continued infringement after the defendant was put on notice by the lawsuit itself.

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

  • A core issue will be one of definitional scope: can the term "set-top box identifier," as defined and used in the asserted patents, be construed to cover identifiers for software, such as Automatic Content Recognition technology, that is integrated directly into modern smart televisions rather than housed in a separate physical box? The explicit and broad definition of "STB" in the ’198 patent's specification will be a central piece of evidence in this dispute.
  • A second central issue will be one of evidentiary proof: what technical evidence will emerge from discovery to substantiate the complaint’s allegation that the Samba TV platform performs the specific steps of the asserted method claims? In particular, the case may turn on evidence demonstrating how the accused system associates devices across a network and whether it does so "without using personally identifiable information," a key limitation in several of the asserted claims.