DCT
1:25-cv-01095
Ricoh Co Ltd v. Zoom Communications Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ricoh Company, Ltd. (Japan)
- Defendant: Zoom Communications, Inc. f/k/a Zoom Video Communications, Inc. (Delaware)
- Plaintiff’s Counsel: Ashby & Geddes; Norton Rose Fulbright US LLP
- Case Identification: 1:25-cv-01095, D. Del., 08/29/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware, conducts substantial business in the district, and has committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s cloud-based communication and collaboration platform, including its videoconferencing and interactive whiteboard products, infringes seven patents related to user interface management, data transmission, and session control in collaborative digital environments.
- Technical Context: The lawsuit involves technologies central to modern cloud-based videoconferencing and collaboration platforms, a market that enables remote communication and teamwork for enterprise and individual users.
- Key Procedural History: The complaint alleges Defendant had pre-suit knowledge of the asserted patents based on a notice letter sent on April 11, 2024. It further alleges that patents issued to Defendant cite members of one of the asserted patent families as prior art, which may be used to support allegations of awareness of Plaintiff's technology portfolio.
Case Timeline
| Date | Event |
|---|---|
| 2010-05-06 | U.S. Patent No. 10,931,917 Priority Date |
| 2011-02-28 | U.S. Patent No. 11,546,548 Priority Date |
| 2012-03-22 | U.S. Patent No. 11,256,464 Priority Date |
| 2012-08-01 | U.S. Patent No. 11,516,278 Priority Date |
| 2014-03-31 | U.S. Patent No. 10,909,059 Priority Date |
| 2015-05-09 | U.S. Patent No. 10,904,487 Priority Date |
| 2018-11-29 | U.S. Patent No. 11,289,093 Priority Date |
| 2021-01-26 | U.S. Patent No. 10,904,487 Issues |
| 2021-02-02 | U.S. Patent No. 10,909,059 Issues |
| 2021-02-23 | U.S. Patent No. 10,931,917 Issues |
| 2022-02-22 | U.S. Patent No. 11,256,464 Issues |
| 2022-03-29 | U.S. Patent No. 11,289,093 Issues |
| 2022-11-29 | U.S. Patent No. 11,516,278 Issues |
| 2023-01-03 | U.S. Patent No. 11,546,548 Issues |
| 2024-04-11 | Plaintiff allegedly sends Notice Letter to Defendant |
| 2025-08-29 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,904,487 - "Integration Of Videoconferencing With Interactive Electronic Whiteboard Appliances"
The Invention Explained
- Problem Addressed: The patent describes a technical problem arising from the "limited capability... to use other applications on interactive whiteboard appliances concurrent with the sharing of an electronic whiteboard" ('487 Patent, col. 2:33-37).
- The Patented Solution: The invention proposes an "application manager" that integrates a whiteboard application and a separate videoconferencing (or "collaboration") client on a single device ('487 Patent, col. 4:46-51). This manager provides graphical user interface controls that allow a user to launch and switch between the two functionalities, specifically by overlaying a videoconferencing window "on top of an interactive whiteboard session window" ('487 Patent, Abstract).
- Technical Importance: This approach enables the integration of two distinct collaborative functions on devices that may not have been natively designed to run them concurrently in a user-friendly manner (Compl. ¶16; '487 Patent, col. 3:12-16).
Key Claims at a Glance
- The complaint asserts independent claim 15 (Compl. ¶45).
- Essential elements of claim 15 include:
- Displaying an interactive whiteboard session window, on which a selection menu is overlaid for starting a video conference session.
- After receiving an instruction via that menu, overlaying a videoconference window on the interactive whiteboard session window.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 10,909,059 - "Transmission Terminal, Non-Transitory Recording Medium, Transmission Method, And Transmission System"
The Invention Explained
- Problem Addressed: The patent addresses the user interface challenge of conducting large-scale videoconferences where displaying video feeds from all participants simultaneously is impractical due to screen size limitations ('059 Patent, col. 33:45-54).
- The Patented Solution: The invention is a method for a user's terminal that simultaneously displays two types of information: (1) video feeds from a subset of participating terminals and (2) information indicating the total number of all terminals participating in the conference ('059 Patent, Abstract). This ensures the user is aware of the full scope of the meeting even when not all participants are visible.
- Technical Importance: This method improves a user's situational awareness in large virtual meetings, providing context about the meeting's scale without cluttering the display with an unmanageable number of video tiles (Compl. ¶16).
Key Claims at a Glance
- The complaint asserts independent claims 4 and 6 (Compl. ¶¶68-69).
- Essential elements of claim 4 include:
- Displaying, on a screen, information concerning a total number of participating transmission terminals.
- Also displaying respective sets of image data transmitted from participating terminals.
- The number of displayed sets of image data is smaller than the total number of participating terminals.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 10,931,917 - "Transmission Terminal, Transmission Method, And Computer-Readable Recording Medium Storing Transmission Program"
- Technology Synopsis: The patent describes a method for a first transmission terminal in a video conference to incorporate video from an external device (e.g., a smartphone) that is not logged into the conference management system. The first terminal transmits its own primary video data and, upon connection of the external device, also transmits the secondary video data received from that device for sharing with other conference participants (Compl. ¶93).
- Asserted Claims: Independent claim 8 (Compl. ¶93).
- Accused Features: The complaint accuses Zoom's screen mirroring functionality, where a user in a Zoom Room can connect an external device like an iPhone to share its screen content concurrently with the main room's video feed (Compl. ¶¶104-105).
U.S. Patent No. 11,256,464 - "Communication System, Communication Device, And Computer Program"
- Technology Synopsis: The patent addresses display management for a device with first and second displays. The method involves displaying captured video images on the first display while a third image (e.g., shared content) is shown on the second. When the sharing of the third image finishes, the system automatically controls the second display to show nothing, while the first display continues to show the captured video images (Compl. ¶119).
- Asserted Claims: Independent claim 5 (Compl. ¶119).
- Accused Features: The complaint accuses Zoom's handling of dual-display configurations (e.g., on a DTEN D7 device with an HDMI output), alleging it practices the claimed method for automatically managing screen content when a user stops sharing their screen or a document (Compl. ¶¶129-130).
U.S. Patent No. 11,289,093 - "Apparatus, System, And Method Of Display Control, And Recording Medium"
- Technology Synopsis: The technology involves synchronizing a media playback with its corresponding text transcript. A graphical control region (e.g., a seek bar) is displayed, and when a user selects a portion of the displayed text transcript, the system determines the corresponding time and moves the graphical control region to that position in the media playback (Compl. ¶144).
- Asserted Claims: Independent claim 17 (Compl. ¶144).
- Accused Features: Zoom's Cloud Recording feature, which includes an "Audio Transcript," is accused. The complaint alleges that when a user clicks on a block of text in the transcript, the video playback jumps to the corresponding point in time (Compl. ¶¶153-155).
U.S. Patent No. 11,516,278 - "Transmission Management System, Transmission System, And Recording Medium"
- Technology Synopsis: The patent describes a method for updating a participant's name during a meeting. The system reads a user's first name from memory, transmits it to a terminal in the meeting, receives an updated second name from that terminal, and stores the second name in association with the meeting information (Compl. ¶170).
- Asserted Claims: Independent claim 16 (Compl. ¶170).
- Accused Features: The complaint accuses the feature in Zoom Meetings that allows a user to change their display name during a session (Compl. ¶¶179-181).
U.S. Patent No. 11,546,548 - "Transmission Management Apparatus"
- Technology Synopsis: The technology relates to managing and distributing attendance state information in a video communication. The method involves updating and storing the attendance state (e.g., "attending") and identification name for multiple terminals, acquiring this information from storage, and transmitting it to a first terminal so it can display a list of sites attending the communication and their corresponding video images (Compl. ¶195).
- Asserted Claims: Independent claim 9 (Compl. ¶195).
- Accused Features: The complaint accuses Zoom's system for managing and displaying participant presence and status information, as embodied in features like the "Participants" list (Compl. ¶¶201, 206-208).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are cloud-based communication and collaboration products and services offered under the "Zoom Workplace" platform (formerly "Zoom One"), including but not limited to Zoom Meetings, Zoom Rooms, Zoom Team Chat, Zoom Whiteboard, and Zoom Cloud Recording (Compl. ¶¶27, 29, 31).
Functionality and Market Context
The accused products provide a suite of tools for virtual meetings, webinars, and collaboration, accessible via web portals and downloadable applications (Compl. ¶26). The complaint alleges these services are used on various devices, including computers, mobile devices, and dedicated conference room hardware such as DTEN interactive displays (Compl. ¶¶28, 32). The platform is described as enabling users to conduct virtual meetings and collaborative sessions for both individual and enterprise customers (Compl. ¶26). A screenshot from Zoom's website illustrates the breadth of the "Zoom Workplace" platform, showing integrated tools for meetings, chat, whiteboard, and other services (Compl. p. 7).
IV. Analysis of Infringement Allegations
U.S. Patent No. 10,904,487 Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an interactive whiteboard session window, including at least an interactive whiteboard session content area, to be displayed on a display of a whiteboard device, wherein a selection menu to receive an instruction for starting a video conference session is overlaid on the interactive whiteboard session window; | When a user selects the "Whiteboard" icon in the Zoom interface, an interactive whiteboard session window is opened on the display. A selection menu, which includes a "START MEETING" option, is allegedly overlaid on this window. A diagram illustrates that selecting "START MEETING" from the overlaid menu results in a videoconference window appearing on top of the whiteboard session (Compl. p. 14). | ¶¶51-52 | col. 5:40-54 |
| and after receiving the instruction for starting the video conference session via the selection menu overlaid on the interactive whiteboard session window, a videoconference window to be overlaid on the interactive whiteboard session window. | After the user selects the "START MEETING" option from the overlaid menu, the accused products start a video conference session, and a videoconference window is then overlaid on the interactive whiteboard session window. | ¶¶53-54 | col. 6:45-53 |
Identified Points of Contention
- Scope Questions: A central question may be whether the persistent menu bar shown in the complaint's evidence (Compl. p. 13) qualifies as a "selection menu... overlaid on the interactive whiteboard session window" as required by the claim. The defense could argue that the patent's figures (e.g., '487 Patent, Fig. 3B) depict a distinct, floating pop-up menu, whereas the accused product uses an integrated, persistent toolbar, raising a question of definitional scope.
- Technical Questions: The patent describes an "application manager" that coordinates separate whiteboard and collaboration applications. The complaint accuses Zoom's integrated platform. A potential point of contention is whether Zoom's unified software architecture performs the claimed method steps of displaying and overlaying distinct "windows," or whether it operates as a single application with different view panes, creating a potential mismatch in technical operation.
U.S. Patent No. 10,909,059 Infringement Allegations
| Claim Element (from Independent Claim 4) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| displaying on a screen of the transmission terminal, information concerning a total number of transmission terminals participating in the video conference, | The accused products display on the screen a total number of participants in a video conference. The complaint provides a screenshot showing a total participant count of 52. | ¶75 | col. 18:3-10 |
| and displaying, on the screen of the transmission terminal, respective sets of image data transmitted by transmission terminals participating in the video conference to each other, | The accused products simultaneously display the video feeds (sets of image data) from various participants in the conference, as shown in the gallery view screenshot. A screenshot depicts a Zoom gallery view showing numerous participant videos, with an annotation pointing to the displayed total number of participants (Compl. p. 19). | ¶75 | col. 33:45-50 |
| wherein a number of the sets of image data, transmitted by transmission terminals participating in the video conference to each other, to display on the screen of the transmission terminal is smaller than the total number of transmission terminals participating in the video conference. | The complaint alleges that the number of displayed video feeds (e.g., 49) is smaller than the total number of participants in the conference (e.g., 52). | ¶76 | col. 35:20-29 |
Identified Points of Contention
- Scope Questions: A potential dispute could arise over the meaning of "transmission terminals." A defendant might argue that the displayed participant count reflects user accounts, not necessarily the technical "transmission terminals" required by the claim, though this distinction may be difficult to maintain in practice.
- Technical Questions: The infringement allegation appears to map directly onto the described functionality. The primary technical question for the court will be to verify the factual accuracy of the complaint's description of how the Zoom platform operates with respect to displaying participant counts and video feeds in large meetings.
V. Key Claim Terms for Construction
The Term: "overlaid on the interactive whiteboard session window" (from '487 Patent, claim 15)
- Context and Importance: The infringement theory for the '487 Patent depends on the specific spatial and hierarchical relationship between three UI elements: the whiteboard window, the selection menu, and the video window. The definition of "overlaid" will be critical in determining whether Zoom's integrated UI, which may present these elements as panes or toolbars within a single application frame, meets the claim's structural requirements.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification uses the phrase "on top of" when describing the relationship between the videoconferencing window and the whiteboard window ('487 Patent, col. 3:5-7), which could support an interpretation where any element appearing visually above another, without necessarily being a separate, floating window, meets the "overlaid" limitation.
- Evidence for a Narrower Interpretation: Figure 3B of the '487 Patent explicitly depicts the "Collaboration Menu 312" as a distinct, floating dialog box that is superimposed on the "Interactive Whiteboard Session Content Area 304." This visual embodiment may support a narrower construction requiring a separate UI element that is temporarily placed over the primary window, rather than an integrated toolbar.
The Term: "information concerning a total number of transmission terminals" (from '059 Patent, claim 4)
- Context and Importance: Practitioners may focus on this term because the infringement allegation relies on the participant count displayed in the Zoom interface satisfying this limitation. The dispute will center on whether a simple integer (e.g., "52") constitutes "information concerning" the total number of technical "terminals," or if the claim requires something more specific.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's detailed description and figures repeatedly refer to displaying the "number of bases" or "number of participants" in a designated area of the screen ('059 Patent, FIG. 18, element ar2; col. 23:7-14). This suggests that a numerical count is precisely what the inventors contemplated.
- Evidence for a Narrower Interpretation: The complaint does not provide sufficient detail for analysis of intrinsic evidence that would support a narrower interpretation. The patent's own examples appear to support that a numerical count is sufficient.
VI. Other Allegations
Indirect Infringement
The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on allegations that Defendant provides its software for download and provides instructions, advertisements, and technical support that encourage infringing use (e.g., Compl. ¶¶56, 81). Contributory infringement is based on the allegation that the accused products are a material part of the claimed inventions and are not staple articles of commerce suitable for substantial non-infringing use (e.g., Compl. ¶¶57, 82).
Willful Infringement
Willfulness is alleged for all asserted patents. The claims are based on alleged pre-suit and post-suit knowledge. Pre-suit knowledge is alleged to stem from an April 11, 2024 notice letter, as well as from citations to Plaintiff’s patent family in Defendant’s own issued patents (Compl. ¶¶33, 36). Continued infringement after the filing of the complaint forms the basis for post-suit willfulness allegations (e.g., Compl. ¶59).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical and definitional scope: can claims drafted in the context of managing separate applications and windows (as in the '487 Patent) be construed to cover the functionality of a modern, highly integrated software platform like Zoom Workplace, where features such as whiteboarding and video may coexist as panes or elements within a single application interface rather than as distinct, overlaid windows?
- A central validity question will be one of obviousness: for patents claiming features that are now common in the industry, such as displaying a participant count ('059 Patent) or allowing users to rename themselves during a meeting ('278 Patent), the case will likely turn on whether these inventions represented a non-obvious step over the prior art at the time of their respective priority dates.
- A key evidentiary question will be one of functional operation: for method claims covering user interactions, such as synchronizing a transcript with video playback ('093 Patent) or incorporating an external video source ('917 Patent), the analysis will require a detailed examination of whether the accused products perform the specific sequence of receiving, processing, and transmitting steps as recited in the claims, or if they achieve a similar result through a technically distinct process.