Gamehancement LLC v. Figma Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Gamehancement LLC (Delaware)
  • Defendant: Figma, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01277, D. Del., 10/20/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that unspecified products from Defendant infringe a patent related to methods for controlling the visual presentation of data, particularly transitions between different display states.
• Technical Context: The technology at issue concerns systems for managing visual presentations, such as slideshows or video productions, by pre-defining aesthetic transition effects between different screen layouts or "states."
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 7,102,643 - Method and apparatus for controlling the visual presentation of data

• Patent Identification: U.S. Patent No. 7,102,643, issued September 5, 2006 (’643 Patent).

The Invention Explained

• Problem Addressed: The patent describes a problem in creating professional-quality multimedia presentations where presenters may deviate from a planned sequence of slides (’643 Patent, col. 2:4-24). In such cases, prior art systems would either use an inappropriate, pre-planned transition effect or a jarring default transition (e.g., a "straight cut"), detracting from the presentation's quality and distracting the audience (’643 Patent, col. 2:11-24).
• The Patented Solution: The invention proposes a system that associates a specific transition effect with every potential pair of "display configuration states" (’643 Patent, col. 2:50-57). By pre-defining an appropriate transition for any possible sequence (e.g., from State A to State B, State A to State C, etc.), the system can automatically apply an aesthetically pleasing transition even when a presenter makes an unplanned jump between slides, ensuring a professional appearance without requiring the user to have the skills of a trained director (’643 Patent, col. 1:62-2:2). This concept is illustrated in Figure 3, which shows a matrix (200) defining the transition effect to be used between any given "Current State" and "Next State" (’643 Patent, col. 7:22-38).
• Technical Importance: The invention aims to democratize the creation of high-quality visual presentations by automating the selection of aesthetically appropriate transitions, a task that previously required significant skill and pre-planning (’643 Patent, col. 1:36-44).

Key Claims at a Glance

• The complaint asserts "one or more claims" and refers to "exemplary method claims" but does not identify any specific claims (Compl. ¶11). Independent method claim 16 is representative of the method claims.
• Claim 16 (Independent):
  • A method of controlling a visual presentation of data to a viewer... the method comprising:
  • providing a plurality of transition effects;
  • for each pair of potentially successive visual display configuration states, associating a transition effect therewith;
  • receiving transition input indicative to transition from a current visual display configuration state to a next visual display configuration state...; and
  • during the transition... presenting to the viewer the transition effect associated with the defined pair of successive visual display configuration states.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products on its face. It refers to "Exemplary Defendant Products" that are purportedly identified in "charts incorporated into this Count" via an "Exhibit 2" (Compl. ¶11, 13). However, Exhibit 2 was not filed with the complaint.

Functionality and Market Context

• The complaint does not describe the functionality of the accused products. It alleges that Defendant directly infringed by "making, using, offering to sell, selling and/or importing" the accused products, and also by having employees "internally test and use" them (Compl. ¶11-12). No allegations regarding the products' market importance are provided.

IV. Analysis of Infringement Allegations

The complaint’s infringement theory relies entirely on claim charts in an Exhibit 2, which was not provided with the public filing (Compl. ¶13-14). The complaint states that these charts "satisfy all elements of the Exemplary '643 Patent Claims," but provides no specific factual allegations in the body of the complaint to support this conclusion (Compl. ¶13). No probative visual evidence provided in complaint.

Due to the absence of the referenced claim charts, a detailed infringement analysis based on the complaint is not possible. The narrative allegations are limited to conclusory statements that the "Exemplary Defendant Products practice the technology claimed by the '643 Patent" (Compl. ¶13).

• Identified Points of Contention:
  • Scope Questions: The patent is described in the context of "multimedia slideshow presentations, videoconferences, video phone calls, and video productions" (’643 Patent, col. 1:28-32). A potential dispute may arise over whether the term "visual presentation," as used in the claims, can be construed to cover the user interface and functionalities of Defendant's products, which are not described in the complaint.
  • Technical Questions: Without identification of the accused products or their specific functionalities, it is not possible to frame technical questions from the complaint. A central question for the court will be whether the complaint provides sufficient factual matter to state a plausible claim for relief, given that its infringement allegations are contained entirely within an unattached exhibit.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of how specific claim terms read on the accused products. However, based on the patent's subject matter, the construction of the following terms from independent claim 16 may be central to the dispute.

• The Term: "visual display configuration state"

  • Context and Importance: This term defines the fundamental building blocks of the claimed presentation system. The patent describes these states as screen formats with frames for content like video or text (e.g., a full-screen video, or a video with an "over-the-shoulder" graphic) (’643 Patent, col. 5:11-15, Fig. 1(a)-(j)). Practitioners may focus on whether this term should be limited to discrete, pre-defined layouts akin to television news graphics and presentation slides, or if it can be interpreted more broadly to cover other forms of user interface layouts.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that a "display configuration state is the format of a screen and defines the framework through which data content is presented," and that "persons of ordinary skill in the art are readily capable a designing a virtually infinite number of different display configuration states" (’643 Patent, col. 5:7-14). This language could support a broad definition not strictly limited to the examples shown.
    • Evidence for a Narrower Interpretation: The specification's examples consistently depict slide-like or video-production-like layouts with distinct frames for specific content types (’643 Patent, Fig. 1(a)-(j)). An argument could be made that the term's meaning is informed and limited by these consistent embodiments.

• The Term: "transition effect"

  • Context and Importance: This term is the core of the patented solution. Its definition will determine what kinds of visual changes between "states" constitute an infringing act. The dispute may turn on whether a "transition effect" must be a distinct, aesthetic animation (like a "wipe" or "dissolve") that is separate from the content itself.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent abstract describes the method as "presenting to the viewer the transition effect associated with the defined pair of successive display configuration states," without explicitly limiting the nature of that effect (’643 Patent, Abstract). Claim 16 itself only requires "presenting" the effect.
    • Evidence for a Narrower Interpretation: The background section provides specific examples of transition effects, including "wipes, dissolves, fades, focuses, flying planes, pushes, pulls, cuts, and the like" (’643 Patent, col. 1:51-53). This list of conventional, aesthetic video transitions could be used to argue for a narrower construction that excludes more basic or functional changes between interface views.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of induced or contributory infringement.
• Willful Infringement: The complaint does not allege willful infringement or make any factual claims regarding Defendant's knowledge of the ’643 Patent prior to the lawsuit. The prayer for relief requests a declaration that the case is "exceptional" under 35 U.S.C. § 285, but the body of the complaint provides no factual basis for this request (Compl. Prayer for Relief ¶E.i).

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

1. A core procedural issue will be one of pleading sufficiency: does the complaint, which incorporates its entire infringement theory by reference to an unfiled exhibit, provide Defendant with fair notice and state a plausible claim for relief under federal pleading standards?
2. A central issue will be one of definitional scope: can the term "visual display configuration state," which is rooted in the patent’s context of pre-defined slideshows and video productions, be construed to read on the functionalities of Defendant's modern software products?
3. A key evidentiary question will be one of technical implementation: assuming the complaint survives, what evidence will show that the accused products "associate" and "present" a pre-defined "transition effect" for each "pair of potentially successive" states, as strictly required by the claims, rather than employing a different technical architecture for managing user interface changes?