DCT

1:25-cv-01278

Gamehancement LLC v. Quark Software Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01278, D. Del., 10/20/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Delaware corporation with an established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s unnamed software products infringe a patent related to methods for controlling the visual presentation of data, specifically the transitions between different display states.
  • Technical Context: The technology concerns software for creating multimedia presentations (e.g., slideshows), aiming to automate the selection of aesthetically appropriate visual transitions between slides or display layouts.
  • Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

Case Timeline

Date Event
2001-11-09 U.S. Patent No. 7,102,643 Priority Date
2006-09-05 U.S. Patent No. 7,102,643 Issues
2025-10-20 Complaint Filed

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.

The Invention Explained

  • Problem Addressed: The patent addresses the difficulty faced by unskilled users in creating professional-quality multimedia presentations (’643 Patent, col. 1:36-44). Specifically, when a presenter deviates from a pre-planned sequence of slides, prior art systems would use an inappropriate or disruptive default visual transition, detracting from the presentation's message (’643 Patent, col. 2:3-24).
  • The Patented Solution: The invention proposes a method where a transition effect is pre-associated with every possible pair of "display configuration states" (e.g., slide layouts) (’643 Patent, col. 3:38-47). This ensures that no matter the sequence of slides presented—even an unplanned one—an appropriate, aesthetically congruous transition is automatically displayed, mimicking the decision-making of a skilled director (’643 Patent, col. 1:62-2:2). Figure 3 illustrates this concept with a matrix that maps every "Current State" to every "Next State" to define a specific "Transition Effect" (’643 Patent, Fig. 3).
  • Technical Importance: The technology aimed to democratize the creation of high-quality presentations by embedding directorial logic into the software, thereby reducing the need for user expertise in visual design and timing (’643 Patent, col. 1:56-62).

Key Claims at a Glance

  • The complaint asserts infringement of "exemplary method claims" without specifying claim numbers (Compl. ¶11). Claim 16 is the first independent method claim.
  • Independent Claim 16 (paraphrased elements):
    • A method of controlling a visual presentation of data to a viewer.
    • The presentation comprises a plurality of display configuration states through which data content is presented.
    • The presentation is responsive to transition input to transition from a current to a next visual display configuration state.
    • The method comprises:
      • 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 state to a next state, defining a pair of successive states; and
      • during the transition, presenting the associated transition effect to the viewer.
  • The complaint does not explicitly reserve the right to assert dependent claims but refers to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

  • The complaint does not identify the specific accused products by name. It refers to them collectively as "Exemplary Defendant Products" (Compl. ¶11, ¶13).

Functionality and Market Context

  • The complaint provides no description of the accused products' functionality, features, or market context. It states only that these products "practice the technology claimed by the '643 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are made by incorporating an external document, "Exhibit 2," which was not filed with the complaint (Compl. ¶13-14). The complaint itself contains no narrative explanation of how the accused products allegedly infringe any claim of the ’643 Patent. As such, a direct analysis of the plaintiff's infringement theory is not possible based on the provided documents.

No probative visual evidence provided in complaint.

  • Identified Points of Contention: Given the lack of specific allegations, any points of contention are necessarily speculative. However, based on the language of representative Claim 16, disputes may arise over the following:
    • Scope Questions: What constitutes a "display configuration state" in the context of the accused products? The patent describes this broadly as "the format of a screen" including one or more frames for content like video or text (’643 Patent, col. 5:12-15). A dispute could arise over whether this term reads on the accused products' user interface elements or layouts.
    • Technical Questions: Does the accused product in fact "associat[e] a transition effect" for "each pair of potentially successive" states, as required by Claim 16? A key factual question will be whether the accused system pre-defines transitions for all possible state-to-state changes, or if it uses a more limited set of rules or default transitions for unplanned sequences. The complaint provides no evidence on this point.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of specific claim construction disputes. However, based on the technology and representative Claim 16, the following terms may be central to the case.

  • The Term: "display configuration state"

    • Context and Importance: This term defines the fundamental building blocks of the claimed method. Its scope will determine what types of user interface layouts or presentation slides fall within the claims. A broad construction could cover a wide range of modern software interfaces, while a narrow construction might limit the claims to the specific slideshow-style embodiments shown in the patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification defines the term broadly as "the format of a screen" that "defines the framework through which data content is presented" and "includes one or more frames" (’643 Patent, col. 5:12-15). This language suggests the term is not limited to any particular type of content or layout.
      • Evidence for a Narrower Interpretation: The detailed examples provided in the patent almost exclusively depict television news-style or slideshow presentation layouts (e.g., full-screen video, video with a text overlay, "Over-the-Shoulder" graphics) (’643 Patent, Figs. 1(a)-1(j); col. 5:16-6:26). A defendant may argue these embodiments limit the term's scope to similar presentation-centric formats.

  • The Term: "associating a transition effect therewith" [for each pair of potentially successive visual display configuration states]

    • Context and Importance: This is the core functional step of the invention. The dispute will likely center on whether the accused product's architecture performs this comprehensive "association" for all possible transitions, or merely for a subset of planned transitions.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language is broad, simply requiring an "association." This could arguably be met by any system that has a rule, lookup table, or algorithm that determines a transition for any given pair of states, even if implemented efficiently rather than as a literal, exhaustive matrix.
      • Evidence for a Narrower Interpretation: The patent repeatedly emphasizes the problem of "unplanned" transitions and presents Figure 3 as the solution: a matrix that explicitly defines a transition for every possible current-to-next state pairing (’643 Patent, col. 2:3-24; Fig. 3). A defendant may argue that this detailed disclosure implies the "associating" step requires a pre-defined, exhaustive mapping for all potential state pairs, not a system that uses default or procedurally generated transitions for unexpected sequences.

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

With the complaint lacking specific factual allegations, the initial phase of this case will likely focus on pleadings and discovery to establish a basic infringement theory. Once established, the case may turn on two central questions:

  1. A core issue will be one of definitional scope: How broadly will the term "display configuration state" be construed? The answer will determine whether the patent applies only to traditional slideshow applications, as primarily depicted in the specification, or extends to a wider range of modern graphical user interfaces that transition between different layouts.
  2. A key evidentiary question will be one of technical implementation: Does the accused product’s architecture meet the claim requirement of "associating a transition effect" for "each pair of potentially successive" states? This will require a factual inquiry into whether the software pre-defines outcomes for all possible transitions, or if it uses a different logic, such as a limited set of rules or default effects, that may not satisfy this claim limitation.