DCT

1:25-cv-01365

InterDigital Inc v. Amazon.com Services LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01365, D. Del., 11/07/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware based on Defendant's incorporation in Delaware and its maintenance of a regular and established place of business in the district, including a 3.8 million square foot fulfillment center.
  • Core Dispute: Plaintiff alleges that Defendant’s Fire TV and Prime streaming products and services infringe five U.S. patents related to digital video processing, including technologies for displaying High Dynamic Range (HDR) content and for efficiently coding video using codecs such as AV1 and VP9.
  • Technical Context: The technologies at issue concern methods for encoding, decoding, and displaying high-quality digital video, which are foundational to modern video streaming services that must deliver content efficiently across a wide range of devices and display capabilities.
  • Key Procedural History: The complaint states that prior to filing suit, Plaintiff engaged Defendant in licensing discussions. It also notes that Defendant initiated litigation in the United Kingdom and Brazil concerning different patents in Plaintiff's portfolio, which may suggest that licensing negotiations were unsuccessful.

Case Timeline

Date Event
2006-07-11 U.S. Patent No. 8,363,724 Priority Date
2007-10-12 U.S. Patent No. 8,681,855 Priority Date
2012-07-18 U.S. Patent No. 9,747,674 Priority Date
2013-01-29 U.S. Patent No. 8,363,724 Issued
2014-03-25 U.S. Patent No. 8,681,855 Issued
2014-12-22 U.S. Patent No. 10,741,211 Priority Date
2017-03-27 U.S. Patent No. 11,917,146 Priority Date
2017-08-29 U.S. Patent No. 9,747,674 Issued
2020-08-11 U.S. Patent No. 10,741,211 Issued
2024-02-27 U.S. Patent No. 11,917,146 Issued
2025-11-07 Complaint Filing Date

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

U.S. Patent No. 10,741,211 - Information processing device, information recording medium, and information processing method (Issued Aug. 11, 2020)

The Invention Explained

  • Problem Addressed: The patent's background section notes that at the time of the invention, there was no established definition or mechanism for recording High Dynamic Range (HDR) specific metadata within the standardized MP4 file format (Compl. ¶33; ’211 Patent, col. 2:62-67). This made it difficult for playback devices to optimally reproduce HDR content on displays with varying capabilities (Compl. ¶32; ’211 Patent, col. 1:20-27).
  • The Patented Solution: The invention proposes a modification to the MP4 file structure by defining a new "HDR image metadata storage box" (identified as hdrm). This box can be placed within a track-level trak box or a track-fragment-level traf box to store HDR-specific metadata, such as luminance levels (MaxCLL), color information, and the electro-optical transfer function (EOTF) (’211 Patent, col. 10:8-53; Figs. 5-8). A playback device can then acquire this metadata from the file and also acquire information about the display's capabilities to determine whether a conversion process is necessary to adapt the video for optimal playback (’211 Patent, Abstract).
  • Technical Importance: This approach enables a standardized method for embedding HDR playback parameters directly into a video file, facilitating adaptive playback that can account for the specific capabilities of different display devices (Compl. ¶36).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (method) and 12 (device) (Compl. ¶71).
  • The essential elements of independent claim 1 include:
    • acquiring HDR image metadata, including a maximum value of frame average luminance, from an MP4 file;
    • acquiring display function information of a display unit;
    • reading the HDR image data from the MP4 file;
    • executing a conversion process of the read HDR image data based on the acquired HDR metadata and the acquired display function information; and
    • executing an output image generation process based on the conversion.
  • The complaint reserves the right to assert additional claims (Compl. ¶76).

U.S. Patent No. 9,747,674 - Method and device for converting an image sequence whose luminance values belong to a high dynamic range (Issued Aug. 29, 2017)

The Invention Explained

  • Problem Addressed: The patent describes a problem with prior art tone-mapping operators (TMOs) used to convert HDR video to a lower dynamic range (LDR). When these operators process each frame independently, they can introduce temporal artifacts, particularly a "flickering effect," where an object with constant brightness in the original HDR sequence appears to fluctuate in brightness in the converted LDR sequence (’674 Patent, col. 2:21-25; Compl. ¶41).
  • The Patented Solution: The invention introduces a two-step process. First, a standard TMO is applied to each image's luminance component. Second, a correction step is performed where the dynamic range of this modified luminance is reduced by a value "calculated from a global characteristic of the original image sequence" (’674 Patent, Abstract; Compl. ¶43). This correction is designed to preserve perceptual and temporal coherence across frames, thereby reducing flicker (’674 Patent, col. 3:60-66). The complaint includes Figure 3 from the patent, which graphically illustrates how the claimed correction step stabilizes the luminance of an object across a sequence (Compl. ¶44).
  • Technical Importance: The invention aims to improve the visual quality of HDR-to-LDR video conversion by ensuring temporal stability and eliminating the flicker artifact common in prior systems, leading to a more coherent viewing experience (Compl. ¶46).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (method) and 10 (device) (Compl. ¶79).
  • The essential elements of independent claim 1 include:
    • converting, image-by-image, the dynamic range of a luminance component of each image by applying a dynamic range conversion operator; and
    • correcting the dynamic range of the values of the luminance component thus modified by reducing it by a value calculated from a global characteristic of the original image sequence.
  • The complaint reserves the right to assert additional claims (Compl. ¶84).

Multi-Patent Capsule: U.S. Patent No. 8,363,724

  • Patent Identification: U.S. Patent No. 8,363,724, "Methods and apparatus using virtual reference pictures," issued January 29, 2013.
  • Technology Synopsis: The patent addresses limitations in video compression systems that rely only on previously decoded pictures as reference frames. It introduces the concept of "Virtual Reference Pictures" (VRPs), which are generated from decoded frames but are not intended for display, to serve as additional reference sources to improve prediction accuracy and compression efficiency (Compl. ¶¶50-51; ’724 Patent, Abstract).
  • Asserted Claims: Independent claim 39 (Compl. ¶87).
  • Accused Features: The AV1/VP9 decoding capabilities of the Accused Instrumentalities (Compl. ¶¶86-87).

Multi-Patent Capsule: U.S. Patent No. 8,681,855

  • Patent Identification: U.S. Patent No. 8,681,855, "Method and apparatus for video encoding and decoding geometrically partitioned bi-predictive mode partitions," issued March 25, 2014.
  • Technology Synopsis: The patent seeks to improve video compression efficiency by moving beyond traditional rectangular block partitioning. It introduces adaptive geometric partitioning (e.g., dividing a block with a "wedge" partition) into the bi-predictive (B-frame) coding framework, allowing the codec to better model the actual geometric shapes of objects in a video scene (Compl. ¶¶58-59; ’855 Patent, Abstract).
  • Asserted Claims: Independent claim 13 (Compl. ¶95).
  • Accused Features: The AV1 decoding capabilities of the Accused Instrumentalities (Compl. ¶¶94-95).

Multi-Patent Capsule: U.S. Patent No. 11,917,146

  • Patent Identification: U.S. Patent No. 11,917,146, "Methods and apparatus for picture encoding and decoding," issued February 27, 2024.
  • Technology Synopsis: The patent addresses inefficiencies in prior video coding standards (like HEVC) that imposed rigid rules for splitting coding blocks located at a picture's boundary. It discloses a flexible decision framework that dynamically determines which split modes (including asymmetric and triple-split modes) are permissible for a boundary block, thereby improving coding efficiency and reducing artifacts (Compl. ¶¶65-67; ’146 Patent, Abstract).
  • Asserted Claims: Independent claim 7 (Compl. ¶103).
  • Accused Features: The AV1 decoding capabilities of the Accused Instrumentalities (Compl. ¶¶102-103).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies two overlapping categories of accused products: "HDR Accused Instrumentalities" and "AV1/VP9 Accused Instrumentalities" (Compl. ¶3, fn. 1). These include various Amazon streaming media players and smart TVs such as the Fire TV Stick series, Fire TV Cube, Fire TV 2-Series and 4-Series, Fire TV Omni Series, Fire Max 11, and Echo Show models (Compl. ¶70, fn. 4; Compl. ¶86, fn. 5).
  • Functionality and Market Context: The accused products are devices that receive and decode compressed digital video streams for display (Compl. ¶¶18, 23). The complaint alleges that these devices are capable of decoding and playing back content in advanced formats, including HDR (HDR10, HDR10+) and modern codecs (VP9, AV1) (Compl. ¶4). Amazon advertises these features to consumers, as shown in a product listing for an Amazon Fire TV which promotes its "HDR10+ display" (Compl. p. 19). A comparative chart of Amazon's streaming devices further details which models support specific formats like "Dolby Vision, HDR10, HDR10+" (Compl. p. 20). The complaint also points to Amazon's developer documentation, which lists "AV1" and "VP9" as supported video codecs for devices like the Fire Tablet and Echo Show (Compl. p. 27).

IV. Analysis of Infringement Allegations

’211 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
acquire high dynamic range (HDR) image metadata from an MP4 file, wherein the acquired HDR image metadata includes a maximum value of frame average luminance... Amazon's HDR devices are capable of playing back HDR10 and HDR10+ content, which requires acquiring and processing HDR metadata embedded in the video stream. ¶71 col. 2:56-60
acquire display function information of a display unit from the display unit; Amazon's devices interact with the connected display to determine its capabilities. The complaint provides customer help documents instructing users to check their TV's picture settings and HDMI input modes to enable HDR playback. ¶74; p. 21 col. 4:15-20
execute a conversion process of the read HDR image data based on the acquired HDR image metadata and the acquired display function information... The devices use the acquired HDR metadata from the video stream and the display's capabilities to perform adaptive processing and generate an optimal output signal for that specific display. ¶71 col. 4:21-24
execute an output image generation process based on the execution of the conversion process... The devices generate and output a video signal for display after performing the adaptive conversion process. ¶35 col. 2:60-62
  • Identified Points of Contention:
    • Scope Questions: A potential point of contention may be the scope of the term "MP4 file." The defense may argue that modern adaptive bitrate streaming protocols (e.g., HLS, DASH) do not deliver a single "MP4 file" in the traditional sense, raising the question of whether streaming segments fall within the claim's scope.
    • Technical Questions: The infringement analysis may focus on what evidence demonstrates that the accused devices perform a "conversion process" based on both the acquired metadata and the display's function information, as required by the claim, rather than simply passing through an HDR signal or performing a non-adaptive conversion.

’674 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
converting, image-by-image, the dynamic range of the luminance component of each image of the original image sequence by applying a dynamic range conversion operator... Amazon's HDR devices enable HDR playback, which includes performing tone-mapping to convert HDR content for display on screens with lower dynamic range capabilities. ¶79 col. 1:16-21
correcting the dynamic range of the values of the luminance component thus modified by reducing it by a value calculated from a global characteristic of the original image sequence. The complaint alleges that the tone-mapping process used by Amazon's devices for HDR playback constitutes infringement, which implies the use of a correction step based on a global characteristic to maintain temporal coherence. ¶79 col. 3:60-66
  • Identified Points of Contention:
    • Technical Questions: The central issue for this patent will likely be evidentiary. The complaint alleges that enabling HDR playback infringes, but it does not provide technical details on how Amazon's tone-mapping algorithm functions. The analysis will hinge on whether Plaintiff can demonstrate that the accused devices perform the specific, two-step process of applying a TMO and then applying a correction based on a "global characteristic" to reduce flicker, as opposed to using a different tone-mapping technique.

V. Key Claim Terms for Construction

’211 Patent

  • The Term: "MP4 file"
  • Context and Importance: The applicability of the patent to modern streaming services depends on this term's construction. Practitioners may focus on whether "MP4 file" is limited to a discrete, self-contained file or can be construed to cover the fragmented MP4 segments used in protocols like MPEG-DASH, which are common in streaming.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification explicitly illustrates both "FRAGMENT TYPE (fragmented movie)" and "NON-FRAGMENT TYPE (non-fragmented movie)" structures, which may support an interpretation that covers the fragmented files used in streaming (’211 Patent, Figs. 1(a)-1(b), col. 6:1-10).
    • Evidence for a Narrower Interpretation: An opposing argument could focus on embodiments describing the generation and recording of a singular "MP4 file," suggesting the invention was directed at file-based storage rather than dynamic streaming environments (’211 Patent, col. 4:7-14).

’674 Patent

  • The Term: "global characteristic of the original image sequence"
  • Context and Importance: This term defines the source of the value used for the claimed correction step, which is the core of the invention. Its construction will be critical to determining what kind of calculation is required for infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The abstract describes the term broadly as "a value calculated from a global characteristic of the original image sequence," which could suggest any value derived from the sequence as a whole, such as its average brightness or peak luminance (’674 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The background section discusses prior art TMOs that use a "key k" calculated from the logarithmic average of luminance values in an image (’674 Patent, col. 2:1-4). A party could argue that the "global characteristic" should be interpreted in light of this context, potentially limiting it to similar statistical metrics derived from the entire video sequence.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for all five patents. The factual basis for this allegation is that Defendant advertises the accused functionalities (e.g., "HDR10+ display," AV1/VP9 decoding) and provides instructions, user manuals, and customer service documentation that allegedly encourage and instruct users to perform the infringing acts (Compl. ¶¶74, 82, 90, 98, 106). The complaint includes screenshots of Amazon's customer help pages for "Dolby Vision or High Dynamic Range Not Working," which provide troubleshooting steps for users (Compl. p. 21).
  • Willful Infringement: For each patent, the complaint alleges that "Amazon has been aware of the [asserted] Patent and its infringement thereof at least as of the filing of this Complaint" (Compl. ¶¶73, 81, 89, 97, 105). This allegation primarily supports a claim for post-suit willful infringement, and the prayer for relief seeks a judgment that Amazon's infringement has been willful (Compl. p. 32).

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

  • A central evidentiary question for the HDR-related patents ('211 and '674) will be one of technical implementation: what evidence shows that Amazon's devices perform the specific, multi-step processes required by the claims? For the '674 patent in particular, the case may turn on whether Plaintiff can prove that Amazon's tone-mapping algorithm uses a correction step based on a "global characteristic of the original image sequence" to reduce flicker, or if it employs a different, non-infringing method.
  • For the video codec-related patents ('724, '855, and '146), a key issue will be one of standards mapping and claim scope: do the specific algorithms and structures defined in the AV1 and VP9 video coding standards, as implemented in Amazon's products, practice the methods claimed in the patents? The analysis will likely involve a detailed comparison of the patent claims to the technical specifications of the accused codecs.
  • A core issue of definitional scope for the '211 patent will be the construction of the term "MP4 file." The outcome of this construction could determine whether the patent, which describes modifying file-based container formats, is applicable to the segmented and fragmented video delivery methods used by modern streaming services like Amazon Prime Video.