JBF Interlude 2009 Ltd v. Artisan Tech LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: JBF Interlude 2009 Ltd. ("eko") (Israel)
  • Defendant: Artisan Technologies LLC ("Artisan") (Delaware)
  • Plaintiff’s Counsel: Potter Anderson & Corroon LLP; Gish PLLC (Of Counsel)
• Case Identification: 1:25-cv-01553, D. Del., 12/23/2025
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Artisan is a Delaware limited liability company and therefore resides in the district.
• Core Dispute: Plaintiff alleges that Defendant’s interactive e-commerce video production services infringe two patents related to technologies for creating seamless, interactive video streams.
• Technical Context: The technology at issue addresses limitations in traditional linear video by enabling real-time user interaction, such as selecting different video segments or product features, without interrupting playback to enhance consumer engagement in e-commerce.
• Key Procedural History: The complaint alleges that the parties had a multi-year commercial relationship from 2022 to 2025, during which Defendant provided video production services for Plaintiff and allegedly became well-acquainted with the patented technology. The lawsuit was filed after this relationship ended and Defendant began promoting its own interactive video services. This prior relationship forms the basis for the allegations of willful infringement.

Case Timeline

Date	Event
2013-12-24	’898 Patent Priority Date
2017-05-02	’898 Patent Issue Date
2021-09-24	’306 Patent Priority Date
2022-01-01	Alleged start of Eko/Artisan contractual relationship
2024-01-18	’306 Patent application filed
2025-01-01	Alleged end of Eko/Artisan contractual relationship
2025-10-21	’306 Patent Issue Date
2025-12-23	Complaint Filing Date

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

U.S. Patent No. 9,641,898 - “Methods and Systems for In-Video Library” (Issued May 2, 2017)

The Invention Explained

• Problem Addressed: The patent addresses the problem that prior streaming video systems did not allow users to search for and select other video content for later viewing while watching an uninterrupted video stream (Compl. ¶¶15, 19; ’898 Patent, col. 1:15-26). This forced users to choose between continuous playback and interaction, leading to interruptions, rebuffering, and decreased engagement (Compl. ¶15).
• The Patented Solution: The invention is a system where a video player presents an initial video stream comprising a "predefined path" of segments. During playback, the player displays a library of other selectable video segments, receives a user's selections, and adds them to a "video segment watch-list." The system then identifies "decision points" in the predefined path where it can seamlessly insert and play segments from the watch-list before continuing the original stream, all without interrupting playback (Compl. ¶¶14, 17; ’898 Patent, Abstract). The detailed description explains that this allows a user to build a customized playback queue in real-time while viewing content (’898 Patent, col. 3:28-46).
• Technical Importance: This approach enables real-time modification of a video stream's playback path based on user input, avoiding the buffering delays and context switching that characterized prior systems (Compl. ¶18).

Key Claims at a Glance

• The complaint asserts independent claim 16 (Compl. ¶37).
• Essential elements of claim 16 include:
  • Presenting a video stream comprising a predefined path of prerecorded video segments.
  • Concurrently displaying a library of selectable prerecorded video segments.
  • Receiving a user selection from the library.
  • Adding the selected segments to a video segment watch-list.
  • Identifying a decision point in the predefined path where the stream can transition.
  • Inserting a segment from the watch-list into the video stream at the decision point.
  • Presenting the inserted segment.
  • Continuing the presentation of the predefined path after the inserted segment has played.

U.S. Patent No. 12,450,306 - “Video Player Integration within Website” (Issued October 21, 2025)

The Invention Explained

• Problem Addressed: The patent addresses the inability of prior video systems to allow users to interact with and personalize video content on a website without interrupting playback, rebuffering, or disengaging the viewer (Compl. ¶24). Conventional video players on websites were typically "predetermined and unalterable" (’306 Patent, col. 1:24-27).
• The Patented Solution: The invention describes a system with two distinct but communicating software layers on a webpage: an "application layer" (the webpage itself) containing user interface (UI) elements, and a "video player layer" (e.g., an iFrame) integrated within it. A user interaction with a UI element in the application layer (e.g., selecting a product color on the webpage) sends a message to the video player layer, which dynamically modifies the video content in response. This creates a synchronized, interactive experience between the webpage and the embedded video (’306 Patent, Abstract; Compl. ¶¶23, 25). The specification details that communication between these layers occurs via an Application Program Interface (API) (’306 Patent, col. 2:42-45).
• Technical Importance: The invention provides a specific technical mechanism for "two-way state synchronization between isolated browser contexts," allowing user interactions on a webpage to control an embedded video player in real time without playback disruption (Compl. ¶27).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶51).
• Essential elements of claim 1 include:
  • Providing a product webpage and displaying an application layer with multiple UI elements corresponding to product features.
  • Displaying a video player layer integrated in the application layer to present an interactive video.
  • Receiving a first user interaction with a first UI element (e.g., selecting a first feature).
  • Sending a first message from the application layer to the video player layer.
  • Presenting first video content based on the first message.
  • Receiving a second user interaction with a second UI element.
  • Sending a second message from the application layer to the video player layer.
  • Transitioning to second video content based on the second message.

III. The Accused Instrumentality

Product Identification

The accused products are the "Donatello Arm Interactive Services," which are used to create interactive e-commerce videos for customers, and the resulting interactive videos themselves (Compl. ¶34).

Functionality and Market Context

Artisan is an e-commerce media production company that, after a contractual relationship with eko ended, allegedly began promoting services for "interactive" e-commerce video creation (Compl. ¶¶32-33). The complaint alleges that interactive videos demonstrated on Artisan's website ("donatelloarm.com") embody the infringing technology (Compl. ¶34). These videos purportedly allow users to interact with on-screen elements to customize the video content in real time, for example by selecting different product features to view (Compl. ¶¶3, 34).

IV. Analysis of Infringement Allegations

The complaint states that claim charts demonstrating infringement are attached as Exhibits C and D (Compl. ¶¶39, 53). However, these exhibits were not provided with the complaint for analysis. The infringement theory is therefore summarized from the complaint's narrative allegations.

• ’898 Patent Infringement Allegations: The complaint alleges that Artisan's interactive videos infringe claim 16 by presenting a primary video stream while allowing users to select additional video segments from an on-screen library. These selections are allegedly added to a playback queue (a "watch-list") and are seamlessly inserted into the main stream at predefined "decision points" before the main stream resumes, thereby practicing the claimed method (Compl. ¶¶17, 38-39).

• ’306 Patent Infringement Allegations: The complaint alleges that Artisan's website and interactive videos infringe claim 1 by implementing the claimed two-layer architecture. The website itself is alleged to be the "application layer" containing UI elements (e.g., product selectors), while the embedded video player functions as the "video player layer." When a user interacts with a UI element on the webpage, the application layer allegedly sends a "message" to the video player layer, causing it to dynamically change the video content to correspond with the user's selection (Compl. ¶¶25, 52-53).

• Identified Points of Contention:

  • Scope Questions: A central dispute for the ’898 Patent may be the scope of terms like "predefined path," "decision point," and "video segment watch-list." The analysis may question whether Artisan’s system uses a different technical architecture that achieves a similar interactive result without meeting these specific structural limitations. For the ’306 Patent, a key question will be whether Artisan's web implementation constitutes distinct "application" and "video player" layers that communicate via "messages," as required by the claims, or if it is a more integrated, single-layer system.
  • Technical Questions: A factual question for the ’898 Patent is what evidence shows that the accused videos "insert" segments into an ongoing stream rather than simply linking to or loading entirely new videos. For the ’306 Patent, a technical question is whether the communication between the webpage and the video player on Artisan's site functions as the claimed API-based messaging system designed to synchronize isolated browser contexts.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

For the ’898 Patent:

• The Term: "decision point"
• Context and Importance: This term is critical to defining the structure of the claimed method. Infringement will depend on whether the accused system identifies specific, pre-authored locations within a "predefined path" for transitions, distinguishing it from systems where any user interaction at any time can trigger a change.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language describes it as simply "a location at which the video stream can transition," which could be argued to cover any point where a user choice is enabled (’898 Patent, col. 18:1-5).
  • Evidence for a Narrower Interpretation: The specification states that "Decision points and/or periods can be predefined, occurring at fixed points or during fixed periods in the multimedia content segments" (’898 Patent, col. 12:44-47). This language suggests the points are structurally determined in advance, not arbitrary.

For the ’306 Patent:

• The Terms: "application layer" and "video player layer"
• Context and Importance: The claimed invention is premised on this specific two-layer architecture. The outcome of the case may hinge on whether Artisan's website is found to have this structure, as opposed to a single, monolithic architecture.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff may argue the terms should be construed functionally to cover any system where webpage elements and a video player are functionally distinct and exchange data to synchronize state.
  • Evidence for a Narrower Interpretation: The specification explicitly provides an example where the "application layer 802 corresponds to a webpage or website" and the "video player layer 804 corresponds to an inline frame (iFrame)" (’306 Patent, col. 13:9-14). The patent's focus on an API using a "JavaScript library based on the 'postMessage' iFrame framework" further supports a narrower construction limited to technically distinct browser contexts (’306 Patent, col. 13:56-58).

VI. Other Allegations

• Indirect Infringement: The complaint alleges Artisan induces infringement by providing customers with "education and promotion materials and support and service activities" that instruct on the use of the infringing services (Compl. ¶¶43, 57). It also alleges contributory infringement, stating the accused services are "specially made or adapted to infringe" and are not staple articles of commerce (Compl. ¶¶44, 58).
• Willful Infringement: Willfulness is alleged for both patents based on Artisan's pre-suit knowledge of the technology. This knowledge was allegedly gained during a "long-running" multi-year commercial relationship with eko where Artisan was exposed to the patented technology before launching its own competing service (Compl. ¶¶4, 40, 54). For the ’306 patent, the complaint notes its application was pending while the contractual relationship was still in place (Compl. ¶54).

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

• A core issue will be one of architectural equivalence: Does the accused "Donatello Arm" service technically operate using the specific structures claimed in the patents—namely, the "predefined path," "decision point," and "watch-list" system of the ’898 Patent and the two-layer, API-messaging system of the ’306 Patent—or does it achieve a similar interactive user experience through a different, non-infringing technical implementation?
• A second central issue will be willfulness and damages: Given the allegation that Artisan was a former partner of eko with direct exposure to the patented technology, the question of whether its subsequent development of a competing service constitutes willful infringement will be a focal point of the dispute, carrying significant implications for potential enhanced damages.