DCT
1:25-cv-08469
Juke Audio Inc v. Zhongke Wanying Beijing Technology Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Juke Audio Inc. (Delaware)
- Defendant: Zhongke Wanying (Beijing) Technology Co., Ltd. d/b/a OpenAudio (China)
- Plaintiff’s Counsel: BEW LLC
- Case Identification: 1:25-cv-08469, N.D. Ill., 07/23/2025
- Venue Allegations: Venue is asserted on the basis that Defendant is a foreign entity with no principal place of business in the United States. Personal jurisdiction is alleged based on Defendant’s interactive Amazon.com storefront and commercial website, which target and complete sales to consumers in Illinois.
- Core Dispute: Plaintiff alleges that Defendant’s multi-room streaming amplifiers infringe a patent related to digital multi-zone audio systems.
- Technical Context: The technology concerns networked systems that receive multiple digital audio streams and distribute them to different speaker zones, allowing user control over which audio plays in which zone.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the alleged infringement via a letter on January 8, 2025. Plaintiff also notes it made prior, unsuccessful attempts to enforce its patent rights through Amazon.com's internal procedures. The complaint states that Plaintiff's own products are virtually marked with the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2018-11-09 | ’102 Patent Priority Date |
| 2021-11-02 | ’102 Patent Issue Date |
| 2025-01-08 | Plaintiff sent letter to Defendant alleging infringement |
| 2025-07-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,166,102 - "Digital Multi-Zone Audio System," issued Nov. 2, 2021
The Invention Explained
- Problem Addressed: The patent describes conventional multi-zone audio systems as complex to install, requiring numerous components, and being energy inefficient due to their use of analog signal processing, which generates significant waste heat (’102 Patent, col. 1:21-38).
- The Patented Solution: The invention proposes an embedded computing device that receives and buffers one or more digital audio streams from networked sources like smartphones or computers. An "audio stream manager" then distributes these streams to a series of digital amplifiers, each connected to speakers in a different zone. This architecture allows a user to select which audio stream plays in which zone at a desired volume (’102 Patent, Abstract). The system is designed to be entirely digital from the source through to the amplification stage, which is intended to reduce component count and improve energy efficiency (’102 Patent, col. 2:49-54).
- Technical Importance: By maintaining a digital signal path until the final amplification stage, the described system architecture aims to simplify installation and operation while improving audio quality and power efficiency over prior art systems that required more extensive analog-to-digital or digital-to-analog conversions (’102 Patent, col. 2:49-54).
Key Claims at a Glance
- The complaint asserts direct and indirect infringement of at least independent claim 1 (Compl. ¶45-46).
- The essential elements of Claim 1 are:
- An embedded computing device connected to a network that receives a plurality of digital audio streams from other computing devices.
- The embedded computing device is configured to cause a user device to display a user interface with a listing of zones for audio playback.
- An audio stream manager connected to the embedded computing device and a plurality of digital amplifiers.
- The audio stream manager is configured to receive the audio streams and a user's selection of a stream and target zone(s).
- The audio stream manager transmits the selected stream to the corresponding digital amplifier for the target zone, causing the audio to be played.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused instrumentalities as the "OpenAudio Infringing Products," which include various models such as "Holo-Whas," "Holo-Whas Ultra," and others sold under the "OpenAudio" brand (Compl. ¶28-29).
Functionality and Market Context
- The accused products are described as multi-room streaming amplifiers sold to U.S. consumers through Defendant’s Amazon storefront and its own website (Compl. ¶9, 13). The complaint provides a screenshot of the Defendant's Amazon storefront, showing the accused "HOLOWHAS" product marketed as an "8 Streams 8 Zones Multi-Room Streaming Amplifier" (Compl. p. 2). This functionality is alleged to directly practice the patented technology for distributing multiple audio streams to distinct zones (Compl. ¶30, 43).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in an unprovided exhibit (Compl. ¶43). The following chart summarizes the apparent infringement theory based on the complaint's narrative allegations and descriptions of the accused products.
’102 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an embedded computing device connected to a plurality of computing devices via a network and which is configured to receive a plurality of digital audio streams from each of the plurality of computing devices... | The OpenAudio amplifier contains an embedded computer that connects to a network to receive digital audio streams from user devices (e.g., smartphones streaming from online services). | ¶30; p. 2 | col. 2:10-21 |
| ...the embedded computing device being further configured to cause a user device...to display on the user device a user interface including a listing of a plurality of zones where a digital audio stream from the user device may be played... | The OpenAudio amplifier hosts or provides access to a user interface (e.g., a web page or application) that allows a user on a networked device to see and select from available audio zones. | ¶43; ¶45 | col. 6:52-58 |
| an audio stream manager connected to and in communication with the embedded computing device and a plurality of digital amplifiers... | The internal hardware of the OpenAudio amplifier is alleged to contain an audio stream manager, or functionally equivalent circuitry, that communicates with the device's embedded computer and its multiple digital amplifier channels. | ¶30; ¶45 | col. 2:31-44 |
| ...the audio stream manager being configured to: receive the plurality of digital audio streams and a user selection...and transmit the selected digital audio stream to a corresponding digital amplifier...causing the selected digital audio stream to be played to the target zone. | Based on user selections made in the interface, the OpenAudio amplifier's internal logic routes the selected digital audio stream to the specific digital amplifier circuit corresponding to the user-selected zone for playback. | ¶30; ¶43 | col. 6:21-36 |
- Identified Points of Contention:
- Scope Questions: A central question may be the proper construction of "audio stream manager." The defense could argue that their product's architecture is more integrated and does not contain a distinct "manager" component as depicted in the patent's preferred embodiment, which describes a separate FPGA (’102 Patent, col. 2:33-35).
- Technical Questions: The infringement analysis may focus on whether the accused products perform the specific two-step buffering process described in the patent specification, where an embedded computer first buffers network data and then passes it to a second-stage FIFO buffer within the audio stream manager for precisely timed delivery to the amplifiers (’102 Patent, col. 8:53-9:10). Evidence of this specific buffering architecture in the accused devices would be a key point of proof.
V. Key Claim Terms for Construction
Term: "audio stream manager"
- Context and Importance: This term defines a core architectural component of the claimed system. Its construction will be critical in determining whether the accused products, which may have a different internal hardware or software layout, fall within the scope of the claims. Practitioners may focus on this term because the patent discloses both a specific hardware embodiment and a more functional alternative.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the term is not limited to a single type of hardware, stating that the manager "may comprise or a microprocessor-based device running a real-time operating system (RTOS), which may provide the same functionality" as an FPGA, and noting the manager and embedded computer "may comprise a singular processor" (’102 Patent, col. 2:35-42).
- Evidence for a Narrower Interpretation: The primary embodiment described and illustrated shows the "audio stream manager 125" as a distinct "field programmable gate array 150 (FPGA)" that is separate from the "embedded computer 120" (’102 Patent, Fig. 1; col. 2:33-35). This could support an argument that the term requires a distinct component dedicated to stream management.
Term: "embedded computing device ... configured to cause a user device ... to display ... a user interface"
- Context and Importance: This limitation describes the interaction between the core system and the user's control device. The meaning of "cause ... to display" will be important for determining infringement by systems that use standard web or app protocols.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discloses an embodiment where "users control the system via web pages hosted by the embedded computer 120," which aligns with a standard client-server model where the embedded device serves content that a browser on the user device then displays (’102 Patent, col. 6:55-58).
- Evidence for a Narrower Interpretation: An argument could be made that the term "cause ... to display" implies a more active role by the embedded device than simply responding to a standard HTTP request from a user's browser. However, the specification's explicit mention of a hosted web interface may limit the viability of a significantly narrower construction.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement and contributory infringement, asserting that Defendant had knowledge of the ’102 Patent since at least January 8, 2025, from a notice letter (Compl. ¶44, 46). The allegation of inducement is based on Defendant selling the accused products to customers for their intended, and allegedly infringing, use as multi-zone audio systems (Compl. ¶46).
- Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after receiving notice of the ’102 Patent on January 8, 2025, and its alleged failure to "alter or avoid infringement" thereafter (Compl. ¶47-48).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term "audio stream manager," described in the patent’s preferred embodiment as a distinct FPGA, be construed to cover a software module running on a general-purpose processor within a more integrated system architecture that may be used in the accused products?
- A key evidentiary question will be one of technical operation: does the accused OpenAudio system implement the specific two-step buffering and precisely timed stream-handling architecture described in the ’102 Patent specification, or does it use a different method for managing data flow from the network to the amplifiers? The outcome may depend on whether the claim language is interpreted to require that specific implementation.