Gamehancement LLC v. Sparkol Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Gamehancement LLC (Delaware)
  • Defendant: Sparkol Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-04356, E.D.N.Y., 08/05/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Eastern District of New York and having committed alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods and systems for controlling the visual presentation of data, particularly by automating the selection of transition effects between different display layouts or slides.
• Technical Context: The technology at issue resides in the field of digital presentation software, aiming to automate aesthetic choices to allow non-expert users to create professional-quality, dynamic visual content like slideshows or video productions.
• Key Procedural History: The complaint does not allege any prior litigation, Inter Partes Review (IPR) 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

The Invention Explained

• Problem Addressed: The patent's background section identifies a problem for unskilled users creating digital presentations: the difficulty of selecting appropriate and aesthetically pleasing "transition effects" (e.g., wipes, dissolves, fades) between slides. This problem is acute when a presenter deviates from a pre-planned sequence, as a pre-selected transition may appear "inappropriate" or "disruptive," distracting the audience. (’643 Patent, col. 1:36-58; col. 2:5-24).
• The Patented Solution: The invention proposes a system that associates a specific transition effect with each potential pair of "display configuration states." By pre-defining a suitable transition for every possible move from a current state to a next state, the system can automatically apply an aesthetically congruous effect even during unplanned sequence changes. This concept is illustrated in a matrix (Figure 3) that maps current states and next states to specific transition effects. (’643 Patent, Abstract; col. 3:38-47).
• Technical Importance: This approach sought to automate the complex decision-making of a skilled video director, enabling users without specialized training to produce dynamic, high-quality presentations that maintain a professional appearance regardless of how the content is navigated. (’643 Patent, col. 1:59-col. 2:2).

Key Claims at a Glance

• The complaint asserts "one or more claims" without specifying them, but independent claim 16 is representative of the core technology (Compl. ¶11).
• The essential elements of independent claim 16 are:
  • 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, the transition defining a pair of successive visual display configuration states; and
  • during the transition from the current display configuration state to the next display configuration state, presenting to the viewer the transition effect associated with the defined pair of successive visual display configuration states.
• The complaint suggests that additional claims may be asserted later (Compl. ¶11-12).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers generally to "Exemplary Defendant Products" that are purportedly identified in an exhibit not attached to the filed complaint. (Compl. ¶11, ¶13).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused product's functionality or market context. It alleges only that the "Exemplary Defendant Products practice the technology claimed by the '643 Patent." (Compl. ¶13).

IV. Analysis of Infringement Allegations

Claim Chart Summary

The complaint states that it incorporates claim charts by reference from an "Exhibit 2" (Compl. ¶13-14). However, this exhibit was not filed with the complaint. As a result, a detailed analysis of the infringement allegations is not possible based on the provided documents. No probative visual evidence provided in complaint.

Identified Points of Contention

Given the limited information, the central disputes will likely revolve around fundamental questions of claim scope and evidence.

• Scope Questions: A likely point of contention will be the proper construction of "display configuration state." The question for the court may be whether this term, as used in the patent, should be interpreted broadly to cover any slide layout, or more narrowly to require the kind of complex, multi-element arrangements of video, text, and graphic frames depicted in the patent’s figures (’643 Patent, Fig. 1(b)-1(j)).
• Technical Questions: A key evidentiary question will be whether the accused products actually perform the claimed step of "associating a transition effect" with each pair of potentially successive states. The plaintiff may need to show that the accused software contains a specific data structure or set of rules (e.g., a matrix as shown in Fig. 3) that maps state-pairs to transitions, as distinct from a system that uses a smaller set of generic transition rules.

V. Key Claim Terms for Construction

"display configuration state"

• Context and Importance: This term defines the basic architectural unit of the claimed invention. Its interpretation will determine the types of visual presentations that fall within the scope of the claims. Practitioners may focus on this term because the infringement analysis hinges on whether the accused products' screen layouts meet this definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification defines the term as "the format of a screen" which "defines the framework through which data content is presented," language that could support a broad reading covering any distinct screen layout. (’643 Patent, col. 5:12-15).
  • Evidence for a Narrower Interpretation: The patent’s detailed description and figures consistently illustrate "display configuration states" as complex layouts containing multiple, distinct frames for different content types like video, text, and still images, sometimes overlapping. This could support an argument that the term is limited to such multi-component arrangements. (’643 Patent, Fig. 1(b), 1(f), 1(i)).

"associating a transition effect therewith"

• Context and Importance: This phrase describes the central, operative step of the claimed method. The meaning of "associating" is critical to determining whether an accused product's method for selecting transitions infringes.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification refers to "associational rules defined by the matrix 200," which could suggest that any logical link or rule-based system for selecting a transition effect for a given state-pair meets the limitation. (’643 Patent, col. 7:31-33).
  • Evidence for a Narrower Interpretation: The patent repeatedly emphasizes the concept of a pre-defined mapping for each pair of potentially successive states, exemplified by the comprehensive matrix in Figure 3. This may support a narrower construction requiring an explicit, exhaustive data structure that links every possible transition to a specific effect, rather than a more generalized or algorithmic approach. (’643 Patent, col. 3:38-47; Fig. 3).

VI. Other Allegations

Indirect Infringement

The complaint does not allege specific facts to support claims of induced or contributory infringement. (Compl. ¶11-12).

Willful Infringement

The complaint does not contain an explicit allegation of willful infringement. However, the prayer for relief includes a request for a judgment that the case be declared "exceptional" under 35 U.S.C. § 285 and for an award of attorneys' fees, which may be predicated on a later showing of willfulness or other litigation misconduct. (Compl., Prayer E.i).

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

• A central issue will be one of evidentiary demonstration: given the conclusory nature of the complaint, the case will depend on what discovery reveals about the inner workings of the accused products. The key question is whether Plaintiff can produce evidence that the products implement the specific mechanism of associating a pre-defined transition effect with each potential pair of display states, as claimed in the patent.
• The outcome may also turn on a question of definitional scope: can the term "display configuration state," which is illustrated in the patent with complex, multi-frame layouts, be construed to read on the potentially simpler slide designs used in the accused products? The court’s interpretation of this term will be critical in defining the boundaries of the patent’s claims.