Innobrilliance LLC v. Ubiquiti Networks Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Innobrilliance, LLC (Texas)
  • Defendant: Ubiquiti Networks, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:24-cv-10000, S.D.N.Y., 12/30/2024
• Venue Allegations: Venue is asserted on the basis that Defendant maintains an established place of business within the Southern District of New York and has allegedly committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to a system and method for organizing and displaying multiple video streams in thematic groups on a single screen.
• Technical Context: The technology addresses the user interface challenge of navigating numerous television channels by allowing users to view curated groups of channels (e.g., by genre) simultaneously.
• Key Procedural History: The asserted patent claims priority back to an application filed in 2007. The complaint is the first formal notice of infringement alleged against the Defendant.

Case Timeline

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

• Patent Identification: U.S. Patent No. 9,247,299, "Method and system for television channel group," issued January 26, 2016.
• The Invention Explained:
  • Problem Addressed: The patent’s background section describes the "daunting task" for users of navigating the rapidly expanding number of available television channels, particularly in multi-picture viewing environments where managing several video feeds at once is difficult (’299 Patent, col. 2:1-6). Existing solutions like simple programmed channel lists are described as inflexible and cumbersome for households with multiple users having different tastes (’299 Patent, col. 2:22-36).
  • The Patented Solution: The invention proposes a system featuring a "frame controller" that organizes video channels into "channel groups" based on a shared "attribute," such as genre (e.g., sports, news, movies) or language (’299 Patent, Abstract; col. 8:43-51). This system allows a user to select a thematic group and see multiple channels from that group displayed simultaneously in separate, non-overlapping picture frames on a television screen, simplifying navigation within a category of interest (’299 Patent, col. 2:41-57; Fig. 4).
  • Technical Importance: This approach aimed to improve the user experience for managing content overload resulting from the growth of digital cable, satellite, and internet television services by providing a theme-based organizational layer for channel surfing.
• Key Claims at a Glance:
  • The complaint asserts one or more claims, including, for example, independent claim 1 (Compl. ¶11).
  • The essential elements of independent claim 1 include:
    • An input interface for receiving video data from multiple video streams.
    • A frame controller that displays the video data in multiple, separate pictures on a display.
    • The frame controller receives a user selection to display a "video group related to an attribute," where the group contains at least two video streams.
    • The controller receives and displays those video streams in separate pictures.
    • The controller receives a second user selection to change the display in one picture to another video stream from within the same video group.
  • The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

• Product Identification: The complaint alleges infringement by "Exemplary Defendant Products" that are identified in charts attached as Exhibit 2 (Compl. ¶11). However, Exhibit 2 was not filed with the complaint, so the specific accused products are not identified in the available documents.
• Functionality and Market Context: The complaint alleges that the unidentified accused products "practice the technology claimed by the '299 Patent" (Compl. ¶16). Without access to the infringement charts in Exhibit 2, the complaint does not provide sufficient detail for analysis of the specific functionality of the accused products or their market context.

IV. Analysis of Infringement Allegations

The complaint incorporates its infringement allegations by reference to claim charts in Exhibit 2, which was not publicly filed (Compl. ¶16-17). The complaint alleges that the accused products satisfy all elements of the asserted claims (Compl. ¶16). Based on the patent and the general allegations, the infringement theory appears to be that the accused products provide a system for receiving and displaying multiple video streams, and include a feature that allows users to organize these streams into groups and navigate within them in a manner that maps to the steps of the asserted claims.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A primary issue may be whether the patent's claims, which are described in the context of a "television system" with integrated hardware like a "frame controller" and "tuners" (’299 Patent, Fig. 1), can be construed to read on Defendant's products. As Ubiquiti is a network technology company, its products may be software-based or network-centric, raising the question of whether such an architecture constitutes a "television system" as contemplated by the patent.
  • Technical Questions: A key factual question will be what feature, if any, in the accused products constitutes a "video group related to an attribute" as required by the claims (’299 Patent, col. 11:57-59). The complaint does not provide evidence showing that the accused products organize streams based on thematic attributes (e.g., 'sports,' 'news,' 'movies' as shown in Fig. 5a) as opposed to other methods like user-created playlists, which may not meet the "attribute" limitation.

V. Key Claim Terms for Construction

• The Term: "video group related to an attribute"

• Context and Importance: This term is the central inventive concept. Its construction will be critical to determining whether any grouping feature in the accused products infringes. The dispute will likely focus on what qualifies as an "attribute."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of potential attributes, including "sports, news, or movies," "ethnicity, language or culture," and "age appropriateness," and states that "numerous attributes about which channel groups may be formed... are not enumerated herein" (’299 Patent, col. 3:8-14; col. 10:39-41). This language may support a broad interpretation covering any form of thematic or categorical grouping.
  • Evidence for a Narrower Interpretation: The patent’s exemplary embodiments show pre-defined, genre-based groups (e.g., "Channel Group 460a" for sports, "460b" for news) (’299 Patent, Fig. 5a). The specification also describes obtaining these groups from a "multi-channel operator" or a manufacturer, which could suggest the "attribute" is an externally defined characteristic rather than an arbitrary, user-defined label (’299 Patent, col. 10:45-52).

• The Term: "frame controller"

• Context and Importance: This is the core processing element of the claimed system. Whether the accused products contain a "frame controller" will be a central infringement question, particularly if the accused system is software-based or distributed across a network.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Plaintiff may argue that a "frame controller" is any component, whether hardware or software, that performs the claimed functions: causing video to be displayed, receiving user selections, and managing the display of video groups (’299 Patent, col. 6:8-11).
  • Evidence for a Narrower Interpretation: The patent includes detailed diagrams depicting the "frame controller" as a specific hardware component (150) connected to multiple "tuners" (151, 153, etc.) and an "output interface" within a television system architecture (’299 Patent, Fig. 1). This could support a narrower construction limited to a localized hardware device, as opposed to a software application or a distributed network function.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to use the accused products in a manner that infringes the ’299 Patent (Compl. ¶14). The allegation is also predicated on knowledge acquired "at least since being served by this Complaint" (Compl. ¶15).
• Willful Infringement: While the complaint does not use the term "willful," it alleges that Defendant has "Actual Knowledge of Infringement" via the service of the complaint and continues to infringe despite this knowledge (Compl. ¶13-14). This forms a basis for a claim of post-filing willful infringement.

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

• A core issue will be one of definitional scope: can the term "video group related to an attribute," which is rooted in the patent's examples of broadcast television genres like "sports" and "news," be construed to cover the specific grouping and playlisting functionalities present in the accused modern networking products?
• A key evidentiary question will be one of architectural mapping: does the accused system, which is likely software-based, contain a component or set of components that performs the functions of the claimed "frame controller," or will the patent’s depiction of a hardware-centric controller integrated with a television set limit the claim scope to exclude the accused architecture?