DCT

1:25-cv-05390

Altice USA Inc v. Adeia Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-05390, S.D.N.Y., 06/27/2025
  • Venue Allegations: Plaintiff asserts that venue is proper based on clauses in prior licensing agreements between the parties consenting to exclusive jurisdiction in New York, and also based on Defendant’s business contacts within the district, including licensing negotiations and activities.
  • Core Dispute: Plaintiff seeks a declaratory judgment of noninfringement for ten U.S. patents owned by Defendant, arguing that its set-top boxes, mobile applications, and over-the-top content systems do not practice the claimed inventions related to digital media technology.
  • Technical Context: The patents-in-suit cover a range of technologies central to modern digital media distribution, including on-chip security for content decryption, dynamic generation of program guides for mobile devices, and methods for searching and delivering content.
  • Key Procedural History: The parties and their corporate predecessors have a long history of licensing agreements, with the current license set to expire on June 30, 2025. The present declaratory judgment action was filed after Defendant sent Plaintiff claim charts on or around May 30, 2025, alleging that Plaintiff’s products and services infringe the patents-in-suit and require a renewed license.

Case Timeline

Date Event
2004-02-17 U.S. Patent No. 7,406,598 Priority Date
2005-11-23 U.S. Patent No. 8,589,324 Priority Date
2006-10-02 U.S. Patent No. 7,818,769 Priority Date
2006-10-02 U.S. Patent No. 8,165,598 Priority Date
2007-03-09 U.S. Patent No. 9,326,025 Priority Date
2007-05-25 U.S. Patent No. 9,690,833 Priority Date
2008-06-13 U.S. Patent No. 8,601,526 Priority Date
2009-09-14 U.S. Patent No. 9,369,758 Priority Date
2010-09-30 U.S. Patent No. 10,506,010 Priority Date
2011-01-01 Initial license agreement between CSC and Rovi Guides
2012-05-14 U.S. Patent No. 8,713,606 Priority Date
2014-01-01 License agreement between Cequel and Rovi
2017-12-31 "2017 Adeia Agreements" provide license until Dec. 31, 2023
2023-02-16 Agreements extend Altice's license to June 30, 2025
2025-05-30 Adeia sends Altice claim charts alleging infringement
2025-06-27 Complaint for Declaratory Judgment filed

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

U.S. Patent No. 7,406,598 - “Method and System for Secure Content Distribution”

  • Patent Identification: U.S. Patent No. 7,406,598, issued July 29, 2008.

The Invention Explained

  • Problem Addressed: The patent addresses the problem of securing digital audio and video content from unauthorized copying by protecting the secret keys and codeword values used in scrambling and encryption techniques from being discovered and made public (’6,598 Patent, col. 1:26-44).
  • The Patented Solution: The invention proposes a System-on-a-Chip (SOC) architecture where sensitive data, such as a private decryption key, is stored in a "first secure storage location" that is physically and logically decoupled from all external outputs of the chip. An on-chip decryption engine uses this key to decrypt incoming content and is architected to write the resulting decrypted data only to other secure on-chip memory locations, preventing the key or the unscrambled content from being intercepted externally (’6,598 Patent, col. 2:16-44; Abstract).
  • Technical Importance: This hardware-based security approach, often called a "secure enclave" or "trusted execution environment," became a foundational technology for digital rights management (DRM) systems, enabling content providers to securely distribute high-value content to consumer devices like set-top boxes.

Key Claims at a Glance

  • The complaint asserts noninfringement of at least independent claim 1 (Compl. ¶67).
  • The essential elements of claim 1 include:
    • A system on a chip (SOC) device comprising external input and output interfaces.
    • A first secure storage location operably de-coupled from all external output nodes of the SOC device.
    • A decryption engine comprising a first data input, a private key input coupled to a portion of the first secure storage location, and an output coupled to a second secure storage location.
    • The decryption engine is operable to determine decrypted data based on a private key received at the private key input.
    • The decryption engine is further operable to write the decrypted data only to the first secure memory location and the second secure storage location.
  • The complaint does not explicitly reserve the right to assert noninfringement of dependent claims, but seeks a declaration of noninfringement for "any claim" of the patent (Compl. ¶70).

U.S. Patent No. 7,818,769 - “Methods and Apparatus for Implementing Dynamic Program Guides on Mobile Devices”

  • Patent Identification: U.S. Patent No. 7,818,769, issued October 19, 2010.

The Invention Explained

  • Problem Addressed: Providing comprehensive television program guides on mobile devices is challenging due to limited memory, processing power, and network bandwidth. Downloading an entire guide at once is inefficient and creates a poor user experience (’769 Patent, col. 1:12-28).
  • The Patented Solution: The patent describes a two-step method for dynamically retrieving guide data. A mobile device first sends a request for "program guide structure information," such as a list of available channels ("lineup data"). After receiving this basic structure, and in response to the user navigating to a specific portion of the guide (e.g., scrolling to a block of channels or a time slot), the device sends a second, separate request for the detailed "program guide content information," such as program titles and descriptions for that specific portion only (’769 Patent, Abstract; col. 2:1-10).
  • Technical Importance: This "just-in-time" data retrieval method allows for a responsive and seemingly endless program guide on resource-constrained devices, a key enabling technology for the transition of television viewing to mobile platforms.

Key Claims at a Glance

  • The complaint asserts noninfringement of at least independent claim 1 (Compl. ¶76).
  • The essential elements of claim 1 include:
    • Sending a first request from a mobile device to a server associated with program guide structure information.
    • Receiving a first response at the mobile device associated with the program guide structure information, which includes a plurality of channel identifiers.
    • Sending a second request from the mobile device to the server associated with program guide content information.
    • The second request is sent in response to navigation to a first portion of a program guide generated using the program guide structure information.
    • Receiving a second response at the mobile device associated with the program guide content information, which includes a plurality of program titles.
  • The complaint seeks a declaration of noninfringement for "any claim" of the patent (Compl. ¶80).

U.S. Patent No. 8,165,598 - “Methods and Apparatus for Providing Media on Mobile Devices”

  • Patent Identification: U.S. Patent No. 8,165,598, issued April 24, 2012.
  • Technology Synopsis: This patent addresses providing location-relevant media content to mobile devices. The invention involves identifying a location associated with a mobile device and, upon receiving a request, sending program guide information that corresponds to that specific location and a requested block of channels (’5,598 Patent, Abstract).
  • Asserted Claims: The complaint asserts noninfringement of at least independent claim 1 (Compl. ¶86).
  • Accused Features: The accused functionality is the provision of “Available Out of Home” content listings in the guide of Altice's Optimum TV App (Compl. ¶40, 83).

U.S. Patent No. 8,589,324 - “System and Method for Finding Desired Results by Incremental Search Using an Ambiguous Keypad with the Input Containing Typographic Errors”

  • Patent Identification: U.S. Patent No. 8,589,324, issued November 19, 2013.
  • Technology Synopsis: The patent describes a system for searching content using an ambiguous keypad (like a phone keypad where '2' can be A, B, or C). The system is designed to handle typographic errors and presents the most likely matching items in response to each incremental keystroke (’324 Patent, Abstract).
  • Asserted Claims: The complaint asserts noninfringement of at least independent claim 8 (Compl. ¶96).
  • Accused Features: The accused functionality relates to content search features on Altice's Optimum TV App (Compl. ¶43, 93).

U.S. Patent No. 8,601,526 - “Systems and Methods for Displaying Media Content and Media Guidance Information”

  • Patent Identification: U.S. Patent No. 8,601,526, issued December 3, 2013.
  • Technology Synopsis: The invention relates to a system where a portable electronic device transmits media guidance information to a primary display system (e.g., a television). This information is then displayed on the main screen simultaneously with other media content received from a different source (’526 Patent, Abstract).
  • Asserted Claims: The complaint asserts noninfringement of at least independent claim 1 (Compl. ¶106).
  • Accused Features: The accused functionalities relate to recording selections and the display of recording indicators within Altice's Optimum TV Service and Optimum TV App (Compl. ¶46, 103).

U.S. Patent No. 8,713,606 - “Systems and Methods for Generating a User Profile Based Customized Media Guide with User-Generated Content and Non-User-Generated Content”

  • Patent Identification: U.S. Patent No. 8,713,606, issued April 29, 2014.
  • Technology Synopsis: This patent describes an interactive media guide that integrates user-generated content (e.g., from online sources) with traditional non-user-generated content (e.g., linear television). The guide generates a display where source identifiers for both types of content are presented along a common axis (’606 Patent, Abstract).
  • Asserted Claims: The complaint asserts noninfringement of at least independent claim 1 (Compl. ¶116).
  • Accused Features: The accused functionality is the generation and display of “Related on YouTube” listings alongside traditional television listings on Altice's Optimum TV Service (Compl. ¶49, 113).

U.S. Patent No. 9,326,025 - “Media Content Search Results Ranked by Popularity”

  • Patent Identification: U.S. Patent No. 9,326,025, issued April 26, 2016.
  • Technology Synopsis: The patent details a method for ranking media content search results based on a "popularity rating." This rating is derived from tracking viewer interactions, such as their programming choices, to determine which content is most popular and should be ranked higher in search results (’025 Patent, Abstract).
  • Asserted Claims: The complaint asserts noninfringement of at least independent claim 1 (Compl. ¶126).
  • Accused Features: The accused functionality is the text-based content searching on Altice's Optimum TV App (Compl. ¶52, 123).

U.S. Patent No. 9,369,758 - “Multifunction Multimedia Device”

  • Patent Identification: U.S. Patent No. 9,369,758, issued June 14, 2016.
  • Technology Synopsis: The invention describes a method for overlaying information onto high-definition video frames. It involves loading uncompressed high-definition frames into a frame buffer and then writing message-associated information into that same buffer to overlay the original frames (’758 Patent, Abstract).
  • Asserted Claims: The complaint asserts noninfringement of at least independent claim 1 (Compl. ¶135).
  • Accused Features: This patent is asserted against functionality allegedly implemented by the Broadcom BCM7252S SoC in Sagemcom STBs, specifically relating to overlaying information in a frame buffer (Compl. ¶55, 132).

U.S. Patent No. 9,690,833 - “System and Method for Text Disambiguation and Context Designation in Incremental Search”

  • Patent Identification: U.S. Patent No. 9,690,833, issued June 27, 2017.
  • Technology Synopsis: This patent describes a multi-step search method. After receiving a first keystroke sequence and a user selection from a first result set, the system automatically obtains metadata from the selected item and then performs a second search on that metadata to generate a second result set (’833 Patent, Abstract).
  • Asserted Claims: The complaint asserts noninfringement of at least independent claim 1 (Compl. ¶144).
  • Accused Features: The accused functionality is text-based content searching on Altice's Optimum TV Service (Compl. ¶58, 141).

U.S. Patent No. 10,506,010 - “Delivering Content in Multiple Formats”

  • Patent Identification: U.S. Patent No. 10,506,010, issued December 10, 2019.
  • Technology Synopsis: The invention describes a system at an edge location of a network that transcodes a content item into first and second video streams in different formats. It then fragments both streams and aligns the fragments based on a common point in the content item, allowing for efficient switching between formats during delivery (’010 Patent, Abstract).
  • Asserted Claims: The complaint asserts noninfringement of at least independent claim 1 (Compl. ¶153).
  • Accused Features: The accused functionalities are the transcoding, fragmenting, aligning, and storage capabilities of Altice's Optimum TV OTT multimedia content system (Compl. ¶61, 150).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies several accused instrumentalities: the Sagemcom DCIWA384 Set-top-box ("STB") that incorporates the Broadcom BCM7252S System-on-a-Chip ("SoC") with "CryptoFirewall security technology" (Compl. ¶34, 55); the Altice "Optimum TV App" for mobile devices (Compl. ¶37); the broader "Optimum TV Service" accessible through both STBs and the App (Compl. ¶46); and Altice’s "Optimum TV Over the Top (‘OTT’) multimedia content system" (Compl. ¶61).

Functionality and Market Context

  • The accused instrumentalities collectively form Altice's digital media service platform. The STBs with Broadcom SoCs are alleged to perform secure content decryption and video frame buffer operations (Compl. ¶34, 55). The Optimum TV App is alleged to implement program guides and search functionalities for mobile users (Compl. ¶37, 43). The OTT system is alleged to perform back-end content processing, including transcoding and fragmenting media for delivery in multiple formats (Compl. ¶61). These products and services are central to Altice's consumer offerings in the U.S. cable and telecommunications market.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’6,598 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a decryption engine comprising... an output coupled to a second secure storage location... The hardware architecture of the CryptoFirewall security technology implemented on the Broadcom BCM7252S SoC. ¶67 col. 11:20-22
...and further operable to write the decrypted data only to the first secure memory location and the second secure storage location. The data write operations of the decryption engine within the CryptoFirewall security technology. ¶67 col. 11:23-28
  • Identified Points of Contention:
    • Scope Questions: A central dispute will be the structural definition of a "secure storage location." The complaint’s argument raises the question of whether the memory architecture within the Broadcom SoC contains what can be construed as a "second secure storage location" distinct from the first, as required by the claim (Compl. ¶67).
    • Technical Questions: The complaint makes a direct technical assertion that the accused decryption engine is not "operable to write the decrypted data" to the "first secure memory location" (Compl. ¶67). A key factual question will be what evidence exists to support or refute this assertion about the operational capabilities of the accused chip's internal data paths.

’769 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
...receive a first response “associated with program guide structure information” from the server, where a “program guide [is] generated using the program guide structure information”... The process by which the Optimum TV App receives initial data from Altice's servers to begin displaying a program guide. ¶76 col. 8:50-55
...sending a second request... to the server... in response to navigation to a first portion of the program guide generated using the program guide structure information. The process by which the Optimum TV App requests additional data as a user scrolls or navigates within the displayed program guide. ¶77 col. 8:56-62
  • Identified Points of Contention:
    • Scope Questions: The dispute may turn on the definition of "program guide structure information." The complaint suggests a possible mismatch, raising the question of whether the initial data transfer to the Optimum TV App constitutes the specific "structure information" from which a guide is then generated, or if the app's process differs fundamentally from this claimed two-step method (Compl. ¶76).
    • Technical Questions: The complaint alleges that the accused app does not perform the claimed second step of "send[ing] a second request... in response to navigation" (Compl. ¶77). An evidentiary question will be whether technical analysis of the app's network traffic shows distinct data requests triggered by user navigation that correspond to the claimed method.

V. Key Claim Terms for Construction

’6598 Patent: "secure storage location"

  • The Term: "secure storage location"
  • Context and Importance: This term is dispositive for the infringement analysis of the ’6598 Patent. Altice’s primary non-infringement argument is that its accused STB does not include a "second secure storage location" as required by claim 1 (Compl. ¶67). The construction of what constitutes a "secure" and distinct "location" within the SoC will be critical.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses storage more generally, which could support an argument that any partitioned or logically distinct memory area on the chip could qualify as a "location" (’6598 Patent, col. 9:60-67).
    • Evidence for a Narrower Interpretation: The patent abstract and claim 1 itself require this location to be "operably de-coupled from all external output nodes," suggesting a high standard for what qualifies as "secure." The figures also depict distinct blocks for "Protected Storage 150" and "Private Key Storage 170," which may support an argument that the claim requires physically or architecturally distinct memory units, not just logical partitions (’6598 Patent, Fig. 1).

’769 Patent: "program guide structure information"

  • The Term: "program guide structure information"
  • Context and Importance: The novelty of the ’769 Patent’s method hinges on the sequential request for two different types of data: "structure" information first, then "content" information. Altice contends its app does not infringe because it does not receive a response "associated with program guide structure information" from which a guide is then generated (Compl. ¶76). The case may turn on whether the initial data received by the app meets this definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term could be construed broadly to mean any data that helps organize or lay out the program guide for the user.
    • Evidence for a Narrower Interpretation: The specification explicitly states that "The program guide structure information includes lineup data" (’769 Patent, col. 2:1-2). The summary and abstract consistently describe a two-request process where "structure" is obtained before "content," suggesting the patentee intended a clear distinction between a basic framework (e.g., channel list) and the detailed listings that populate it (’769 Patent, Abstract).

VI. Other Allegations

  • Indirect Infringement: The complaint seeks a declaratory judgment that Altice "does not infringe and has not infringed, directly or indirectly, any claim" of the patents-in-suit (Compl. ¶65, 74). While no specific facts related to indirect infringement are alleged by Altice, this language indicates that the scope of the controversy for which it seeks judgment includes inducement and contributory infringement.

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

  • A core issue will be one of architectural correspondence: for the hardware-focused patents (’6598, ’758), can the specific circuit layouts and data pathways of the accused Broadcom SoC be mapped onto the structural and operational limitations recited in the asserted claims, particularly the requirements for distinct secure memory locations and specific frame buffer write operations?
  • A central question will be one of procedural fidelity: for the method-focused patents (’769, ’5,598, ’833, ’010), does the operational sequence of Altice's software and OTT systems—such as the manner in which they request guide data, handle location information, or process video streams—match the specific, ordered steps required by the claims, or is there a fundamental divergence in the technical process?
  • Underlying the technical disputes is a broader question of licensing scope: given the decade-long licensing history between the parties, the case will ultimately determine whether Altice's current generation of technology has evolved outside the boundaries of Adeia's patent portfolio, or if it continues to practice inventions for which a license is required.