Cedar Lane Tech Inc v. Eleven Labs Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Eleven Labs Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-07842, S.D.N.Y., 09/22/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the Southern District of New York and having committed alleged acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s products and services infringe a patent related to systems and methods for generating, customizing, and presenting interactive audio publications.
• Technical Context: The technology addresses the conversion of text-based or speech-based content (like news articles or podcasts) into structured, navigable audio formats that allow for interactive, non-visual consumption.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,438,485 - System, method, and apparatus for generating, customizing, distributing, and presenting an interactive audio publication

• Patent Identification: U.S. Patent No. 8,438,485 ("System, method, and apparatus for generating, customizing, distributing, and presenting an interactive audio publication"), issued May 7, 2013 (the "'485' Patent").

The Invention Explained

• Problem Addressed: The patent’s background section identifies a need for an audio-based news consumption system that combines the dynamic content of visually-oriented media with greater interactivity than is available in traditional podcasts or broadcast radio, which are often limited to simple linear playback controls (’485 Patent, col. 1:26-48). This is particularly aimed at individuals who are multitasking, such as driving or exercising (’485 Patent, col. 1:30-33).
• The Patented Solution: The invention describes a comprehensive system to convert text and speech content into "interactive audio publications" (’485 Patent, Abstract). This is achieved by transforming source material into "audio content items" that include not only the spoken audio but also metadata defining the content's internal structure (e.g., word, sentence, and paragraph boundaries) (’485 Patent, col. 9:65-col. 10:9). These items are then assembled into publications with defined sections, which can be customized by a subscriber and distributed to a presentation device that enables navigation via voice commands or a button interface (’485 Patent, Fig. 1; col. 2:26-35).
• Technical Importance: The described technology aims to provide an audio experience with navigability and user control analogous to browsing a text-based website, moving beyond the linear playback model of conventional audio media (’485 Patent, col. 1:59-63).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" without specifying them in the body of the complaint, instead referencing an unattached exhibit (Compl. ¶11). The analysis below focuses on independent claim 1 as a representative claim.
• Independent Claim 1 (Method Claim) Elements:
  • Enabling a subscriber to access a subscriber portal to generate a custom audio publication template.
  • Receiving a plurality of content items (text-based or speech-based).
  • Converting the content items into corresponding audio content items, each including digital audio data and metadata indicating the structure of the audio data.
  • Assembling an audio publication from the audio content items according to the custom template, with the publication organized into one or more sections.
  • Generating audio publication metadata that defines the structure of the audio publication.
  • Distributing the audio publication to the subscriber for interactive presentation.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" without naming specific products or services (Compl. ¶11).

Functionality and Market Context

• The complaint does not provide a specific description of the accused product's functionality. It alleges that the accused products "practice the technology claimed by the ’485 Patent" and that they "satisfy all elements of the Exemplary ’485 Patent Claims," incorporating by reference claim charts from an unattached exhibit for the specific details of operation (Compl. ¶16, ¶17).

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or detailed infringement allegations in its body, instead incorporating by reference "the claim charts of Exhibit 2," which was not provided (Compl. ¶17). The narrative theory of infringement is that Defendant's "Exemplary Defendant Products" practice the claimed technology and satisfy all elements of certain exemplary claims (Compl. ¶16).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A potential area of dispute may arise from the scope of the term "interactive audio publication." The litigation may question whether the output of Defendant's services constitutes a structured, navigable "publication" assembled from multiple content items, as contemplated by the patent, or if it is more accurately characterized as a synthesized audio file generated from a single user input.
  • Technical Questions: The complaint does not provide factual support for several key claim elements. An evidentiary question will be whether Defendant's system performs the steps of (1) enabling a user to generate a "custom audio publication template" that dictates the assembly of content, (2) "assembling" an audio publication from multiple "content items" according to such a template, and (3) generating the specific two-tiered metadata structure (both "audio content item metadata" and "audio publication metadata") required by the claims.

V. Key Claim Terms for Construction

• The Term: "interactive audio publication"

  • Context and Importance: This term defines the invention's ultimate output and is central to the dispute. Its construction will determine whether the accused products, known in the market for voice synthesis, generate an output that falls within the scope of the claims. Practitioners may focus on whether this term requires a collection of distinct, navigable content items assembled into sections, or if a single, structured audio file could suffice.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent abstract describes the invention broadly as systems for "generating, customizing, distributing, and presenting an interactive audio publication." The term itself is not explicitly defined with a single, limiting definition.
    • Evidence for a Narrower Interpretation: The specification repeatedly describes an "audio publication" as a collection of "audio content items" organized into one or more "sections" (e.g., "Technology, Entertainment, Sports Podcasts") (’485 Patent, col. 7:64-col. 8:2). The interactivity is linked to specific runtime modes ("title mode," "summary mode") and navigation via voice commands (’485 Patent, col. 25:1-20). This may support an interpretation requiring a multi-part, sectioned compilation rather than a single audio stream.

• The Term: "custom audio publication template"

  • Context and Importance: This term is a key limitation in claim 1, requiring that the "audio publication" be assembled according to subscriber-defined rules. The infringement analysis will depend on whether Defendant's services provide a comparable customization functionality.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language requires only that the template be "custom" and "subscriber-defined," which could arguably cover a wide range of user settings (’485 Patent, col. 51:41-43).
    • Evidence for a Narrower Interpretation: The detailed description provides specific examples of what a template entails, including "static assignment rules and/or dynamic search-based criteria" for selecting and organizing content, renaming or reordering sections, and combining items from multiple source publications into a new section (’485 Patent, col. 2:54-56; col. 17:15-34). This suggests a template is a set of structural assembly rules, not merely settings for audio output like voice or speed.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users" to use its products in an infringing manner (Compl. ¶14). Specifics are purportedly provided in the unattached Exhibit 2 (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based on post-suit knowledge. The complaint asserts that its service "constitutes actual knowledge of infringement" and that Defendant's continued activities despite this knowledge support a claim for willfulness (Compl. ¶13, ¶14). No pre-suit knowledge is alleged.

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

• A core issue will be one of definitional scope: does Defendant’s service, which generates synthesized audio from user input, create an "interactive audio publication" as described in the ’485 Patent? This will likely depend on whether the output is merely a linear audio file or a structured compilation of distinct content items assembled according to a user-defined "template."
• The primary challenge for the plaintiff appears to be evidentiary sufficiency. The complaint makes conclusory allegations of infringement without providing specific facts in its body to support key claim limitations, such as the assembly of a publication from multiple sources via a custom template. A key question will be whether discovery reveals that the accused products perform these specific system-level functions beyond basic text-to-speech conversion.