DCT
2:19-cv-00223
Uniloc 2017 LLC v. Riot Games Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Uniloc USA Inc (Delaware)
- Defendant: Riot Games Inc (Delaware)
- Plaintiff’s Counsel: Etheridge Law Group
- Case Identification: 2:19-cv-00223, W.D. Tex., 12/18/2019
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a "regular and established place of business" in the district through its network infrastructure used to service local residents and deliver low-latency content.
- Core Dispute: Plaintiff alleges that Defendant’s "League of Legends" online game platform infringes patents related to the network-based management and distribution of configurable software applications.
- Technical Context: The patents concern client-server systems for centrally managing and distributing software applications that have both administrator-defined and user-specific configuration options.
- Key Procedural History: The complaint alleges that a prior lawsuit, Uniloc USA Inc et al v. Riot Games, Inc., Case No. 2:17-cv-284 (E.D. Tex.), placed Defendant on notice of the asserted patents, a fact which may be relevant to the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 1998-12-14 | ’578 and ’293 Patents Priority Date |
| 2001-11-27 | ’578 Patent Issue Date |
| 2006-06-27 | ’293 Patent Issue Date |
| 2017 | Prior lawsuit (2:17-cv-284) served, allegedly putting Defendant on notice |
| 2019-12-18 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,324,578 - "METHODS, SYSTEMS AND COMPUTER PROGRAM PRODUCTS FOR MANAGEMENT OF CONFIGURABLE APPLICATION PROGRAMS ON A NETWORK" (issued Nov. 27, 2001)
The Invention Explained
- Problem Addressed: The patent’s background describes the difficulty of managing software applications and maintaining user-specific settings in a distributed network environment where users may access applications from various different client workstations, each with potentially different hardware or connections (’578 Patent, col. 1:45-2:34).
- The Patented Solution: The invention proposes a centralized, on-demand server system to manage configurable applications. The server distributes two types of programs: a "configuration manager" for an administrator to establish a set of preferences, and an "application launcher" for the end-user (’578 Patent, col. 3:50-4:5). When a user initiates the launcher, it sends the user's identity to the server, which then executes the application using a combination of the pre-stored administrator preferences and the user's own set of preferences, providing a consistent experience regardless of the client device used (’578 Patent, Abstract; col. 4:6-14).
- Technical Importance: This approach aimed to centralize administrative control over software and user settings, simplifying deployment and management in large, heterogeneous corporate or online networks (’578 Patent, col. 1:45-55).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶22).
- Independent Claim 1 requires:
- Installing an application program (with configurable preferences and authorized users) on a server.
- Distributing an associated "application launcher program" to a client.
- Obtaining a "user set" of configurable preferences from an authorized user executing the launcher.
- Obtaining an "administrator set" of configurable preferences from an administrator.
- Executing the application program using both the user and administrator sets of preferences in response to a request from the user.
- The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶23).
U.S. Patent No. 7,069,293 - "METHODS, SYSTEMS AND COMPUTER PROGRAM PRODUCTS FOR DISTRIBUTION OF APPLICATION PROGRAMS TO A TARGET STATION ON A NETWORK" (issued June 27, 2006)
The Invention Explained
- Problem Addressed: The patent addresses the challenge of deploying and installing software from a central administrative point to multiple "on-demand servers" within a larger network, which in turn serve applications to end-users (’293 Patent, col. 1:60-2:11).
- The Patented Solution: The invention describes a method executed on a "centralized network management server" for distributing software to a "target on-demand server." The method involves preparing a "file packet" that contains the application program along with a "segment configured to initiate registration operations" at the target. This packet is then distributed to the target server, which uses the registration segment to install the program and make it available to its clients (’293 Patent, Abstract; col. 21:23-37). The process is illustrated in the patent’s Figure 8 (’293 Patent, FIG. 8).
- Technical Importance: This architecture provides a framework for automating the end-to-end deployment of software across a distributed server infrastructure from a single point of control (’293 Patent, col. 5:36-44).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶34).
- Independent Claim 1 requires a method executed on a centralized network management server comprising the steps of:
- Providing an application program to be distributed.
- Specifying source and target directories for the distribution.
- Preparing a file packet for the program that includes a "segment configured to initiate registration operations" at the target.
- Distributing the file packet to the "target on-demand server" to make the program available for use.
- The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶35).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Riot Games Inc' "League of Legends" software platform, specifically its "software licensing and delivery system," which includes the game's "launcher" program and the "associated backend server architecture" (Compl. ¶12, 22, 34).
Functionality and Market Context
- The system requires users to create an account and log in via a launcher program (Compl. ¶17). A screenshot of the login screen shows fields for "Username" and "Password," indicating user identification (Compl. ¶17). After logging in, users can select from various configurable game options, such as different game modes, which the complaint presents as evidence of configurable preferences (Compl. ¶15, 16). By clicking a "Launch" button, the user initiates the game, which is delivered from Riot Games' servers (Compl. ¶18). The complaint cites marketing materials stating the game has tens of millions of daily players, suggesting significant commercial scale (Compl. ¶13).
IV. Analysis of Infringement Allegations
’578 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| installing an application program having a plurality of configurable preferences and a plurality of authorized users on a server... | Riot Games installs the "League of Legends" application program on its backend server architecture. | ¶22 | col. 14:66-15:2 |
| distributing an application launcher program associated with the application program to a client... | Riot Games distributes the "League of Legends" launcher program to users, who use it to start the game. | ¶22, 18 | col. 15:3-6 |
| obtaining a user set of the plurality of configurable preferences associated with one of the plurality of authorized users... | The user obtains a set of configurable preferences, for example by selecting a specific game mode like "Nemesis Draft." | ¶22, 15 | col. 15:7-11 |
| obtaining an administrator set of the plurality of configurable preferences from an administrator | Riot Games, as the administrator, obtains a set of configurable preferences that govern the application's operation. | ¶22 | col. 15:12-14 |
| executing the application program using the obtained user set and the obtained administrator set...responsive to a request from the user | The game is executed using both the user's choices and Riot Games' administrator-set rules after the user requests to start a match. | ¶22, 18 | col. 15:15-24 |
- Identified Points of Contention:
- Scope Questions: A central question for claim construction may be whether in-game choices, such as selecting a game mode or character, constitute "configurable preferences" as that term is used in the patent. The patent specification provides examples such as "keyboard mapping, screen configuration and destination host preference values," which may suggest a more technical, application-level meaning (’578 Patent, col. 9:15-17).
- Technical Questions: The complaint alleges the use of a distinct "administrator set" of preferences. A technical question will be what evidence shows that Riot's system uses a separate, administrator-defined set of preferences that is combined with the user's set at execution time, as opposed to simply enforcing server-side game rules that are not "preferences" in the manner claimed.
’293 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing an application program to be distributed to the network management server | Riot Games' backend architecture provides the "League of Legends" application for distribution across its network. | ¶34 | col. 21:26-27 |
| specifying a source directory and a target directory for distribution of the application program | The backend architecture allegedly specifies source and target locations for distributing game content and updates. | ¶34 | col. 21:28-30 |
| preparing a file packet...including a segment configured to initiate registration operations for the application program at the target... | Riot Games' system allegedly prepares and distributes game updates in file packets that include a component to register them on target servers. | ¶34 | col. 21:31-34 |
| distributing the file packet to the target on-demand server to make the application program available for use by a user at a client | Riot Games distributes these file packets to its on-demand servers, which then make the game available to players. | ¶34 | col. 21:35-37 |
- Identified Points of Contention:
- Scope Questions: Does Riot's internal content delivery network (CDN) and patching architecture map to the patent's more specific model of a "centralized network management server" distributing to a separate "target on-demand server"? The patent’s figures depict a specific tiered architecture that may raise questions of architectural equivalence with the accused system (’293 Patent, FIG. 1).
- Technical Questions: What evidence does the complaint provide to support the existence of a "segment configured to initiate registration" within Riot's game update packets? The allegations are described at a high level and will depend on technical evidence revealed during discovery.
V. Key Claim Terms for Construction
Term: "configurable preferences" (’578 Patent, Claim 1)
- Context and Importance: The viability of the infringement case for the ’578 Patent may depend heavily on the construction of this term. Its definition will determine whether dynamic, user-selected gameplay options fall within the scope of the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not explicitly limit the term, referring broadly to "a plurality of configurable preferences" (’578 Patent, col. 14:67).
- Evidence for a Narrower Interpretation: The specification's examples of user-settable preferences include "keyboard mapping, screen configuration and destination host preference values," suggesting a context of technical application settings rather than in-game content choices (’578 Patent, col. 9:15-17).
Term: "target on-demand server" (’293 Patent, Claim 1)
- Context and Importance: The infringement theory for the ’293 Patent requires mapping Riot's infrastructure onto the patent's specific architectural model. The definition of this term is critical to determining if such a mapping is possible.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term could be read broadly to encompass any server that receives a software package and subsequently serves it to end-users upon request.
- Evidence for a Narrower Interpretation: The patent’s specification and Figure 1 consistently depict the "target on-demand server" (22) as a distinct intermediary between a "network management server" (20) and "client stations" (24, 26), suggesting a specific three-tier architecture that the accused system may or may not employ (’293 Patent, FIG. 1; col. 6:46-62).
VI. Other Allegations
- Indirect Infringement: For both patents, the complaint alleges induced infringement, stating that Riot Games "intentionally instructs its customers and/or agents to infringe through training videos, demonstrations, brochures, and installation and user guides" (Compl. ¶24, 36). Contributory infringement is also alleged (Compl. ¶26-27, 38-39).
- Willful Infringement: The complaint alleges that Riot Games had pre-suit knowledge of both patents based on the "service of the complaint in Uniloc USA Inc v. Riot Games Inc](https://ai-lab.exparte.com/case/dct/txed/2:17-cv-00284/uniloc-usa-inc-v-riot-games-inc), Case No. 2:17-cv-284 in the Eastern District of Texas" (Compl. ¶28, 40). This alleged knowledge forms the basis for the willfulness claims.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "configurable preferences", which the ’578 patent specification grounds in the context of technical application settings like keyboard maps, be construed to cover the dynamic, in-game content choices offered in the accused "League of Legends" platform?
- A key evidentiary question will be one of architectural mapping: does Riot Games' internal software deployment and content delivery system operate in a manner that maps onto the specific "centralized network management server" to "target on-demand server" architecture required by the claims of the ’293 patent, or is there a fundamental mismatch in technical operation?
- A third central question will concern the evidentiary basis for claimed functionality: what technical evidence will show that the accused system uses distinct "user" and "administrator" sets of preferences that are combined at runtime as claimed in the '578 patent, and that its update files contain a "segment configured to initiate registration" as claimed in the '293 patent?