DCT

2:23-cv-00471

SportsCastr Inc v. Genius Sports Ltd Pursuant To Court Order Docket Only In Lead Case

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00471, E.D. Tex., 09/04/2024
  • Venue Allegations: Plaintiff asserts venue is proper because Defendant is a foreign entity and has allegedly committed acts of infringement in the district, including recruiting employees and forming business partnerships with Texas-based entities.
  • Core Dispute: Plaintiff alleges that Defendant’s sports data and video streaming products infringe four U.S. patents related to the scalable, low-latency delivery of live video streams enhanced with synchronized, interactive data.
  • Technical Context: The technology addresses the synchronization of live video broadcasts with contextually matched data overlays, a critical feature for the online sports betting and interactive fan engagement industries.
  • Key Procedural History: Plaintiff states it provided Defendant with affirmative notice of infringement for three of the asserted patents via a letter on October 4, 2023, and for the fourth patent via a letter on April 17, 2024. The complaint also notes that Plaintiff has had communications with Defendant's executives since 2018.

Case Timeline

Date Event
2016-08-05 Priority Date for ’687, ’218, and ’697 Patents
2016-01-01 Genius Sports founded
2017-05-16 Priority Date for ’088 Patent
2019-09-24 U.S. Patent No. 10,425,697 issues
2019-10-08 Genius Sports announces live video streaming service
2020-10-13 U.S. Patent No. 10,805,687 issues
2021-06-15 U.S. Patent No. 11,039,218 issues
2024-01-09 U.S. Patent No. 11,871,088 issues
2024-09-04 First Amended Complaint filed

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

U.S. Patent No. 10,805,687 - “Systems, apparatus, and methods for scalable low-latency viewing of broadcast digital content streams of live events, and synchronization of event information with viewed streams, via multiple internet channels”

  • Patent Identification: U.S. Patent No. 10,805,687, entitled “Systems, apparatus, and methods for scalable low-latency viewing of broadcast digital content streams of live events, and synchronization of event information with viewed streams, via multiple internet channels,” issued October 13, 2020 (Compl. ¶40).
  • The Invention Explained:
    • Problem Addressed: The patent addresses shortcomings in conventional live video streaming, such as significant viewer latency (delay) and the difficulty of synchronizing contextual event information (e.g., sports statistics, betting odds) with the video signal across many viewers (Compl. ¶6, ¶45). Prior systems often hard-embedded this data into the video, which created processing overhead and limited flexibility (Compl. ¶44).
    • The Patented Solution: The invention proposes a server architecture that separates the delivery of video from the delivery of event data (Compl. ¶13). It uses a "one-to-many socket architecture" where multiple viewers connect to a single, dedicated "event socket" for a specific live event to receive synchronized data, while the video is delivered via a separate channel (Compl. ¶11, ¶47). This architecture is designed to provide scalable, low-latency, and interactive data overlays without modifying the original video stream (’687 Patent, col. 26:37-56).
    • Technical Importance: This architectural approach facilitates scalable, low-latency viewing of live events enhanced with synchronized data, which is a foundational technology for the modern online sports betting and interactive streaming industries (Compl. ¶1, ¶57).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 19 and dependent claim 20 (Compl. ¶63).
    • Essential elements of independent claim 19 include:
      • A system for providing copies of a first live stream relating to a first live sporting event and a second live stream relating to a second live sporting event.
      • A plurality of media sources to receive the first and second live streams and provide copies to viewer client devices over first and second Internet communication channels.
      • A control server to periodically retrieve first and second event information germane to the respective sporting events.
      • At least one socket server to receive the event information from the control server and transmit it to viewer devices over third and fourth Internet communication channels, using distinct first and second event sockets (Compl. ¶64).

U.S. Patent No. 11,039,218 - “Systems, apparatus and methods for rendering digital content relating to a sporting event with online gaming information”

  • Patent Identification: U.S. Patent No. 11,039,218, entitled “Systems, apparatus and methods for rendering digital content relating to a sporting event with online gaming information,” issued June 15, 2021 (Compl. ¶41).
  • The Invention Explained:
    • Problem Addressed: The patent addresses the technical challenge of providing synchronized, interactive "online gaming information" (e.g., betting data) to viewers of a live sporting event without incurring the high latency and inflexibility of conventional streaming systems (’218 Patent, col. 4:42-58; Compl. ¶45).
    • The Patented Solution: The patented system uses a webserver to provide a client device with two separate addresses: one for a media source to establish a video channel, and another for a socket server to establish an event information channel (’218 Patent, col. 50:50-51:4). This separation allows online gaming information to be transmitted via the dedicated socket and synchronized with the video at the client device, enabling interactive features like clickable overlays (Compl. ¶48, ¶52-53).
    • Technical Importance: The claimed solution provides a technical framework for integrating real-time, actionable gaming content with live sports video, improving the functionality of computer networks for the sports betting market (Compl. ¶4, ¶57).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1 and dependent claim 4 (Compl. ¶112).
    • Essential elements of independent claim 1 include:
      • A system for controlling viewer devices to receive digital content and event information for a sporting event, where the event information includes online gaming information.
      • A control server to periodically retrieve the event information.
      • At least one socket server to receive the event information and transmit it (including the online gaming information) to a viewer client device via a first event information channel.
      • At least one webserver to transmit to the viewer client device both a first Internet address of a media source (for the video) and a first socket address of the event socket (for the gaming information) (Compl. ¶113).

Multi-Patent Capsule: U.S. Patent No. 10,425,697

  • Patent Identification: U.S. Patent No. 10,425,697, entitled “Systems, apparatus, and methods for scalable low-latency viewing of broadcast digital content streams of live events, and synchronization of event information with viewed streams, via multiple internet channels,” issued September 24, 2019 (Compl. ¶42).
  • Technology Synopsis: This patent, from the same family as the ’687 and ’218 Patents, addresses the technical problem of synchronizing event information, specifically score information, with live video-based commentary from multiple broadcasters covering multiple sporting events (Compl. ¶39, ¶157). The solution employs a server architecture with separate channels for video and event data, using a control server to retrieve score information and a socket server to transmit it to viewers in sync with the corresponding video stream (Compl. ¶157).
  • Asserted Claims: Independent claim 19 and dependent claim 20 are asserted (Compl. ¶156).
  • Accused Features: The complaint alleges infringement by Genius Sports’ streaming products that provide overlaid information, including real-time score updates synchronized with video commentary, to multiple viewers for various sporting events (Compl. ¶160).

Multi-Patent Capsule: U.S. Patent No. 11,871,088

  • Patent Identification: U.S. Patent No. 11,871,088, entitled “Systems, apparatus, and methods for providing event video streams and synchronized event information via multiple Internet channels,” issued January 9, 2024 (Compl. ¶43).
  • Technology Synopsis: This patent describes a system where a webserver sends instructions to client devices to enable the synchronized rendering of a live video feed and associated event information (Compl. ¶212). The instructions cause the client device to connect to a media source for the audio/video feed and separately to a socket server for the event information, which is then displayed as a user-interactive overlay (Compl. ¶212).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶211).
  • Accused Features: The accused features are Genius Sports’ streaming products, such as BetVision, that provide fans with "integrated odds, promotions, real-time statistics, break-in-action offers, graphic overlays and more" as interactive features alongside live video (Compl. ¶216).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the accused instrumentalities as a suite of video-streaming products including LiveData, LiveTrading, Genius Trading Services, BetVision, and In-Play MultiBet (Compl. ¶17).
  • Functionality and Market Context: The Accused Products are alleged to provide a platform for integrating live sports video streams with synchronized data feeds for sportsbooks (Compl. ¶59, ¶67). The system is alleged to offer two primary integration options for its customers (sportsbooks): a "Drop & Play" video player widget or a "Video API" that allows customers to use their own player (Compl. ¶72). In both options, authentication data for a video stream is retrieved and passed to a video player on the client device, which then requests the video from a Content Delivery Network (CDN) (Compl. ¶72-74). A process diagram in the complaint illustrates the data flow for the "Drop & Play" option, showing the customer website passing a URL, token, and DRM to the video player on the client device (Compl. p. 27). Separately, event information, such as betting data for the "Multibet" widget, is allegedly transmitted from Genius Sports' back-end (e.g., its Pricing Engine) to the client device via a "long running socket" or WebSockets (Compl. ¶78-80, ¶82).

IV. Analysis of Infringement Allegations

10,805,687 Patent Infringement Allegations

Claim Element (from Independent Claim 19) Alleged Infringing Functionality Complaint Citation Patent Citation
A system for providing a first plurality of copies of a first live stream of digital content relating to a first live sporting event...and for providing a second plurality of copies of a second live stream...relating to a second live sporting event... Genius Sports’ streaming product provides video streams of numerous sporting events to viewers' devices (Compl. ¶66). ¶66, ¶68 col. 9:16-24
A) a plurality of media sources to: receive the first live stream...and the second live stream... Genius Sports utilizes an expansive portfolio of live sporting event video feeds from a plurality of media sources, including top-tier football and basketball leagues (Compl. ¶69). ¶68-69 col. 9:25-28
B) a control server to periodically retrieve...first event information...and second event information... Genius Sports’ streaming product provides fixture information, such as "Sport, Start (local time of user), Competition, Fixture... and Assigned", as well as "Statistics" (Compl. ¶75). ¶75 col. 9:43-48
C) at least one socket server...to: receive from the control server at least some of the first event information and...the second event information; and transmit the...first event information...via a third Internet communication channel between at least one first event socket...and transmit the...second event information...via a fourth Internet communication channel between at least one second event socket... The system allegedly sends "a stream of messages over a long running socket" to its Warehouse/Statistics Engine and relies on services like Ably to handle data delivery with WebSockets. This data, including bets generated for the Multibet widget, is transmitted separately from the video stream (Compl. ¶78-80). ¶78, ¶80 col. 9:48-67
  • Identified Points of Contention:
    • Scope Questions: The complaint's infringement theory combines various components (APIs, third-party services like Ably, widgets) to map onto the claimed architecture. A potential point of contention may be whether this distributed, service-based system constitutes the claimed "control server" and "at least one socket server," or if the patent contemplates a more integrated server architecture.
    • Technical Questions: Claim 19 recites providing streams and corresponding event information for two distinct live sporting events. A key question for the court may be what evidence the complaint provides that the accused system is configured to transmit synchronized, socket-based event information for two different live events to a single viewer device simultaneously, as the examples provided largely focus on data for a single event.

11,039,218 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A system for controlling a plurality of viewer client devices to receive first digital content relating to a first sporting event and first event information germane to the first sporting event, the first event information including online gaming information... Genius Sports’ streaming product includes both a live stream of a sporting event and overlaid event information, including online gaming/betting data (Compl. ¶116). ¶115-116 col. 50:11-17
A) a control server to periodically retrieve, via the Internet, the first event information germane to the first sporting event; The accused system provides fixture information, such as "Sport, Start (local time of user), Competition, Fixture, FixtureId..." as well as "Statistics" (Compl. ¶118). ¶118 col. 50:18-21
B) at least one socket server...to transmit at least some of the first event information, including the online gaming information, to at least a first viewer client device...via a first event information Internet communication channel between a first event socket... The system allegedly transmits bets generated by a sportsbook's trading platform to a "Multibet widget" on the client's device via the Internet using WebSockets and a "long running socket" (Compl. ¶120, ¶122-123). This functionality is alleged to be the claimed socket server (Compl. ¶122). ¶122-123 col. 50:22-34
C) at least one webserver...to transmit, to the first viewer client device: a first Internet address of a first media source...and a first socket address of the first event socket... The accused system uses a webserver to deliver its "Drop & Play" player or provide access to its Video API, which in turn provides authentication data (e.g., a URL) to the client device to retrieve the video stream from a CDN. This is alleged to be the transmission of the media source address. The instructions that cause the client to connect to the socket server for gaming data are also alleged to originate from the webserver (Compl. ¶128-133). ¶128, ¶130-131, ¶133 col. 50:35-51
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the system's process of providing API access and widget integration code, which then facilitates connections to CDNs and data services, meets the claim limitation of "at least one webserver...to transmit...a first Internet address of a first media source" and "a first socket address."
    • Technical Questions: What evidence does the complaint provide that a "socket address" is explicitly transmitted from the webserver to the client device, as distinct from the "Internet address of a first media source"? The defense may argue that providing widget code that establishes a connection is functionally different from transmitting a discrete "socket address" as required by the claim. The complaint's description of a process flow for the Video API shows the customer's back-end, not a webserver, calling the API to retrieve the video stream parameters (Compl. p. 29).

V. Key Claim Terms for Construction

Term: "at least one socket server" (from ’687 Patent, Claim 19)

  • Context and Importance: This term is central to the plaintiff's "one-to-many socket architecture" theory of invention and infringement. The case may turn on whether the accused system's use of a combination of its own back-end services, third-party data delivery platforms like Ably, and WebSockets constitutes a "socket server" as understood in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The '697 Patent (from the same family) describes the socket server in functional terms as being "communicatively coupled to the control server" and configured to "receive...event information" and "transmit" it to client devices ('697 Patent, col. 9:48-55). This functional language may support an interpretation that covers any combination of components performing that role.
    • Evidence for a Narrower Interpretation: Figure 2 of the '697 Patent depicts the "Socket Server(s)" as a distinct architectural block (600), separate from the "Control Server" (500) and "Media Sources" (300). This depiction could support a narrower construction requiring a more discrete server component rather than a distributed collection of APIs and services.

Term: "at least one webserver...to transmit...a first socket address" (from ’218 Patent, Claim 1)

  • Context and Importance: The infringement theory for the ’218 Patent hinges on the webserver providing separate addresses for the video and the gaming data. Practitioners may focus on this term because the defendant could argue that its system, which provides widget code or API access, does not "transmit" a "socket address" in the manner claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The abstract of the ’218 Patent states the webserver transmits instructions that "cause the first client device to...connect to a first socket." This functional "cause to connect" language may support a broader reading where providing a script that establishes the connection satisfies the limitation.
    • Evidence for a Narrower Interpretation: The claim explicitly recites transmitting "a first socket address." This could be construed to require the transmission of a literal network address string for the socket, which may be a higher evidentiary burden for the plaintiff than showing the provision of code that initiates a connection.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement based on Defendant offering, marketing, and distributing the Accused Products with the specific intent that its customers (e.g., sportsbooks) use them in an infringing manner (Compl. ¶97, ¶141). The allegations point to Defendant’s technical documentation, such as for its "Drop & Play" player and "Video API," which allegedly instructs customers on how to integrate the products in a way that practices the claimed methods (Compl. ¶72-74, ¶99).
  • Willful Infringement: The complaint alleges willfulness based on both pre- and post-suit knowledge. It asserts that Plaintiff has had communications with Defendant's executives since 2018 and also provided formal written notice of infringement for the asserted patents on October 4, 2023, and April 17, 2024. Continued infringement after these dates is alleged to be willful (Compl. ¶108-109, ¶152-153).

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

  • A core issue will be one of architectural equivalence: does Genius Sports’ distributed system—which integrates its own back-end services, third-party data platforms, and customer-side widgets—constitute the more discretely claimed architecture of a "control server" and "socket server," or is there a fundamental mismatch between the accused product's modern, service-oriented architecture and the system described in the patents?
  • A key evidentiary question will be one of functional operation: does the accused system's method of providing widget code and API authentication tokens meet the specific claim requirement of a "webserver transmit[ting]... a first socket address," or does the actual technical implementation of establishing data connections in the accused products differ materially from the mechanism recited in the claims?
  • A third question will concern claim scope: do claims reciting systems for providing and synchronizing data for multiple distinct sporting events read on the accused products, which are primarily described in the complaint as enhancing a user’s experience for a single event at a time?