Media Key LLC v. Ledger SAS

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Media Key LLC (New York)
  • Defendant: Ledger SAS (France)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00264, E.D. Tex., 03/05/2025
• Venue Allegations: Venue is asserted on the basis that the defendant is a foreign corporation and has allegedly committed acts of patent infringement within the district, causing harm to the plaintiff.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to a system for delivering dynamically updated content to a user via a physical media device that connects to a networked computer.
• Technical Context: The technology addresses methods for pairing a physical, portable token with a network connection to receive personalized and up-to-date information from a remote server, bridging static media with dynamic online content.
• Key Procedural History: The complaint does not mention 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. 7,606,876 - "Media Keying for Updateable Content Distribution" (Issued Oct. 20, 2009)

The Invention Explained

• Problem Addressed: The patent addresses the limitations of distributing content on static, physical media like CD-ROMs, where information (e.g., a sales catalog) quickly becomes outdated, and updating requires the impractical measure of sending a new physical medium to every user (’876 Patent, col. 1:21-38).
• The Patented Solution: The invention proposes a hybrid system where a user receives a portable "media" device (e.g., a CD, memory card) pre-loaded with a unique "Source ID" and a "Keying Application." When this device is connected to a networked computer, the Keying Application launches, communicates with a remote "Content Server," and uses the Source ID and a generated User ID to fetch and display personalized, up-to-date content that is not stored on the original media ('876 Patent, Abstract; col. 2:10-23). The system is designed to deliver customized content based on the user's profile and interaction history ('876 Patent, col. 7:48-58).
• Technical Importance: This approach enabled content providers to leverage the tangible, low-cost distribution of physical media while providing a "live" or "dynamic" user experience typically associated with direct web browsing ('876 Patent, col. 2:3-8).

Key Claims at a Glance

• The complaint asserts infringement of "exemplary claims" identified in a chart that was not attached to the publicly filed document (Compl. ¶11). The patent's independent claims include 1, 9, 12, and 22. Claim 1, a system claim, includes the following essential elements:
  • At least one content server connected to a network, adapted to create and update information according to a user profile.
  • The user profile is generated from factors including a "storage media identifier," a "user identity (user ID)," and transaction histories.
  • A "keying application" stored on an "external storage media" that launches on an electronic device to select and transmit the user ID and media identifier to the content server.
  • The keying application selects the user ID based on the media identifier and other indicia.
  • If the external storage media is "non-recordable," the keying application records the user ID (generated by the content server) onto the "local electronic device" running the application.
• The complaint notes that infringement is alleged "literally or under the doctrine of equivalents" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products as "Exemplary Defendant Products" detailed in an unattached Exhibit 2 (Compl. ¶11). The defendant is Ledger SAS, a company known for producing cryptocurrency hardware wallets.

Functionality and Market Context

The complaint does not provide specific details about the accused products' functionality. It makes the conclusory allegation that the products "practice the technology claimed by the '876 Patent" (Compl. ¶16). It further alleges that the defendant distributes "product literature and website materials" that direct users on how to use the products (Compl. ¶14). The complaint does not provide sufficient detail for analysis of the accused products' specific operation or market position.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from an unattached Exhibit 2, which allegedly compare the "Exemplary '876 Patent Claims to the Exemplary Defendant Products" (Compl. ¶¶16-17). As this exhibit was not provided with the complaint, a detailed element-by-element infringement analysis is not possible based on the filed documents. The narrative infringement theory is that the defendant makes, uses, and sells products that satisfy all elements of the asserted claims (Compl. ¶16).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: The patent specification frequently references "media" such as "floppy disk, magnetic tape or compact disc (CD)" for distributing content like a "sales catalog" ('876 Patent, col. 1:16-28). A potential dispute may arise over whether a modern hardware security wallet constitutes "external storage media" as contemplated by the patent, and whether firmware updates or cryptocurrency applications constitute the claimed "updateable content."
• Technical Questions: Claim 1 requires that if the media is "non-recordable," the "keying application" records a server-generated "user ID" on the "local electronic device" (i.e., the user's computer) ('876 Patent, col. 9:56-64). A central technical question will be whether the accused system performs this specific function. For instance, does the firmware on a hardware wallet (the potential "keying application") cause its companion desktop software to store a specific, server-generated user ID on the computer's hard drive? The complaint provides no facts to support this specific allegation.

V. Key Claim Terms for Construction

"keying application"

• Context and Importance: The definition of this term is central to identifying the infringing software component. Practitioners may focus on this term to determine if it is limited to a user-facing program, as described in parts of the patent, or if it can broadly cover firmware or a bootloader on a hardware device that initiates a connection.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent describes the application's function as launching, connecting to a server, and delivering content, a general process that could encompass various types of software ('876 Patent, col. 7:21-28).
  • Evidence for a Narrower Interpretation: The specification suggests a more specific form, describing the user interface as a "network browser or browser-like application" and noting it "eliminates the need for use of any other external programs" ('876 Patent, col. 4:40-44). This could support an argument that the "keying application" must be a self-contained, user-interactive program, not merely device firmware.

"non-recordable"

• Context and Importance: This term triggers a specific limitation in Claim 1 regarding where the user ID is stored. The patent was drafted in an era of "write-once media" like CD-ROMs ('876 Patent, col. 1:33-35). Whether a modern hardware wallet with rewritable flash memory is "non-recordable" for the purposes of the claim will be a critical issue.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue "non-recordable" refers to the portion of memory where the core "keying application" is stored, which may be protected from user modification, thus functioning like a non-recordable medium even if other parts of the device's memory are writable.
  • Evidence for a Narrower Interpretation: The patent explicitly distinguishes "write-once media" from "re-writable media (e.g., floppy disks, CD-RW, key-chain RAM, etc.)" ('876 Patent, col. 1:39-40). This could support a narrow definition where any device capable of receiving and storing new data, such as a firmware update, would be considered "recordable," thereby making the final limitation of Claim 1 inapplicable.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that the defendant provides "product literature and website materials" that instruct customers on how to use the accused products in a manner that infringes the '876 Patent (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based on post-suit knowledge. The complaint asserts that service of the complaint and its attached (but unfiled) claim charts provides the defendant with "actual knowledge of infringement" and that any continued infringement would be willful (Compl. ¶¶13-15).

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

• A core issue will be one of definitional scope: Can claim terms rooted in the 2003-era context of distributing "sales catalogs" on "CDs"—such as "external storage media" and "updateable content"—be construed to cover a modern cryptocurrency hardware wallet and its associated firmware updates or software applications?
• A key evidentiary question will be one of technical operation: Does the interaction between the accused hardware device and its companion desktop software meet the specific functional requirements of the asserted claims, particularly the limitation in Claim 1 requiring a "keying application" on a "non-recordable" device to record a server-generated user ID on the separate host computer?