DCT
2:25-cv-00335
Sportradar US LLC v. SportsCastr
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sportradar US LLC, Sportradar Solutions LLC (Delaware), and Sportradar AG (Switzerland)
- Defendant: Sportscastr, Inc. d/b/a PANDA Interactive (Delaware)
- Plaintiff’s Counsel: Young Conaway Stargatt & Taylor, LLP
- Case Identification: 2:25-cv-00335, D. Del., 02/08/2024
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant PANDA Interactive is a Delaware corporation and therefore "resides" in the district.
- Core Dispute: Plaintiffs seek a declaratory judgment that their sports data and live streaming products do not infringe three of Defendant's patents related to the synchronized delivery of live video streams with associated event data, such as scores and gaming information.
- Technical Context: The technology at issue facilitates modern "second screen" sports viewing experiences by synchronizing live video with real-time data overlays, a critical feature for interactive fan engagement and in-game sports betting platforms.
- Key Procedural History: This declaratory judgment action was filed by Sportradar in Delaware following a patent infringement complaint filed by PANDA Interactive against Sportradar's parent holding company, Sportradar Group AG, in the Eastern District of Texas on October 5, 2023. Sportradar notes its parent company intends to move to dismiss the Texas action for lack of personal jurisdiction, indicating a potential dispute over the proper forum for the litigation.
Case Timeline
| Date | Event |
|---|---|
| 2016-08-05 | Earliest Priority Date for ’687, ’218, and ’697 Patents |
| 2019-09-24 | U.S. Patent No. 10,425,697 Issues |
| 2020-10-13 | U.S. Patent No. 10,805,687 Issues |
| 2021-06-15 | U.S. Patent No. 11,039,218 Issues |
| 2023-10-05 | PANDA files complaint against Sportradar Group AG in E.D. Tex. |
| 2024-02-08 | Sportradar files this Complaint for Declaratory Judgment in D. Del. |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,805,687 - "Systems, Apparatus, And Methods For Rendering Digital Content Relating To A Sporting Event With Online Gaming Information"
The Invention Explained
- Problem Addressed: The patent family addresses the technical challenge of viewer "latency"—the delay between a live event occurring and a viewer seeing it on a stream—which can undermine a "second screen" experience where synchronized data is critical (’697 Patent, col. 2:27-34). Conventional streaming techniques create difficulties in synchronizing low-latency video with event information, especially across a large number of viewers (’697 Patent, col. 2:35-47).
- The Patented Solution: The invention proposes a system architecture that separates the delivery of video content from the delivery of event-related data, such as online gaming information (Compl. ¶22). It utilizes a "control server" to retrieve event data and a "socket server" to transmit that data to viewer devices over a dedicated "event information" channel, distinct from the video channel, thereby allowing for synchronized presentation of video and data (Compl. ¶22; ’687 Patent, Abstract).
- Technical Importance: This architectural approach aims to provide a scalable, low-latency method for combining live video with real-time data overlays, a key enabling technology for the growth of interactive online sports betting and enhanced fan engagement platforms (’697 Patent, col. 4:25-40).
Key Claims at a Glance
- The complaint identifies independent claim 19 and dependent claim 20 as asserted by PANDA (Compl. ¶9).
- Independent Claim 19 requires a system comprising three main components:
- A) A plurality of media sources to receive live streams of digital content for two different sporting events and provide copies to viewer devices over first and second Internet channels.
- B) A control server to periodically retrieve, via the Internet, event information germane to both live sporting events.
- C) At least one socket server, communicatively coupled to the control server, to receive the event information and transmit it to viewer devices over third and fourth Internet channels using dedicated event sockets.
- The complaint does not explicitly reserve the right to assert other dependent claims.
U.S. Patent No. 11,039,218 - "Systems, Apparatus And Methods For Rendering Digital Content Relating To A Sporting Event With Online Gaming Information"
The Invention Explained
- Problem Addressed: As with the related ’687 Patent, this invention addresses the need for a scalable and low-latency system to synchronize live video with event data, with a specific focus on "online gaming information" (’218 Patent, Claim 1).
- The Patented Solution: The patented system uses a multi-server architecture to control the delivery of content and data to viewer devices. A "control server" retrieves event information, a "socket server" transmits it, and a "webserver" provides the client device with the necessary Internet addresses to establish a video channel with a media source and a separate data channel with the socket server's "event socket" (’218 Patent, Claim 1). This separation of channels is designed to ensure synchronized delivery (’218 Patent, Abstract).
- Technical Importance: The system provides a specific method for initiating and managing the separate data and video streams required for a synchronized, low-latency viewing experience, which is particularly important in the context of real-time online gaming and betting applications tied to live sports.
Key Claims at a Glance
- The complaint identifies independent claim 1 and dependent claim 4 as asserted by PANDA (Compl. ¶9).
- Independent Claim 1 requires a system for controlling viewer devices, comprising:
- A) A control server to periodically retrieve first event information, including online gaming information.
- B) At least one socket server communicatively coupled to the control server to receive the event information and transmit it to a viewer device via a first event information channel.
- C) At least one webserver communicatively coupled to the socket server to transmit two addresses to the viewer device: a first Internet address for a media source to establish a video channel, and a first socket address to establish the event information channel.
- The complaint does not explicitly reserve the right to assert other dependent claims.
U.S. Patent No. 10,425,697 - "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"
Technology Synopsis
This patent addresses the technical problems of viewer latency and data synchronization in live streaming environments (’697 Patent, Abstract). The proposed solution involves a system architecture with multiple servers (media, control, socket) and distinct Internet channels for delivering video content (specifically "video-based commentary") and synchronized event data (such as "score information") to a plurality of viewers (’697 Patent, Claim 19).
Asserted Claims
Independent claim 19 and dependent claim 20 (Compl. ¶9).
Accused Features
The complaint argues that Sportradar's products do not infringe because, among other reasons, they are not used to provide "video-based commentary" and do not employ the specific "plurality of media sources" or "control server" architecture required by the claims (Compl. ¶38).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are the Sportradar® branded products emBET, OTT, and Live Channel Trading (“LCT”) (Compl. ¶1).
Functionality and Market Context
The complaint describes the accused products as part of Sportradar's business in "global sports information, data, and technology" (Compl. ¶8). The product offerings include "sports data, content, engagement tools, live streaming, and gaming products" (Compl. ¶8). The product names "emBET" and "Live Channel Trading" suggest functionalities related to embedding betting information within live video streams and facilitating sports-related trading, which aligns with the technology domain of the patents-in-suit.
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following tables summarize Sportradar’s asserted bases for non-infringement, which in turn outline the infringement theories that PANDA Interactive would need to prove.
U.S. Patent No. 10,805,687 Infringement Allegations
| Claim Element (from Independent Claim 19) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a plurality of media sources to: receive the first live stream...and the second live stream | Sportradar alleges its products do not employ, incorporate, or otherwise make use of “a plurality of media sources.” | ¶24 | col. 5:29-41 |
| a control server to periodically retrieve...first event information...and second event information | Sportradar alleges its products do not employ, incorporate, or otherwise make use of “a control server.” | ¶24 | col. 5:42-49 |
| at least one socket server communicatively coupled to the control server to: receive from the control server at least some of the first event information | Sportradar alleges its products do not employ, incorporate, or otherwise make use of a “socket server communicatively coupled to the control server.” | ¶24 | col. 5:50-54 |
U.S. Patent No. 11,039,218 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a control server to periodically retrieve, via the Internet, the first event information germane to the first sporting event | Sportradar alleges its products do not employ, incorporate, or otherwise make use of “a control server.” | ¶31 | col. 8:27-30 |
| at least one socket server communicatively coupled to the control server to: receive from the control server at least the first event information | Sportradar alleges its products do not employ, incorporate, or otherwise make use of a “socket server communicatively coupled to the control server.” | ¶31 | col. 8:31-34 |
| at least one webserver communicatively coupled to the at least one socket server to transmit...a first Internet address...and a first socket address | Sportradar alleges its products do not employ, incorporate, or otherwise make use of a “webserver communicatively coupled to the at least one socket server.” | ¶31 | col. 8:50-52 |
Identified Points of Contention
The non-infringement arguments presented by Sportradar focus entirely on the absence of specific architectural components recited in the claims. This suggests the central dispute will be one of claim construction and the mapping of the accused system's architecture onto the patent claims.
- Scope Questions: A primary question will be whether the terms "control server," "socket server," and "webserver" can be construed to read on components of Sportradar’s system. For example, if Sportradar uses a single, integrated server that performs the functions attributed to the claimed "control server" and "socket server," a dispute will arise as to whether that single server can satisfy two separate claim limitations.
- Technical Questions: What evidence does PANDA have that Sportradar’s system architecture is, in fact, divided into the discrete, communicatively coupled components as required by the claims? The dispute may require a detailed technical analysis of Sportradar's backend infrastructure to determine if it practices the specific multi-server, multi-channel architecture that is a core element of the patented solution.
V. Key Claim Terms for Construction
The Term: "control server"
- Context and Importance: This term appears in the independent claims of all three asserted patents and is a foundational element of the claimed architecture (’687 Patent, Claim 19; ’218 Patent, Claim 1; ’697 Patent, Claim 19). Sportradar explicitly alleges its products do not "employ, incorporate, or otherwise make use of" this element, making its construction central to the infringement analysis (Compl. ¶24, ¶31, ¶38). Practitioners may focus on this term because the dispute appears to be whether a single, multi-function component in the accused system can meet a limitation for a discretely named server.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims define the "control server" functionally as an element that "periodically retrieve[s]...event information" (’218 Patent, Claim 1). This functional language could support an argument that any component performing this retrieval function, regardless of its name or integration with other components, is a "control server."
- Evidence for a Narrower Interpretation: The patent figures consistently depict the "Control Server" (500) as a distinct block, separate from the "Socket Server(s)" (600) and "Media Sources" (300) (’697 Patent, Fig. 2). This repeated structural separation in the drawings could support a narrower construction requiring a physically or logically distinct server component.
The Term: "socket server communicatively coupled to the control server"
- Context and Importance: This limitation, also present in all asserted independent claims, defines the required relationship between two key components. Sportradar's denial that it uses such a component (Compl. ¶24, ¶31, ¶38) places this term's construction at the heart of the dispute. The case may turn on the degree of separation and the nature of the "coupling" required between the functions of retrieving event data and transmitting it to clients.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the socket server (600) as being "communicatively coupled to the web server(s) 700 and the control server 500," without specifying a required protocol or directness of the connection (’697 Patent, col. 20:66-68). This could support a broad interpretation where any data path between the component that retrieves data and the component that transmits it constitutes a "communicative coupling."
- Evidence for a Narrower Interpretation: The detailed description explains that the socket server "receive[s] from the control server" event information to transmit (’697 Patent, col. 10:22-26). This directional language, combined with figures showing distinct server blocks, may support a narrower construction requiring two separate entities where one provides data to the other, as opposed to a single entity performing both functions internally.
VI. Other Allegations
Indirect Infringement
The complaint seeks a declaratory judgment that Sportradar does not "directly or indirectly infringe" the asserted patents (Compl. ¶A in Prayer for Relief). However, as a complaint for non-infringement, it does not plead facts related to the elements of knowledge and intent that would be required for an indirect infringement claim. The complaint does not provide sufficient detail for analysis of indirect infringement.
Willful Infringement
The complaint does not contain allegations related to willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this declaratory judgment action will likely depend on the court's determination of two central questions:
- A core issue will be one of architectural mapping: Can the specific multi-component system described in the patents—requiring distinct and coupled "control," "socket," and "web" servers—be read onto Sportradar's accused products? The case will likely require a deep technical dive to determine if Sportradar's system embodies the claimed architecture, either literally or through functionally equivalent components.
- A key legal question will be one of definitional scope: How will the court construe the structural limitations of the claims? A broad, functional construction of terms like "control server" may present a greater challenge for Sportradar's non-infringement position, while a narrower construction requiring the discrete server blocks depicted in the patents' figures may support Sportradar's argument that its products do not practice the claimed invention.