DigiMedia Tech LLC v. Resideo Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigiMedia Tech, LLC (Georgia)
  • Defendant: Resideo Technologies, Inc. and Resideo LLC (Delaware)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:25-cv-00731, E.D. Tex., 07/21/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district and maintains a regular and established place of business in the district, citing a facility in Fort Worth, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s C2 Camera infringes patents related to video processing and encoding.
• Technical Context: The technologies at issue relate to the processing of digital video, specifically methods for creating user-defined views from wide-angle footage and for compressing video data in a "visually lossless" manner.
• Key Procedural History: The complaint alleges that Plaintiff, through its licensing agent, contacted Defendant on multiple occasions between December 2022 and July 2024 to discuss a potential license. An Inter Partes Review (IPR) proceeding (IPR2022-01182) was previously filed against U.S. Patent No. 6,473,532. The resulting IPR certificate, issued March 28, 2024, indicates that independent claim 6 of the '532 patent was cancelled. This is significant because the complaint asserts claims 12, 16, and 17, all of which depend from the cancelled claim 6.

Case Timeline

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

U.S. Patent No. 6,741,250 - “Method and System for Generation of Multiple Viewpoints into a Scene Viewed by Motionless Cameras and for Presentation of a View Path,” issued May 25, 2004

The Invention Explained

• Problem Addressed: The patent describes the disadvantages of using traditional, remotely controlled moveable cameras to track an area of interest in a scene, noting issues with cost, mechanical reliability, and the difficulty of placing cameras close to the action (Compl. ¶ 20; ’250 Patent, col. 2:22-49). It also acknowledges that using stationary wide-angle lenses to solve this problem introduces optical distortion (Compl. ¶ 20; ’250 Patent, col. 2:63-65).
• The Patented Solution: The invention proposes recording a video stream from one or more cameras, which may contain distorted images (e.g., from a wide-angle lens). A user can then designate a "video segment" from this stream and specify a "view path" through it. This path determines which portions of the distorted frames are selected, transformed into an un-distorted view, and presented to the user, effectively allowing for digital pan, tilt, and zoom effects on pre-recorded footage ('250 Patent, Abstract; col. 3:1-10).
• Technical Importance: This approach enabled the creation of dynamic, multi-perspective video presentations from stationary, potentially inexpensive cameras, offering new creative possibilities for sports and event broadcasting (Compl. ¶ 20).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶ 47).
• The essential elements of claim 1 are:
  • recording a video stream comprising a plurality of frames, wherein said plurality of frames define a plurality of distorted images;
  • designating a portion of said video stream to be a video segment; and
  • specifying a view path through said video segment.
• The complaint does not explicitly reserve the right to assert dependent claims, though this is common practice.

U.S. Patent No. 6,473,532 - “Method and Apparatus for Visual Lossless Image Syntactic Encoding,” issued October 29, 2002

The Invention Explained

• Problem Addressed: The patent identifies the technical challenge of balancing video quality with file size, noting that standard compression techniques often introduce undesirable visual artifacts like "blockiness, low resolution and wiggles" ('532 Patent, col. 1:19-30; Compl. ¶ 37).
• The Patented Solution: The invention describes a pre-processing method for "visual lossless" encoding. It involves analyzing video frames to determine "visual perception thresholds"—the level of contrast below which the human eye cannot distinguish details. The system then classifies details in the frame into subclasses based on these thresholds and transforms them accordingly before standard compression, aiming to reduce file size without a perceptible loss in quality ('532 Patent, Abstract; col. 2:26-41).
• Technical Importance: The technology provided a method to enhance the performance of standard video compressors by intelligently removing image data that is imperceptible to the human visual system (Compl. ¶ 38).

Key Claims at a Glance

• The complaint asserts dependent claims 12, 16, and 17, which all depend from independent claim 6 (Compl. ¶ 39, 53). As a result of IPR proceeding IPR2022-01182, independent claim 6 has been cancelled (’532 Patent, IPR Certificate).
• The essential elements of the cancelled independent claim 6 are:
  • spatially and temporally separating and analyzing details of said frames;
  • estimating parameters of said details;
  • defining a visual perception threshold for each of said details in accordance with said estimated detail parameters;
  • classifying said frame picture details into subclasses in accordance with said visual perception thresholds and said detail parameters; and
  • transforming each said frame detail in accordance with its associate subclass.

III. The Accused Instrumentality

Product Identification

The complaint identifies "Defendant's C2 Camera" and "C2 product" as the accused instrumentalities (Compl. ¶¶ 47, 53).

Functionality and Market Context

The complaint alleges the accused product has "video processing functionality" and "video recording functionality" (Compl. ¶¶ 48, 54). No probative visual evidence provided in complaint. The complaint does not provide sufficient detail for analysis of the C2 Camera's specific operation or its market context beyond these general characterizations.

IV. Analysis of Infringement Allegations

The complaint references preliminary claim charts in Exhibits D and E, which are incorporated by reference but were not attached to the public filing (Compl. ¶¶ 47, 53). In the absence of these charts, the infringement theory is summarized from the complaint's narrative allegations.

• ’250 Patent Infringement Allegations: The complaint alleges that the accused C2 Camera directly infringes at least claim 1 by making, using, or selling products that perform the claimed method (Compl. ¶¶ 47-48). The theory appears to be that the C2 Camera's "video processing functionality" inherently includes recording a video stream with distorted images, allowing a user to designate a segment, and specifying a view path through it (Compl. ¶ 48).
• ’532 Patent Infringement Allegations: The complaint alleges that the accused C2 product directly infringes claims 12, 16, and 17 by performing the steps of the parent claim 6 related to "visually lossless" encoding (Compl. ¶¶ 53-54). However, this entire count is predicated on the validity of claims that depend from independent claim 6, which was cancelled during an Inter Partes Review ('532 Patent, IPR Certificate). A dependent claim cannot be infringed if the independent claim from which it depends is invalid.
• Identified Points of Contention:
  • Validity Question ('532 Patent): The central issue for the '532 patent allegations is legal rather than technical: what is the legal status of dependent claims 12, 16, and 17 when their parent independent claim 6 has been cancelled by the USPTO?
  • Technical Questions ('250 Patent): What evidence does the complaint provide that the C2 Camera's functionality meets the specific limitations of "designating a... video segment" and "specifying a view path"? The complaint's allegations are conclusory and depend on an unattached exhibit.

V. Key Claim Terms for Construction

• ’250 Patent:

  • The Term: "view path"
  • Context and Importance: This term is central to claim 1 and defines the novel user interaction with the recorded video. Its construction will be critical to determining infringement. Practitioners may focus on this term because its scope will determine whether any user-directed selection of a video portion infringes, or if it is limited to the more complex, multi-frame traversals shown in the patent's figures.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims do not explicitly define "view path", which may suggest it should be given its plain and ordinary meaning, potentially covering any method of specifying a view within a video segment.
    • Evidence for a Narrower Interpretation: The specification describes the "view path" as enabling effects like pan, tilt, and zoom, and allowing the view to "dwell in a particular video frame" ('250 Patent, col. 3:4-7). Figure 11A illustrates the "view path" (1111) as a trajectory that moves through multiple frames (1105, 1107, 1109) of a video segment (1100), suggesting a more specific meaning than simply selecting a static area.

• ’532 Patent:

  • Analysis of key claim terms for the asserted claims is likely obviated by the cancellation of independent claim 6 during IPR proceedings, which may render the asserted dependent claims invalid as a matter of law.

VI. Other Allegations

• Indirect Infringement: While the complaint only contains counts for direct infringement, it includes factual allegations that could support a claim for induced infringement. The complaint alleges that to the extent a user performs any claimed steps, "Defendant conditioned the user's use of the functionality... on the performance of that step" and "controlled the manner and/or timing of the accused functionality" (Compl. ¶¶ 48, 54).
• Willful Infringement: The complaint does not contain a count for willful infringement. However, it alleges that Plaintiff's licensing agent contacted Defendant multiple times starting on December 13, 2022, informing Defendant of the patent portfolio (Compl. ¶¶ 8-11). These allegations of pre-suit knowledge could form the basis for a future willfulness claim.

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

1. A dispositive threshold issue will be one of validity: can asserted claims 12, 16, and 17 of the '532 patent, which depend from the cancelled independent claim 6, survive a challenge for being invalid as a matter of law?
2. A key evidentiary question will be one of factual support: what evidence will Plaintiff provide to demonstrate that the accused C2 Camera performs the specific steps of "designating a... video segment" and "specifying a view path" as required by claim 1 of the '250 patent?
3. A core issue for the '250 patent will be one of definitional scope: can the term "view path", which is described in the patent in the context of creating dynamic pan/tilt/zoom effects across multiple frames, be construed to cover the functionality of the accused C2 Camera?