DCT

2:25-cv-00823

Cedar Lane Tech Inc v. Neosapience Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00823, E.D. Tex., 08/20/2025
  • Venue Allegations: Venue is alleged to be proper on the basis that the defendant is a foreign corporation and has committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to systems and methods for generating, customizing, and presenting interactive audio publications.
  • Technical Context: The technology at issue addresses the conversion of text-based or speech-based content into navigable, interactive audio formats, a field of increasing importance with the rise of podcasts, audiobooks, and on-demand news consumption on mobile devices.
  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2009-03-17 U.S. Patent No. 8,438,485 Priority Date
2010-03-17 U.S. Patent No. 8,438,485 Application Date
2013-05-07 U.S. Patent No. 8,438,485 Issue Date
2025-08-20 Complaint Filing Date

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

Patent Identification

U.S. Patent No. 8,438,485, System, method, and apparatus for generating, customizing, distributing, and presenting an interactive audio publication, issued May 7, 2013 (’485 Patent).

The Invention Explained

  • Problem Addressed: The patent’s background section identifies a need for an audio-based news consumption method that combines the dynamic, detailed nature of visually-oriented online media with the presentation flexibility required for multitasking activities like driving or exercising, where traditional audio podcasts offer limited interactivity (’485 Patent, col. 1:18-50, 1:59-64).
  • The Patented Solution: The invention describes a system that ingests text or speech content and converts it into "interactive audio content items" associated with structural metadata (’485 Patent, Abstract). These items are then assembled into navigable "audio publications" based on user-defined templates, allowing a user to interact with the audio content via voice commands or a button interface in a manner analogous to browsing visual content (’485 Patent, Abstract; col. 2:26-35).
  • Technical Importance: The described technology sought to provide a standardized method for segmenting and navigating audio news content, enhancing its usability beyond the linear playback functions of conventional media players (’485 Patent, col. 1:55-64).

Key Claims at a Glance

The complaint asserts infringement of "one or more claims" of the ’485 Patent, with specific claims identified in an external exhibit not attached to the complaint (Compl. ¶11). The following analysis focuses on independent claim 1.

  • Independent Claim 1:
    • enabling a subscriber to access a subscriber portal to generate a custom audio publication template used to generate an audio publication for the subscriber...
    • receiving a plurality of content items that includes at least one text-based content item or speech-based content item;
    • converting the received plurality of content items into corresponding audio content items that each include digital audio data... and audio content item metadata indicating a structure of the included digital audio data...
    • assembling the audio publication from one or more of the audio content items according to the custom audio publication template, the audio publication being organized into one or more sections;
    • generating audio publication metadata that defines a structure of the audio publication...
    • distributing the audio publication to the subscriber for interactive presentation...

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products by name in its main body (Compl. ¶¶1-19). It refers generally to "Exemplary Defendant Products" that are purportedly identified in charts within an external "Exhibit 2" (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint asserts that the "Exemplary Defendant Products practice the technology claimed by the '485 Patent" but provides no specific description of their features, functions, or market positioning (Compl. ¶16). All detailed allegations regarding the accused functionality are incorporated by reference from the unattached Exhibit 2 (Compl. ¶17).

IV. Analysis of Infringement Allegations

The complaint references but does not include Exhibit 2, which it states contains claim charts comparing the asserted claims to the accused products (Compl. ¶16, ¶17). In the absence of these charts, the infringement theory is summarized from the complaint’s narrative allegations.

The complaint alleges that the Defendant’s "Exemplary Defendant Products" infringe the ’485 Patent because they "practice the technology claimed" and "satisfy all elements of the Exemplary ’485 Patent Claims" (Compl. ¶16). The infringement allegations are conclusory and rely entirely on the contents of the referenced exhibit. The complaint further alleges direct infringement through Defendant’s internal use and testing of the products (Compl. ¶12). No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The Term: "custom audio publication template"

Context and Importance

This term appears central to the claimed invention's architecture, defining how a subscriber's preferences are used to structure the final audio product. The scope of what constitutes a "template" will be critical to determining whether the accused system’s user preference settings meet this limitation.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification describes the term as "a collection of subscriber-specified rules and preferences that are used to generate a 'custom audio publication'" (’485 Patent, col. 8:39-43). This language could support an interpretation that covers a wide range of user settings, not just a formal template structure.
  • Evidence for a Narrower Interpretation: The patent depicts specific embodiments, such as a "Section Layout Template" (308) and modules for applying "static selection & assignment rules" (548) or "keyword search-based assignment rules" (542), which could be argued to require a more structured, rule-based system than simple user preferences (’485 Patent, Fig. 3A; Fig. 5B).

The Term: "audio content item metadata indicating a structure of the included digital audio data"

Context and Importance

This limitation defines the technical basis for the "interactive" nature of the audio content. The dispute will likely focus on the level of granularity and type of structural information required by the claim.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The claim language itself does not specify the format or detail of the metadata, only that it "indicat[es] a structure" (’485 Patent, col. 51:60-63). This could support a reading on systems that use relatively simple structural indicators, such as chapter markers.
  • Evidence for a Narrower Interpretation: The detailed description explains that this metadata may include "a plurality of word-based boundary markers," "time-based boundary markers," and references to distinct "title, summary, and story body segments" (’485 Patent, col. 7:21-34). This detailed disclosure may be used to argue for a narrower construction that requires more than basic structural tags.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that the Defendant sells its products and distributes "product literature and website materials" that instruct end users to use the products in a manner that infringes the ’485 Patent (Compl. ¶14).

Willful Infringement

The complaint does not use the term "willful" but alleges "Actual Knowledge of Infringement" arising from the service of the complaint and its attached claim charts (Compl. ¶13). It further alleges that "Despite such actual knowledge, Defendant continues" its infringing activities, which provides a basis for a claim of post-suit willful infringement (Compl. ¶14).

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

  • A central issue will be one of architectural correspondence: does the accused system implement the specific, user-driven, template-based architecture required by claim 1 for "assembling" an "audio publication," or does it operate on a different technical principle for delivering customized audio?
  • A key evidentiary question will be the nature of the metadata: does the accused system generate and utilize metadata that provides the granular structural information for interactivity described in the ’485 Patent specification (e.g., word and sentence boundaries), or does it rely on a more generalized metadata scheme that may fall outside the scope of the claims?
  • A significant procedural question will be one of pleading sufficiency: given that the complaint’s factual allegations of infringement are contained entirely within an unattached exhibit, the court may need to determine whether the pleading itself provides sufficient notice and factual support to state a plausible claim for relief under prevailing federal standards.