DCT
2:25-cv-00896
Control Sync Systems LLC v. Sony Electronics Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Control Sync Systems, LLC (Wyoming)
- Defendant: Sony Electronics Inc. (Delaware)
- Plaintiff’s Counsel: Direction IP Law
- Case Identification: 2:25-cv-00896, E.D. Tex., 08/27/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains regular and established places of business in the district and has allegedly committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s televisions and devices featuring BRAVIA Sync technology infringe a patent related to the synchronous control of separate display and media playback devices.
- Technical Context: The technology concerns unified control systems for home entertainment setups, where multiple devices (e.g., a television and a Blu-ray player) are controlled by a single remote control over a common communication bus.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2005-07-29 | ’889 Patent Priority Date |
| 2010-10-12 | ’889 Patent Issue Date |
| 2025-08-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,812,889 - “Control System For Synchronously Controlling Display Device And Play Device”
The Invention Explained
- Problem Addressed: The patent describes the user "annoyance" and inconvenience of using separate remote controls for a display device (e.g., a television) and a play device (e.g., a DVD player) (’889 Patent, col. 1:40-41). For example, a user might adjust the volume on the DVD player's remote only to realize the television's volume was the actual source of the issue, requiring the use of a second remote in a "troublesome" process (’889 Patent, col. 1:41-54).
- The Patented Solution: The invention proposes a control system that allows commands received by one device to be communicated to the other over a shared bus. A command, referred to as an "OSD signal," received by the display device from its remote can be encoded into a data signal, transmitted over the bus to the play device, and then decoded by the play device to control its own parameters synchronously (’889 Patent, Abstract; Fig. 2). This eliminates the need for multiple remotes to control shared functions like volume or playback.
- Technical Importance: The invention addresses a common consumer frustration in home theater systems by proposing a method for unifying control of disparate devices from different manufacturers over a standard interface.
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2 and 10 of the ’889 Patent (Compl. ¶14).
- Independent Claim 1:
- A control system for controlling video and audio parameters of a display device and a play device.
- An on-screen display (OSD) system within the display device for receiving a "first OSD signal" from an external source.
- An encoding/decoding module within the display device for encoding the "first OSD signal" into a "first data signal."
- A bus connected to the display device for sending the "first data signal" to the play device.
- The system operates such that when the display device receives the "first OSD signal" to control its own parameters, the play device decodes the "first data signal" from the bus to control its own parameters.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Sony's BRAVIA Sync technology, as implemented in products such as the BRAVIA XR 75” Class Z9K television (Compl. ¶¶14-15).
Functionality and Market Context
- BRAVIA Sync is a feature based on the HDMI-CEC (Consumer Electronics Control) standard, which allows devices connected via an HDMI cable to communicate and be controlled by a single remote control (Compl. ¶15). The complaint alleges that when a user operates the TV remote to control a function like playback, the TV sends a corresponding command over the HDMI cable to a connected "play device" (e.g., a Blu-ray player or AV receiver), causing that device to execute the command (Compl. ¶15). A diagram in the complaint shows the TV's remote control operating a connected Blu-ray player or AV receiver (Compl. p. 6). The system allows for unified control over functions including power, volume, and playback across multiple devices (Compl. p. 7).
IV. Analysis of Infringement Allegations
U.S. Patent No. 7,812,889 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an on screen display (OSD) system of the display device disposed in the display device for receiving a first OSD signal from external of the display device | The Sony BRAVIA TV includes an OSD system that receives playback and volume signals ("first OSD signal") from the TV's remote control. | ¶16 | col. 4:21-27 |
| an encoding/decoding module of the display device disposed in the display device for encoding the first OSD signal received by the OSD system into a first data signal | The complaint alleges that the TV includes a module that encodes the received remote command into a play command ("first data signal") that is then sent to the connected device. | ¶17 | col. 4:28-30 |
| a bus connected to the display device for sending the first data signal out of the display device and transmitting the first data signal to the play device | The HDMI cable connecting the BRAVIA TV to a CEC-compatible device (e.g., Blu-ray player) serves as the bus. | ¶18 | col. 4:41-45 |
| wherein the display device receives the first OSD signal to control the video and audio parameters of the display device, the play device is decoding the first data signal received from the bus to control the video and audio parameters of the play device | The TV receives the remote command, and the connected "play device" receives and decodes the command sent over the HDMI bus to control its playback (e.g., play/pause). A message flow diagram illustrates a TV sending a <Play> ["Forward"] command to a playback device (Compl. p. 9). |
¶19 | col. 5:7-12 |
Identified Points of Contention
- Scope Questions: The case may turn on the definition of an "OSD signal." The complaint appears to equate a raw remote control command with the claimed "OSD signal" (Compl. ¶16). A central question will be whether this term, as used in the patent, refers to the initial remote command itself or to a signal generated internally by the OSD system in response to that command.
- Technical Questions: The complaint's allegation of an "encoding/decoding module" is inferential, stating its existence "would be apparent for a person having ordinary skills in the art" because the system functions as described (Compl. ¶17). A key question will be whether the TV's translation of a remote command into a standardized HDMI-CEC protocol message constitutes the specific "encoding" process described in the patent, or if it is a distinct, non-infringing technical operation. The complaint does not identify a discrete hardware or software component corresponding to the claimed module.
V. Key Claim Terms for Construction
The Term: "encoding...the first OSD signal...into a first data signal"
Context and Importance: This term is central to the infringement theory. The complaint alleges that the BRAVIA TV's act of converting a remote control command into an HDMI-CEC command constitutes "encoding" (Compl. ¶17). The viability of the infringement case may depend on whether this standard protocol messaging falls within the scope of the patent's specific claim language.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes the function in general terms: "The encoding/decoding module...is disposed in the display device for encoding the first OSD signal received by the OSD system...into a first data signal" (’889 Patent, col. 4:28-30). This broad functional language may support an argument that any process converting the initial command into a transmittable signal meets the limitation.
- Evidence for a Narrower Interpretation: The patent’s flow chart (Fig. 4) depicts "encode the first OSD signal into the first data signal" as a distinct step (S34) that follows the receipt of the signal (S32). This may support an argument that "encoding" refers to a specific transformation process taught in the patent, rather than the simple act of formatting a command according to a pre-existing industry standard like HDMI-CEC.
The Term: "on screen display (OSD) system"
Context and Importance: The complaint identifies the TV's remote-control-receiving apparatus as the "OSD system" (Compl. ¶16). The proper construction of this term is crucial because it defines the input to the "encoding" step. Practitioners may focus on whether the term requires a system that generates a visual on-screen display, or if it can simply mean the circuitry that receives commands that might control such a display.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 1 describes the system as "for receiving a first OSD signal," focusing on its receptive function (’889 Patent, col. 5:1-3). This could support a reading that any system receiving such signals qualifies, regardless of its display-generating capabilities.
- Evidence for a Narrower Interpretation: The term itself, "on screen display system," suggests a connection to what is visually displayed. The background section discusses separate OSD systems for the display and play devices, tying the system to the user interface that controls device parameters (’889 Patent, col. 1:26-28). The complaint provides a screenshot of a TV menu for enabling HDMI-CEC, which is a form of on-screen display (Compl. p. 10). This could support an interpretation that the system must be tied to a visual GUI.
VI. Other Allegations
- Indirect Infringement: The complaint's prayer for relief requests a judgment that the ’889 patent has been infringed "directly and indirectly" (Compl. p. 36). However, the factual allegations in the body of the complaint do not appear to plead the specific elements of knowledge and intent required to state a claim for either induced or contributory infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical equivalence: does the accused BRAVIA Sync system, which operates by implementing the industry-standard HDMI-CEC protocol, perform the specific function of "encoding" an "OSD signal" into a "data signal" as claimed in the patent? The court will need to determine if complying with a standard protocol is the same as the bespoke encoding process described in the patent.
- A second key issue will be one of definitional scope: can the term "OSD signal" be construed to mean a command sent by a remote control, as the Plaintiff alleges? The outcome of this claim construction may determine whether the accused system's input signal is the same as the input signal required by the patent claims.
- A third issue will be evidentiary: what evidence does the complaint provide for the existence of a distinct "encoding/decoding module" in the accused devices, beyond the inference that such a module must exist for the system to function? The Plaintiff’s ability to prove the existence of this claimed structure will be critical.