Contentnexus LLC v. Shenzhen Geniatech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:

  • Plaintiff: ContentNexus LLC (New Mexico)
  • Defendant: Shenzhen Geniatech Inc, Ltd (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC

• Case Identification: 2:25-cv-00987, E.D. Tex., 10/01/2025

• Venue Allegations: Venue is asserted on the basis that the Defendant is a foreign corporation.

• Core Dispute: Plaintiff alleges that Defendant’s products infringe seven patents related to systems and methods for processing signals to combine broadcast media with computer-generated information.

• Technical Context: The technology relates to embedding data signals within television, radio, or other broadcast transmissions to control computers at subscriber locations, enabling personalized content, data overlays, and interactive features.

• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit. All asserted patents claim priority to an application filed in 1981, a fact which may be significant for claim construction and potential invalidity arguments based on intervening technological developments.

Case Timeline

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

U.S. Patent No. 10,616,638 - "Signal processing apparatus and methods"

• Patent Identification: U.S. Patent No. 10616638, titled “Signal processing apparatus and methods,” issued April 7, 2020.

The Invention Explained

• Problem Addressed: The patent’s background section describes the limitations of then-existing media, where broadcast television and radio are powerful but impersonal mass media, while computers can process user-specific information but lack broad distribution capabilities (’638 Patent, col. 2:38-54). The invention aims to overcome the inability to efficiently combine these different forms of communication ('638 Patent, col. 2:50-54).
• The Patented Solution: The invention is a unified system that embeds digital data and instructions, termed "SPAM signals," into broadcast transmissions (e.g., television or radio signals) ('638 Patent, Abstract; col. 22:28-31). A decoder and microcomputer at a subscriber's location detect these signals, which can then instruct the computer to perform functions like generating and displaying personalized graphic overlays on a television screen, combining user-specific data (e.g., a stock portfolio's performance) with a conventional broadcast program (e.g., a financial news show) ('638 Patent, col. 13:27-48; Fig. 1).
• Technical Importance: This technology describes an early architecture for making passive broadcast media interactive and personalized for individual users ('638 Patent, col. 7:5-15).

Key Claims at a Glance

• The complaint does not identify specific asserted claims, instead incorporating by reference "the charts incorporated into this Count below" and an external "Exhibit 8" containing claim charts, which was not filed with the complaint (Compl. ¶17, ¶22). Therefore, the specific claims asserted against the Defendant cannot be determined from the complaint.

U.S. Patent No. 7,747,217 - "Signal processing apparatus and methods"

• Patent Identification: U.S. Patent No. 7747217, titled “Signal processing apparatus and methods,” issued June 29, 2010.

The Invention Explained

• Problem Addressed: Similar to the ’638 Patent, the ’217 Patent addresses the technical problem of separating broadcast media, which is one-to-many, from computer processing, which can be user-specific ('217 Patent, col. 1:24-col. 2:48). The patent notes that prior art systems lacked the capacity for "simultaneous generation of user specific information at a plurality of receiver stations" ('217 Patent, col. 3:5-8).
• The Patented Solution: The patent describes an integrated system where a "combined medium" is created by embedding control signals and data within a broadcast transmission ('217 Patent, col. 2:62-65). These embedded signals are received by a subscriber station, which includes a computer that processes the signals to generate user-specific output, such as overlaying personalized graphics on a video display ('217 Patent, col. 13:62-col. 14:18).
• Technical Importance: The system provides a method for delivering personalized or "user specific" content via mass media broadcast channels, a foundational concept for later developments in interactive television and data broadcasting ('217 Patent, col. 7:6-12).

Key Claims at a Glance

• The complaint does not identify specific asserted claims of the ’217 Patent. It incorporates by reference an unprovided claim chart (Exhibit 9) to identify the "Exemplary '217 Patent Claims" (Compl. ¶26, ¶31).

U.S. Patent No. 7,769,170 - "Signal processing apparatus and methods"

• Patent Identification: U.S. Patent No. 7769170, titled “Signal processing apparatus and methods,” issued August 3, 2010 (Compl. ¶11).
• Technology Synopsis: This patent, part of the same family, describes a unified communication system for combining broadcast programming with user-specific computer processing. It uses embedded signals to control user hardware, enabling the generation of personalized information overlays and other automated functions at subscriber stations (’170 Patent, Abstract).
• Asserted Claims: The complaint refers to an unprovided claim chart (Exhibit 10) for the "Exemplary '170 Patent Claims" (Compl. ¶35, ¶40).
• Accused Features: The complaint generically alleges that "Exemplary Defendant Products" infringe the patent (Compl. ¶35).

U.S. Patent No. 7,818,778 - "Signal processing apparatus and methods"

• Patent Identification: U.S. Patent No. 7818778, titled “Signal processing apparatus and methods,” issued October 19, 2010 (Compl. ¶12).
• Technology Synopsis: This patent describes a system for embedding digital data within a broadcast signal to create a "combined medium." A computer at a receiver station processes the embedded data to generate viewer-specific information, which can be displayed as an overlay on a conventional television program (’778 Patent, Abstract; col. 14:3-18).
• Asserted Claims: The complaint refers to an unprovided claim chart (Exhibit 11) for the "Exemplary '778 Patent Claims" (Compl. ¶44, ¶49).
• Accused Features: The complaint generically alleges that "Exemplary Defendant Products" infringe the patent (Compl. ¶44).

U.S. Patent No. 7,823,175 - "Signal processing apparatus and methods"

• Patent Identification: U.S. Patent No. 7823175, titled “Signal processing apparatus and methods,” issued October 26, 2010 (Compl. ¶13).
• Technology Synopsis: This patent discloses an integrated communication system that uses embedded signals to link broadcast media with local computer processing. The system is designed to provide personalized information and control various apparatus at a subscriber station based on instructions transmitted within a television or radio signal (’175 Patent, Abstract).
• Asserted Claims: The complaint refers to an unprovided claim chart (Exhibit 12) for the "Exemplary '175 Patent Claims" (Compl. ¶53, ¶58).
• Accused Features: The complaint generically alleges that "Exemplary Defendant Products" infringe the patent (Compl. ¶53).

U.S. Patent No. 8,566,868 - "Signal processing apparatus and methods"

• Patent Identification: U.S. Patent No. 8566868, titled “Signal processing apparatus and methods,” issued October 22, 2013 (Compl. ¶14).
• Technology Synopsis: Belonging to the same patent family, this patent details a system for embedding control signals in broadcast media to trigger operations on computers at receiving stations. This enables the combination of mass media with personalized data, such as generating custom graphic overlays on a TV monitor (’868 Patent, Abstract).
• Asserted Claims: The complaint refers to an unprovided claim chart (Exhibit 13) for the "Exemplary '868 Patent Claims" (Compl. ¶62, ¶67).
• Accused Features: The complaint generically alleges that "Exemplary Defendant Products" infringe the patent (Compl. ¶62).

U.S. Patent No. 8,804,727 - "Signal processing apparatus and methods"

• Patent Identification: U.S. Patent No. 8804727, titled “Signal processing apparatus and methods,” issued August 12, 2014 (Compl. ¶15).
• Technology Synopsis: This patent describes a system for unified programming communication where embedded signals control subscriber computers to combine broadcast content with user-specific information. The technology allows for automated and personalized media experiences by processing instructions sent over broadcast channels (’727 Patent, Abstract).
• Asserted Claims: The complaint refers to an unprovided claim chart (Exhibit 14) for the "Exemplary '727 Patent Claims" (Compl. ¶71, ¶76).
• Accused Features: The complaint generically alleges that "Exemplary Defendant Products" infringe the patent (Compl. ¶71).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are identified in claim charts (Exhibits 8-14), which were not provided with the filed complaint (Compl. ¶17, ¶26, ¶35, ¶44, ¶53, ¶62, ¶71).

Functionality and Market Context

• The complaint does not describe the specific functionality of any accused product. It alleges in a conclusory manner that the unspecified products "practice the technology claimed" by the patents-in-suit (Compl. ¶22, ¶31, ¶40, ¶49, ¶58, ¶67, ¶76). No allegations are made regarding the products' market positioning or commercial importance.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges direct and induced infringement of all seven patents-in-suit but provides no specific factual allegations in the body of the complaint to support its infringement theories. Instead, for each asserted patent, the complaint states that infringement is demonstrated in an accompanying claim chart exhibit (Exhibits 8 through 14) (Compl. ¶22, ¶31, ¶40, ¶49, ¶58, ¶67, ¶76). As these exhibits were not filed with the complaint, a detailed analysis of the infringement allegations is not possible.

• '638 Patent Infringement Allegations

  • The complaint alleges that Defendant directly infringes by making, using, and selling products identified in the unprovided Exhibit 8, and that these products satisfy all elements of the "Exemplary '638 Patent Claims" (Compl. ¶17, ¶22). The complaint does not provide sufficient detail for analysis of potential points of contention.

• '217 Patent Infringement Allegations

  • The complaint alleges that Defendant directly infringes by making, using, and selling products identified in the unprovided Exhibit 9, and that these products satisfy all elements of the "Exemplary '217 Patent Claims" (Compl. ¶26, ¶31). The complaint does not provide sufficient detail for analysis of potential points of contention.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of key claim terms. Because the complaint fails to identify any specific asserted independent or dependent claims from any of the seven patents-in-suit, it is not possible to identify specific claim terms whose construction may be central to resolving the dispute.

VI. Other Allegations

• Indirect Infringement: For each of the seven asserted patents, the complaint alleges induced infringement. The allegations are based on Defendant allegedly selling its products to customers and providing "product literature and website materials" that instruct and direct end users to use the products in a manner that infringes the patents-in-suit (e.g., Compl. ¶20-21, ¶29-30). These allegations rely on evidence purportedly contained within the unprovided exhibits (e.g., Compl. ¶20, ¶29).

• Willful Infringement: The complaint does not explicitly use the term "willful infringement." However, for each asserted patent, it alleges that the service of the complaint and its associated (unprovided) claim charts constitutes "Actual Knowledge of Infringement" (e.g., Compl. ¶19, ¶28). It further alleges that "Despite such actual knowledge, Defendant continues to make, use, test, sell, offer for sale, market, and/or import" infringing products (e.g., Compl. ¶20, ¶29). These allegations may form the basis for a claim of post-suit willfulness.

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

Based on the complaint and the nature of the asserted patents, the case appears to present several fundamental questions for the court.

• A primary procedural question will be one of evidentiary sufficiency: The complaint's infringement allegations are entirely dependent on external exhibits that were not filed with the court. A threshold issue will be whether the complaint, standing alone, meets the pleading standards required to state a plausible claim for relief, or if it must be amended to include the specific factual basis for its claims.

• The central substantive issue will likely be one of technological scope: Given that all asserted patents claim priority to a 1981 application, a core dispute may concern whether the patent claims, which were drafted in the context of analog broadcast and early personal computers, can be construed to read on the accused modern digital signal processing technologies. The vast technological evolution between the priority date and the present may raise significant questions during claim construction and any analysis under the doctrine of equivalents.

• A foundational factual question will be one of product identification and function: As the complaint fails to identify a single accused product or describe its operation, the initial phase of litigation will likely focus on discovering precisely which of the Defendant's products are accused and how they are alleged to function in an infringing manner.