DCT
2:25-cv-01224
Control Sync Systems LLC v. Hisense USA Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Control Sync Systems, LLC (Wyoming)
- Defendant: Hisense USA Corporation (Georgia)
- Plaintiff’s Counsel: Direction IP Law
- Case Identification: 2:25-cv-01224, E.D. Tex., 12/17/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a place of business and authorized retailers within the Eastern District of Texas, and offers for sale the accused products in the district.
- Core Dispute: Plaintiff alleges that Defendant’s televisions supporting the HDMI-CEC standard infringe a patent related to the synchronous control of a display device and a separate media play device.
- Technical Context: The technology concerns simplifying the user experience in home entertainment systems by enabling a single remote control and on-screen interface to manage multiple interconnected devices.
- Key Procedural History: The complaint does not allege any prior litigation, licensing history, or inter partes review proceedings related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2005-07-29 | ’889 Patent Priority Date |
| 2010-10-12 | ’889 Patent Issue Date |
| 2025-12-17 | 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
- Patent Identification: U.S. Patent No. 7,812,889, Control System for Synchronously Controlling Display Device and Play Device, issued October 12, 2010.
The Invention Explained
- Problem Addressed: The patent describes the user inconvenience and frustration that arises from using separate remote controls for a display device (like a projector) and a play device (like a DVD player). A user might, for example, adjust the volume on the DVD player's remote only to realize the projector's volume was the actual source of the issue, requiring a second adjustment with a different remote (’889 Patent, col. 1:40-54).
- The Patented Solution: The invention proposes a control system where two devices are connected by a bus. When a user inputs a command via an On-Screen Display (OSD) on the display device, the command is encoded into a data signal, sent over the bus to the play device, and then decoded by the play device. This allows a single user action to synchronously control the parameters (e.g., volume, playback) of both devices, eliminating the need for multiple remotes and separate control actions (’889 Patent, Abstract; Fig. 2; col. 2:1-34).
- Technical Importance: The technology aimed to unify the control architecture for increasingly complex but physically separate home entertainment components.
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶16).
- The essential elements of Claim 1 are:
- An On-Screen Display (OSD) system within a 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 transmitting the first data signal to a play device.
- Wherein the display device uses the first OSD signal to control its own parameters, and the play device decodes the first data signal from the bus to control its parameters.
III. The Accused Instrumentality
Product Identification
- Hisense televisions that support the HDMI-CEC (High-Definition Multimedia Interface - Consumer Electronics Control) standard, including the R6, R7, R8, H8, H9, U8, U7, U6, and QD6 Series. The 100" Class U70 Series QLED 4K Google TV is used as an exemplary device (Compl. ¶16).
Functionality and Market Context
- The accused functionality is HDMI-CEC, a feature that allows the TV's remote control to command other HDMI-connected devices, such as Blu-ray players, set-top boxes, or soundbars (Compl. ¶17). User commands entered via the TV remote are transmitted over the HDMI cable to the connected device to control functions like play, pause, power on/off, and volume (Compl. ¶17). The complaint provides a screenshot from a Hisense user manual describing this "CEC Function" as letting a user "control HDMI CEC-compatible devices connected to the HDMI ports on your TV using the remote control that came with your TV" (Compl. p. 6).
IV. Analysis of Infringement Allegations
’889 Patent 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 accused Hisense TV includes an on-screen display that presents menus and receives commands from the TV's remote control. | ¶18 | col. 4:20-27 |
| 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 Hisense TV receives a command from its remote (the "first OSD signal") and encodes it into an encoded data signal for transmission via the HDMI-CEC protocol. | ¶19 | col. 4:27-30 |
| 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 Hisense TV to a multimedia device (e.g., DVD player) serves as the bus for transmitting the encoded commands. The complaint includes a diagram from a user manual illustrating this connection (Compl. p. 23). | ¶20 | 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 acts on the remote command (e.g., pause), and the connected play device receives the command via the HDMI cable, decodes it, and executes the command (e.g., pausing the video stream). The complaint includes a message flow diagram from the HDMI specification showing this interaction (Compl. p. 10). | ¶21 | col. 5:8-12 |
- Identified Points of Contention:
- Scope Questions: The core of the dispute may turn on whether the accused products' implementation of the widely adopted, standardized HDMI-CEC protocol falls within the scope of the patent's claims. This raises the question of whether practicing an industry standard can constitute infringement of this particular patent.
- Technical Questions: What evidence does the complaint provide that the TV’s conversion of a remote command into a standard HDMI-CEC message is the specific "encoding" of an "OSD signal" into a "data signal" as required by the claim? A defendant could argue that the functions are technically distinct.
- Divided Infringement Questions: The final limitation of the claim requires a "play device" to perform the decoding step. Because the defendant, Hisense, only manufactures and sells the "display device" (the TV), a potential issue is whether Hisense can be held liable for direct infringement of a claim that requires action by a separate, third-party product connected by the end-user.
V. Key Claim Terms for Construction
The Term: "encoding/decoding module"
Context and Importance: This term is central to the invention's mechanism. Its construction will determine whether the standard signal processing in an HDMI-CEC-compliant TV constitutes the claimed "encoding." Practitioners may focus on this term because the plaintiff's case relies on mapping this term to the functionality of standard HDMI-CEC chipsets.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the module's function broadly as "encoding the first OSD signal received by the OSD system 40 into a first data signal" ('889 Patent, col. 4:27-30), which could support an interpretation covering any conversion of a user command into a transmittable data packet.
- Evidence for a Narrower Interpretation: The specific embodiment shown in Figure 2 illustrates a bespoke "Player encoding/decoding module" (48) and "Displayer encoding/decoding module" (42). A defendant might argue this implies a specific component distinct from a general-purpose processor executing a standard protocol.
The Term: "OSD signal"
Context and Importance: The nature of the "OSD signal" that is "encoded" is a prerequisite for infringement. The dispute may involve whether a raw signal from a remote control qualifies as an "OSD signal," or if the term is limited to a signal generated by the OSD system itself.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states the OSD system receives the signal "from external of the display device," for example, from a "first remote controller 50a" ('889 Patent, col. 4:22-24), suggesting the signal originates from the user's input device.
- Evidence for a Narrower Interpretation: A defendant could argue that the remote sends a command to the OSD system, and the OSD system then generates its own internal signal that is acted upon, potentially distinguishing the remote's signal from the claimed "OSD signal."
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Hisense provides online user manuals and instructions that encourage and instruct customers on how to use the accused HDMI-CEC functionality in an infringing manner (Compl. ¶22).
- Willful Infringement: The complaint does not contain an explicit allegation of willful infringement based on pre-suit knowledge. It alleges knowledge of the ’889 patent and infringement "at least as of service of the Complaint," which may form a basis for seeking enhanced damages for any post-filing infringement (Compl. ¶22).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "encoding/decoding module" be construed to read on the standard signal processing and protocol management functions inherent in the accused TVs' off-the-shelf HDMI-CEC implementation?
- A second central question will be one of infringement liability: assuming the claim is construed broadly, can Hisense be held liable for direct infringement for selling a "control system" when the final, decoding step of the asserted claim is necessarily performed by a separate, third-party "play device" that Hisense does not manufacture or sell?
- Finally, a key evidentiary question will be one of technical operation: does the accused TV's system operate by "encoding" the "first OSD signal" as claimed, or does it operate in a fundamentally different way, for instance, by receiving a remote command that separately triggers a screen display and the transmission of a distinct HDMI-CEC command?