DCT

2:26-cv-00014

L4T Innovations LLC v. Haivision Systems Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00014, E.D. Tex., 01/08/2026
  • Venue Allegations: Venue is asserted on the basis that Defendant is a foreign corporation and may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s video transmitter products and associated software infringe a patent related to systems for marking specific moments in a media recording for later retrieval.
  • Technical Context: The technology relates to event marking in media capture, a field relevant to live sports, broadcasting, and surveillance, where identifying key moments in lengthy recordings is a significant workflow challenge.
  • Key Procedural History: The complaint alleges that Plaintiff sent Defendant a letter on October 22, 2025, providing notice of the asserted patent and its alleged infringement. This pre-suit notice, allegedly received by Defendant on November 6, 2025, forms the basis for Plaintiff's allegations of willful and indirect infringement.

Case Timeline

Date Event
2017-10-02 ’321 Patent Priority Date
2021-11-30 ’321 Patent Issue Date
2025-10-22 Plaintiff sends notice letter to Defendant
2025-11-06 Defendant receives notice letter
2026-01-08 Complaint Filing Date

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

U.S. Patent No. 11,189,321 - "Retrospective Capture Trigger"

  • Patent Identification: U.S. Patent No. 11,189,321, "Retrospective Capture Trigger," issued November 30, 2021 (the "’321 Patent").

The Invention Explained

  • Problem Addressed: The patent addresses the difficulty of locating specific "noteworthy events" within hours of captured media, noting that manually searching through such voluminous recordings can be "tedious and time-consuming." (’321 Patent, col. 3:9-12).
  • The Patented Solution: The invention is an "event marking device" that allows a user to generate a "trigger signal" at the moment a notable event occurs. This device contains a microcontroller and a real-time clock. Upon receiving the trigger, the microcontroller records the precise time and outputs this "trigger event data" to an external device, such as a video camera. (’321 Patent, Abstract; col. 4:1-11). This timestamped data allows a user or system to later identify the relevant media segment or cause a media capture device to "retrospectively capture media." (’321 Patent, col. 3:12-18). The device is depicted in various embodiments, including as a wearable wrist device communicating with a head-mounted camera. (’321 Patent, Fig. 5).
  • Technical Importance: The described solution provides a method for creating metadata in real-time that is synchronized with a separate media recording, aiming to streamline post-production and media review workflows. (Compl. ¶16).

Key Claims at a Glance

  • Independent Claim 1 (Apparatus): An "event marking device" comprising:
    • a housing;
    • a microcontroller;
    • a memory;
    • a real-time clock;
    • a communication interface; and
    • a trigger circuit arranged to be enabled by a user to identify an event for recording.
  • Independent Claim 8 (Method): A method comprising the steps of:
    • generating real-time clock data with a real-time clock of an event marking device;
    • generating a trigger signal with a trigger circuit;
    • identifying a real time corresponding to receipt of the trigger signal;
    • writing trigger signal data to a memory indicating the real time; and
    • outputting the trigger event data to an external device.
  • The complaint asserts claims 1, 8, 9, 14, 15, and 16. (Compl. ¶19).

III. The Accused Instrumentality

Product Identification

  • The "Accused Products" include the Haivision Falkon X2 Transmitter, Haivision Pro460 Transmitter, Haivision Pro Series Transmitters, and the Haivision Air (collectively, “Haivision Video Transmitters”), along with the Haivision Hub 360 and Haivision Streamhub software products (collectively, “Haivision software products”). (Compl. ¶14).

Functionality and Market Context

  • The complaint identifies the accused products as video transmitter systems and associated software. (Compl. ¶14). Figure 1 of the complaint depicts several of the accused transmitters, described as devices for mobile video transmission with features for live production of sports and other events. (Compl. at 4). The complaint alleges these products perform a method of generating real-time clock data, generating a trigger signal, and processing that signal to preserve a recording. (Compl. ¶20).

IV. Analysis of Infringement Allegations

The complaint references an "Exhibit 2" containing detailed infringement evidence but does not attach it. The infringement theory for method claim 8 is summarized narratively in the complaint body. (Compl. ¶¶19-20).

’321 Patent Infringement Allegations

Claim Element (from Independent Claim 8) Alleged Infringing Functionality Complaint Citation Patent Citation
generating real-time clock data with a real-time clock of an event marking device; The Accused Products allegedly perform a method that includes generating real-time clock data with a real-time clock. ¶20 col. 3:31-33
generating, with a trigger circuit of the event marking device, a trigger signal; The Accused Products allegedly generate a trigger signal via a trigger circuit. ¶20 col. 4:45-48
identifying, from the real-time clock data with a microcontroller of the event marking device, a real time corresponding to a receipt of the trigger signal; A microcontroller within the Accused Products allegedly identifies the real-time clock data upon receipt of the trigger signal. ¶20 col. 4:5-9
writing, with the microcontroller, trigger signal data to a memory of the event marking device indicating the real time associated with receipt of the trigger signal; The microcontroller allegedly writes data indicating the time of the trigger signal to a memory. ¶20 col. 4:9-11
and outputting, with a communication interface of the event marking device, the trigger event data including the time of generating the trigger signal to an external device; A communication interface allegedly outputs the trigger event data to an external device. ¶20 col. 4:51-59
whereby outputting the trigger event data causes the external device to preserve a recording captured at the time of the enablement of the trigger circuit. The outputted trigger event data allegedly causes an external device to preserve a recording. ¶20 col. 14:19-23

Identified Points of Contention

  • Scope Questions: The complaint alleges that integrated video transmitters practice the claimed method. A central question may be whether such a system constitutes an "event marking device" that communicates with a separate "external device" as contemplated by the patent's specification and figures, which often depict a distinct, user-worn trigger device separate from the primary media recorder. (’321 Patent, Fig. 5).
  • Technical Questions: What specific functionality in the Accused Products corresponds to the "trigger circuit"? How is a trigger signal "generated" and how does the system "preserve a recording" in response? The complaint does not detail the specific user actions or system architecture that allegedly perform these claimed functions.

V. Key Claim Terms for Construction

  • The Term: "event marking device"
  • Context and Importance: This term defines the entire apparatus in claim 1 and is the central component in method claim 8. Its construction will be critical to determining whether the patent's claims read on the accused integrated video transmitter systems. Practitioners may focus on this term because the complaint's theory appears to equate an integrated professional video transmitter with the "event marking device," while the patent's specification frequently describes it as a discrete, often simple, trigger mechanism separate from the primary media capture hardware.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims themselves do not require the device to be separate from a media recorder, only that it contain the recited components (microcontroller, clock, trigger circuit, etc.) and output data to an "external device." (’321 Patent, cl. 1, 8).
    • Evidence for a Narrower Interpretation: The specification repeatedly describes the device in contexts suggesting a separate physical object, such as a "purpose-built circuit separate from a smart watch or smart phone," a device coupled to handlebars or a ski pole, or a wrist-worn device. (’321 Patent, col. 3:26-29; Figs. 4B, 4C, 5). The abstract describes the device as one that "marks the real time at which notable events occur" and then "outputs the trigger event data to an external device," implying two distinct entities. (’321 Patent, Abstract).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement based on Defendant's knowledge of the patent since at least November 6, 2025. It further alleges Defendant provides instructions and user guides that direct end-users to operate the Accused Products in an infringing manner. (Compl. ¶22). Contributory infringement is also alleged, on the basis that the Accused Products contain special features not suitable for substantial non-infringing use. (Compl. ¶23).
  • Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after receiving actual notice of the ’321 Patent and Plaintiff's infringement allegations on November 6, 2025. (Compl. ¶24).

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

  1. A core issue will be one of definitional scope: Can the term "event marking device," as described in a patent focused on simple, often wearable triggers, be construed to cover a complex, integrated professional video transmitter as alleged in the complaint?
  2. A second key issue will be architectural mapping: Does the accused system, which appears to be an integrated unit, actually contain a distinct "event marking device" that outputs data to a separate "external device" as required by the claims, or are these functionalities inseparable parts of a single product, raising questions about whether the claim limitations are met?
  3. An important evidentiary question will concern the "whereby" clause: What proof demonstrates that the output of trigger data from the Accused Products "causes" an external device to "preserve a recording captured at the time of the enablement of the trigger circuit," as the final functional step of the asserted method claim requires?