DCT

2:26-cv-00036

Interactive Content Engines LLC v. Eros Intl Media Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00036, E.D. Tex., 01/16/2026
  • Venue Allegations: Venue is asserted on the basis that Defendant is a foreign entity not resident in the United States and may therefore be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s "Eros Now" video streaming platform infringes patents related to distributed systems for storing and delivering digital content.
  • Technical Context: The patents address architectural challenges in delivering large media files, such as video-on-demand, to many simultaneous users by distributing content across multiple commodity servers instead of using a single, specialized server.
  • Key Procedural History: The complaint alleges Defendant had or should have had notice of the patents-in-suit as of August 24, 2022, due to awareness of a lawsuit Plaintiff filed against another party in the streaming media space.

Case Timeline

Date Event
2001-11-28 Earliest Priority Date ('472 Patent, '136 Patent)
2008-10-14 '472 Patent Issued
2010-01-05 '136 Patent Issued
2022-08-24 Date of Alleged Notice to Defendant via Prior Litigation
2026-01-16 Complaint Filing Date

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

U.S. Patent No. 7,437,472 - *"Interactive Broadband Server System"*

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of creating a cost-effective and scalable server system for services like video-on-demand, noting that traditional server designs were limited in the number of simultaneous streams they could generate from a single copy of a media title, which required costly redundant storage for popular content (ʼ472 Patent, col. 1:46-57).
  • The Patented Solution: The invention is a distributed server architecture comprising multiple processors connected by a high-speed "backbone switch." Media content, or "titles," are divided into "data chunks" that are distributed across storage devices coupled to the different processors. When a user requests a title, "user processes" running on the processors retrieve the necessary data chunks from multiple processors via the switch to assemble and deliver the content. The complaint includes a figure from the patent illustrating this architecture of interconnected processors, storage, and a management processor communicating via a backbone switch (Compl. p. 11; '472 Patent, Fig. 2A). This distributed approach aims to balance the processing load and avoid the bottlenecks of a single-server system (ʼ472 Patent, Abstract; col. 2:1-7).
  • Technical Importance: This architecture sought to enable large-scale, fault-tolerant media delivery using interconnected commodity hardware, moving away from reliance on expensive, specialized, and monolithic server systems (Compl. ¶12).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 25 (Compl. ¶42).
  • Essential elements of Claim 25 include:
    • An interactive broadband server system, comprising:
    • a backbone switch including a plurality of bi-directional ports;
    • a disk array comprising a plurality of disk drives, said disk array storing a plurality of titles sub-divided into a plurality of data chunks which are distributed across said disk array;
    • a plurality of processors, each having a plurality of interfaces including a first interface coupled to a port of said backbone switch, a second interface coupled to at least one disk drive of said drive array, and a third interface for coupling to a network;
    • a plurality of processes for execution on said plurality of processors, enabling each processor to retrieve a plurality of data chunks of a requested title from two or more of said plurality of processors, to assemble said requested title, and to transmit said requested title.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,644,136 - *"Virtual File System"*

The Invention Explained

  • Problem Addressed: The patent describes the need for a scalable solution for the "storage and delivery of streaming media content" to a very large number of simultaneous users, a goal that was difficult to achieve with conventional systems due to cost, bandwidth, and scalability constraints (Compl. ¶17; ’136 Patent, col. 1:18-28, 1:41-44).
  • The Patented Solution: The invention is a "virtual file system" that manages and maintains information about data that is distributed across an array of storage devices. A central "management node" executes a "virtual file manager" which maintains "directory entries" for each media title. Each directory entry contains a detailed list of locations for every "subchunk" of the title, specifying the storage processor node identifier, the disk drive identifier, and the logical address for each piece of data. This allows user processes to precisely locate and retrieve the distributed subchunks needed to assemble the content for delivery ('136 Patent, Abstract). The complaint provides a diagram from the patent illustrating a system of interconnected "Storage Processor Nodes" (SPNs) communicating via a switch, which represents the underlying hardware architecture (Compl. p. 8; ’136 Patent, Fig. 1).
  • Technical Importance: This system provides a method for managing file data at a granular level within a distributed hardware architecture, enabling coordinated, high-speed retrieval of content that is physically spread across many different commodity storage devices (Compl. ¶13).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶50).
  • Essential elements of Claim 1 include:
    • A virtual file system, comprising:
    • a plurality of storage processor nodes, each comprising a processor and a plurality of disk drives;
    • a backbone switch, coupled to the storage processor nodes;
    • at least one management node executing a virtual file manager that manages storage and access of each subchunk and maintains a plurality of directory entries;
    • each directory entry comprising a list of subchunk location entries, where each location entry includes a storage processor node identifier, a disk drive identifier, and a logical address for locating and accessing each subchunk.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The "Eros Now" subscription-based video streaming service (Compl. ¶¶3, 39).

Functionality and Market Context

The Eros Now service delivers digital media content to subscribers' internet-connected devices (Compl. ¶¶39, 44). The complaint alleges this service is implemented using a Content Delivery Network (CDN) architecture. Specifically, it alleges that content is delivered from "origin servers" (identified as Azure and/or Apple servers) to user devices through geographically distributed "CDN edge servers" (identified as Azure CDN and/or Apple Edge Cache servers) (Compl. ¶¶44, 52). The complaint asserts that these interconnected server systems collectively form the accused "interactive broadband server system" and "virtual file system" (Compl. ¶¶44, 52).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not provided. The narrative infringement theory is summarized below.

'472 Patent Infringement Allegations

The complaint alleges that the Eros Now service infringes at least Claim 25 of the ’472 Patent (Compl. ¶42). The infringement theory posits that the collection of origin servers and CDN edge servers used by Eros Now constitutes the claimed "interactive broadband server system" (Compl. ¶44). Under this theory, the various servers (origin and edge) map to the claimed "plurality of processors," and their collective storage maps to the "disk array" where content is distributed. The delivery of video from origin servers via edge servers to a user is alleged to be the claimed process of retrieving data chunks from multiple processors to assemble a title for transmission over a network (Compl. ¶44).

'136 Patent Infringement Allegations

The complaint alleges that the Eros Now service infringes at least Claim 1 of the ’136 Patent (Compl. ¶50). The infringement theory maps the same accused architecture of origin and edge servers onto the claims of the ’136 Patent, alleging that they collectively constitute a "virtual file system" (Compl. ¶52). This theory suggests that the management and coordination between the origin and edge servers for content delivery performs the function of the claimed "virtual file manager" that tracks the location of content "subchunks" across the distributed system (Compl. ¶52).

Identified Points of Contention

  • Scope Questions: A central question may be whether the claimed system, which the patent figures depict as a relatively localized and integrated collection of processors connected to a single "backbone switch," can be construed to read on a geographically vast and disaggregated modern CDN architecture involving separate origin servers and third-party edge servers. The interpretation of terms like "processor" and "backbone switch" will be critical to this analysis.
  • Technical Questions: For the ’136 Patent, a key factual question will be what evidence demonstrates that the accused CDN architecture uses a "virtual file manager" that maintains "directory entries" with the specific, granular structure required by Claim 1: a "storage processor node identifier, a disk drive identifier, and a logical address" for each "subchunk." The complaint does not provide specific details on how the accused Eros Now CDN technically manages file locations.

V. Key Claim Terms for Construction

"a plurality of processors" ('472 Patent, Claim 25)

  • Context and Importance: The definition of this term is critical for determining if the accused architecture, comprising distinct origin servers and third-party CDN edge servers, meets this limitation. Practitioners may focus on this term because the infringement theory requires grouping geographically and administratively separate servers into a single claimed "plurality of processors."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad, not specifying that the processors must be co-located or of a homogenous type. The specification describes using "commodity components" which "accommodates individual components of varying capability," which may support an argument that different types of servers can form the claimed plurality (Compl. ¶19; '136 Patent, col. 2:54-57, which is a related patent).
    • Evidence for a Narrower Interpretation: Figure 2A of the '472 Patent, included in the complaint, depicts processors P1, P2...Pn all connected to a common "BACKBONE SWITCH 203" in a seemingly integrated system ('472 Patent, Fig. 2A). This could support a narrower construction where the "processors" are components of a more tightly coupled system rather than a disparate collection of third-party internet servers.

"virtual file manager" ('136 Patent, Claim 1)

  • Context and Importance: This term is central to the '136 Patent's invention. The infringement analysis will depend on whether the accused CDN's control plane or management system performs the specific functions of the claimed "virtual file manager," particularly its role in maintaining highly structured directory entries.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the VFS in functional terms, stating it is "responsible for reporting where a given content title is stored" and "allocating the required storage space" ('136 Patent, col. 5:16-20). A party could argue that any system performing these general management functions in a distributed environment is a "virtual file manager."
    • Evidence for a Narrower Interpretation: Claim 1 itself provides a narrow functional definition, requiring the virtual file manager to maintain directory entries with a specific three-part location structure for each subchunk ("storage processor node identifier, a disk drive identifier, and a logical address") ('136 Patent, col. 8:14-18). The detailed description of the directory entry further reinforces this specific structure, suggesting the term requires more than just general content management ('136 Patent, col. 5:30-41).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that upon filing and service of the complaint, Defendant will have knowledge of the patents and will induce infringement by continuing to provide and advertise the Eros Now service for use by its customers (Compl. ¶¶60, 61, 63).
  • Willful Infringement: Willfulness is alleged based on Defendant's knowledge of the patents, which the complaint claims exists from at least the date of service of the complaint (Compl. ¶57). It alternatively alleges pre-suit knowledge based on Defendant's alleged awareness of prior lawsuits filed by Plaintiff against others in the industry (Compl. ¶57). The complaint further alleges Defendant has a policy of not reviewing the patents of others, constituting willful blindness (Compl. ¶58).

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

  • A core issue will be one of architectural mapping: can the patented inventions, which describe integrated, distributed server systems, be construed to cover a modern, disaggregated CDN service that relies on geographically separate origin servers and third-party edge cache servers? This will likely require the court to resolve significant claim construction disputes over fundamental terms like "processor" and "backbone switch."
  • A key evidentiary question will be one of informational equivalence: what evidence exists that the accused Eros Now platform manages content location with the specific, granular three-part structure (node ID, disk ID, logical address) required by the "directory entry" limitation in the '136 Patent? The outcome may depend on whether the accused system's internal file management mirrors the highly structured approach claimed in the patent.