DigiMedia Tech LLC v. Redfin Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DigiMedia Tech, LLC (Georgia)
  • Defendant: Redfin Corporation (Delaware)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:26-cv-00095, E.D. Tex., 02/04/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas on the grounds that Defendant maintains a regular and established place of business in the district, citing several physical office locations in Texas.
• Core Dispute: Plaintiff alleges that Defendant’s systems and processes for managing digital photos infringe three patents related to methods for reducing data transmission and storage requirements by uploading a full image to a server only once and subsequently referencing it with a unique identifier for further actions.
• Technical Context: The patents address technology for conserving bandwidth and on-device memory, a significant technical challenge for portable, internet-connected imaging devices in the early 2000s when mobile data was slow and expensive.
• Key Procedural History: The complaint states that Plaintiff's counsel sent Defendant a draft complaint on April 30, 2025, and that subsequent licensing discussions over a period of months ceased. The complaint also references the prosecution history of the asserted patent family to argue for the novelty and patent eligibility of the claimed inventions.

Case Timeline

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

U.S. Patent No. 7,287,088 - “Transmission Bandwidth and Memory Requirements Reduction in a Portable Image Capture Device by Eliminating Duplicate Image Transmissions”

The Invention Explained

• Problem Addressed: The patent’s background section describes the technical challenge faced by early digital cameras and other portable imaging devices connecting to the internet Compl. ¶30 Transmitting large digital image files consumed significant bandwidth, which was slow and costly, and the devices themselves had limited storage capacity Compl. ¶32 ’088 Patent, col. 1:53-64 The problem was compounded when a user needed to send the same image multiple times for different purposes, as each transmission would send the full data again ’088 Patent, col. 2:1-9
• The Patented Solution: The invention provides a method where an image is transmitted from the portable device to a server only once for storage Compl. ¶35 The server assigns a unique "image identifier" to the stored image ’088 Patent, abstract For any subsequent action involving that image (e.g., sending it to a recipient, printing it), the portable device transmits only the small image identifier and the requested action to the server ’088 Patent, col. 2:33-37 The server then executes the action using the full-resolution image it already has in storage, thereby "eliminating redundancy in image transmission" Compl. ¶35 ’088 Patent, Fig. 4 The invention also discloses reducing the size of the image file on the local device after upload to free up memory ’088 Patent, col. 2:37-40
• Technical Importance: This client-server communication protocol was designed to make online photo sharing from resource-constrained mobile devices more efficient and affordable in an era of limited network bandwidth and device memory Compl. ¶43

Key Claims at a Glance

• The complaint asserts independent claims 14 and 22 Compl. ¶61
• Essential elements of Claim 14 (Method):
  • Uploading captured images to a server for the first time, where the server assigns a respective image identifier to each.
  • Receiving the image identifiers and "action information" from the server.
  • Presenting an "action control" based on the received action information.
  • In response to a selection, transmitting the action and the image identifier—rather than the image itself—to the server.
• Essential elements of Claim 22 (Method):
  • A server receives captured images uploaded from an image capture device.
  • The server assigns an image identifier to the uploaded images.
  • The image capture device downloads the image identifiers for association with the images.
  • The image capture device downloads "action information" for actions that can be applied by the server.
  • The server receives a request from the device that includes only the image identifier and the requested action.

U.S. Patent No. 7,587,514 - “Transmission Bandwidth and Memory Requirements Reduction in a Portable Image Capture Device”

The Invention Explained

• Problem Addressed: As a continuation of the '088 Patent, the '514 Patent addresses the same technical problems of excessive bandwidth consumption and limited storage on portable devices when transmitting digital images over a network Compl. ¶21 ’514 Patent, col. 1:21-25
• The Patented Solution: The '514 Patent describes a similar method where captured images are uploaded from a portable device to a "hardware server" ’514 Patent, claim 1 The server assigns an image identifier, and the device downloads both the identifiers and "action information." Subsequent requests from the device to the server to perform an action on an image include the identifier and the action "rather than the image itself, thereby eliminating the need to retransmit the image" ’514 Patent, abstract ’514 Patent, claim 1 The common specification details this process as a way to free memory space and reduce transmission costs ’514 Patent, col. 2:45-53
• Technical Importance: The invention provided a technical framework for making early mobile photo management feasible by minimizing data transfer over constrained networks Compl. ¶49

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶68
• Essential elements of Claim 1 (Method):
  • Receiving captured images uploaded from an image capture device to a hardware server.
  • Assigning an image identifier to the images by the hardware server.
  • Downloading the image identifiers to the device.
  • Downloading "action information" to the device, which includes actions the server can perform.
  • Receiving a request from the device to apply an action, where the request contains the image identifier and action rather than the image itself.

U.S. Patent No. 8,073,965 - “Transmission Bandwidth and Memory Requirements Reduction in a Portable Image Capture Device by Eliminating Duplicate Image Transmissions”

Technology Synopsis

The '965 Patent, also in the same family, discloses methods to reduce network transmission bandwidth for a portable image capture device Compl. ¶47 The claimed solution involves a "photo-sharing service" that receives an image, provides an image identifier back to the device, and then processes subsequent action requests from the device containing only the identifier, thus avoiding re-transmission of the full image file ’965 Patent, abstract

Asserted Claims

The complaint asserts independent claims 1 and 13 Compl. ¶75

Accused Features

The complaint alleges that Defendant's "systems and processes for managing photos" infringe by using methods to reduce bandwidth requirements that practice the steps of the asserted claims Compl. ¶¶75-76

III. The Accused Instrumentality

Product Identification

• Defendant’s "systems and processes for managing photos" Compl. ¶61 Compl. ¶68 Compl. ¶75

Functionality and Market Context

• The complaint alleges that the accused instrumentality includes functionality for "uploading and managing images in such a way as to reduce bandwidth requirements" Compl. ¶62 Compl. ¶69 Compl. ¶76 The complaint does not provide specific technical details about how Defendant's systems operate. The allegations suggest that the accused systems involve a client-server architecture where users upload and manage photographs, presumably in the context of Redfin's real estate business. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references preliminary claim charts (Exhibits M, N, and O) that were not provided with the filed document Compl. ¶61 Compl. ¶68 Compl. ¶75 The narrative infringement theory alleges that Redfin's photo management systems practice the patented methods for reducing bandwidth. This suggests an allegation that when a user interacts with Redfin's platform to manage a photo that has already been uploaded, the user's device communicates an identifier for that photo to Redfin's servers rather than re-transmitting the entire image file for each management action, thereby mapping to the core steps of the asserted claims Compl. ¶62 Compl. ¶69 Compl. ¶76

• Identified Points of Contention:
  • Scope Questions: The patents-in-suit describe a "portable image capture device" and consistently use a "digital camera" as the primary example ’088 Patent, col. 3:20-22 A central question may be whether this term, conceived in the context of early-2000s technology, can be construed to cover the modern smartphones and computers that interact with Redfin's platform. The answer may depend on how the court interprets the patent's disclosure of other devices like a "cellphone or PDA" ’088 Patent, col. 3:39-40
  • Technical Questions: The asserted claims from the ’088 and ’514 patents recite a specific client-server workflow, including the device "downloading action information" from the server and then using it to formulate a request ’514 Patent, claim 1 A potential point of dispute is whether Redfin’s architecture operates in this specific manner. For example, does Redfin’s server send a discrete package of "action information" to the client device as claimed, or does the system operate using a more conventional web application architecture where such steps may not be distinctly performed in the claimed sequence?

V. Key Claim Terms for Construction

The Term: "portable image capture device"

• (preamble of asserted claims, e.g., ’514 Patent, claim 1)
• Context and Importance: This term defines the client-side component of the claimed methods. Its construction is critical to determining whether the modern devices (e.g., smartphones, laptops) used to access Redfin's services fall within the scope of the claims. Practitioners may focus on this term because the technological capabilities of modern devices differ substantially from the resource-constrained devices described as the motivation for the invention.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that "any portable device capable of capturing images could be used, such as a cellphone or PDA equipped with a lens attachment" ’088 Patent, col. 3:38-41, which could support an interpretation covering modern smartphones.
  • Evidence for a Narrower Interpretation: The specification repeatedly frames the invention around a "digital camera" ’088 Patent, col. 1:29-32 and its specific limitations at the time, which a party could argue limits the term to devices with analogous constraints, not powerful, modern computing devices.

The Term: "downloading action information"

• ’514 Patent, claim 1 ’088 Patent, claim 22
• Context and Importance: This claim element requires a specific data transfer from the server to the client device. The infringement analysis will depend on whether the communication in Redfin's system can be characterized as a "download" of "action information." This is important because modern web applications may not perform a discrete "download" in the manner contemplated by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent depicts an "ACTION LIST" with user-selectable options like "Print Images" and "Send to Mom" as an example of what this information could represent ’088 Patent, Fig. 6 This could support a reading on any UI data that allows a user to select an action.
  • Evidence for a Narrower Interpretation: The specification describes this process as the action list being "downloaded to the user's camera... and stored on the camera" ’088 Patent, col. 4:4-6 This language may support a narrower construction requiring a distinct data file to be saved on the client device, which may differ from how information is dynamically displayed in a web browser.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that to the extent any steps are performed by a third party (i.e., a user), Defendant "conditioned the third party's use of the functionality" on performing those steps and "controlled the manner and/or timing of the functionality" Compl. ¶62 Compl. ¶69 Compl. ¶76 These allegations raise a question of divided infringement, where Plaintiff must show Defendant directs or controls the actions of its users to satisfy the claim limitations.
• Willful Infringement: The complaint alleges that Defendant had knowledge of the patents-in-suit at least as of April 30, 2025, when Plaintiff sent a draft complaint and offered to engage in licensing discussions Compl. ¶6 This alleged pre-suit notice forms the basis for a potential claim of willful infringement.

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

This case appears to present several central questions for the court's determination:

1. Technological Equivalence: A core issue will be whether the architecture of Redfin's modern, web-based photo management system performs the specific, sequential communication steps recited in the asserted claims. The dispute may turn on whether there is a fundamental mismatch between the patented method—conceived for early, resource-scarce mobile devices—and the technical operation of Redfin's current platform.
2. Definitional Scope: A key legal question will be one of claim construction: can the term "portable image capture device," rooted in the technological context of year-2000 digital cameras, be interpreted to encompass the modern smartphones, tablets, and computers that interact with Defendant's services?
3. Divided Infringement Liability: Given that the asserted method claims involve actions taken by both a user's device and Defendant's servers, a critical question will be whether Plaintiff can produce evidence that Defendant directs or controls its users' actions in a manner sufficient to attribute their conduct to Defendant for infringement purposes.