Anadex Data Communications LLC v. Verizon Communications Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Anadex Data Communications LLC (Texas)
  • Defendant: Verizon Communications, Inc. (Delaware)
  • Plaintiff’s Counsel: Shea | Beaty PLLC
• Case Identification: 4:25-cv-00322, E.D. Tex., 03/28/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a "regular and established place of business" in the district, citing a specific Verizon retail store located in Tyler, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s set-top boxes, digital video recorders (DVRs), and similar systems infringe a patent related to methods for converting analog video signals and controlling the display of video frames using a specialized buffering system.
• Technical Context: The technology addresses the management of video data streams where the input frequency (e.g., from a camera) and output frequency (e.g., to a display) may differ, a common challenge in video processing systems.
• Key Procedural History: The complaint notes that the patent-in-suit has been the subject of prior litigation in the Eastern and Western Districts of Texas, as well as the Central District of California, against defendants including Lowe's Companies, Inc., Samsung Electronics America, Inc., and The Home Depot, Inc.

Case Timeline

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

U.S. Patent No. 7,310,120 - "RECEIVER OF ANALOGUE VIDEO SIGNAL HAVING MEANS FOR ANALOGUE VIDEO SIGNAL CONVERSION AND METHOD FOR CONTROL OF DISPLAY OF VIDEO FRAMES"

• Patent Identification: U.S. Patent No. 7,310,120, "RECEIVER OF ANALOGUE VIDEO SIGNAL HAVING MEANS FOR ANALOGUE VIDEO SIGNAL CONVERSION AND METHOD FOR CONTROL OF DISPLAY OF VIDEO FRAMES," issued December 18, 2007.

The Invention Explained

• Problem Addressed: The patent describes drawbacks in prior art video processing systems. Systems using a single frame buffer could suffer from visual "interferences" if input and output timers were not synchronized. Systems using two buffers ("double buffering") avoided this but required copying large amounts of data, which was inefficient ('120 Patent, col. 1:26-47; Compl. ¶11, ¶16).
• The Patented Solution: The invention proposes a receiver that uses at least three frame buffers organized in a "two-way list" ('120 Patent, col. 2:30-34). This structure, managed by distinct decoding and displaying controllers, allows the system to flexibly handle mismatches between input and output video frequencies. It can either skip input frames (if input is faster than output) or repeat displayed frames (if output is faster than input) without causing visual artifacts or requiring large data-copying operations ('120 Patent, col. 4:15-28, Fig. 6).
• Technical Importance: This approach provided a more robust and efficient method for processing video signals, particularly in consumer electronics like set-top boxes where source signals and display standards could vary ('120 Patent, col. 1:16-24).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶26).
• Claim 1 requires a receiver comprising:
  • a receiving block for a first analogue video signal;
  • a conversion block to convert the analogue signal to a digital signal;
  • a buffer controller having frame buffers "organized as a two-way list," a decoding frame controller, and a displaying frame controller;
  • a video coder to transform the digital signal into a second analogue signal;
  • a receiver for displaying the second analogue signal; and
  • a processor to control the aforementioned components.
• The complaint notes that its infringement analysis is preliminary and reserves the right to amend its contentions (Compl. ¶27).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as Defendant’s "set top boxes, cable boxes, digital video recorders, and similar devices, and similar systems," including "security video camera DVR recording system(s)" (Compl. ¶26).

Functionality and Market Context

• The complaint alleges these products possess both "analog inputs as well as analog outputs" (Compl. ¶26). The core accused function is the receipt and conversion of analog video signals for display, which the Plaintiff alleges is performed in a manner that infringes the ’120 patent (Compl. ¶26). The complaint does not provide further technical detail regarding the specific operation of the accused products' internal components or software.

IV. Analysis of Infringement Allegations

The complaint states that an "Exemplary infringement analysis" is provided as Exhibit 2, but this exhibit was not attached to the filed complaint (Compl. ¶27). The complaint’s narrative theory alleges that Defendant’s products directly infringe at least claim 1 of the ’120 patent because they constitute receivers that perform all the claimed steps: receiving an analog video signal, converting it to digital, processing it using a buffer controller, and outputting it for display (Compl. ¶26, ¶28). The complaint does not, however, offer specific factual allegations mapping the internal architecture of the accused products to the specific elements of claim 1.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A likely point of dispute is whether the buffering architecture in Defendant's products is "organized as a two-way list" as required by the claim. The definition of this term will be critical to determining infringement.
  • Technical Questions: A key question for discovery will be whether the accused products contain distinct software or hardware modules that function as the claimed "decoding frame controller" and "displaying frame controller." The complaint does not provide evidence to support the existence of these specific, separated functions within the accused products.

V. Key Claim Terms for Construction

• The Term: "frame buffers organized as a two-way list"
• Context and Importance: This term appears to be the central novel element of claim 1, distinguishing the invention from prior art single- or double-buffering systems. The outcome of the infringement analysis may depend heavily on how this term is construed. Practitioners may focus on this term because its construction will determine whether a wide range of modern buffering systems fall within the claim's scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the list as one where each buffer contains pointers to the "next buffer" and the "previous buffer" ('120 Patent, col. 5:5-8). Plaintiff may argue this language covers any data structure that logically links sequential frames, not just a specific implementation.
  • Evidence for a Narrower Interpretation: Claim 3, which depends from claim 2, specifies that "the last element of the two-way list is linked to the first element of the two-way list" ('120 Patent, col. 6:33-35). Defendant may argue that this, along with diagrams like Figure 6, implies that the term "two-way list" should be limited to such a circular or cyclically-linked structure.

VI. Other Allegations

The complaint does not include separate counts for indirect or willful infringement. While the prayer for relief requests a declaration that the case is "exceptional" under 35 U.S.C. § 285, the body of the complaint does not contain the specific factual allegations of pre-suit knowledge or egregious conduct typically required to support a claim for willfulness (Compl. Prayer for Relief ¶C).

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

1. A core issue will be one of claim scope: Can the term "organized as a two-way list," as used in the patent, be construed broadly to cover modern, dynamically allocated video buffer systems, or will it be limited by the patent’s specification to a more rigid, cyclically-linked data structure?

2. A primary evidentiary challenge for the Plaintiff will be to demonstrate a direct correspondence between the claimed elements and the accused technology. Specifically, the case may turn on whether discovery reveals that Verizon's products utilize distinct "decoding" and "displaying" controllers that operate on a buffer structure meeting the court's construction of a "two-way list," as the complaint currently lacks such specific allegations.