DCT
3:18-cv-03071
Uniloc 2017 LLC v. LG Electronics USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Uniloc 2017 LLC (Delaware)
- Defendant: LG Electronics U.S.A., Inc. (Delaware) and LG Electronics, Inc. (South Korea)
- Plaintiff’s Counsel: Prince Lobel Tye LLP; Nelson Bumgardner Albritton P.C.
- Case Identification: 3:18-cv-03071, N.D. Tex., 01/07/2019
- Venue Allegations: Venue is based on Defendant LG Electronics U.S.A., Inc. having a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s digital televisions, which include a "Live Zoom" feature, infringe a patent related to dynamically resampling broadcast video signals to fit different display sizes.
- Technical Context: The technology addresses the challenge of displaying video broadcast in one resolution and aspect ratio (e.g., HDTV 16:9) on displays with different characteristics (e.g., SDTV 4:3) without losing important visual information.
- Key Procedural History: The complaint notes that during the patent's prosecution, the applicant distinguished the invention from prior art by emphasizing the capability to resample a decoded image at a variable re-sampling rate defined at the receiving end to adapt a partition of important subject matter, a feature allegedly absent in the cited art.
Case Timeline
| Date | Event |
|---|---|
| 2001-05-17 | ’408 Patent Priority Date |
| 2007-03-13 | ’408 Patent Issue Date |
| 2019-01-07 | Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,190,408 - "TV-RECEIVER, IMAGE DISPLAY APPARATUS, TV-SYSTEM AND METHOD FOR DISPLAYING AN IMAGE," Issued March 13, 2007
The Invention Explained
- Problem Addressed: The patent describes a problem arising with digital television, where broadcast signals of a certain resolution and aspect ratio (e.g., 16:9 HDTV) must be displayed on screens with different characteristics (’408 Patent, col. 1:17-26). Prior art methods relied on a fixed resampling rate dictated by the broadcaster, which could cause important parts of the image to be cropped or lose detail when down-sampled (’408 Patent, col. 1:31-46; Compl. ¶11). Existing "pan and scan" technology could identify the location of an important area but was not capable of identifying its size to selectively resample the image in response (Compl. ¶12).
- The Patented Solution: The invention is a receiver that processes an incoming TV signal containing both image data and control data. Crucially, this control data defines not only the location of a "partition of important subject matter" but also its size (’408 Patent, col. 2:21-25). The receiver uses a resampling unit that operates at a variable rate, defined at the receiving end, to extract and adapt the important partition to fit the local display screen according to a specific criterion, thereby preserving details that might otherwise be lost (’408 Patent, col. 2:25-35; Compl. ¶13). The system can also be manipulated by the user to adapt the image to their viewing angle or visual acuity (’408 Patent, col. 4:30-43).
- Technical Importance: This approach provided a more intelligent and flexible method for adapting video content to various display types, ensuring that the most critical visual information was preserved regardless of the end-user's screen size (Compl. ¶14).
Key Claims at a Glance
- The complaint asserts infringement of independent claim 1 (Compl. ¶23).
- Claim 1 Elements:
- A receiver comprising: a decoder for receiving and decoding a signal representing an image and control data wherein the control data defines a vector indicating a location of a partition of important subject matter within said image;
- the control data further defining the size of said partition showing said important subject matter; and
- a re-sampling unit for extracting a re-sampled image to be displayed on the screen of a display device from said decoded image by re-sampling said decoded image at a variable re-sampling rate defined at the receiving end such that the size of the partition of important subject matter in the re-sampled image is adapted according to a criterion.
III. The Accused Instrumentality
Product Identification
- A wide range of LG digital televisions, including numerous models from its OLED, SJ, and UH series (collectively, "Accused Infringing Devices") (Compl. ¶21).
Functionality and Market Context
- The complaint alleges that the Accused Infringing Devices implement the Advanced Television Systems Committee (“ATSC”) standard and include a "zoom picture functionality" (Compl. ¶21). Specifically, the "Live Zoom function" is identified as allowing a viewer to "enlarge a portion of the image for better viewing" by changing the size of the image derived from decoded TV signals (Compl. ¶22). The complaint does not provide further technical detail on how the Live Zoom function operates internally. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’408 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a decoder for receiving and decoding a signal representing an image and control data wherein the control data defines a vector indicating a location of a partition of important subject matter within said image | The Accused Infringing Devices are digital televisions that receive and decode broadcast TV signals in digital format, such as DTV signals. | ¶22 | col. 7:13-17 |
| the control data further defining the size of said partition showing said important subject matter | The complaint alleges the devices include a receiver that has every limitation of claim 1, which requires control data defining the size of the partition. | ¶23 | col. 7:18-19 |
| a re-sampling unit for extracting a re-sampled image to be displayed...by re-sampling said decoded image at a variable re-sampling rate defined at the receiving end | The "Live Zoom function" allegedly allows a viewer to enlarge a portion of the image, thereby changing its size for display. | ¶22 | col. 7:20-25 |
| such that the size of the partition of important subject matter in the re-sampled image is adapted according to a criterion | The viewer's use of the Live Zoom function to "enlarge a portion of the image for better viewing" is alleged to be the adaptation of the image according to a criterion. | ¶22 | col. 7:25-28 |
- Identified Points of Contention:
- Scope Questions: A central question may be the interpretation of "control data." The patent describes this data as being part of the broadcast signal sent from a broadcaster (’408 Patent, col. 2:30-32). The complaint accuses the user-driven "Live Zoom" feature (Compl. ¶22). The litigation may therefore turn on whether "control data" must originate from the broadcaster as part of the signal, or if it can be generated by the user at the receiver.
- Technical Questions: The complaint does not specify what technical information serves as the claimed "control data" that defines the "size" of the partition in the accused LG televisions. It is unclear if the plaintiff's theory is that this data is embedded in the broadcast signal and used by the Live Zoom feature, or if the user's manual selection of a zoom area itself constitutes the creation of this "control data" at the receiver.
V. Key Claim Terms for Construction
The Term: "control data"
Context and Importance: The definition of this term appears critical. If "control data" is construed to mean data that must be embedded within the received broadcast signal by the broadcaster, the infringement case may depend on evidence that LG's TVs process such specific data. If construed more broadly to include data generated by a user's interaction with the device (e.g., selecting a zoom region), it may better align with the complaint's focus on the "Live Zoom" feature.
Intrinsic Evidence for Interpretation:
- Evidence for a Narrower Interpretation: The specification repeatedly links the control data to the broadcaster. It states, "the control data in particular define a fixed re-sampling rate for re-sampling the image at the receiving end" in prior art systems (’408 Patent, col. 1:31-34) and that the invention's "control data" is "broadcasted together with image data" (’408 Patent, col. 1:60-64).
- Evidence for a Broader Interpretation: The patent also contemplates user manipulation at the receiving end. The specification notes that a "user may provide a control signal" to the resampling unit "for manipulating the control data" to achieve an appropriate displayed image (’408 Patent, col. 4:59-65). This suggests that user input can at least modify or influence the data used for resampling.
The Term: "variable re-sampling rate defined at the receiving end"
Context and Importance: This term distinguishes the invention from prior art that used a fixed rate defined by the broadcaster (Compl. ¶18). The dispute will likely focus on whether the accused "Live Zoom" feature's operation constitutes resampling at a "variable" rate "defined" at the receiver in the manner claimed.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification explicitly states that the resampling rate can be "manipulated by a user watching the re-sampled image on the screen" to adapt it to the "user's individual viewing angle" or "visual acuity" (’408 Patent, col. 4:30-43). This language may support an argument that a user-controlled zoom function falls within the claim's scope.
- Evidence for a Narrower Interpretation: The primary context for the variable rate is adapting a predefined partition (based on the "control data") to a screen of a different size (’408 Patent, col. 4:10-17). An argument could be made that the rate is "defined" by an automatic calculation based on partition size and screen size, with user input being an optional manipulation, rather than the primary means of definition.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that LG induces infringement by providing "training videos, demonstrations, brochures, manuals, installation and user guides" that instruct customers on how to use the accused features (Compl. ¶27-28). It further alleges that LG knows these instructions cause infringement (Compl. ¶27).
- Willful Infringement: The willfulness allegation is based on post-suit knowledge. The complaint alleges that LG has been on notice of the ’408 Patent and its infringement since, at the latest, the service of the Original Complaint in this action (Compl. ¶24, ¶31).
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to hinge on two central questions of claim scope and technical evidence:
A core issue will be one of definitional scope: can the term “control data,” which the patent repeatedly describes as originating from the broadcaster, be construed to cover data generated by a user's real-time interaction with a "Live Zoom" feature at the receiver?
A key evidentiary question will be one of technical operation: does the accused "Live Zoom" function operate by processing "control data" that defines a "partition size" as required by the claim, or does it operate on a different technical principle, such as a simple magnification of a user-selected pixel area, that may not map to the specific claim elements? The complaint's lack of technical detail on this point makes it a primary open question for discovery.