Noblewood IP LLC v. McClatchy Co LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Noblewood IP LLC (Texas)
  • Defendant: The McClatchy Company, LLC (Delaware)
  • Plaintiff’s Counsel: PRA Law; Chong Law Firm PA
• Case Identification: 3:22-cv-01421, N.D. Tex., 06/30/2022
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of patent infringement in the district and maintains a regular and established place of business there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a method for streaming media files over a distributed information system.
• Technical Context: The technology addresses methods for initiating media streaming by intercepting a standard file download request and returning a "metafile" that contains streaming instructions, rather than returning the media file itself.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events relevant to the patent-in-suit.

Case Timeline

Date	Event
2002-10-18	U.S. Patent No. 7,941,553 Priority Date
2003-07-22	U.S. Patent No. 7941553 Application Filing Date
2011-05-10	U.S. Patent No. 7,941,553 Issue Date
2022-06-30	Complaint Filing Date

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

• Patent Identification: U.S. Patent No. 7,941,553, "Method and device for streaming a media file over a distributed information system," issued May 10, 2011. (Compl. ¶7-8).

U.S. Patent No. 7,941,553 - Method and device for streaming a media file over a distributed information system

The Invention Explained

• Problem Addressed: The patent's background section describes the challenges of delivering streaming media using standard web protocols like HTTP. Direct downloads of large media files force users to wait, while early streaming technologies required proprietary, player-specific "metadata" files that were cumbersome to create and maintain, especially for large media libraries. ('553 Patent, col. 1:15-35; col. 2:36-47).
• The Patented Solution: The invention proposes a server-side method that simplifies media streaming. When a user on a client computer makes a standard request to download a media file (e.g., by clicking a link to video.mpg), the server intercepts this request. Instead of sending the large media file, the server generates and returns a small "metafile." This metafile contains information about the media's location and format, which a media player application on the client computer can use to immediately connect to a streaming server and begin playback. ('553 Patent, Abstract; col. 4:38-44).
• Technical Importance: This approach allows web pages to use simple, direct links to media files, as if for a standard download, while transparently enabling a more advanced streaming experience. It decouples the web page design from the underlying streaming technology, simplifying content management and allowing for more flexible server infrastructure. ('553 Patent, col. 4:51-65).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring only to "the Exemplary '533 Patent Claims" (Compl. ¶11). The patent contains three independent claims: 1, 8, and 15. The elements of independent claim 1 are representative:
  • receiving a request for a particular media file from a client computer running a browser application;
  • providing a metafile, wherein said metafile contains information about the identification, location and format of the media file;
  • returning said metafile back to said client computer;
  • wherein the step of receiving a request comprises:
    • intercepting a download request for the actual media file; and
    • reinterpreting said download request into a request for receiving a corresponding metafile.
• The complaint states that "numerous other devices" may infringe and does not limit its allegations to any specific claims, preserving the right to assert others, including dependent claims. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶11). These products are allegedly detailed in claim charts attached as Exhibit 2 to the complaint. (Compl. ¶13).

Functionality and Market Context

• As Exhibit 2 was not filed with the publicly available complaint, the specific products and their accused functionalities cannot be identified. The complaint makes only a conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '533 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim charts in an exhibit that was not provided with the filing (Compl. ¶13-14). The complaint’s narrative theory states that the accused products "satisfy all elements of the Exemplary '533 Patent Claims" (Compl. ¶13). Without access to the referenced claim charts, a detailed, element-by-element analysis of the infringement allegations is not possible based on the provided documents.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Based on the language of the '533 Patent and the general nature of the dispute, the infringement analysis may raise the following questions:
  • Scope Questions: Does the accused system's architecture meet the "intercepting" and "reinterpreting" limitations of claim 1? A central dispute may be whether a user's request is for an "actual media file" that is then intercepted, or whether the initial web link points to a script or application endpoint that is already designed to generate streaming metadata, potentially bypassing the claimed method.
  • Technical Questions: What evidence demonstrates that the accused system functions as claimed? For infringement to be found, the evidence will need to show that a request for a media file is captured and transformed into a request for a metafile, as opposed to a system that uses a different server-side logic to initiate streaming.

V. Key Claim Terms for Construction

The Term: "intercepting a download request for the actual media file"

• Context and Importance: This phrase appears to be the central novel element of the asserted method. The outcome of the case may depend on whether the Defendant's system architecture can be characterized as performing an "interception" of a standard file request, or if it uses a non-infringing design.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the invention's purpose is to allow web pages "to reference the media files directly instead of referencing an active page that is parameterised to target the media file" ('553 Patent, col. 4:2-5). Plaintiff may argue this supports a broad construction covering any system that receives a request that looks like a direct media file link and returns streaming instructions.
  • Evidence for a Narrower Interpretation: The patent describes implementation via a "redirector plug-in feature" on a web server ('553 Patent, col. 6:10-12). Defendant may argue this disclosure limits "intercepting" to a specific technical act of capturing and redirecting requests that would otherwise be handled by the server's standard file-delivery mechanism.

The Term: "reinterpreting said download request"

• Context and Importance: This term works in conjunction with "intercepting" and is critical to defining the infringing act. Practitioners may focus on this term because its definition will clarify what kind of server-side processing is required to infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states the server "reinterprets the download request into a request for receiving a corresponding metafile" ('553 Patent, col. 4:39-42). This could be read broadly to cover any server logic that treats a request for a media file as a command to generate and return a metafile.
  • Evidence for a Narrower Interpretation: A party could argue that "reinterpreting" requires a formal transformation of the request itself within the server, rather than merely following a conditional logic path that results in a different resource being served. The context of an "Opaque Streaming Meta Data Server" that handles standard HTTP requests may be cited to support a more specific technical meaning. ('553 Patent, col. 4:10-13).

VI. Other Allegations

The complaint does not contain an explicit allegation of willful or indirect infringement. In its prayer for relief, it requests that the court declare the case "exceptional" under 35 U.S.C. § 285, which could entitle Plaintiff to an award of attorneys' fees, but it does not plead facts supporting pre- or post-suit knowledge of the patent. (Compl., Prayer for Relief ¶E.i.).

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

• A core issue will be one of architectural functionality: does the Defendant's system operate by "intercepting" a direct request for a media file and "reinterpreting" it to serve a metafile, as required by the patent's claims? Or does it employ a different, more conventional architecture where web links point directly to a script or application endpoint that generates streaming instructions without performing the claimed interception and reinterpretation steps?
• A key evidentiary question will be what the technical evidence, once produced in discovery, reveals about the Defendant's server-side processes. Given the complaint's reliance on an unfiled exhibit, the viability of the infringement claim will depend entirely on whether discovery uncovers facts showing that the accused system's operation maps onto the specific limitations of the asserted claims.