DCT
3:25-cv-02602
Control Sync Systems LLC v. Vizio Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Control Sync Systems, LLC (Wyoming)
- Defendant: Vizio, Inc. (Delaware)
- Plaintiff’s Counsel: DNL Zito
- Case Identification: 3:25-cv-02602, N.D. Tex., 09/25/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas because Defendant Vizio, Inc. maintains a regular and established place of business in Dallas, Texas, and has allegedly committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s televisions implementing the HDMI Consumer Electronics Control (CEC) standard infringe a patent related to a system for synchronously controlling a display device and a connected playback device.
- Technical Context: The technology at issue addresses the unified control of separate home entertainment components, a feature designed to simplify the user experience by allowing a single remote to operate multiple devices connected via HDMI.
- Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2005-07-29 | U.S. Patent No. 7,812,889 Priority Date |
| 2010-10-12 | U.S. Patent No. 7,812,889 Issues |
| 2025-09-25 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,812,889 - "CONTROL SYSTEM FOR SYNCHRONOUSLY CONTROLLING DISPLAY DEVICE AND PLAY DEVICE"
The Invention Explained
- Problem Addressed: The patent's background describes the user "annoyance" and "troublesome steps" associated with using separate remote controls for a multi-device media system, such as a projector ("display device") and a DVD player ("play device"), where parameters like volume must be adjusted independently on each device (’889 Patent, col. 1:40-54).
- The Patented Solution: The invention discloses a control system where both the display device and the play device contain an on-screen display (OSD) system and an "encoding/decoding module" connected by a "bus." When a user sends a command via a remote to one device, the signal is encoded into a data signal, transmitted over the bus to the other device, and then decoded, enabling the "video and audio parameters of the display device and play device [to be] controlled synchronously" (’889 Patent, col. 2:45-48; Fig. 2).
- Technical Importance: The described solution aims to eliminate the need for multiple remote controls by creating a communication pathway between devices for synchronized command and control, thereby improving efficiency and user convenience in home entertainment setups (’889 Patent, col. 1:55-58).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2 and 10 (Compl. ¶14).
- Independent Claim 1 requires:
- An on screen display (OSD) system within a display device for receiving a first OSD signal from an external source.
- An encoding/decoding module within the display device for encoding the first OSD signal into a first data signal.
- A bus connected to the display device for sending the first data signal to a play device.
- The system operates such that the display device receives the first OSD signal to control its own parameters, and the play device decodes the first data signal received from the bus to control its parameters.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Vizio televisions that feature the Consumer Electronic Control ("CEC") standard, with the V4K43M-0801 model cited as an exemplary device (Compl. ¶14). The system operates in conjunction with connected "play devices" such as a VIZIO soundbar (Compl. ¶15, ¶17).
Functionality and Market Context
- The complaint alleges that the accused TVs utilize HDMI-CEC technology to allow a single remote control to operate connected multimedia devices (Compl. ¶15). This enables the TV's remote to send commands, such as volume adjustments, over an HDMI cable to a connected device like a soundbar, thereby controlling the soundbar's functions (Compl. ¶17). A screenshot from Vizio's support website is provided to show the company's description of CEC as a feature that "provides automatic control of HDMI devices using the remote" (Compl. p. 6).
IV. Analysis of Infringement Allegations
U.S. Patent No. 7,812,889 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an on screen display (OSD) system of the display device disposed in the display device for receiving a first OSD signal from external of the display device; | The Vizio TV ("display device") receives playback and volume signals ("first OSD signal") from the TV's remote control ("external of the display device") (Compl. p. 12). | ¶16 | col. 4:20-27 |
| an encoding/decoding module of the display device disposed in the display device for encoding the first OSD signal received by the OSD system into a first data signal; | The complaint alleges the TV includes a module that encodes the received remote command into an HDMI-CEC data signal ("first data signal") to be sent to the connected device. | ¶17 | col. 4:28-31 |
| a bus connected to the display device for sending the first data signal out of the display device and transmitting the first data signal to the play device; | The HDMI cable connecting the TV to an external device (e.g., soundbar) is alleged to function as the "bus" for transmitting the HDMI-CEC control commands (Compl. p. 20). | ¶18 | col. 4:41-45 |
| wherein...the play device is decoding the first data signal received from the bus to control the video and audio parameters of the play device. | The connected multimedia device (e.g., soundbar) allegedly decodes the received HDMI-CEC command to control its own volume or playback parameters. | ¶19 | col. 4:58-64 |
- Identified Points of Contention:
- Scope Questions: A central issue may be whether the term "bus", as used in the patent, can be construed to read on a standardized, multi-purpose connection like an HDMI cable. The complaint provides a diagram from an HDMI standards document illustrating the "Deck Control feature," which depicts communications between a TV and a Playback Device, to support its theory of operation (Compl. p. 10). A further question is whether the patent's claims cover the widely adopted HDMI-CEC industry standard itself.
- Technical Questions: The complaint alleges the existence of an "encoding/decoding module" based on the TV's ability to receive a remote command and transmit a corresponding HDMI-CEC signal, stating that the existence of such a module "would be apparent for a person having ordinary skills in the art" (Compl. ¶17). The case may turn on whether the accused product's standard signal processing architecture contains a component that meets the specific "encoding/decoding module" limitation as it is construed by the court.
V. Key Claim Terms for Construction
The Term: "encoding/decoding module"
- Context and Importance: This term is critical because its presence in the accused device is not explicitly shown but is inferred from the device's overall function (Compl. ¶17). The outcome of the case may depend on whether the standard processing capabilities of Vizio's televisions meet the construed definition of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes this element functionally and depicts it as a simple block in a high-level system diagram, which may support an interpretation where any component that performs the function of converting an OSD signal to a data signal for transmission qualifies (’889 Patent, Fig. 2, item 42).
- Evidence for a Narrower Interpretation: The flow charts in the patent detail specific steps of "encoding the first OSD signal into the first data signal," which could be argued to require a more specific, discrete process than general signal conversion inherent in any modern television chipset (’889 Patent, Fig. 4, step S34).
The Term: "bus"
- Context and Importance: The infringement allegation hinges on equating an HDMI cable with the claimed "bus" (Compl. ¶18). Practitioners may focus on this term to determine if the claim is limited to a proprietary or internal communication channel versus a standardized, external interface.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the bus functionally as being "connected to both the display device and the play device" and used for "sending the first data signal," language which does not appear to exclude an external cable like HDMI (’889 Patent, col. 4:41-43).
- Evidence for a Narrower Interpretation: The patent's block diagram shows the "Bus" as a direct connection between the "encoding/decoding" modules of the two devices, which a party could argue suggests a dedicated data link rather than the complex, multi-layered protocol of an HDMI connection (’889 Patent, Fig. 2, item 44).
VI. Other Allegations
- Indirect Infringement: While not pleaded as a separate count, the prayer for relief requests a judgment of indirect infringement (Compl. p. 26). The complaint provides a factual basis that may support such a claim by alleging that Vizio provides instructions and documentation encouraging users to connect and control external devices using the accused HDMI-CEC functionality (Compl. ¶15, pp. 7, 21-22).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the patent's relatively generic claim terms, such as "encoding/decoding module" and "bus," be construed broadly enough to encompass the standardized components and protocols that implement the industry-wide HDMI-CEC standard?
- A key evidentiary question will be one of technical implementation: what evidence will be presented to demonstrate that Vizio's products contain a distinct "encoding/decoding module" and perform the claimed "encoding" step, as opposed to merely executing the inherent signal processing functions required by the HDMI-CEC protocol?