DCT

1:25-cv-00486

Thomas Majchrowski & Associates Inc v. Revcom Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00486, W.D. Tex., 04/01/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and has committed alleged acts of infringement in Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s interactive transcript editor infringes patents related to multipurpose media players that synchronize media playback with a corresponding text transcript.
  • Technical Context: The technology enables users to navigate audio or video files by interacting with a time-stamped transcript, a function particularly relevant to the media production and transcription industries.
  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history involving the asserted patents.

Case Timeline

Date Event
2005-02-14 Earliest Priority Date for Asserted Patents
2012-06-19 U.S. Patent No. 8,204,750 Issued
2013-11-05 U.S. Patent No. 8,577,683 Issued
2022-10-11 U.S. Patent No. 11,467,706 Issued
2025-04-01 Complaint Filing Date

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

U.S. Patent No. 8,577,683

  • Patent Identification: U.S. Patent No. 8,577,683, “Multipurpose Media Players,” issued November 5, 2013.
  • The Invention Explained:
    • Problem Addressed: The patent’s background section describes that conventional digital media players were inefficient for navigating the large volumes of video data required for productions like reality television, as they did not allow for navigation between a video file and a corresponding text transcript (Compl. ¶13; ’683 Patent, col. 1:58-62).
    • The Patented Solution: The invention provides a computer-implemented method where a digital medium is played alongside a transcript. The transcript contains "text hyperlinks" associated with "embedded time stamp[s]" (Compl. ¶14). This allows a user to click on words in the transcript, which activates the hyperlink and causes the media player to jump directly to the corresponding time point in the video or audio file (’683 Patent, col. 11:18-52).
    • Technical Importance: This approach provided a more efficient workflow for media professionals to review and edit content by directly linking the textual representation of the content to the media file itself (Compl. ¶13).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 14 of the ’683 Patent (Compl. ¶18).
    • Claim 14 is a computer-implemented method comprising the steps of:
      • Displaying at least a portion of a transcript associated with a digital medium.
      • The transcript has one or more words that are hyperlinked, providing a text hyperlink, and is embedded with a time stamp representing a time code.
      • Receiving an activation of the text hyperlink.
      • Upon receiving the activation, playing the digital medium starting at the time code associated with the embedded time stamp.
    • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,204,750

  • Patent Identification: U.S. Patent No. 8,204,750, “Multipurpose Media Players,” issued June 19, 2012.
  • The Invention Explained:
    • Problem Addressed: Similar to the ’683 Patent, the technology addresses the limitations of traditional media players in navigating large volumes of digital video for media production (Compl. ¶35; ’750 Patent, col. 1:53-57).
    • The Patented Solution: The invention provides a method for a user to generate a description (e.g., a transcript or log) of a digital medium. The method allows the user to insert time stamps into the data file by using a "preselected keystroke command." The system detects this command and inserts a time stamp corresponding to the current point in the playing time of the audio or video, facilitating navigation and logging (’750 Patent, col. 11:6-14).
    • Technical Importance: This solution offered a streamlined method for users to create time-coded logs or transcripts while reviewing media, without needing to manually note and enter time codes (Compl. ¶36).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 32 of the ’750 Patent (Compl. ¶40).
    • Claim 32 is a method for enabling a user to generate a description of a digital medium, comprising the steps of:
      • Receiving a digital medium from a server over a network.
      • Playing the digital medium to the user.
      • Receiving keystrokes from a keyboard, storing them in a data file, and displaying them.
      • Sending the data file to the server over a network.
      • Providing a preselected keystroke command for the user to insert time stamps.
      • Detecting an instance of the preselected keystroke command and inserting a time stamp into the data file that is representative of the playing time when the command was detected.
    • The complaint does not explicitly reserve the right to assert dependent claims.

Multi-Patent Capsule: U.S. Patent No. 11,467,706

  • Patent Identification: U.S. Patent No. 11,467,706, “Multipurpose Media Players,” issued October 11, 2022.
  • Technology Synopsis: This patent addresses the same general problem of navigating digital video for media production (Compl. ¶57; ’706 Patent, col. 2:1-6). The solution involves a "wrapper program" that establishes a graphical user interface "container" which defines two distinct areas: a first area for a media player and a second area for a text editor, enabling synchronized interaction between the two components (Compl. ¶58, ¶66; ’706 Patent, col. 9:46-10:3).
  • Asserted Claims: The complaint asserts independent claim 14 (Compl. ¶62).
  • Accused Features: The complaint accuses Rev's editor of infringing by providing a user interface that displays a media player and a text editor in separate, defined areas of the screen (Compl. ¶66).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is Defendant Rev’s "Accused Software Products," identified as its interactive transcript editor available online (Compl. ¶5, ¶18).

Functionality and Market Context

  • The Accused Software Products provide an interface where a user can play a video or audio file in one part of the screen while viewing and editing a corresponding text transcript in another part (Compl. ¶22-23). The interface displays a video player on the left and a transcript on the right, as shown in a screenshot provided in the complaint (Compl. ¶23, p. 7).
  • The complaint alleges that users can click on words within the transcript to cause the media player to jump to that specific time code in the media file (Compl. ¶24, ¶27). A screenshot with annotations demonstrates a user clicking the word "transcription" in the text, causing the video player to seek to the corresponding point in the video (Compl. ¶24, p. 8).
  • The software allegedly also allows users to add comments, which inserts a time stamp into the transcript, and to use keyboard shortcuts ("hotkeys") such as "CTRL+ALT+C" to perform this function (Compl. ¶49-50).
  • The complaint alleges that Rev markets these features as part of a service that creates "interactive transcripts" for its customers (Compl. ¶29, ¶31).

IV. Analysis of Infringement Allegations

8,577,683 Patent Infringement Allegations

Claim Element (from Independent Claim 14) Alleged Infringing Functionality Complaint Citation Patent Citation
...displaying at least a portion of the transcript associated with the digital medium, one or more words in the series of words being hyperlinked providing a text hyperlink, the transcript embedded with a time stamp representing a time code of the digital medium associated. Rev's editor displays a transcript alongside a video, and the words in the transcript are allegedly embedded with time stamps and act as hyperlinks. ¶24, ¶26 col. 5:2-21
...receiving an activation of the text hyperlink. The Accused Software Products receive a user's click on a word in the transcript, which the complaint alleges is an activation of a text hyperlink. ¶27 col. 5:15-21
...upon receipt of the text hyperlink activation, playing the digital medium starting at the time code associated with the embedded time stamp. After a user clicks on the transcript, the software allegedly plays the video starting from the time code associated with the clicked word. ¶28 col. 5:15-21

8,204,750 Patent Infringement Allegations

Claim Element (from Independent Claim 32) Alleged Infringing Functionality Complaint Citation Patent Citation
...receiving a digital medium from a server over a network connection. Rev's software receives video files from users who upload them or provide a URL to a file on a server. ¶45 col. 3:15-20
...playing the digital medium to the user. The software plays the audio/video file in an embedded media player when the user clicks the play button. ¶46 col. 4:51-54
...receiving keystrokes from a keyboard, storing representations of the received keystrokes in a data file, and displaying the representations of the received keystrokes on a display. The software receives user input from a keyboard to edit transcripts or add comments/notes, stores this information, and displays it. ¶47 col. 8:54-62
...providing a preselected keystroke command to the user to enable the user to insert one or more time stamps into the data file... The software provides a "hotkey" combination of "CTRL+ALT+C" to add a comment, which the complaint alleges inserts a time stamp. A screenshot shows the list of available keyboard shortcuts (Compl. ¶50, p. 17). ¶49, ¶50 col. 6:40-47
...detecting an instance of the preselected keystroke command and inserting a time stamp into the data file, the inserted time stamp being substantially representative of the point in the playing time of the audio stream... When a user adds a comment, the software allegedly detects this command and inserts a time stamp corresponding to the current playback time of the media. ¶49 col. 8:33-41
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the functionality of adding a "comment" in the accused product, which includes a time marker, meets the claim limitation of "inserting a time stamp" as contemplated by the ’750 Patent. The analysis could focus on whether the primary function of the accused feature aligns with the function described in the patent.
    • Technical Questions: For the ’683 Patent, a point of contention may be whether the clickable words in Rev's transcript technically constitute a "text hyperlink" as that term is used in the patent. For the ’750 Patent, a question may arise as to whether a GUI button for adding a comment performs the same function as the claimed "preselected keystroke command."

V. Key Claim Terms for Construction

'683 Patent

  • The Term: "text hyperlink"
  • Context and Importance: The infringement theory for the ’683 Patent hinges on the clickable words in the accused transcript being "text hyperlinks." The definition of this term will be critical to determining whether there is a literal match between the claim language and the accused product's functionality. Practitioners may focus on whether the term requires a specific technical implementation (e.g., an HTML <a> tag) or can be construed more broadly to cover any text that, when activated, causes a predetermined action like navigating a media file.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims themselves do not specify a particular implementation, only a function: a hyperlink that, upon activation, causes the media player to play from an associated time code. The specification notes that "a click on a time-stamp hyperlink in a text data file would then be interpreted as a request to play from the media file" (’683 Patent, col. 5:42-45), focusing on the function rather than the form.
    • Evidence for a Narrower Interpretation: The specification discusses hyperlinks in the context of file links and HTML, which could suggest a more limited, conventional definition of the term (’683 Patent, col. 9:14-16).

'750 Patent

  • The Term: "preselected keystroke command"
  • Context and Importance: Infringement of the final limitation of claim 32 of the ’750 Patent depends on the accused product providing a "preselected keystroke command" to insert time stamps. The complaint identifies the "CTRL+ALT+C" hotkey for adding a comment as meeting this limitation. The construction of this term will determine if it is limited to keyboard-only inputs or if it could also read on GUI-based inputs, such as clicking an "Add Comment" button.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent frequently refers to a more general "preselected user input command" (’750 Patent, col. 8:22-26), which could encompass mouse clicks or other non-keyboard inputs. The specification describes menu selections using a mouse as an alternative to keyboard shortcuts for selecting class members, suggesting "user input" is a broad concept (’750 Patent, col. 6:15-19).
    • Evidence for a Narrower Interpretation: The term itself explicitly recites "keystroke," which typically refers to pressing a key on a keyboard. The specification's examples of such commands include function keys (F1-F12) and combinations using "Ctrl" or "Alt" (’750 Patent, col. 6:40-47), which are all keyboard-based. This could support an interpretation that excludes mouse clicks.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is alleged based on Defendant’s provision of user guides and instructions (e.g., Rev Transcript Editor Guide) that allegedly encourage customers to use the accused software in an infringing manner (Compl. ¶19, ¶41, ¶63). Contributory infringement is alleged on the basis that Defendant provides specialized code that is not a staple article of commerce suitable for substantial non-infringing use (Compl. ¶19, ¶41, ¶63).
  • Willful Infringement: The complaint alleges that Defendant’s infringement was willful. The basis for this allegation is that Defendant had knowledge of the patents at least as of the filing of the complaint (for post-suit willfulness) and that any pre-suit lack of knowledge was due to Defendant "being willfully blind to the possibility that its acts would cause infringement" (Compl. ¶20, ¶42, ¶64).

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

  • A core issue will be one of definitional scope: can patent claims rooted in the technical context of desktop software and file-based media be construed to cover the functionality of a modern, web-based, collaborative editor? Specifically, the court will likely need to determine whether terms like "text hyperlink" (’683 Patent) and "wrapper program" (’706 Patent) read on the accused product's implementation.
  • A key evidentiary question will be one of functional mapping: does the accused product's feature for adding a "comment" perform the specific function of "inserting a time stamp" via a "preselected keystroke command" as required by claim 32 of the ’750 Patent? The case may turn on whether creating a time-stamped annotation is legally and technically equivalent to the patented method of inserting a navigational time stamp directly into a data file.