DCT
6:23-cv-00058
Sockeye Licensing TX LLC v. Best Buy Co Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sockeye Licensing TX LLC (Texas)
- Defendant: Best Buy Co., Inc. (Minnesota)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 6:23-cv-00058, W.D. Tex., 01/30/2023
- Venue Allegations: Venue is alleged based on Defendant maintaining an established place of business in the Western District of Texas and committing alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant indirectly infringes a patent related to using a mobile phone to control and stream media to an external display device by selling certain Philips-branded wireless projectors.
- Technical Context: The technology concerns using a mobile communications device, such as a smartphone, as the central processing and control hub for a larger, desktop-like media environment.
- Key Procedural History: The complaint notes that during prosecution of the asserted patent and its parent, the inventor distinguished the invention from "conventional tethering" and prior art that required content to be fully downloaded before viewing. It also states that the Patent Trial and Appeal Board (PTAB) declined to institute an Inter Partes Review (IPR) against a claim of the parent patent and that the examiner considered these IPRs before allowing the patent-in-suit to issue. Plaintiff alleges Defendant had notice of the patent-in-suit from a prior complaint filed in October 2022.
Case Timeline
| Date | Event |
|---|---|
| 2006-09-15 | Earliest Priority Date (’981 Patent) |
| 2017-01-17 | Issue Date (U.S. Patent No. 9,547,981) |
| 2022-10-06 | Prior complaint filed against Best Buy alleging '981 infringement |
| 2023-01-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,547,981 - "System, Method and Apparatus for Using a Wireless Device to Control Other Devices," issued January 17, 2017
The Invention Explained
- Problem Addressed: The patent addresses the ergonomic and practical limitations of consuming media and using complex applications on the small, low-resolution screens of early mobile devices ('981 Patent, col. 2:28-34). The patent contends that prior art either treated the mobile device as a self-contained media player or, in limited cases, as a simple modem (i.e., "conventional tethering") for a computer, rather than as the primary control device for a full-featured media environment ('981 Patent, col. 2:17-27; Compl. ¶11).
- The Patented Solution: The invention proposes a new paradigm where a wireless cell phone acts as a "thin client" or a central hub ('981 Patent, col. 2:39-44). The phone connects to and controls full-sized peripheral devices, such as a desktop monitor, keyboard, and speakers, to create a "desktop computing environment" ('981 Patent, col. 1:26-36). This allows a user to leverage the phone's internet connectivity to access and interact with browser-based applications and streaming media, but with the user experience of a full-sized computer system ('981 Patent, Abstract; Fig. 1).
- Technical Importance: The approach sought to shift the mobile device from being merely an endpoint for content consumption to the central controller of a more expansive and ergonomic user experience, effectively turning any compatible set of peripherals into a temporary, phone-powered workstation (Compl. ¶¶9, 11).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 5, 15, and 16 (Compl. ¶27).
- Independent Claim 1 contains the following essential elements:
- Electrically coupling a display device suitable for a media center environment with a mobile communications device.
- Causing a first graphical user interface (GUI) to be displayed on the display device, which conveys information about downloadable movies or videos.
- Receiving entertainment selection commands on the mobile device based on user interaction with the first GUI.
- The mobile device receiving the selected movie or video from a server.
- Transmitting at least some of the movie or video from the mobile device to the display device simultaneously while at least some of it is being downloaded from the server to the mobile device.
- The electrical coupling must support this transmission when the mobile device is a distance away from the display device.
III. The Accused Instrumentality
Product Identification
The "Projector Infringing Products," which include Philips-branded projectors from the "NeoPix, PicoPix, and Screeneo Collections" that are sold by Defendant (Compl. ¶¶25-26). One specific model identified is the "Philips NeoPix Prime 2" (Compl. ¶26).
Functionality and Market Context
The complaint alleges that the accused products' infringing functionality is their ability to perform "screen mirroring or casting" (Compl. ¶27.a). Specifically, a user can select a video (e.g., on YouTube) on their smartphone, and the video is then wirelessly cast from the smartphone to the projector for display on a surface (Compl. ¶27). The complaint references Defendant's product description for the NeoPix Prime Two, which states an end user "can also stream multimedia content from your mobile devices via Wi-Fi screen mirroring" (Compl. ¶28). The complaint alleges Defendant promotes these features to its customers (Compl. ¶30).
IV. Analysis of Infringement Allegations
'981 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) electrically coupling for consumer electronic entertainment purposes a display device suitable for use in a media center environment with a mobile communications device that does not form a part of the media center environment | A user's smartphone is wirelessly coupled to the accused projector's casting circuitry. The projector lens and the surface it projects upon allegedly form the "display device." | ¶27.b | col. 15:43-48 |
| (b) causing a first graphic user interface to be displayed on the display device that conveys information to a viewer...about movies or videos that are individually downloadable from a server | A GUI, such as the YouTube interface, is cast from the smartphone to the projector and displayed on the projection surface, allowing the user to browse and select videos. | ¶27.c | col. 15:49-54 |
| (c) receiving entertainment selection commands by the mobile communications device to allow a particular one of the movies or videos to be selected for downloading from the server based on visual feedback the viewer receives...on the display device | The user selects a video to watch by entering commands into the smartphone while viewing the GUI that is projected onto the surface. | ¶27.d | col. 15:55-61 |
| (d) receiving by the mobile communications device of the particular movie or video that is sent to it from the server | The user's selection on the smartphone signals the server (e.g., YouTube's server) to send the selected video to the smartphone. | ¶27.e | col. 15:62-66 |
| (e) transmitting by the mobile communications device of at least some of the particular movie or video to the display device for display thereon simultaneously while at least some of the particular movie or video is being downloaded from the server... | The selected video is "streamed from the Server to the casting circuitry of each Projector Infringing Product via the user's smartphone or tablet." This streaming allegedly meets the "simultaneously" requirement. | ¶27.f | col. 16:1-5 |
| (f) wherein the electrical coupling...allows the particular movie or video to be sent there between when the mobile communications device is located a distance away from the display device at which a person watches a video at home | The wireless connection between the smartphone and the projector is allegedly "sufficiently strong and robust" to allow operation from "10-15 feet away." | ¶27.g | col. 16:6-11 |
Identified Points of Contention
- Scope Question: A central question may be whether a projector combined with the surface upon which it projects an image constitutes a "display device suitable for use in a media center environment" as recited in the claim. The patent specification appears to describe more traditional devices like a "desktop computer monitor" or "television" ('981 Patent, col. 4:7-10), raising the question of whether the claim language can be construed to cover the accused projector configuration.
- Technical Question: The complaint asserts that the products' "streaming" functionality satisfies the "simultaneously" transmitting and downloading limitation (Compl. ¶27.f), a feature the inventor allegedly relied upon to overcome prior art (Compl. ¶12). An evidentiary question will be whether the accused products' "Wi-Fi screen mirroring" (Compl. ¶28) technically operates by having the mobile device act as a pass-through—simultaneously downloading from a server and transmitting to the projector—or if the phone merely instructs the projector to pull the stream directly from the server, which may not meet the claim's specific data path requirement.
V. Key Claim Terms for Construction
The Term: "display device suitable for use in a media center environment"
- Context and Importance: The infringement theory depends on construing this term to cover a projector and the surface it projects onto. The defendant may argue for a narrower definition limited to self-contained screen devices, which could challenge the applicability of the claim to the accused products.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses the general term "display device," and the patent's summary describes connecting to a "full-sized desktop monitor or other digital display device" ('981 Patent, col. 3:21-22), which could be argued to encompass any technology that creates a large digital display.
- Evidence for a Narrower Interpretation: The specification repeatedly provides examples such as a "desktop computer monitor" and "television" ('981 Patent, col. 4:8-10, col. 16:29-30), which may suggest the invention was conceived for and limited to integrated screen-based devices.
The Term: "transmitting ... simultaneously while ... downloading"
- Context and Importance: This limitation was allegedly key to distinguishing the invention from prior art during prosecution (Compl. ¶12). Practitioners may focus on this term because its construction will determine whether generic "streaming" or "casting" infringes, or if a specific technical showing of the data path through the mobile device is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent discusses accessing "streaming video" generally ('981 Patent, col. 2:55), which could support an argument that the term encompasses the common understanding of streaming, where content plays as it downloads.
- Evidence for a Narrower Interpretation: The claim language is specific: "transmitting by the mobile communications device ... while ... downloading from the server to the mobile communications device." This suggests a specific architecture where the mobile device is an active intermediary. An argument could be made that this requires proof that data packets are flowing from the server, through the mobile device's memory/processor, and then out to the display device, as opposed to the mobile device simply initiating a direct connection between the display and the server.
VI. Other Allegations
- Indirect Infringement: The complaint exclusively pleads indirect infringement, specifically active inducement. It alleges that Defendant encourages its customers to perform the patented method by marketing and describing the infringing functionality, such as providing instructions on how to "stream multimedia content from your mobile devices via Wi-Fi screen mirroring" (Compl. ¶¶28, 30).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the '981 patent since at least October 6, 2022, the filing date of a previous lawsuit involving the same patent and defendant (Compl. ¶31). This forms the basis for alleged post-suit willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the term "display device," which the patent specification exemplifies with monitors and televisions, be construed to cover the combination of a projector and the wall or screen it projects onto, as alleged in the complaint? The outcome of this claim construction question may be dispositive for infringement.
- A second key question will be one of technical and functional proof: Does the accused "Wi-Fi screen mirroring" function operate in a manner that meets the claim requirement for the mobile device to be "simultaneously" downloading content from a server and transmitting that same content to the display? The resolution will likely depend on evidence detailing the specific data flow architecture of the accused systems, particularly since this limitation was highlighted during the patent's prosecution.