Ak Meeting IP LLC v. Zoom Communications Video Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: AK Meeting IP, LLC (Texas)
  • Defendant: Zoom Communications Video, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 6:23-cv-00062, W.D. Tex., 02/01/2023
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas based on Defendant’s advertising of job openings in Austin, its regular and established places of business in the district, and its business conducted through the Zoom Certified Partner Program.
• Core Dispute: Plaintiff alleges that Defendant’s multi-party video communication products and services infringe two patents related to sharing content and displaying pointers in a computer network communication.
• Technical Context: The technology concerns client-server architectures for real-time collaboration, aiming to reduce latency and improve the sense of "presence" among participants in an online meeting.
• Key Procedural History: U.S. Patent No. 10,963,124, one of the two patents-in-suit, was the subject of an Inter Partes Review (IPR) proceeding, IPR2022-01142. On March 20, 2024, a certificate was issued cancelling all asserted claims (1-14) of the patent. This post-complaint event may render the infringement allegations regarding this patent moot.

Case Timeline

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

U.S. Patent No. 8,627,211 - "Method, apparatus, system, medium, and signals for supporting pointer display in a multiple-party communication"

• Patent Identification: U.S. Patent No. 8,627,211, "Method, apparatus, system, medium, and signals for supporting pointer display in a multiple-party communication," issued January 7, 2014.

The Invention Explained

• Problem Addressed: The patent’s background section describes that online communications suffer from delays in transmitting information between parties, which reduces the feeling of "presence" of other participants ('211 Patent, col. 1:44-51).
• The Patented Solution: The invention provides a system where a user's local mouse movement generates a "cursor message" that is sent to a server. The server then transmits a corresponding "pointer message" back to all participants. This allows each user to see a secondary "pointer" representing the cursor movements of other users on their own screen, distinct from their own primary cursor, thereby showing where others are focused. ('211 Patent, Abstract; col. 2:1-13).
• Technical Importance: This approach aims to make users aware of other participants' actions in real-time, providing a feeling of a "real multiple-party presence" in the online communication ('211 Patent, col. 2:14-22).

Key Claims at a Glance

• The complaint asserts claims 1-150 (Compl. ¶9). Independent claim 1 is representative and includes the following essential elements:
  • A method for supporting multiple-party communications on a client computer in communication with a server.
  • Transmitting a first cursor message to the server to elicit a first pointer message.
  • The cursor message represents a change in position of a first cursor associated with the client computer.
  • Receiving the first pointer message from the server.
  • The pointer message represents the change in the position of the first cursor.
  • Causing a corresponding change in a position of a first pointer associated with the first cursor and displayed on a display area, in response to the pointer message.

U.S. Patent No. 10,963,124 - "Sharing Content Produced By A Plurality Of Client Computers In Communication With A Server"

• Patent Identification: U.S. Patent No. 10,963,124, "Sharing Content Produced By A Plurality Of Client Computers In Communication With A Server," issued March 30, 2021.

The Invention Explained

• Problem Addressed: The patent identifies a need for communication systems that "improve a user's experience" in multi-party network communications where delays can reduce the sense of shared presence ('124 Patent, col. 2:2-10).
• The Patented Solution: The invention discloses a method where multiple client computers display "common content." One user generates input (e.g., typing, drawing) that defines "shared content." This input is sent as messages to a server, which then transmits output messages to all clients. In response, each client computer displays the "shared content" over the "common content," creating a synchronized, collaborative workspace for all participants. ('124 Patent, Abstract; Fig. 1).
• Technical Importance: The system facilitates online collaboration by allowing multiple users to share a common view of a displayed page and post comments or other content that is transmitted to all users ('124 Patent, col. 1:59-67).

Key Claims at a Glance

• The complaint asserts claims 1-14 (Compl. ¶16). Independent claim 1 is representative and includes the following essential elements:
  • A method on a plurality of client computers, each displaying common content.
  • Generating messages representing user input at one client computer, with the input defining content to be shared.
  • Causing the client computer to transmit the messages to a server to elicit output messages.
  • The output messages include information defining the content to be shared.
  • In response to receiving the output messages at each client, displaying the shared content over the common content on their respective display areas.
• All asserted claims (1-14) were cancelled in IPR2022-01142 ('124 Patent K1, p. 2).

III. The Accused Instrumentality

• Product Identification: The complaint accuses Defendant’s "systems, products, and services" that perform "multiple-party communications conducted between client computers in a computer network" (Compl. ¶¶8-9, 15-16). This appears to target the core functionality of the Zoom video conferencing platform.
• Functionality and Market Context: The complaint alleges that Defendant "maintains, operates, and administers" these systems which allow for multi-party communications over a network (Compl. ¶¶9, 16). The complaint frames these as commercially significant products from which Defendant derives monetary benefit (Compl. ¶¶9, 16).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references external claim chart exhibits (Exhibits B and D) that were not provided with the filing (Compl. ¶¶10, 17). The complaint’s narrative infringement allegations are high-level and state that Defendant’s systems and services perform methods that infringe the asserted claims (Compl. ¶¶9, 16). Without the specific mappings of the claim charts, a detailed element-by-element analysis is not possible.

• ’211 Patent Infringement Allegations: The complaint alleges that Defendant’s products and services infringe by supporting multi-party communications that involve pointer displays (Compl. ¶¶8-9). A central question may be whether Zoom’s functionality for showing a user’s mouse pointer to other participants meets the specific claim requirements of generating a "cursor message" to elicit a distinct "pointer message" from a server, and then displaying a "pointer" that is separate from the user's local "cursor."
• ’124 Patent Infringement Allegations: The complaint alleges that Defendant’s products and services infringe by enabling the sharing of content among multiple client computers via a server (Compl. ¶¶15-16). Infringement allegations against the ’124 patent may be moot given the cancellation of all asserted claims in IPR2022-01142.

V. Key Claim Terms for Construction

For the ’211 Patent:

• The Term: "cursor" versus "pointer"
• Context and Importance: Claim 1 requires transmitting a "cursor message" representing a "cursor" to elicit a "pointer message" that causes a "pointer" to be displayed. The distinction between these two terms is fundamental to the claimed invention. The infringement analysis may depend on whether Zoom's system maintains such a technical distinction or uses a single, undifferentiated data stream for cursor/pointer location.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The terms are used in the context of a "display area" on a "client computer," which could suggest they apply broadly to any graphical representation of a user's focus on a screen ('211 Patent, col. 43:2-4).
  • Evidence for a Narrower Interpretation: The specification explicitly defines "cursor" as the local representation and "pointer" as the secondary, remote representation, stating, "In this application the word 'cursor' is used to refer to the client computer cursor... The word 'pointer' is used to refer to a secondary pointer, which is also displayed." ('211 Patent, col. 12:22-28). This suggests the terms refer to two technically distinct graphical objects.

For the ’124 Patent:

• The Term: "common content"
• Context and Importance: Claim 1 requires displaying "shared content" over "common content." The viability of the infringement theory would have depended on how broadly "common content" is defined. Practitioners may focus on this term because its scope determines the baseline upon which infringement occurs.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification refers to sharing "a common view of a displayed page in an internet browser window," which could mean any underlying application view serves as "common content" ('124 Patent, col. 1:62-64).
  • Evidence for a Narrower Interpretation: The claim requires that the "plurality of client computers each display common content," suggesting a prerequisite state where all users have a synchronized, identical base layer before any infringing "shared content" is displayed ('124 Patent, col. 62:15-17).

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. The basis for inducement is that Defendant actively encourages and instructs customers on how to use its products in an infringing manner (Compl. ¶¶11, 18). The basis for contributory infringement includes these same allegations, plus the assertion that there are "no substantial noninfringing uses for Defendant's products and services" (Compl. ¶¶12, 19).
• Willful Infringement: The complaint alleges willfulness based on Defendant's knowledge of the patents "from at least the filing date of the lawsuit" (Compl. ¶¶11, 12, 18, 19). This frames the willfulness allegation as being based on post-suit conduct.

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

1. Impact of IPR: The central and likely dispositive threshold issue is the legal effect of the IPR certificate cancelling all asserted claims of the ’124 patent. A primary question for the court will be whether the infringement counts related to the ’124 patent can proceed.

2. Technical Implementation: For the remaining ’211 patent, a key evidentiary question will be one of technical architecture: does the accused Zoom platform implement the specific two-step, message-based "cursor" and "pointer" system required by the claims, or does it use a different method for displaying remote cursor positions that falls outside the claim scope?

3. Definitional Scope: The case may also turn on a question of definitional distinction: can the patent’s explicit separation of the terms "cursor" (local) and "pointer" (remote representation) be read onto a system where a single data object may represent both, or is there a fundamental mismatch that precludes infringement?