DCT

6:25-cv-00185

MessageLoud Inc v. Apple Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-00185, W.D. Tex., 05/06/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Apple maintains a regular and established place of business in the district, including corporate campuses and retail stores in Austin, derives substantial revenue from the district, and has committed the alleged acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s devices and associated software, including iPhones, iPads, and Apple Watches running features like Siri and CarPlay, infringe five patents related to methods for automatically reading electronic messages aloud to a user without requiring user input.
  • Technical Context: The technology addresses hands-free interaction with electronic communications, aiming to allow users to safely receive and manage messages from various sources while engaged in activities such as driving or exercising.
  • Key Procedural History: The complaint alleges that Defendant has been on notice of the patents-in-suit since at least April 4, 2024. No other significant procedural events, such as prior litigation or administrative challenges to the patents, are mentioned in the complaint.

Case Timeline

Date Event
2014-11-21 Earliest Priority Date for all Patents-in-Suit
2017-03-07 U.S. Patent No. 9,591,117 Issues
2018-10-23 U.S. Patent No. 10,110,725 Issues
2019-04-30 U.S. Patent No. 10,277,728 Issues
2019-11-20 Apple announces expansion of its Austin campus
2019-12-24 U.S. Patent No. 10,516,775 Issues
2022-04-26 U.S. Patent No. 11,316,964 Issues
2023-09-30 Construction begins on Apple's Austin campus expansion
2024-01-01 Apple consolidates Data Operations Annotations team in Austin
2024-04-04 Date of alleged notice to Apple regarding Patents-in-Suit
2025-03-30 Estimated completion date for Apple's Austin campus expansion
2025-05-06 Complaint Filed

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

U.S. Patent No. 9,591,117 - Method and System for Communication, Issued March 7, 2017

The Invention Explained

  • Problem Addressed: The patent's background describes the hazard and difficulty of using a mobile phone to receive and read various types of messages (e.g., emails, texts) while engaged in an activity like driving, noting that existing solutions still require substantial and distracting user input (’725 Patent, col. 1:15-58).
  • The Patented Solution: The invention is a computer-implemented method that automatically, without user input, detects the arrival of different message types, places them into a single queue based on receipt time, announces the sender's identity, and then reads the message body aloud (’725 Patent, Abstract). The system is designed for hands-free operation, providing the user a window to interrupt the reading with a simple, memorized gesture on the touch screen (’117 Patent, Claim 1e).
  • Technical Importance: The technology sought to provide a unified, automated, and safer way for users to access time-sensitive electronic communications while engaged in activities that preclude visual or manual interaction with a device (Compl. ¶28-29).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶38).
  • Essential elements of Claim 1 include:
    • Determining without user input that at least two different message types (text, email, messenger) have arrived.
    • Analyzing the content of the message without user input.
    • Placing the messages in a single queue to be read aloud in order of receipt time, regardless of type.
    • Informing the user of the sender's identity by reading it aloud, without user input.
    • Allowing the user time to take an affirmative action, limited to a memorized gesture on the touch screen, to stop the reading.
    • Reading the message body aloud if no such affirmative action is received.
    • Not displaying the message on the screen if the user is driving a vehicle.
  • The complaint reserves the right to assert other claims (Compl. ¶38).

U.S. Patent No. 10,110,725 - Method and System For Communication, Issued October 23, 2018

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of accessing multiple types of electronic messages on a mobile device when a user is occupied with an activity that makes it unsafe or impractical to interact with the device's screen (’725 Patent, col. 1:15-30).
  • The Patented Solution: The patent describes a system where a mobile device's software automatically detects incoming messages (text, email, messenger), parses their content to identify elements like the sender and body, and places them in a unified queue to be read aloud sequentially (’725 Patent, Fig. 24; col. 4:6-14). This process operates "without any input by a user," providing a hands-free communication experience unless the user affirmatively intervenes with a simple gesture (’725 Patent, Claim 1).
  • Technical Importance: This approach aimed to improve safety and convenience by creating a consistent, voice-based interface for disparate messaging platforms, particularly for users in distracting environments like a vehicle (Compl. ¶29).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶55).
  • Essential elements of Claim 1 include:
    • Determining without user input that two or more different message types (text, email, messenger) have been received.
    • Analyzing the message content without user input.
    • Placing the messages in a single queue to be read aloud in order of receipt time regardless of type.
    • Informing the user of the sender's identity by reading it aloud, without user input.
    • Allowing the user time to take an affirmative action, limited to a gesture on the touch screen, to stop the reading.
    • Reading the message body aloud if no such action is taken.
  • The complaint reserves the right to assert other claims (Compl. ¶55).

U.S. Patent No. 10,277,728 - Method and System For Communication, Issued April 30, 2019

  • Technology Synopsis: This patent, part of the same family as the lead patents, claims a method for automatically processing and audibly presenting messages of different types from a single queue. The core technology focuses on enabling hands-free message consumption without initial user input, particularly for users engaged in activities like driving or working (Compl. ¶29; ’728 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶71).
  • Accused Features: The complaint alleges that the same features of the Accused Instrumentalities that read notifications aloud infringe the ’728 Patent (Compl. ¶71).

U.S. Patent No. 10,516,775 - Method and System For Communication, Issued December 24, 2019

  • Technology Synopsis: Continuing the technology of the parent applications, this patent covers a computer-implemented method for receiving multiple message types, queuing them for sequential audible playback, and reading them to the user without requiring interaction. The invention is framed as a solution for safely accessing messages while preoccupied (Compl. ¶29; ’775 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶87).
  • Accused Features: The complaint accuses the same hands-free notification and message-reading features of infringing the ’775 Patent (Compl. ¶87).

U.S. Patent No. 11,316,964 - Method and System For Communication, Issued April 26, 2022

  • Technology Synopsis: This patent further covers the core invention of a system that automatically detects, queues, and reads aloud messages from various sources (text, email, messenger). A key aspect is the hands-free nature of the process, which proceeds without user input unless a user affirmatively acts to stop it (Compl. ¶29; ’964 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶103).
  • Accused Features: The features of the Accused Instrumentalities that audibly announce and read messages are alleged to infringe the ’964 Patent (Compl. ¶103).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Accused Instrumentalities" as a broad range of Apple hardware products, including iPhone models (XR and newer), various iPad models, Apple Watch models, and the Apple Vision Pro (Compl. ¶39). These devices are accused when used with associated hardware (Apple AirPods, Beats headphones, CarPlay-enabled vehicles) and running various versions of Apple's operating systems (iOS, iPadOS, watchOS, visionOS) that "support or enable features that read notifications aloud without user input" (Compl. ¶39).

Functionality and Market Context

  • The relevant functionality is the system's ability to audibly announce and read the content of incoming notifications, such as text messages and other alerts, without requiring the user to look at or physically handle the device (Compl. ¶39). This is commonly associated with features like "Announce Messages with Siri" when used with compatible headphones or CarPlay. The complaint alleges that Apple derives substantial revenue from these commercially significant products, which are sold throughout the United States and within the judicial district (Compl. ¶14, ¶30).

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits (Exhibits F-J) that were not filed with the public complaint; therefore, the infringement allegations are summarized below in prose based on the complaint's narrative. No probative visual evidence provided in complaint.

'117 Patent and '725 Patent Infringement Allegations

The complaint alleges that the Accused Instrumentalities practice the methods claimed in the ’117 and ’725 patents (Compl. ¶41, ¶57). The narrative theory suggests that when a feature like "Announce Messages" is active in CarPlay or with AirPods, Apple's devices perform the claimed steps. The system allegedly determines "without any input by a user" that a message (e.g., from iMessage, SMS, or a third-party messenger app) has arrived. It then audibly informs the user of the sender's identity. The system is alleged to place these different message types in a "single queue" to be read in order of receipt. After announcing the sender, if the user does not take an "affirmative action" to stop the process, the system proceeds to read the body of the message aloud. The complaint also points to functionality in driving modes where the message content is not displayed on the screen, allegedly satisfying a specific limitation of the ’117 Patent (Compl. ¶37).

  • Identified Points of Contention:
    • Scope Questions: Claim 1 of both the ’117 and ’725 patents requires that the user's "affirmative action" to stop the read-aloud process be "limited to a gesture performed on the touch screen." A central question may be whether interactions with other hardware—such as tapping an AirPod, pressing a steering wheel button, or giving a voice command—can be construed to fall within the scope of this "touch screen" limitation.
    • Technical Questions: The claims require placing messages from different sources into "a single queue to be read aloud in order of receipt time regardless of message type." The infringement analysis may raise the question of whether Apple's notification architecture, which manages alerts from numerous applications, operates as a simple, non-prioritized, first-in-first-out queue as claimed, or if it uses a more complex, multi-channel system with varying priorities that may not align with the claim's requirements.

V. Key Claim Terms for Construction

  • The Term: "a single queue to be read aloud in order of receipt time regardless of message type" (Claim 1c of '117 and '725 patents)

    • Context and Importance: The structure and behavior of this "single queue" is a core technical element of the claimed invention. The construction of this term will be critical in determining whether Apple's sophisticated notification management system, which handles alerts from many different applications with potential prioritization, performs the function described by the claim.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The abstract states that "All messages can be placed in a single queue, and read to the user in order of receipt," which may support an argument that any system presenting various messages audibly in a sequential order meets the limitation (’725 Patent, Abstract).
      • Evidence for a Narrower Interpretation: Figure 24 of the ’725 Patent depicts a specific data structure labeled "Queue" where different message types are interleaved strictly by arrival order. Parties may argue that the term requires this specific, non-prioritized, first-in-first-out architecture and that a system using categories or priorities for notifications would fall outside its scope (’725 Patent, Fig. 24).

  • The Term: "affirmative action is limited to a gesture performed on the touch screen" (Claim 1e of '117 and '725 patents)

    • Context and Importance: This term defines the specific user interaction for interrupting the automated process. Its construction is important because the accused features are often controlled through voice commands, taps on connected accessories (like AirPods), or physical buttons (on a steering wheel), not just the device's touch screen. Practitioners may focus on this term because of the potential mismatch between the claim language and the operation of the accused products.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification discusses the goal of allowing a user to command the application "without looking at the screen," mentioning "tapping or swiping" as examples (’725 Patent, col. 4:45-51). This could support an argument that the term encompasses any simple, non-visual gesture, regardless of the specific hardware interface.
      • Evidence for a Narrower Interpretation: The claim preamble explicitly recites a method carried out with a "touch screen," and the limitation itself specifies the gesture is "performed on the touch screen." This language may support a plain-meaning construction limiting the action to physical contact with the device's screen itself (’725 Patent, Claim 1).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all patents-in-suit. Inducement is alleged based on Apple's actions in "disseminating, manufacturing, distributing... and promoting the use of the Accused Instrumentalities through... operating manuals, technical information, and other instructions on how to implement and configure" the accused features with knowledge and intent to cause infringement (Compl. ¶43, ¶59). Contributory infringement is alleged on the basis that the accused software and hardware are "especially designed or adapted to operate in a manner that infringes" and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶45, ¶61).
  • Willful Infringement: Willfulness is alleged for all patents-in-suit "on information and belief" (Compl. ¶48, ¶64). The complaint alleges that Apple has had "actual or constructive knowledge" of each patent and its infringement "since at least the service of this Complaint," suggesting a primary theory of post-suit willfulness (Compl. ¶42, ¶58). The complaint also makes a general allegation that Apple has been on notice of the patents-in-suit since at least April 4, 2024 (Compl. ¶31).

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

  • A core issue will be one of definitional scope: Can the term "gesture performed on the touch screen," which appears in claims with a 2014 priority date, be construed to cover the modern multi-modal inputs central to the accused functionality, such as voice commands to Siri, taps on wireless AirPods, or controls integrated into a vehicle's steering wheel?
  • A key evidentiary question will be one of technical architecture: Does Apple's notification system, which manages alerts from dozens of applications, operate as the "single queue... regardless of message type" required by the claims, or will evidence reveal a more complex, prioritized architecture that creates a fundamental mismatch in technical operation?
  • A third question will concern the driving-specific limitation in the ’117 Patent: What evidence will be presented to show that the screens of the accused devices do "not display any portion" of a message when a user is engaged in driving, and how will the system's behavior across different versions of iOS and CarPlay affect this analysis?