Ak Meeting IP LLC v. Adobe Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: AK Meeting IP, LLC (Texas)
  • Defendant: Adobe, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00019, W.D. Tex., 01/24/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant has a regular and established place of business in the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s multimedia communication products and services infringe a patent related to methods for managing multi-party collaboration over a computer network.
• Technical Context: The technology concerns client-server architectures for real-time online collaboration, focusing on methods to manage network latency and improve the user experience by differentiating how user-generated content and cursor movements are transmitted and displayed.
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity and notes that it and its predecessors have entered into prior settlement licenses. The complaint preemptively argues that patent marking requirements under 35 U.S.C. § 287 do not apply to limit damages, asserting that the prior licenses were not for the production of patented articles.

Case Timeline

Date	Event
2007-03-30	'765 Patent - Earliest Priority Date
2019-01-15	'765 Patent - Issue Date
2025-01-24	Complaint Filing Date

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

U.S. Patent No. 10,180,765 - "MULTI-PARTY COLLABORATION OVER A COMPUTER NETWORK"

• Patent Identification: U.S. Patent No. 10,180,765, “MULTI-PARTY COLLABORATION OVER A COMPUTER NETWORK,” issued January 15, 2019.

The Invention Explained

• Problem Addressed: The patent describes a common problem in online collaboration systems where delays in transmitting information between participants "reduce the usefulness of an online communication" and detract from the feeling of a live, shared experience (’765 Patent, col. 1:53-63).
• The Patented Solution: The invention proposes a specific client-server method to manage these delays. A central server receives messages from multiple users (clients) in a collaboration session. The system distinguishes between messages containing substantive "client content" (e.g., typed text, images) and messages containing "cursor movement information." The server transmits the "client content" messages back to all participants, including the sender. However, it transmits the "cursor movement" messages only to the other participants, where they are used to display a "pointer" representing the remote user's cursor. (’765 Patent, Abstract; col. 11:6-19). This architecture provides immediate local feedback for a user's own cursor while efficiently updating other users on cursor positions, enhancing the sense of real-time presence (’765 Patent, col. 12:1-5).
• Technical Importance: This method provides a specific architectural solution to the persistent problem of network latency in real-time collaborative applications by intelligently filtering and routing different types of user-generated data. (’765 Patent, col. 1:59-63).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-11 (’765 Patent, col. 62:1-64:12; Compl. ¶8). Plaintiff reserves the right to assert additional claims (Compl. ¶8).
• Independent Claim 1 is a method claim with the following essential elements:
  • Receiving messages at a server from multiple client computers in a collaborative session.
  • The messages include two distinct types of information: "cursor movement information" and "client content input."
  • The server produces two corresponding types of output messages: "cursor output messages" and "content output messages."
  • Transmitting the "content output messages" to all client computers, including the one that generated the content.
  • Transmitting the "cursor output messages" to at least client computers other than the client computer that generated the cursor movement to facilitate the display of a "pointer."

III. The Accused Instrumentality

Product Identification

The complaint broadly accuses Adobe’s "systems, products, and services that facilitate multimedia communication, in particular video, audio, and/or text chat between terminals" (Compl. ¶8). No specific Adobe product, such as Adobe Connect or Acrobat, is named.

Functionality and Market Context

• The complaint alleges that Defendant "maintains, operates, and administers" the accused systems for "multi-party collaboration across a network" (Compl. ¶¶7-8).
• It does not provide specific technical details about the operation of the accused products. Instead, it makes conclusory allegations that the products perform the steps of the claimed invention (Compl. ¶8).
• The complaint alleges that Adobe's website provides instructions that suggest an infringing use, referencing a screenshot included in Exhibit B (Compl. ¶11). This screenshot, described as showing instructions or advertisements from Defendant's website, represents the primary visual evidence cited in the complaint (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit B but does not attach it (Compl. ¶9). The infringement theory is therefore summarized from the complaint's narrative allegations.

Plaintiff alleges that Defendant’s collaboration systems directly infringe the ’765 patent by performing the patented method (Compl. ¶8). The central theory is that when multiple users collaborate using an accused Adobe product, their client devices transmit messages containing user inputs (e.g., text chat, constituting "client content") and pointer location data (constituting "cursor movement information") to Adobe's servers. The complaint alleges these servers then process and route the information to the session participants in the specific manner recited in claim 1: sending content updates to all users while sending pointer location updates only to other users in the session (Compl. ¶¶7-8). This alleged bifurcated data routing forms the basis of the direct infringement claim.

A key question for the court will be whether discovery reveals evidence that any accused Adobe product actually implements the specific, two-tiered message-handling architecture required by claim 1, or whether the products use a more generic data synchronization model that does not map onto the claim's limitations. The lack of specificity in the complaint regarding which products are accused and how they technically operate suggests this will be a central point of discovery and contention.

V. Key Claim Terms for Construction

The Term: "cursor movement information"

• Context and Importance: This term is foundational to the claim's logic, which requires differentiating this type of information from "client content" for separate routing. Its construction will determine whether generic pointer location data within a larger data packet, or only specific, non-persistent coordinate packets, meet the limitation. Practitioners may focus on this term because the patent's core novelty lies in the special handling of this information type.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term is not explicitly defined in the specification, which could support an argument for applying its plain and ordinary meaning, potentially covering any data that communicates a user's cursor position.
  • Evidence for a Narrower Interpretation: The specification describes this information as being part of "non-persistent messages" that are distinct from "persistent" content changes (’765 Patent, col. 11:27-35). Embodiments show it as discrete "MouseMove" messages containing X/Y coordinates (’765 Patent, Fig. 12). A party may argue the term is limited to such discrete, non-persistent coordinate data, rather than any data that happens to include a cursor location.

The Term: "pointer"

• Context and Importance: The claim requires the display of a "pointer" on remote clients, which the patent explicitly distinguishes from the local user's "cursor." The viability of the infringement claim may depend on whether the accused system displays such a distinct, server-generated representation of a remote user's cursor.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Plaintiff may argue the term should be given its ordinary meaning of any on-screen icon representing another user's cursor location.
  • Evidence for a Narrower Interpretation: The specification explicitly defines its terms: "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" (’765 Patent, col. 11:6-12). This creates a potential distinction where the "pointer" is a specific, server-relayed image that embodies network latency, as opposed to the real-time local "cursor." A party could argue that infringement requires a system that displays this particular secondary indicator, not just a generic representation of a remote cursor.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. The inducement allegation is based on claims that Adobe's "website and product instruction manuals" actively encourage customers to use the products in an infringing manner (Compl. ¶¶10-11). The contributory infringement claim asserts the products are not staple articles of commerce and their only reasonable use is an infringing one (Compl. ¶11).
• Willful Infringement: The complaint pleads willfulness based on knowledge of the ’765 patent "from at least the filing date of the lawsuit" (Compl. ¶10). This allegation supports a claim for post-filing willfulness, and Plaintiff expressly reserves the right to amend the complaint if pre-suit knowledge is discovered (Compl. ¶10, n.3).

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

• A central issue will be one of evidentiary sufficiency: The complaint broadly accuses Adobe's "multimedia communication" systems without identifying specific products or their technical architecture. A key question for the litigation will be whether Plaintiff can uncover evidence in discovery that a specific Adobe product actually implements the precise, bifurcated data-routing logic required by claim 1.
• The case will also likely turn on a question of functional scope: Does the data-sharing protocol in a modern, complex collaboration product perform the specific function claimed in the patent—namely, distinguishing "cursor movement information" from "client content" to generate and transmit a separate, server-relayed "pointer" to other users? Or is there a fundamental mismatch between the patent’s targeted solution for latency perception and the actual operation of the accused systems?