DCT

7:25-cv-00446

Advanced Coding Tech LLC v. Apple Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00446, W.D. Tex., 10/01/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant [Apple Inc.](https://ai-lab.exparte.com/party/apple-inc) has multiple regular and established places of business within the district and has committed acts of alleged infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s devices, software, and services implementing the AV1 video codec, as well as products utilizing content caching and 5G NR communication technologies, infringe six patents related to video coding, media server control, and communication quality judgment.
  • Technical Context: The technologies at issue primarily concern methods for efficiently compressing, decoding, and transmitting digital video, which are foundational to modern media streaming, as well as methods for managing digital content and assessing wireless communication quality.
  • Key Procedural History: The complaint alleges Defendant has been on notice of U.S. Patent No. 8,090,025 since at least February 2012, when it was cited during the prosecution of one of Defendant’s patent applications. The complaint also references Defendant’s role as a founding member of the Alliance for Open Media (AOM), which developed the accused AV1 codec, and alleges Defendant conducted "patent due diligence" during that process. Plaintiff has previously asserted the patents-in-suit against Defendant in two actions filed in the Eastern District of Texas in July and August 2024.

Case Timeline

Date Event
2004-03-31 ’891 Patent Priority Date
2006-04-17 ’025 Patent Priority Date
2007-03-02 ’101 Patent Priority Date
2008-05-30 ’995 and ’448 Patents Priority Date
2010-09-28 ’891 Patent Issued
2012-01-03 ’025 Patent Issued
2012-02-24 Complaint alleges Apple had notice of ’025 Patent
2012-07-24 ’101 Patent Issued
2014-03-31 ’303 Patent Priority Date
2015-05-26 ’448 Patent Issued
2018-01-01 Defendant joined the Alliance for Open Media (AOM) (approx. date)
2018-05-29 ’303 Patent Issued
2019-02-26 ’995 Patent Issued
2024-07-22 First prior infringement action filed by Plaintiff against Defendant (E.D. Tex.)
2024-08-20 Second prior infringement action filed by Plaintiff against Defendant (E.D. Tex.)
2025-10-01 Complaint Filing Date

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

U.S. Patent No. 8,090,025 - "Moving-Picture Coding Apparatus, Method and Program, and Moving-Picture Decoding Apparatus, Method and Program," issued January 3, 2012

The Invention Explained

  • Problem Addressed: Conventional block-based motion compensation in video compression can create visual artifacts, known as block distortion, at the borders between blocks. Smoothing filters used to mitigate this can degrade image texture and may not be optimal for compression efficiency (’025 Patent, col. 1:49–2:11).
  • The Patented Solution: The invention proposes a method that avoids traditional block matching. Instead, it identifies the boundary conditions (gradients) of a block to be coded and searches for a matching boundary in a reference frame to generate "border motion-vector data." This data is then used as an input to Poisson's Equation to generate an estimated video signal for the block, creating a predictive picture that maintains signal continuity across block borders without aggressive smoothing (’025 Patent, Abstract; col. 2:45–3:24).
  • Technical Importance: This technique aims to improve compression efficiency, particularly at low bit rates, by creating a more accurate predictive picture, which reduces the amount of residual error data that must be encoded and transmitted (Compl. ¶14).

Key Claims at a Glance

  • The complaint asserts at least Claim 10 (Compl. ¶30).
  • Claim 10, an independent method claim for decoding, includes the essential elements of:
    • Demultiplexing coded data from an input signal.
    • Performing entropy decoding to generate post-quantization data and border motion-vector data.
    • Performing inverse-quantization and inverse-orthogonal transform to produce a decoded residual picture.
    • Defining a boundary condition based on the border motion-vector data and generating an estimated video signal that "satisfies Poisson's Equation," thereby producing a first predictive picture.
    • Combining the first predictive picture and the decoded residual picture to generate a decoded moving-picture signal.
    • Storing the decoded moving-picture signal as a reference picture.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 9,986,303 - "Video Image Coding Data Transmitter, Video Image Coding Data Transmission Method, Video Image Coding Data Receiver, and Video Image Coding Data Transmission and Reception System," issued May 29, 2018

The Invention Explained

  • Problem Addressed: The complaint describes the technology as relating to the efficient transmission and reception of video data at different resolutions (Compl. ¶15). This is a common challenge in adaptive bitrate streaming, where content quality must adapt to changing network conditions.
  • The Patented Solution: The invention describes a system for transmitting video in two layers: a "basic hierarchy" and a "supplementary hierarchy." The supplementary hierarchical pictures have a coding and display order that are "earlier by a factor of a group of pictures" than the basic pictures. This structure allows a receiver to reconstruct video by combining previously received basic data with newly received supplementary data, enabling seamless switching between different resolution layers (Compl. ¶15, 50).
  • Technical Importance: This method facilitates adaptive streaming by allowing a receiver to switch between, for example, a lower-resolution base layer and a higher-resolution supplementary layer without requiring a full, computationally expensive keyframe, thereby improving the user experience over variable-quality networks (Compl. ¶53-55).

Key Claims at a Glance

  • The complaint asserts at least Claim 1 (Compl. ¶51).
  • Claim 1, an independent apparatus claim for a receiver, includes the essential elements of:
    • A processor and memory configured to perform operations.
    • Receiving and decoding "basic video image coding data."
    • Receiving "supplementary video image coding data" that includes a supplementary hierarchical picture whose coding and display order are "earlier by a factor of a group of pictures" than those of a basic hierarchical picture.
    • Acquiring basic video data that was received before the current supplementary data.
    • Reconstructing video image data from the combination of the basic and supplementary data.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 10,218,995 - "Moving Picture Encoding System, Moving Picture Encoding Method..." issued February 26, 2019

  • Technology Synopsis: The patent relates to hierarchical video encoding that uses a "super-resolution enlargement" process (’995 Patent, Abstract). A standard-resolution video stream is decoded, then upscaled to a higher resolution. A second, separate encoded stream can then be decoded using both the original standard-resolution pictures and the newly created super-resolution pictures as references, allowing for enhanced detail and quality (Compl. ¶16, 69).
  • Asserted Claims: The complaint asserts at least Claim 2 (Compl. ¶70).
  • Accused Features: The complaint alleges that Apple's AV1/SVT-AV1 implementation infringes by using a pipeline that can be activated for "super-resolution," which involves upscaling and loop restoration operations to enlarge decoded pictures to a higher resolution (Compl. ¶71, 73).

U.S. Patent No. 9,042,448 - "Moving Picture Encoding System, Moving Picture Encoding Method..." issued May 26, 2015

  • Technology Synopsis: The patent relates to a moving picture encoding system that encodes a sequence of pictures at a resolution higher than a standard resolution by using the standard-resolution content as a reference (’448 Patent, col. 3:49-51). The system employs multiple "super-resolution enlargers" and resolution converters to create reference pictures at various scales for predictive encoding, enabling efficient compression of high-resolution video (Compl. ¶17, 87).
  • Asserted Claims: The complaint asserts at least Claim 1 (Compl. ¶88).
  • Accused Features: The complaint accuses the libaom-av1 encoder, allegedly used by Apple, which features an "in-loop frame super-resolution mode" allowing an encoder to code a frame at a reduced resolution and then upsample it to full resolution for use as a reference, thereby changing resolution mid-stream (Compl. ¶89).

U.S. Patent No. 8,230,101 - "Server Device for Media, Method for Controlling Server for Media, and Program," issued July 24, 2012

  • Technology Synopsis: The patent describes a media server system for managing large amounts of digital content by offloading some content from an internal storage device to a network storage device. The system is designed to maintain a unified "tree structure" of the content for the user, respond to playback requests by searching both locations, and handle potential network failures during content transfer (’101 Patent, Abstract).
  • Asserted Claims: The complaint asserts at least Claim 1 (Compl. ¶105).
  • Accused Features: Apple's content delivery and caching architecture, used for services like iCloud and HTTP Live Streaming, is accused of infringement. This architecture uses Apple's servers as the "internal storage device" and local user network caches as the "network storage device," with the system managing content location and delivery from either source (Compl. ¶104, 106, 108).

U.S. Patent No. 7,804,891 - "Device and Method for Judging Communication Quality and Program Used for the Judgment," issued September 28, 2010

  • Technology Synopsis: The patent discloses a method for judging the quality of a communication channel by embedding redundant bits with a predetermined value into a transmitted signal. The receiving device judges channel quality by identifying the number of these redundant bits that are received correctly or incorrectly, allowing for a quality assessment based on the transmitted data itself (’891 Patent, Abstract).
  • Asserted Claims: The complaint asserts at least Claim 1 (Compl. ¶120).
  • Accused Features: Apple products with 5G NR capability are accused of infringement. The complaint alleges that the 3GPP standard's use of Cyclic Redundancy Check (CRC) and Low-Density Parity-Check (LDPC) for error detection constitutes a method of judging communication quality based on redundant bits (parity bits) within the transmitted symbol (Compl. ¶121, 122, 124).

III. The Accused Instrumentality

Product Identification

The complaint names a wide range of Apple products and services. For the video coding patents ('025, '303, '995, '448), the accused instrumentalities are iPhones and iPads (running iOS 15 or later), Macs (running macOS Big Sur or later), Apple TVs (running tvOS 14 or later), and associated software like Safari, QuickTime, and Apple TV+ that implement the AV1 video codec (Compl. ¶29, 50, 69, 87). For the media server patent ('101), the accused instrumentalities include systems using iCloud, HTTP Live Streaming, and Apple HomeKit Secure Video (Compl. ¶104). For the communication quality patent ('891), the accused products are Apple devices with 5G NR capability, such as recent iPhones, iPads, and Apple Watches (Compl. ¶119).

Functionality and Market Context

The core accused functionality for the video patents is the adoption and use of the AV1 video codec, an open, royalty-free standard developed by the AOM for high-efficiency video streaming (Compl. ¶20, 22). The complaint alleges Apple products use AV1 to decode and play back video content. For the '101 patent, the accused functionality is Apple's content caching system, which stores user and media content on central servers and transparently caches it on local networks to improve access speed (Compl. ¶106, 108). For the '891 patent, the functionality is the error detection and communication quality assessment integral to 5G NR wireless communications (Compl. ¶121-122). These functionalities are central to the operation of Apple's market-leading hardware and digital media ecosystem.

IV. Analysis of Infringement Allegations

’025 Patent Infringement Allegations

Claim Element (from Independent Claim 10) Alleged Infringing Functionality Complaint Citation Patent Citation
demultiplexing coded data from an input signal based on a specific syntax structure... The Accused Products demultiplex coded data from an input signal compliant with the AV1 standard, which defines a specific syntax. ¶31 col. 36:36-53
performing entropy decoding to the data thus demultiplexed to generate, at least, the post-quantization data, the border motion-vector data and parameter data... The Accused Products perform entropy decoding on the demultiplexed data to generate post-quantization data, border motion-vector data, and syntax parameters. ¶35 col. 36:54-61
performing inverse-quantization...to generate post-quantization orthogonal transform coefficients data; performing inverse-orthogonal transform...to produce a decoded residual picture... The Accused Products perform inverse quantization and inverse transforms to produce a decoded residual picture from the post-quantization data. ¶36 col. 36:62-37:1
defining a boundary condition of a border that corresponds to the border motion-vector data...and generate an estimated video signal in each rectangular zone...that satisfies Poisson's Equation, thus producing a first predictive picture... The Accused Products use smoothing algorithms in Overlapped Block Motion Compensation ("OMBC"), which allegedly involves finding predicted pixels that minimize the residual, a process the complaint alleges satisfies Poisson's Equation to produce a predictive picture. ¶34 col. 37:2-8
combining the first predictive picture and the decoded residual picture to generate a decoded moving-picture signal; The Accused Products combine the generated predictive picture and the decoded residual picture to create the final decoded video frame. The complaint provides a diagram from an overview of AV1 coding illustrating this combination. (Compl. p. 16). ¶38 col. 37:9-11
and storing the decoded moving-picture signal for at least one picture as a reference picture. The Accused Products store the decoded signal as a reference picture by updating the set of reference frames for use in decoding subsequent frames. ¶39 col. 37:12-14
  • Identified Points of Contention:
    • Technical Question: A central technical dispute will likely be whether the smoothing and residual-minimizing algorithms used in the AV1 standard's Overlapped Block Motion Compensation (OMBC) can be proven to perform the function of generating a signal "that satisfies Poisson's Equation," as required by the claim. The complaint makes this assertion but its evidence is inferential (Compl. ¶34). This raises the question of whether there is a functional match or a fundamental operational difference between the accused standard and the patented method.
    • Scope Question: Does the term "border motion-vector data" as described in the patent, which is derived from matching boundary conditions, read on the motion vector data generated by the block motion estimation algorithms used in the AV1 standard as alleged by the complaint (Compl. ¶33)?

’303 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a video image coding data receiver comprising a processor and a memory unit... The Accused Products are video image coding data receivers that include a processor and memory. ¶52 col. 17:17-23
receiving basic video image coding data; The Accused Products are configured to receive a bitstream of video at a standard resolution, such as 720p. ¶53 col. 17:24-24
decoding the received basic video image coding data so as to reproduce a video image; The Accused Products decode the received basic data to reproduce a video image. ¶53 col. 17:25-26
receiving supplementary video image coding data including a supplementary hierarchical picture whose coding order and display order are earlier by a factor of a group of pictures... The AV1 standard, implemented in the Accused Products, uses a "Switch Frame" (S Frame) to switch between different resolution/bitrate streams (e.g., to a 1080p stream), which the complaint alleges constitutes the claimed "supplementary hierarchical picture" with an earlier coding and display order. (Compl. p. 21). ¶54, 55 col. 17:27-36
acquiring basic video image coding data received before supplementary video image coding data that has been received at the moment; The Accused Products store received data in a buffer before decoding. When an S Frame initiates a switch to supplementary data, basic hierarchical pictures that were received earlier are still present in the buffer and available for decoding. (Compl. p. 22). ¶57, 58, 59 col. 17:37-40
and reconstructing video image coding data from the basic video image coding data and the supplementary video image coding data. The Accused Products utilize a "Reconstruct process" to perform dequantization, inverse transform, and reconstruction, combining the basic and supplementary data. (Compl. p. 23). ¶60 col. 17:41-44
  • Identified Points of Contention:
    • Scope Question: A key issue will be whether the AV1 "Switch Frame" mechanism can be construed to meet the specific limitations of a "supplementary hierarchical picture whose coding order and display order are earlier by a factor of a group of pictures." The analysis will likely focus on the precise definitions of "hierarchical picture," "group of pictures," and the exact nature of the temporal relationship in the AV1 standard versus the patent's description.
    • Technical Question: Does the process of pulling previously received data from a buffer upon receiving a "Switch Frame" (Compl. ¶58, 59) perform the specific claimed step of "acquiring basic video image coding data received before supplementary video image coding data that has been received at the moment," or is there a technical distinction in how the data is handled?

V. Key Claim Terms for Construction

  • For the ’025 Patent:

    • The Term: "that satisfies Poisson's Equation"
    • Context and Importance: This term is the technical core of the asserted claim's novelty. The infringement case for the ’025 patent may hinge on whether the accused AV1 algorithms, which use methods like Overlapped Block Motion Compensation, can be shown to meet this mathematical condition. Practitioners may focus on this term because it appears to require a specific mathematical property, which could be a high bar for the plaintiff to prove is met by a standardized codec.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent specification may frame the overall goal as achieving "continuity of a video signal...on a block border" (’025 Patent, col. 2:33-36). A party could argue that any method achieving this goal by minimizing discontinuities, as OMBC allegedly does (Compl. ¶34), should be considered to "satisfy" the equation in a functional, rather than strictly mathematical, sense.
      • Evidence for a Narrower Interpretation: The patent explicitly names "Poisson's Equation" multiple times in the Abstract and Detailed Description (’025 Patent, Abstract; col. 3:19). This explicit naming may support an argument that the claim requires a literal, mathematical satisfaction of the equation, not just a method that achieves a similar outcome.

  • For the ’303 Patent:

    • The Term: "supplementary hierarchical picture whose coding order and display order are earlier by a factor of a group of pictures"
    • Context and Importance: This term defines the specific structural and temporal relationship between the basic and supplementary video streams. The infringement allegation rests on mapping the AV1 "Switch Frame" concept onto this language. Practitioners may focus on this term because the phrases "hierarchical picture," "group of pictures," and the temporal requirement "earlier by a factor of" are terms of art in video coding that may have precise meanings that either align with or diverge from the AV1 standard's implementation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent may describe the invention's purpose as enabling seamless switching between different quality layers, a general function that the AV1 Switch Frame is also designed to perform. A party could argue the claim term should be interpreted functionally to cover such mechanisms. The complaint's reliance on the functional description of a "Switch Frame" supports this view (Compl. ¶55).
      • Evidence for a Narrower Interpretation: The specification may provide a very specific definition or embodiment of a "group of pictures" and the "earlier by a factor" timing relationship. If the AV1 standard's implementation of a Switch Frame does not conform to that specific structure (e.g., if it resets references rather than relying on a past GOP), it could support a narrower construction that excludes the accused functionality.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all six patents. The inducement claims are based on Defendant manufacturing and selling the accused products while providing instructions, user manuals, marketing, and technical support that allegedly encourage end-users to use the products in an infringing manner (e.g., Compl. ¶42, 61, 79, 97, 113, 126). The contributory infringement claims allege that components, such as software, are material to the inventions, not staple articles of commerce, and are known by Defendant to be especially made for use in an infringing way (e.g., Compl. ¶43, 62, 80, 98, 114, 127).
  • Willful Infringement: The complaint alleges willful infringement for all six patents, asserting that Defendant had pre-suit knowledge or was willfully blind to its infringement. The allegations are based on several grounds: (1) Defendant's alleged actual notice of the ’025 patent since at least 2012 from a citation during its own patent prosecution (Compl. ¶41); (2) Defendant's alleged "patent due diligence" conducted as a founding member of the Alliance for Open Media during the development of the accused AV1 standard (Compl. ¶44, 63, 81, 99); and (3) Defendant's knowledge from prior patent infringement actions filed by Plaintiff in 2024 asserting the same patents (Compl. ¶25, 100, 115, 128).

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

  • A core issue will be one of technical satisfaction: does the accused AV1 codec's use of Overlapped Block Motion Compensation, an algorithm designed to minimize prediction residuals, perform the specific function of generating a signal "that satisfies Poisson's Equation" as required by Claim 10 of the ’025 patent? The resolution will depend on whether this claim language requires a strict mathematical proof or can be met by demonstrating a functional approximation.
  • A central question will be one of definitional mapping: can the "Switch Frame" mechanism in the AV1 standard be properly construed as the "supplementary hierarchical picture" with the specific temporal ordering ("earlier by a factor of a group of pictures") claimed in the ’303 patent? This will test the alignment between the language of the patent and the operational reality of the industry standard.
  • A key question regarding damages will be one of knowledge and intent: what is the evidentiary strength of the multiple alleged sources of notice—including a 2012 patent citation, Defendant's role in the AV1 "patent due diligence," and prior lawsuits—in establishing pre-suit knowledge and willful blindness sufficient to support a finding of willful infringement across the entire asserted portfolio?