DCT
7:25-cv-00504
Fec IP LLC v. Apple Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Fec IP LLC (Texas)
- Defendant: Apple Inc. (California)
- Plaintiff’s Counsel: Fabricant LLP
- Case Identification: 7:25-cv-00504, W.D. Tex., 10/30/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business within the Western District of Texas and has committed the alleged acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s ecosystem of products, including iPhones, iPads, and Apple TV, infringes five patents related to remote device control, content streaming, and data exchange functionalities.
- Technical Context: The technologies at issue govern device-to-device communication for media control and content sharing, features that are central to the user experience in modern, integrated consumer electronics ecosystems.
- Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 1999-11-02 | U.S. Patent No. 7,631,192 Priority Date |
| 2007-06-19 | U.S. Patent No. 8,055,187 Priority Date |
| 2009-12-08 | U.S. Patent No. 7,631,192 Issued |
| 2011-05-02 | U.S. Patent No. 8,908,106 Priority Date |
| 2011-11-08 | U.S. Patent No. 8,055,187 Issued |
| 2014-12-09 | U.S. Patent No. 8,908,106 Issued |
| 2015-09-08 | U.S. Patent No. 10,171,847 Priority Date |
| 2016-03-18 | U.S. Patent No. 11,375,254 Priority Date |
| 2019-01-01 | U.S. Patent No. 10,171,847 Issued |
| 2022-06-28 | U.S. Patent No. 11,375,254 Issued |
| 2025-10-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,631,192 - “Network Apparatus for Accessing Services Over a Network,” Issued Dec. 8, 2009
The Invention Explained
- Problem Addressed: The patent describes the security risk of displaying private information, such as the content of an email, on a shared screen like a television, where it can be seen by anyone in the vicinity (ʼ192 Patent, col. 1:10-31).
- The Patented Solution: The invention proposes a system where a portable remote controller sends a unique ID code to a main device when requesting information. The main device fetches the information from a network, appends the remote's ID code to it, and transmits the combined data. The remote controller is configured to only display the information if it contains its own ID code, preventing unauthorized viewing on other devices (ʼ192 Patent, Abstract; col. 2:58-67).
- Technical Importance: This approach provided a method for securing personal data within a multi-device, shared-screen environment, addressing privacy concerns that arise when using a central media hub to access personal network services.
Key Claims at a Glance
- The complaint asserts at least method claim 17 (Compl. ¶25).
- Independent Claim 17 breaks down into the following essential steps:
- Sending a request for information from a portable remote controller device having a first display to a main device configured to be connected to a second display.
- Obtaining the requested information from the network.
- Providing the obtained information from the main device to the remote controller device.
- Displaying the sent information on the first display of the remote controller device.
- Sending a display switching signal from the remote controller device to the main device.
- Determining whether the second display of the main device displays the obtained information based on the display switching signal sent from the remote controller device.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 8,908,106 - “Mobile Terminal,” Issued Dec. 9, 2014
The Invention Explained
- Problem Addressed: The patent identifies a user experience issue where a user must wait for two sequential processes to complete before controlling an external device: first, the start-up of a control application on a mobile terminal, and second, the power-on process of the external device (e.g., a TV receiver) (’106 Patent, col. 1:21-36).
- The Patented Solution: The invention claims a mobile terminal that transmits the "turning-on" control signal to the external device before the process of starting the control application on the mobile terminal is completed. By initiating the external device's power-on sequence in parallel with the mobile app's launch, the total waiting time for the user is reduced (’106 Patent, Abstract; col. 2:2-9).
- Technical Importance: This method improves the responsiveness and usability of mobile devices as remote controls for other electronics, reducing latency in establishing a control session.
Key Claims at a Glance
- The complaint asserts at least apparatus claim 1 (Compl. ¶38).
- Independent Claim 1 breaks down into the following essential elements:
- A signal transmission unit which transmits control signals to an external device.
- An operation unit for a user to perform various actions.
- A microprocessor that starts a control application and transmits an operation control signal to the external device in response to a user action.
- Wherein, when starting the control application, the microprocessor transmits a turning-on control signal to the external device before the process of starting the control application is completed.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 8,055,187 - “Communication Terminal and Communication Method for Exchanging Contents,” Issued Nov. 8, 2011
- Technology Synopsis: The patent generally relates to methods for exchanging and duplicating digital content between communication terminals (Compl. ¶16). The described method involves a multi-step handshake process where devices repeatedly transmit requests, receive responses, and exchange "determination information" to decide whether content (image or voice) should be transmitted before the actual content data is sent and stored (Compl. ¶50).
- Asserted Claims: At least method claim 15 is asserted (Compl. ¶50).
- Accused Features: The complaint alleges that Apple's AirDrop functionality, which allows users to share files between nearby Apple devices, infringes the ’187 Patent (Compl. ¶51).
U.S. Patent No. 11,375,254 - “Control Apparatus,” Issued June 28, 2022
- Technology Synopsis: The patent describes a control apparatus that manages playback of content stored on a server device (Compl. ¶17). The apparatus receives content, analyzes it to determine chapter positions (e.g., the start and end of a TV show intro), determines a playback position based on that analysis, and transmits information about that playback position (e.g., a "skip intro" command) to the playback device. The technology is designed to operate in parallel, where the content analysis occurs while the content is being streamed to and played by the playback device (’254 Patent, Abstract; Compl. ¶67).
- Asserted Claims: At least apparatus claim 1 is asserted (Compl. ¶67).
- Accused Features: The complaint alleges that Apple products supporting the Apple TV+ application, which includes a "Skip Intro" feature, infringe the ’254 Patent (Compl. ¶68, ¶70).
U.S. Patent No. 10,171,847 - “Information Device and Distribution Device,” Issued Jan. 1, 2019
- Technology Synopsis: The patent relates to an information device that downloads video data by sequentially requesting divided segments, or "chunks," of the video data from an external device (Compl. ¶18). The controller in the device converts the format of the downloaded data into a playable format, which includes creating a playlist file for playback instruction of the divided files as they are downloaded (’847 Patent, Abstract; Compl. ¶86).
- Asserted Claims: At least apparatus claim 1 is asserted (Compl. ¶86).
- Accused Features: The complaint alleges that the Apple TV+ application, which delivers streaming content using chunked video data and content delivery networks (CDNs), infringes the ’847 Patent (Compl. ¶87, ¶90).
III. The Accused Instrumentality
Product Identification
The complaint identifies the Accused Products as Apple devices that implement "Apple TV Remote, AirPlay, and AirDrop functionalities" and those that support the "Apple TV+" service (Compl. ¶19). This includes, but is not limited to, various models of the iPhone, iPad, Apple Watch, Apple TV 4K, Mac, and Apple Vision Pro (Compl. ¶19).
Functionality and Market Context
- The accused functionalities are core features of Apple's product ecosystem. AirPlay allows users to stream or mirror content from an iPhone or iPad to an Apple TV or compatible smart TV (Compl. ¶26). The Apple TV Remote functionality allows an iPhone to act as a software-based remote control for an Apple TV (Compl. ¶41). AirDrop enables direct peer-to-peer file sharing between nearby Apple devices using Bluetooth and Wi-Fi (Compl. ¶51). Apple TV+ is Apple's streaming service, which relies on a content delivery network (CDN) to stream video content, broken into small "chunks," to user devices (Compl. ¶68, ¶90).
- The complaint positions these features as integral to the Apple user experience, enabling seamless interaction across a wide range of popular and commercially significant consumer electronics (Compl. ¶19). A visual from an Apple support page illustrates the process of using an iPhone's AirPlay feature to select a TV for video streaming (Compl. p. 11). Another visual depicts the user interface of the virtual Apple TV Remote on an iPhone, showcasing controls such as a touch pad, menu button, and power button (Compl. p. 19).
IV. Analysis of Infringement Allegations
’192 Patent Infringement Allegations
| Claim Element (from Independent Claim 17) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| sending a request for information from a portable remote controller device having a first display to a main device configured to be connected to a second display | An iPhone 17 Pro Max (portable remote controller) running AirPlay sends a request for streaming data to an Apple TV 4K (main device), which is connected to a smart television (second display). | ¶26 | col. 2:58-67 |
| obtaining the requested information from the network | The Apple TV 4K obtains the requested online content (e.g., video data) from the network (e.g., Wi-Fi, Internet). | ¶27 | col. 4:51-54 |
| providing the obtained information from the main device to the remote controller device; [and] displaying the sent information on the first display of the remote controller device | The iPhone receives information from the Apple TV 4K, such as an AirPlay code for authentication, and displays it on its screen. The complaint provides a visual showing the AirPlay code displayed on both the iPhone and the television screen (Compl. p. 9). | ¶28 | col. 5:2-8 |
| sending a display switching signal from the remote controller device to the main device | The iPhone sends a signal to the Apple TV 4K to initiate streaming or screen mirroring. This is allegedly done when a user taps the AirPlay button and selects the target device. | ¶29 | col. 5:9-13 |
| determining whether the second display of the main device displays the obtained information based on the display switching signal sent from the remote controller device | The iPhone determines whether the smart television (second display) connected to the Apple TV 4K displays the requested content based on the signal sent from the iPhone. A visual in the complaint shows video playback having been transferred from the iPhone to the TV (Compl. p. 13). | ¶30 | col. 5:14-20 |
Identified Points of Contention
- Scope Questions: The analysis may turn on the interpretation of "determining." The final step of claim 17 requires a determination based on the display switching signal. It raises the question of which device in the accused system performs this "determining" step and whether that mapping aligns with the claim's requirements, which appear to place the action within the overall method, parts of which are performed by the remote controller.
- Technical Questions: A factual question may arise as to what constitutes the "information" that is provided back to the remote controller and displayed. The complaint points to an "AirPlay Code" (Compl. p. 9), but it is a question for the court whether this security code constitutes the "obtained information" (e.g., the substantive streaming content) as contemplated by the claim.
’106 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a signal transmission unit which transmits control signals to an external device | An iPhone's Wi-Fi or Bluetooth transceiver transmits control signals (e.g., power on/off, play, pause) to an external device like an Apple TV 4K. | ¶39 | col. 4:15-20 |
| an operation unit for a user to perform various actions | The iPhone's touch screen allows a user to perform actions such as swiping or tapping buttons within a remote control application. | ¶40 | col. 3:56-61 |
| a microprocessor that starts a control application for control of the external device, and transmits... an operation control signal... in response to a user action... | The iPhone's processor starts a control application (e.g., Apple TV Remote App) and, in response to user input on the touch screen, transmits a control signal (e.g., a Wi-Fi signal to change a channel) to the Apple TV 4K. | ¶41 | col. 4:44-54 |
| wherein when starting the control application, the microprocessor transmits... a turning-on control signal to turn on the external device... before the process of starting the control application is completed | When a user has "Automatically AirPlay" enabled, the iPhone allegedly transmits a "turning-on control signal (e.g., a wake signal)" to the Apple TV 4K "before the process of starting AirPlay is completed." A visual from Apple's support documentation shows the settings screen for "Automatically AirPlay" (Compl. p. 23). | ¶42 | col. 2:2-9 |
Identified Points of Contention
- Scope Questions: The phrase "before the process of starting the control application is completed" will be a central point of claim construction. The parties may dispute what technical milestones define the "completion" of an application's startup process (e.g., when the process is spawned, when the UI is first drawn, or when the application is fully interactive).
- Technical Questions: Evidence will be required to establish the precise timing of the alleged "turning-on control signal." The infringement analysis will depend on whether this signal is in fact transmitted during the specific window between the initiation and "completion" of the control application's startup, as required by the claim.
V. Key Claim Terms for Construction
For the ’192 Patent
The Term
"determining whether the second display of the main device displays the obtained information" (from claim 17)
Context and Importance
This step concludes the claimed method. Its construction is critical because infringement will depend on which entity (the remote controller, the main device, or the system as a whole) is required to perform this "determining" action and whether Apple's AirPlay architecture performs the step in the required manner. Practitioners may focus on this term because the complaint's allegation that the iPhone performs this check (Compl. ¶30) could be a point of technical and legal dispute.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claim is a method claim, and the steps are not all explicitly tied to a single actor. A party could argue that as long as the determination occurs as part of the overall system operation initiated by the remote, the claim is met, regardless of whether the processing occurs on the remote or main device.
- Evidence for a Narrower Interpretation: The patent's focus is on enhancing the security and control available to the user of the portable remote device (’192 Patent, col. 2:58-67). A party could argue that to achieve this goal, the "determining" or verification step must logically be tied to the remote controller itself, which initiated the secure session.
For the ’106 Patent
The Term
"before the process of starting the control application is completed" (from claim 1)
Context and Importance
This temporal limitation is the core inventive concept of the patent, aiming to reduce user wait time. The entire infringement case for this patent may hinge on the definition of when an application's startup is "completed." Practitioners may focus on this term because modern operating systems have complex, multi-stage application launch processes, and the definition could either broaden or narrow the window for infringement.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification discusses reducing the user's "waiting time" until the "external device can be controlled" (’106 Patent, col. 2:6-9). A party could argue "completed" means the point where the user can fully interact with all features of the control app, allowing for a relatively long "starting" phase during which the turning-on signal could be sent.
- Evidence for a Narrower Interpretation: The patent illustrates the process ending when the TV application "has been started" and an "operation screen" is displayed (’106 Patent, FIG. 5; col. 5:4-6). A party could argue this implies "completed" refers to an earlier technical event, such as the initial rendering of the UI, creating a narrower window for the infringing signal to be sent.
VI. Other Allegations
Indirect Infringement
For each patent-in-suit, the complaint alleges both induced and contributory infringement. The inducement allegations are based on Defendant manufacturing and selling the Accused Products while also providing "instructions, documentation, ... marketing, product manuals, advertisements, and online documentation" that allegedly encourage customers to use the products in an infringing manner (e.g., Compl. ¶¶ 31, 43, 60, 79, 92). The contributory infringement allegations state that accused components, such as software, are material to the inventions, are not staple articles of commerce, and are known by Defendant to be especially made for use in an infringing way (e.g., Compl. ¶¶ 33, 45, 62, 81, 94).
Willful Infringement
The complaint alleges that Defendant had "actual notice of the Asserted Patents, at least as of the filing date of this Complaint" (Compl. ¶20). The claims for indirect infringement further allege that Defendant performs its acts "with knowledge of the... Patent and with the intent, or willful blindness, that the induced acts directly infringe" (e.g., Compl. ¶32). These allegations appear to primarily support a claim for post-suit willfulness, as no specific facts demonstrating pre-suit knowledge of the patents are pled.
VII. Analyst’s Conclusion: Key Questions for the Case
This case will likely focus on the detailed, step-by-step operation of Apple's highly integrated software features and whether they map onto the specific claim language of the patents-in-suit. The central questions for the court will include:
- A core issue will be one of functional allocation: Do the accused Apple products perform the specific functions required by the claims on the device required by the claims? For instance, with respect to the ’192 patent, does the iPhone (the "remote controller device") perform the final "determining" step of the method, or does that function reside on the Apple TV (the "main device"), creating a potential mismatch with the claim?
- A key evidentiary question will be one of temporal precision: With respect to the ’106 patent, can Plaintiff provide evidence that a "turning-on control signal" is transmitted by an iPhone within the narrow and technically ambiguous window of "before the process of starting the control application is completed"? This will require a rigorous definition of the application lifecycle and a detailed factual analysis of the accused system's operation.
- A third central question will be one of system-level interpretation: Can a collection of distinct but coordinated software features in a modern operating system (e.g., AirPlay, AirDrop, Apple TV+) be fairly characterized as the more discrete components and sequential steps recited in the asserted patents, or is there a fundamental difference in their architectural and operational design that precludes a finding of infringement?