DCT

1:25-cv-02390

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Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-02390, E.D. Va., 12/18/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Virginia because Defendant maintains a "regular and established place of business" in the district, specifically its "HQ2" second headquarters in Arlington, Virginia. The complaint also cites Defendant's substantial business in the district and prior litigation where venue in this district was deemed proper for Amazon.
  • Core Dispute: Plaintiff alleges that Defendant’s devices and services capable of decoding video in the AV1 format and/or displaying High Dynamic Range (HDR) content infringe four patents related to advanced video coding and processing technologies.
  • Technical Context: The dispute centers on technologies fundamental to modern digital video streaming: efficient video compression (the AV1 codec) and enhanced visual quality (High Dynamic Range), both of which are significant in the competitive market for streaming devices and services.
  • Key Procedural History: The complaint notes that prior to this filing, Amazon initiated litigation against InterDigital in the United Kingdom and Brazil concerning patents in those jurisdictions, which may suggest that pre-suit licensing negotiations between the parties were unsuccessful.

Case Timeline

Date Event
2004-09-29 Earliest Priority Date for ’338 Patent
2006-08-02 Earliest Priority Date for ’435 Patent
2009-08-12 Earliest Priority Date for ’606 Patent
2012-04-03 ’338 Patent Issued
2018-01-24 Earliest Priority Date for ’734 Patent
2022-02-15 ’435 Patent Issued
2024-11-12 ’606 Patent Issued
2024-11-19 ’734 Patent Issued
2025-12-18 Complaint Filed

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

U.S. Patent No. 11,252,435 - "Method and apparatus for parametric, model-based, geometric frame partitioning for video coding"

  • Patent Identification: U.S. Patent No. 11,252,435, "Method and apparatus for parametric, model-based, geometric frame partitioning for video coding," issued on February 15, 2022 (Compl. ¶31).

The Invention Explained

  • Problem Addressed: The patent addresses the inefficiency of traditional block-based video compression standards (e.g., MPEG-4 AVC/H.264), which use rigid rectangular partitions that cannot efficiently capture and encode the natural geometric features of objects in a video, such as curves, edges, or contours (Compl. ¶35; ’435 Patent, col. 2:14-17). This results in suboptimal compression and higher bitrates ('435 Patent, col. 2:43-47).
  • The Patented Solution: The invention proposes a method of partitioning video frames using parametric models, such as curves or line segments, instead of fixed block shapes (Compl. ¶36). These models are defined by encoded parameters, allowing the partitions to more closely align with the actual object boundaries in an image ('435 Patent, col. 6:45-56). The model type and its parameters are embedded into the bitstream, enabling a decoder to reconstruct the geometry-aware partitions (Compl. ¶37).
  • Technical Importance: This model-based approach enables a video codec to represent the geometric structure of visual data with higher fidelity and at a lower coding cost than legacy block-based systems (Compl. ¶38).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 ('435 Patent, col. 29:1-30:30; Compl. ¶61).
  • Essential elements of Claim 1 (an apparatus claim for decoding) include:
    • Obtaining pixel values for a block according to a "parametric model."
    • Classifying pixels into two partitions where some pixels may overlap in a "partial surface."
    • Predicting the block by using a first predictor for the first partition, a second predictor for the second partition, and a "weighted linear average" of the two predictors for the "partial surface."
    • Decoding the block responsive to the predicted block.
  • The complaint reserves the right to assert additional claims (Compl. ¶66).

U.S. Patent No. 12,149,734 - "Generalized bi-prediction for video coding with reduced coding complexity"

  • Patent Identification: U.S. Patent No. 12,149,734, "Generalized bi-prediction for video coding with reduced coding complexity," issued on November 19, 2024 (Compl. ¶39).

The Invention Explained

  • Problem Addressed: Prior video codecs like H.264/AVC and HEVC used limited bi-prediction mechanisms, often a simple 0.5/0.5 averaging of two reference blocks ('734 Patent, col. 3:61-4:4). This approach is suboptimal in scenarios with rapid brightness changes or when the two reference pictures have different quality levels or temporal distances from the current picture (Compl. ¶43).
  • The Patented Solution: The patent describes a "generalized bi-prediction" (GBi) framework that adaptively combines two reference prediction blocks using optimized, selectable weight pairs ('734 Patent, Abstract). The system can dynamically restrict or expand the set of available weight options based on various metrics, including the temporal distances to the reference pictures, quantization parameters (QP), and the similarity between the reference signals (Compl. ¶44; ’734 Patent, col. 6:58-7:65).
  • Technical Importance: This adaptive framework improves prediction accuracy and can reduce computational overhead by pruning the available weight set when conditions allow, providing a more efficient and flexible bi-prediction solution (Compl. ¶44).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 7 ('734 Patent, col. 27:10-28:4; Compl. ¶69).
  • Essential elements of Claim 7 (an apparatus claim for decoding) include:
    • Obtaining the first and second temporal distances from a current block to first and second reference pictures.
    • Selecting a "first predetermined set of weights" based at least in part on a comparison of those temporal distances.
    • Selecting a weight value from that predetermined set.
    • Predicting the current block as a weighted sum of the reference blocks using the selected weight.
  • The complaint reserves the right to assert additional claims (Compl. ¶74).

U.S. Patent No. 12,143,606 - "Methods and apparatus for improved intra chroma encoding and decoding"

  • Patent Identification: U.S. Patent No. 12,143,606, "Methods and apparatus for improved intra chroma encoding and decoding," issued on November 12, 2024 (Compl. ¶46).
  • Technology Synopsis: The invention addresses suboptimal coding efficiency in prior codecs where chroma (color) information was restricted to limited, fixed partitions, unlike the more flexible partitions available for luma (brightness) information ('606 Patent, col. 1:41-43). The patent discloses a method for using a broader and more flexible set of chroma partition types that can be selected independently of the luma partition type, enabling a more accurate and efficient representation of chroma textures (Compl. ¶¶49-50).
  • Asserted Claims: At least Claim 14 (Compl. ¶77).
  • Accused Features: The AV1 decoding capabilities of the AV1 Accused Instrumentalities are alleged to infringe (Compl. ¶77).

U.S. Patent No. 8,149,338 - "Method and apparatus for color decision metadata generation"

  • Patent Identification: U.S. Patent No. 8,149,338, "Method and apparatus for color decision metadata generation," issued on April 3, 2012 (Compl. ¶52).
  • Technology Synopsis: The patent addresses the problem of inconsistently preserving creative color corrections across different devices in a video production workflow ('338 Patent, col. 1:21-27). It introduces a metadata structure that defines the number, type, order, and temporal/spatial application of color correction operations, enabling a rendering device to consistently determine how to apply these corrections and reproduce the intended look (Compl. ¶¶56-57).
  • Asserted Claims: At least Claim 7 (Compl. ¶85).
  • Accused Features: The HDR playback capabilities (HDR10, HDR10+, Dolby Vision) of the HDR Accused Instrumentalities are alleged to infringe (Compl. ¶¶84-85).

III. The Accused Instrumentality

Product Identification

The complaint identifies two overlapping categories of accused products: "AV1 Accused Instrumentalities" and "HDR Accused Instrumentalities" (Compl. fn. 1). These include numerous Amazon devices such as the Fire TV Stick series, Fire TV Cube, Fire TV Omni Series televisions, and Echo Show devices (Compl. fns. 5, 6).

Functionality and Market Context

  • The "AV1 Accused Instrumentalities" are defined as all Amazon devices capable of decoding video content encoded in the AV1 compression format (Compl. fn. 1). The complaint provides a screenshot from an Amazon developer webpage for the Echo Show, which lists "AV1: Hardware accelerated up to 1080p @ 60fps" as a supported video codec (Compl. p. 18, ¶62).
  • The "HDR Accused Instrumentalities" are defined as all Amazon devices capable of playing back HDR10, HDR10+, or Dolby Vision content (Compl. fn. 1). The complaint includes a screenshot of an Amazon.com product page for a Fire TV advertising "HDR10+ display" (Compl. p. 24, ¶86).
  • The complaint alleges these products are central to Amazon's "Fire TV and Prime streaming businesses" and that Amazon derives revenue from their sale and use (Compl. ¶¶4, 60).

IV. Analysis of Infringement Allegations

11,252,435 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
obtain values for pixels of a current block of a picture according to a parametric model; The accused AV1 devices receive and process a bitstream containing parameters that define geometric partitions for a block of video. ¶¶36, 61-62 col. 6:45-56
classify said pixels of said current block into two partitions according to said obtained values, wherein pixels of the two partitions overlap in a partial surface... The device's AV1 decoder uses the parametric model to classify pixels into distinct geometric partitions, including handling pixels that lie on the boundary between partitions. ¶¶37-38, 61 col. 12:25-30
predict said current block ... by: predicting pixels in said first partition using a first predictor, predicting pixels in said second partition using a second predictor, and predicting pixels in said partial surface based on a weighted linear average of said first predictor and said second predictor... The AV1 decoder applies distinct prediction methods to each geometric partition and blends the results for pixels on the partition boundary to form a single predicted block. ¶¶37-38, 61 col. 11:30-40
decode said current block responsive to said predicted block. The accused device's AV1 decoder combines the predicted block with residual data from the bitstream to produce the final, decoded block of video. ¶¶21, 61-62 col. 10:1-10

12,149,734 Patent Infringement Allegations

Claim Element (from Independent Claim 7) Alleged Infringing Functionality Complaint Citation Patent Citation
for a current block, obtaining a first temporal distance to a first reference picture and a second temporal distance to a second reference picture; The accused AV1 devices, when performing bi-prediction, necessarily identify the temporal location of the two reference pictures relative to the current picture being decoded. ¶¶44-45, 69 col. 7:1-8
selecting at least a first weight value from among a plurality of weights in a first predetermined set of weights, the first predetermined set of weights being selected based at least in part on a comparison of the first temporal distance and the second temporal distance; The device's AV1 decoder adaptively determines the available set of bi-prediction weights based on criteria including the temporal distances to the reference frames. ¶¶44-45, 69 col. 6:58-65
and predicting the current block as a weighted sum of a first reference block... and a second reference block... wherein the first reference block is weighted by the first weight and the second reference block is weighted by a second weight. The AV1 decoder selects a weight pair from the available set and uses it to combine prediction data from the two reference blocks to form a final predicted block. ¶¶42, 69 col. 4:41-50
  • Identified Points of Contention:
    • Scope Questions: For the ’435 Patent, a potential issue is whether the specific implementation of geometric partitioning in the AV1 standard, as used by Amazon's devices, meets the definition of a "parametric model" that generates a "partial surface" predicted via a "weighted linear average," as those terms are defined by the patent's specification.
    • Technical Questions: For the ’734 Patent, a key question may be whether Amazon's AV1 decoders perform the specific two-step process required by Claim 7: first selecting a set of available weights based on temporal distance, and then selecting a specific weight from that set. The analysis may focus on whether the decoder's logic directly links temporal distance to the available range of weights, or if it uses a different decision-making process.

V. Key Claim Terms for Construction

’435 Patent

  • The Term: "parametric model"
  • Context and Importance: This term is central to the invention's novelty over block-based partitioning. Practitioners may focus on this term because the infringement case depends on whether the geometric partitioning tools available in the AV1 standard and used by Amazon fall within the patent's specific definition of a "parametric model."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states the model "involves at least one of implicit and explicit formulation of at least one curve" (’435 Patent, col. 6:53-55), which could be argued to cover any non-block-based boundary description.
    • Evidence for a Narrower Interpretation: The specification's primary example describes the model as a "first order polynomial" with parameters for angle and position, f(x,y)=x cos θ+y sin θ−ρ (’435 Patent, col. 12:1-15), which could support a narrower construction limited to such mathematical functions.

’734 Patent

  • The Term: "the first predetermined set of weights being selected based at least in part on a comparison of the first temporal distance..."
  • Context and Importance: This limitation defines the adaptive nature of the invention. Practitioners may focus on this phrase because it requires a specific causal link: the comparison of temporal distances must influence the selection of the available set of weights, not just the final choice of one weight from a static set.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states the "GBi engine determines allowable weights using metrics such as the temporal layer (TL)... [and] temporal distances to reference pictures" (Compl. ¶44, citing '734 Patent, col. 6:58-7:65), suggesting a general relationship.
    • Evidence for a Narrower Interpretation: The claim language recites a sequential process: a "set of weights" is "selected based on" a comparison of distances. This may be interpreted to require a distinct step where the available options are pruned before a final weight is chosen, a more specific operation than simply considering temporal distance as one factor in a one-step decision.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all four patents (Compl. ¶¶64, 72, 80, 88). The allegations are based on Amazon advertising its devices as capable of decoding AV1 and playing back HDR content, and on providing instructions to users on how to enable and use these features. For example, the complaint includes a screenshot of an Amazon Help & Customer Service page titled "Dolby Vision or High Dynamic Range Not Working on Fire TV Devices," which provides troubleshooting instructions for users (Compl. p. 26, ¶86).
  • Willful Infringement: The complaint alleges that Amazon has been aware of the patents and their infringement "at least as of the filing of this Complaint" (Compl. ¶¶63, 71, 79, 87). This forms a basis for post-suit willful infringement. The complaint does not allege specific facts supporting pre-suit knowledge.

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

  • A central issue of technical implementation will be whether Amazon's devices, by complying with the AV1 video standard, necessarily practice the specific methods claimed in the ’435 and ’734 patents. The case may turn on evidence showing how the standardized algorithms for geometric partitioning and generalized bi-prediction in AV1 map to the patent claims.
  • A key question of claim scope will be whether the term "parametric model" in the ’435 patent is broad enough to cover the partitioning tools in the AV1 standard, or if it is limited to the specific polynomial-based embodiments detailed in the patent's specification.
  • An evidentiary question of functional equivalence will arise for the ’338 patent: does Amazon's implementation of HDR playback technology perform the specific steps of determining the "number," "type," and "order" of color corrections from metadata as required by the claims, or does it utilize a fundamentally different metadata processing workflow that falls outside the claim scope?