DCT

2:23-cv-01752

Goel v. Microsoft Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-01752, W.D. Wash., 11/27/2023
  • Venue Allegations: Venue is alleged to be proper because Defendant maintains its principal place of business in the district, has committed alleged acts of infringement in the district, and has an established place of business there.
  • Core Dispute: Plaintiff alleges that Defendant’s Microsoft Teams product infringes a patent related to advanced video conferencing features, including real-time accent modification and customizable multi-user video overlays.
  • Technical Context: The technology at issue addresses user experience in video conferencing platforms by providing enhanced tools for audio-visual customization, a market that has grown in significance with the rise of remote work.
  • Key Procedural History: The complaint alleges that Defendant gained actual knowledge of the patent-in-suit on November 4, 2023, through a message sent via LinkedIn that was acknowledged by Defendant’s counsel. The complaint also references the patent's prosecution history, quoting the patent examiner's statement of reasons for allowance which highlighted the novelty of combining video conferencing with "accent modification and multiple video overlaying."

Case Timeline

Date Event
2021-01-11 ’217 Patent Priority Date (Application Filing)
2021-08-24 ’217 Patent Notice of Allowance issued
2021-09-28 ’217 Patent Issued
2023-11-04 Date of Alleged Actual Knowledge by Defendant
2023-11-27 Complaint Filed

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

U.S. Patent No. 11,134,217 - "SYSTEM THAT PROVIDES VIDEO CONFERENCING WITH ACCENT MODIFICATION AND MULTIPLE VIDEO OVERLAYING"

The Invention Explained

  • Problem Addressed: The patent identifies conventional video conferencing as a "boring" and "poor substitute for a real life gathering" due to a lack of user control. Specific problems cited include users appearing disconnected in separate boxes, being forced to share their entire screen, having accents that are difficult for other participants to understand, and wanting to appear professionally dressed without changing out of casual attire. (’217 Patent, col. 2:26-40).
  • The Patented Solution: The invention provides a system with a suite of features to enhance the user experience. Key functionalities include the ability to modify a speaker's accent in real-time, merge multiple live video streams into a single composite view where users appear to be sitting together in a shared virtual space, digitally alter a user's clothing, and allow users to share only a selected portion of their screen. (’217 Patent, Abstract; col. 2:44-58).
  • Technical Importance: The technology aims to make remote interactions feel more connected and customizable by giving users granular control over their audio and visual representation. (’217 Patent, col. 3:48-54).

Key Claims at a Glance

  • The complaint asserts independent system Claim 1 and independent method Claim 2. (Compl. ¶¶19, 21).
  • Independent Claim 1 requires a system comprising a combination of several features, including:
    • an option to modify a user's accent;
    • an option to merge live video streams so users appear seated together;
    • an option for partial screen sharing;
    • an option to change a user's clothing;
    • an option to choose the display frame;
    • an option to display a looped video; and
    • the option to merge video streams into specific, user-customizable backgrounds and seating arrangements (e.g., a couch of a user-selected color, a conference table, etc.). (’217 Patent, col. 13:53-14:21).

III. The Accused Instrumentality

Product Identification

The complaint names "at least Mcirosoft [sic] Teams" as the Accused Product. (Compl. ¶24).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused product's specific functionality. The infringement allegations rely entirely on a claim chart attached as Exhibit 3, which was not included with the filed complaint document available for review. (Compl. ¶¶24, 30). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint asserts that Microsoft Teams infringes claims 1 and 2 of the ’217 patent but relies on an un-provided exhibit (Exhibit 3) to detail these allegations. (Compl. ¶¶24, 31). A claim chart summary table cannot be constructed. In prose, the infringement theory alleges that Microsoft Teams provides a system and method that includes all the user-selectable "options" recited in the asserted claims, such as accent modification, virtual backgrounds, and partial screen sharing. (Compl. ¶¶19, 21, 24).

Identified Points of Contention

  • Scope Questions: The asserted claims require a system to provide a long list of distinct functionalities. A central dispute may be whether the accused Microsoft Teams product provides every enumerated "option," including the more novel features like real-time accent modification and digitally changing a user's clothing. The absence of even one claimed feature could defeat a literal infringement theory.
  • Technical Questions: What evidence supports the allegation that Microsoft Teams provides an "option to modify an accent of a user"? This is a specific technical capability recited in the claim, and the complaint provides no factual support to show this feature exists in the accused product.
  • Technical Questions: The patent claims require merging video streams into highly specific and customizable environments, such as "seats around a rectangular conference table, wherein the table is of a color selected by a user." (’217 Patent, col. 14:11-13). A question for the court will be whether general-purpose features in Microsoft Teams, such as "Together Mode," meet these specific functional and customization limitations as claimed.

V. Key Claim Terms for Construction

The Term: "an option"

  • Context and Importance: This phrase introduces nearly every element of the asserted independent claims, framing them as a list of available functionalities. Practitioners may focus on this term because its construction will dictate the type of evidence needed to prove the accused product "provides" each claimed feature—for instance, whether a latent capability is sufficient or if an explicit user-facing control is required.
  • Intrinsic Evidence for a Broader Interpretation: The specification does not narrowly define the term, which may support an argument that "option" should be given its plain meaning of a capability or choice available to the user, regardless of its specific implementation.
  • Intrinsic Evidence for a Narrower Interpretation: The patent repeatedly emphasizes giving the user "more control," which may support an interpretation that an "option" requires an explicit, user-selectable interface element. (’217 Patent, col. 4:40-41). The detailed description provides examples where users actively select features, such as by clicking on a display panel. (’217 Patent, col. 7:6-14).

The Term: "modify an accent of a user"

  • Context and Importance: This is a distinct technical limitation that may be a focal point of the infringement analysis. The definition of this term will determine whether any audio-altering effect could meet the limitation, or if a more sophisticated, real-time phonetic transformation is required.
  • Intrinsic Evidence for a Broader Interpretation: The patent describes the function as changing "verbal output within the same language from 1 accent to another accent," which could be argued to encompass any process that achieves this audible result. (’217 Patent, col. 4:58-61).
  • Intrinsic Evidence for a Narrower Interpretation: The specification describes a process of analyzing and translating each word of received audio into a selected accent and provides a list of very specific accent pairs (e.g., "Australian English" to "American English," "Mandarin Chinese from mainland China" to "Mandarin Chinese from Taiwan"). (’217 Patent, col. 7:41-47; col. 9:26-34). This could support a narrower construction requiring a high-fidelity transformation between specific dialects.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement based on Microsoft’s distribution of "product literature and website materials" that allegedly instruct customers on how to use Teams in an infringing manner. (Compl. ¶28). It also alleges contributory infringement, asserting that Teams is "especially made or adapted for infringing" and has "no substantial non-infringing use," although it provides no specific facts to support the latter assertion. (Compl. ¶29).
  • Willful Infringement: The willfulness allegation is based on pre-suit knowledge. The complaint alleges Microsoft had actual knowledge of the ’217 patent as of November 4, 2023, via a LinkedIn message that was allegedly acknowledged in an email by Microsoft’s counsel. (Compl. ¶26). The complaint alleges infringement continued after this date. (Compl. ¶27).

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

  • A core issue will be one of evidentiary proof: The claims require a combination of numerous, specific features. The case may turn on whether the plaintiff can produce sufficient evidence that Microsoft Teams actually performs every single claimed function, particularly the less common ones such as real-time accent modification and digital clothing changes.
  • A key legal question will be one of claim scope: The asserted claims are structured as a long "laundry list" of features. The court will need to determine if an accused general-purpose platform like Microsoft Teams, which serves a wide variety of functions, can be found to practice the entire specific combination recited in the claims, or if the absence of any single element is fatal to the plaintiff's infringement case.
  • A central technical question will be one of functional specificity: Does a generalized feature in the accused product, such as a virtual background mode, perform the specific, highly customizable function required by the claims (e.g., placing users on a "couch, wherein the couch is of a color selected by a user")? The dispute will likely examine the degree of mismatch between the accused product's actual operation and the patent's detailed functional descriptions.