On Friday, plaintiff Media Chain LLC filed a complaint in the Western District of Texas against defendant Roku Inc., alleging that Roku infringed its patents by utilizing its patented method for streaming content to users.
The patents-in-suit are United States Patent Nos. 9,715,581 (the ’581 patent); 9,898,590 (the ’590 patent); 10,489,560 (the ’560 patent); 10,515,191 (the ’191 patent); 10,860,691 (the ’691 patent); and 10,885,154 (the ’154 patent). These patents relate to “(s)ystems and methods for monetizing the reproduction of digital media content for the rights-holders of the digital media content.”
For example, the plaintiff averred that Roku infringed at least claim 1 of the ’581 patent, which is “(a) computer implemented method for providing a multimedia hardware device to generate an authorized reproduction of a media content item included in a digital media file, comprising: loading a digital media file for reproduction, wherein the digital media file includes the media content item; analyzing the digital media file to identifying digital media information associated with the media content.”
According to the claim chart, Roku purportedly infringed the ’581 patent because a Roku account gives the customer access to a variety of streaming content in the Roku Channel Store.
The plaintiff added that Roku TV “is a standalone smart TV with built-in TV display and a simple, intuitive interface that lets you stream content over the internet from services such as Netflix.” Accordingly, “(t)he ChannelStore node and Roku Pay web services are used together to manage the on-device authentication and entitlements in channels” to determine the customer’s existing subscription(s), which is sent to Roku’s validation system to determine the customer’s entitlement. As described in the patent, if the customer is entitled, the customer is granted access to the content; if the customer is not entitled, the customer is prompted to subscribe. Afterward, upon entitlement, the user can select content to play.
The plaintiff claimed that Roku also collects user data and data from online activity for advertisement purposes. Furthermore, the plaintiff stated that Roku’s “Viewership Details table shows the number of visits, streams, streaming hours and rebuffers per streaming hour by Roku device,” thus as stated in the patented claim, Roku is “aggregating the user data into a statistics record for the license request” via the Viewership Details and Visits and Stream Visualization. The plaintiff proffered that Roku secures personal information, issues and analyzes a channel engagement report and summary statistics, some of which is provided to the copyright owner. As a result, the plaintiff alleged that Roku infringed the ’581 patent. Additionally, the allegations for the remaining patents-in-suit are similar to the allegations for the ’581 patent.
Roku is accused of directly infringing the patents-in-suit. The plaintiff has sought declaratory judgment in its favor, an award for damages or a reasonable royalty, prejudgment interest, an award for costs, to enjoin Roku from further infringement, and other relief.
Media Chain is represented by Morgan & Morgan PA.