D&M Holdings Inc v. Sonos Inc.

D&M Holdings Inc v. Sonos Inc, No. 16-141 (D. Del. Apr. 18, 2017) 

Patent(s):

  • 7,343,435 | Entitled “Stream based compressed file download with interruption recovery”
  • 7,734,850 | Entitled “Method for stream based compressed file download with interruption recovery and further decompressing and dearchiving data in file system”
  • 6,539,210 | Entitled “Automatic assignment and tuning of radio call letters to radio presets”
  • 7,305,694 | Entitled “Method and apparatus for remotely controlling a receiver according to content and user selection”

Disposition:               

Grant of Defendant’s 12(b)(6) motion as to ‘435 patent and ‘694 patent, denial as to ‘850 patent and ’210 patent

Abstract Idea:

Yes (‘435 patent and ‘694 patent)

Something More:

No (‘435 patent and ‘694 patent)

Technology:              

  • System and method are provided for storing and using recovery state information during a data stream transfer, such as a download (‘435 patent, ‘850 patent).
  • Method for matched broadcast signals with signal information, such as call letters, genre and geographical location for corresponding signal sources, based on the geographical location of the receiver and the frequency at which the signals are broadcast (‘210 patent).
  • System and method for automatically controlling a media receiver by instructing the media receiver to use a particular receiver connection and to play a selected media unit using one of a plurality of play modes according to characteristics of the media unit (‘694 patent).

Summary:                 

As to the ‘435 patent, the Court concluded the claims were directed to the abstract idea of receiving, detecting, and storing data that is not tied to any device. The representative claim requires “1) receiving a compressed data stream; 2) detecting compression block, archive block, and file boundaries; and 3) saving the information detected in step 2” which is substantively similar to various Federal Circuit decisions holding collecting and storing data is an abstract idea. The claims recite no improvement in data storage or receipt, and the claim does not otherwise cover an improvement in existing technology. 

As to the ‘850 patent, the Court faulted Defendant’s insufficient explanation for why the representative claim failed for the same reasons as the claims of the ‘435 patent. Ultimately, the Court held that Defendant had oversimplified and ignored specific limitations of the representative claim of the ‘850 patent, which the court noted is “more specific” than the corresponding claim of the ‘435 patent. Further, the claim was plausibly directed to an improvement in data management, the resumption of an interrupted file download and a specific use of information to accomplish this. 

As to the ‘210 patent, the Court concluded that construction of some of the terms could impact the Section 101 analysis, as some claims involved mean-plus-function claims, and declined to opine on whether the claims were unpatentable at the pleadings stage. 

As to the ‘694 patent, the Court held the claims were directed to the abstract idea of automating the following process: “1) asking a user to match a receiver connection with an encoding format; 2) identifying the encoding format of a selected piece of media; 3) identifying the receiver connection matched to the encoding format in step 1; 4) telling the receiver to use the receiver connection found in step 3.” The specification effectively admitted this is performed by a user each time a media is selected in the media management system. The Court did not find any technological solution in the claim language, and found no inventive concept. For those reasons, the Court found the asserted claims of the ‘694 patent are invalid for lack of patentable subject matter.