IP Law Daily, PATENT—D. Del.: Multimedia distribution patent held invalid under Alice, (Sep 26, 2025)
Law Firms Mentioned:Richards, Layton, & Finger, PA | Shaw Keller LLP | Smith, Katzenstein, & Jenkins LLP
Organizations Mentioned:Deluxe Media Inc. | Digital Cinema Distribution Coalition, LLC | Digital Media Technology Holdings, LLC | Richards Layton & Finger, PA | Shaw Keller, LLP | Smith Katzenstein & Jenkins, LLP
By Kevin M. Finson, J.D.
Patent claims relating to distribution of multimedia with correlated advertising material were held invalid because they simply carried out well-known business practices using generic and conventional computer technology.
Two different media companies showed that a certain patent for multimedia marketing was invalid for being directed at an abstract idea, the U.S. District Court in Wilmington has held in two different but highly similar opinions. The asserted claims were directed to longstanding human activities merely carried out on generic computer technology, (Digital Media Technology Holdings, LLC v. Digital Cinema Distribution Coalition, LLC and Digital Media Technology Holdings, LLC v. Deluxe Media, Inc., Nos. 1:24-cv-01321-JCG; 1:25-cv-00038-JCG (D. Del. Sept 24, 2025)).
Digital Media Technology Holdings, LLC (Digital Media) was the owner of U.S. Patent No. 7,574,725 (the ’725 Patent), which related to the marketing and distribution of multimedia material for distribution over a computer network to exhibitors and broadcasters using a central server which allowed such exhibitors and broadcasters to preview available programing, verify ownership, and review contract provisions and advertising materials for that programming.
Digital Media brought suit, separately, against Digital Cinema Distribution Coalition, LLC (Digital Cinema) and Deluxe Media, Inc. (Deluxe) in the federal district court of Delaware, alleging that their respective services infringed the ’725 patent. The defendant in each case moved to dismiss on the ground that the ’725 patent was invalid for being directed at a patent-ineligible abstract idea. In two separate, but nearly-identical opinions, the court first found Claim 1 representative for the purposes of the motion and then applied the two-step Alice test.
Abstract idea. Digital Media argued that the claims were not abstract because they involved specific steps describing a specific method for packaging both the multimedia material and advertising material which it described as “correlated information.” The court found that the claimed steps were generic, e.g. receiving, storing, and transmitting media content, and that this merely applied computer technology to distribution of media and marketing thereof, which were long-known business practices and therefore abstract ideas.
Inventive concept. Digital Media argued that the correlating of advertising material with the multimedia constituted an inventive concept which should save patentability. The court found that the claim language did not actually recite any specific improvements to computer technology, but only carried out the abstract idea using generic computer components in conventional ways.
The court granted both motions to dismiss.
The case is No. 1:24-cv-01321-JCG; and No. 1:25-cv-00038-JCG.
Judge: Choe-Groves, J.
Attorneys: Robert J. Katzenstein, Neal C. Belgam, and Daniel A. Taylor (Smith, Katzenstein, & Jenkins LLP) for Digital Media Technology Holdings, LLC. Karen Elizabeth Keller (Shaw Keller LLP) for Deluxe Media Inc. Jason J. Rawnsley (Richards, Layton, & Finger, PA) for Digital Cinema Distribution Coalition, LLC.
Companies: Digital Media Technology Holdings, LLC; Deluxe Media Inc.; Digital Cinema Distribution Coalition, LLC
Cases: Patent TechnologyInternet DelawareNews