Sound View Innovations, LLC v. Hulu, LLC, Appeal No. 2024-1092 (Fed. Cir. Jan. 29, 2026)

This week, the Federal Circuit affirmed a district court’s grant of summary judgment of noninfringement for appellee Hulu, finding that Hulu did not infringe method claim 16 of Sound View Innovations’ U.S. Patent No. 6,708,213. The now-expired ‘213 patent – titled “Method for Streaming Multimedia Information over Public Networks” – discloses methods and apparatuses that reduce network latency while increasing the quality of media streamed to the devices of end-user customers.

Sound View brought this case against Hulu on June 2, 2017, alleging infringement of six patents, although only claim 16 of the ‘213 patent was at issue in this appeal. In the underlying case in the Central District of California, Sound View contended that Hulu infringed claim 16 by directing third-party edge servers (“helper servers”) to perform every step of the asserted claim, which recites “[a] method of reducing latency in a network” and a list of steps comprising the method.  This appeal represented the second time the case has been before the Federal Circuit, with the Court having previously found that the district court erred in its construction of the term “buffer” as used in the claims.

In reviewing the lower court’s second grant of summary judgment of non-infringement to Hulu, the Federal Circuit held that the district court (1) again erred in its construction of the claimed term “buffer,” but (2) correctly construed claim 16 to require a specific order of operation. Because the second ground independently supported the grant of summary judgment, the Court affirmed the district court’s ruling.

In evaluating the lower court’s construction of the term “buffer,” the Court acknowledged that while “a claim term may be clearly redefined without an explicit statement of redefinition,” there was “no reason to depart from the plain and ordinary meaning” in this instance.  The Court therefore held the district court erred in narrowing the claimed “buffer” in its construction to be a specialized kind of buffer.

However, the Court affirmed the district court’s determination that claim 16 requires a specific sequence for the first two recited steps in the claim.  While neither party disputed that the accused products did not perform the claim limitation in the order required by the district court, the parties disagreed on whether claim 16 required an order at all. The Federal Circuit determined that both the grammar and logic of claim 16 required steps to be performed in order, because “implicit ordering exists when there are inherent logical dependencies or functional relationships between the recited steps of a method claim.” Such dependencies and relationships were present in claim 16. The Court concluded that, because the accused products did not perform the claim limitations in the required sequence, they did not infringe. As such, it affirmed the lower court’s grant of summary judgment of noninfringement for Hulu.

The opinion can be found here.

By Julia Davis

This article summarizes aspects of the law and does not constitute legal advice. For legal advice with regard to your situation, you should contact an attorney.