The complaint
The case is Camada Solutions LLC v. Discord Inc., No. 1:26-cv-01276 (D. Del.). The complaint says Camada is a Texas limited liability company with its principal place of business in Barreiro, Portugal, and that the patent's sole inventor, Harald Amundsen, is its sole member and manager. Venue is pleaded under 28 U.S.C. 1391(b) and 1400(b) because Discord is incorporated in Delaware. The '764 patent, titled Method, Navigation and Display System for Widgets on Internet-Enabled Devices, issued May 27, 2014, and the complaint says it expires September 15, 2030.
The claims
Claim 1 recites a system for providing widgets on a display of a TV unit provided with an internal or external Internet-enabled device which provides Internet to the TV unit, the system comprising an internal or external control device for controlling the TV unit. The Internet-enabled device is configured to provide navigation, presentation, and use of widgets on the display of the TV unit together with "a normal TV-sending, other programs, or videos" that a user desires to watch, and is arranged for managing two widget modes: "sticky on change," in which the widget's notifications for off-screen widgets appear on the display of the TV unit for a certain time when their content has been updated or changed, and "sticky," in which the widget remains on the display of the TV unit when the user exits the widget mode. Claim 6 recites a method for providing widgets on such a display, comprising communicating with a web portal for retrieving themes, widgets and widgets profiles by means of the Internet-enabled device; defining and uploading themes, widgets and widgets profiles; providing the widgets on the display of the TV unit together with "a normal TV-sending, other programs, or videos that a TV-viewer desires to watch"; navigating widgets and widgets profiles; and managing the same two widget modes.
The claims recite a TV unit, and the accused products run on Windows desktop computers, Meta Quest headsets, and Android phones. The complaint relies on a specification passage (column 3, lines 20-22) stating that the TV unit "could also include the control device ... in addition to the Internet-enabled device," which the complaint describes as "smartphones and the like"; the patent's next sentence gives "PDAs, mobile phones, and iPhones" as examples. The complaint also says claim 6, as a method claim, recites no separate control device. It matches "sticky on change" to Discord activity such as new messages, mentions, reactions, invites, calls, and voice activity, and says the inventor amended the independent claims during prosecution, in a December 2, 2013 amendment, to require notifications for off-screen widgets.
Theories and relief
The single count pleads direct infringement of at least claim 1 under 35 U.S.C. 271(a) and of at least claim 6 through the operation and use of Discord's software and service architecture; inducement of at least claims 1 and 6 under 35 U.S.C. 271(b) through Discord's download pages, Game Overlay and Mobile Voice Overlay support pages, in-app overlay settings, Discord for Meta Quest materials, and mobile notification settings materials; and contributory infringement of at least claims 1 and 6 under 35 U.S.C. 271(c) with respect to the Windows Game Overlay. The complaint alleges knowledge at least as of the filing and service of the complaint and reserves the right to seek enhanced damages "if discovery shows that Defendant deliberately or intentionally continued its infringement after learning of the '764 Patent and continued infringing despite an objectively high risk that its conduct infringed." The prayer asks for damages, enhanced damages "to the extent permitted by law and supported by the evidence," an exceptional-case finding and fees under 35 U.S.C. 285, a preliminary and permanent injunction, and, in lieu of a permanent injunction, an ongoing royalty.
What to watch next
Watch for Discord's answer or any motion to dismiss, any petition for inter partes review of the '764 patent, and any claim construction dispute over the claims' TV unit language. The case can end at any time by license, settlement, or dismissal.