Case 6:21-cv-00569 Document 1 Filed 06/04/21 Page 1 of 32
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`TOUCHSTREAM TECHNOLOGIES,
`INC.
`
`Plaintiff,
`
`v.
`
`Civil Action No. 6:21-cv______
`
`GOOGLE LLC
`
`JURY TRIAL DEMANDED
`
`Defendant.
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Touchstream Technologies, Inc., hereby files this Original Complaint for Patent
`
`Infringement against Google LLC and alleges, upon information and belief, as follows:
`
`THE PARTIES
`
`1.
`
`Plaintiff Touchstream Technologies, Inc., d/b/a Shodogg (“Touchstream” or
`
`“Plaintiff”) is a New York corporation with its principal place of business in New York, New
`
`York.
`
`2.
`
`Defendant Google LLC (“Google” or “Defendant”) is a Delaware limited liability
`
`corporation with its principal place of business at 1600 Amphitheatre Parkway, Mountain View,
`
`CA 94043. Google maintains a permanent physical presence within the Western District of Texas,
`
`conducting business from its offices at 500 West 2nd Street, Austin, Texas, 78701. Google may
`
`be served with process through its registered agent CSC – Lawyers Incorporating Service
`
`Company, at 211 E. 7th Street, Suite 620, Austin, Texas 78701. Google is currently registered to
`
`do business in the State of Texas, and has been since at least November 17, 2006.
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`NATURE OF THE ACTION
`
`3.
`
`This is a civil action against Google for patent infringement arising under the patent
`
`statutes of the United States, 35 U.S.C. § 271 et seq. for the infringement of United States Patent
`
`Nos. 8,356,251 (the “’251 patent”), 8,782,528 (the “’528 patent”), and 8,904,289 (the “’289
`
`patent”) (collectively, “the Touchstream Patents”). True and correct copies of the ’251 patent, the
`
`’528 patent, and the ’289 patent are attached as Exhibits 1, 2, and 3, respectively, to this Complaint.
`
`JURISDICTION AND VENUE
`
`4.
`
`This action arises under the patent laws of the United States, Title 35 of the United
`
`States Code. This Court has subject matter jurisdiction over the subject matter of this action under
`
`28 U.S.C. §§ 1331 and 1338(a).
`
`5.
`
`This Court has personal jurisdiction over Google in this action because Google has
`
`committed acts within the Western District of Texas giving rise to this action and has established
`
`minimum contacts with this forum such that the exercise of jurisdiction over Google would not
`
`offend traditional notions of fair play and substantial justice. Google has engaged in continuous,
`
`systematic, and substantial activities within this State, including substantial marketing and sales of
`
`products—including the Chromecast products1 that are used by Google in connection with
`
`performing the accused Chromecast functionalities2—within this State and this District.
`
`Furthermore, Google—directly and/or through subsidiaries or intermediaries—has committed and
`
`continues to commit acts of infringement in this District by, among other things, using and
`
`providing the Chromecast service.
`
`6.
`
`Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b) and (c) and/or
`
`1400(b). As discussed above, Google currently has a regular and established place of business in
`
`1 The term “the Chromecast products” is defined at ¶ 48, infra.
`2 The term “accused Chromecast functionalities” is defined at ¶ 48, infra.
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`this District, and has committed and continues to commit acts of patent infringement in this
`
`District.
`
`7.
`
`Google maintains a regular and established place of business within the Western
`
`District of Texas, conducting business from its offices at 500 West 2nd Street, Austin, Texas,
`
`78701.
`
`2007.3
`
`8.
`
`9.
`
`Public reporting indicates that Google has maintained an office in Austin since
`
`Additionally, reporting indicates that Google currently owns or leases over 500,000
`
`square feet of office space in downtown Austin across at least three locations: 100 Congress Ave.,
`
`901 E. Fifth St., and 500 W. Second St. Google has also indicated that it is scheduled to open
`
`another 750,000 square feet of office space in Austin, at 601 W. Second St.4
`
`10.
`
`Google currently employs over 1,100 persons in Austin and—as of June 2019—
`
`Austin was Google’s seventh-largest office outside of the San Francisco Bay Area.5 As of June 1,
`
`2021, Google had job postings for 219 positions in Austin, Texas.6
`
`11.
`
`Google directly and/or indirectly develops, designs, tests, distributes, markets,
`
`offers to sell, sells, and/or utilizes the Chromecast products that Google uses to perform the
`
`accused Chromecast functionalities in the Western District of Texas, and otherwise purposefully
`
`directs infringing activities to this District in connection with its Chromecast products.
`
`3 See, e.g., https://www.builtinaustin.com/2019/06/17/google-new-offices-austin-data-center-
`midlothian.
`4 See, e.g., https://www.kvue.com/article/money/economy/boomtown-2040/google-austin-texas-
`real-estate-report/269-2ce6e60e-e8c3-46f5-aca6-864175e67950.
`5 See, e.g., https://austonia.com/technology/google-austin-office, citing
`https://www.statesman.com/news/20190614/google-says-it-plans-significant-expansion-in-
`austin.
`6 Search conducted via
`https://careers.google.com/locations/austin/?src=Online%2FHouse%20Ads%2FAdSitelinks.
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`12.
`
`On information and belief, the Chromecast products are sold at a variety of retailers
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`in Austin and/or Waco, Texas—including Walmart, Target, Best Buy, Sam’s Club, Lowes, and
`
`Office Depot.
`
`13.
`
`According to Google, its network infrastructure consists of three elements: data
`
`centers, Edge Points of Presence (“PoPs”), and Edge Nodes (“Google Global Cache,” or “CGC”).7
`
`14.
`
`According to Google, its data centers “are the heart of Google content and
`
`services.” 8 Google purportedly owns and operates a $600 million data center in Midlothian,
`
`Texas, which is located in Ellis County, within the Northern District of Texas.9 According to
`
`Google, such data centers “keep all of Google’s products and services up and running around the
`
`clock and around the world.”10
`
`15.
`
`According to Google, it operates “a large, global meshed network that connects our
`
`Edge PoPs to our data centers.”11 Google purports to operate two points of presence (“PoPs”) in
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`Dallas and/or Fort Worth, Texas.
`
`16.
`
`According to Google, it operates Edge Nodes that are used by network operators to
`
`“deploy Google supplied servers” within their networks, and some nodes are used “to support the
`
`delivery of . . . Google services.” 12 According to Google, it currently operates three “network
`
`7 See, e.g., https://peering.google.com/#/infrastructure.
`8 Id.
`9 See, e.g.,
`https://www.google.com/about/datacenters/locations/midlothian/#:~:text=Google%20is%20prou
`d%20to%20call,data%20center%20in%20Midlothian,%20Texas.
`https://www.kvue.com/article/money/economy/boomtown-2040/google-austin-texas-real-estate-
`report/269-2ce6e60e-e8c3-46f5-aca6-864175e67950.
`10 See, e.g., https://www.google.com/about/datacenters/faq/.
`11 See, e.g., https://peering.google.com/#/infrastructure.
`12 Id.
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`edge locations” in Dallas, Texas.13 According to Google, at least one Edge Node (GGC) is located
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`in or close to Austin, Texas. 14
`
`17.
`
`On information and belief, the team lead or “director” responsible for the
`
`development and execution of Google’s initial go-to-market strategy, global retail sales strategy,
`
`and hardware distribution for Chromecast, as well as the development of partnerships for
`
`Chromecast, currently resides in or around Austin, Texas, and is currently employed by Google.
`
`18.
`
`On information and belief, at least one person involved in the discussion between
`
`Touchstream and Google regarding a potential partnership related to the technology invented by
`
`Touchstream, as described further below, currently resides in Texas.
`
`19.
`
`On information and belief, at least one Chromecast “partner” who produces video
`
`content that can be streamed via a Chromecast enabled application is located in Austin, Texas.
`
`20.
`
`On information and belief, at least one Chromecast “partner” live-streams sports
`
`matches from Austin (as well as other locations) for a sports team located in Austin, Texas, via a
`
`Chromecast enabled application.
`
`TOUCHSTREAM’S PATENTS
`
`21.
`
`In 2010, David Strober, the inventor of the Touchstream Patents and the original
`
`founder of Touchstream, was working at Westchester Community College as a Program Manager
`
`and e-learning instructional designer. At this job Mr. Strober facilitated the development of online
`
`college courses, developing software as needed to support those efforts.
`
`22.
`
`At least as early as mid-2010, Mr. Strober perceived the need to be able to take
`
`videos that could be viewed on a smaller device, like a smartphone, and “move” them to a larger
`
`screen, like a computer monitor or television. In working to bring his idea to fruition, Mr. Strober
`
`13 See, e.g., https://cloud.google.com/vpc/docs/edge-locations.
`14 See, e.g., https://peering.google.com/#/infrastructure.
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`expanded his work by using a device like a smartphone to cause a video to play on a second screen,
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`even if that video resided elsewhere (like the public internet). Near the end of 2010, Mr. Strober
`
`had developed a working prototype that demonstrated his groundbreaking concept. Recognizing
`
`that that his invention could revolutionize how people located, viewed, and shared media, Mr.
`
`Strober filed his first patent application in April 2011.
`
`23.
`
`Each of the Touchstream Patents, which are each entitled “Play Control of Content
`
`on a Display Device,” claims priority to U.S. Provisional Patent Application No. 61/477,998 (filed
`
`on April 21, 2011).
`
`24.
`
`On January 15, 2013, the U.S. Patent and Trademark Office duly and legally issued
`
`the ’251 patent to inventor David Strober.
`
`25.
`
`Touchstream is the owner, by assignment, of all rights, title, and interest in the ’251
`
`patent.
`
`26.
`
`On July 15, 2014, the U.S. Patent and Trademark Office duly and legally issued the
`
`’528 patent to inventor David Strober.
`
`27.
`
`Touchstream is the owner, by assignment, of all rights, title, and interest in the ’528
`
`patent.
`
`28.
`
`On December 2, 2014, the U.S. Patent and Trademark Office duly and legally
`
`issued the ’289 patent to inventor David Strober.
`
`29.
`
`Touchstream is the owner, by assignment, of all rights, title, and interest in the
`
`’289 patent.
`
`BACKGROUND OF THE DISPUTE
`
`TOUCHSTREAM REVOLUTIONIZES VIDEO STREAMING
`
`30.
`
`In 2011, inventor David Strober officially incorporated Touchstream to share his
`
`inventions with the world.
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`31.
`
`32.
`
`In the following years, Touchstream raised millions of dollars in investments.
`
`Since 2011, Touchstream, d/b/a “Shodogg,” developed software that enables
`
`content to be wirelessly cast (e.g., accessed, displayed, and controlled) from a mobile device to a
`
`second display screen (e.g., TV, computer, tablet, etc.). Touchstream has been a leader in
`
`developing casting technology and has received numerous awards and recognition.
`
`33.
`
`Unfortunately, the efforts of Touchstream and Touchstream’s partners to
`
`appropriately monetize Mr. David Strober’s inventions were significantly hindered by
`
`infringement of the Touchstream Patents, including by Google. The timing and scope of Google’s
`
`infringement is discussed in more detail below.
`
`GOOGLE MEETS WITH TOUCHSTREAM IN 2011-2012 TO LEARN ABOUT THE
`PATENTED TOUCHSTREAM TECHNOLOGY
`
`34.
`
`Since at least December 14, 2011, Touchstream has made clear that its
`
`revolutionary product offerings were “patent-pending.”15
`
`35.
`
`Just days after the first Touchstream Patent issued on January 15, 2013,
`
`Touchstream issued a press release announcing this patent award.16
`
`15 See e.g., Sean Ludwig, Shodogg will let you pause and restart video from any device
`(exclusive), VentureBeat (Dec. 14, 2011 7:00 AM), https://venturebeat.com/2011/12/14/shodogg-
`video-sharing-phones-tvs-exclusive/; Shodogg, Shodogg Launches at CES and Transforms
`Streaming Video Delivery by Fueling Industry Expansion with Content Providers, Cision PR
`Newswire (Jan. 10, 2012, 9:43 ET), https://www.prnewswire.com/news-releases/shodogg-
`launches-at-ces-and-transforms-streaming-video-delivery-by-fueling-industry-expansion-with-
`content-providers-137010098.html;
`see
`also
`snapshot
`(archived
`https://web.archive.org/web/20111003131546/http://shodogg.com/
`of
`Shodogg website from October 3, 2011) (“Shodogg is a patent-pending technology that allows
`viewers to access online streaming content from any smartphone and display it to any larger
`connected screen, such as a laptop, tablet, or TV.”).
`16 Shodogg, Shodogg announces the release of ScreenDirect a business-to-business solution
`enabling companies to seamlessly direct digital content across screens, Cision PR Newswire (Jan.
`17, 2013 9:15 ET) https://www.prnewswire.com/news-releases/shodogg-announces-the-release-
`of-screendirect-a-business-to-business-solution-enabling-companies-to-seamlessly-direct-digital-
`content-across-screens-187284641.html; See also, e.g., Meet Shodogg Who Won this Year’s
`Competition,
`AlleyWatch
`(12/2014),
`Techweek
`NYC
`Launch
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`36.
`
`In December 2011, Touchstream and Google began discussing a potential
`
`partnership concerning the technology invented by Touchstream.
`
`37.
`
`Touchstream signed Google’s Non-Disclosure Agreement, which provided that
`
`neither company would get rights to the other company’s intellectual property as a result of the
`
`meeting.
`
`38.
`
`39.
`
`Google and Touchstream held a video conference by Skype on December 22, 2011.
`
`At this meeting, the attendees for Touchstream informed the attendees for Google
`
`that Touchstream had filed for a patent on the Touchstream technology being discussed and
`
`demonstrated in the meeting.
`
`40.
`
`In February of 2012, Google informed Touchstream that it did not want to pursue
`
`any business partnership with Touchstream in connection with the presented technology.
`
`41.
`
`One or more of the Touchstream Patents (or their underlying applications) were
`
`cited to or by Google in connection with the following patents and patent applications filed by
`
`Google:
`
`(i) U.S. Patent No. 9,841,939B2, filed December 18, 2014, titled “Methods, systems,
`
`and media for presenting requested content on public display devices” (‘251 patent cited
`
`on face of the issued Google patent);
`
`(ii) U.S. Patent No. 9,916,122B2, filed December 18, 2014, titled “Methods, systems,
`
`and media for launching a mobile application using a public display device” (‘251 patent
`
`cited on face of the issued Google patent);
`
`https://www.alleywatch.com/2014/12/meet-shodogg-who-won-this-years-techweek-nyc-launch-
`competition/.
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`(iii) U.S. Patent No. 9,967,320B2, filed December 18, 2014, titled “Methods, systems,
`
`and media for controlling information used to present content on a public display device”
`
`(the ‘251 patent is cited on face of the issued Google patent);
`
`(iv) U.S. Patent No. 9,367,144B2, filed March 13, 2013, titled “Methods, systems, and
`
`media for providing a remote control interface for a media playback device” (Published
`
`Application No. 2012/0272148, which later issued as the ‘251 patent, is cited on face of
`
`the issued Google patent);
`
`(v) U.S. Patent Application Pub. No. 2015/0046812 A1, filed August 11, 2014, titled
`
`“Dynamic resizable media item player” (Published Application No. 2012/0027214[8],
`
`which later issued as the ‘251 patent, was one of three references identified by Google
`
`on December 4, 2017) (this patent application was later abandoned by Google);
`
`(vi) U.S. Patent No. 10,873,616B1, filed December 10, 2013, titled “Providing content
`
`to co-located devices with enhanced presentation characteristics” (Published
`
`Application No. 2012/0272147, which later issued as the ‘289 patent, and Published
`
`Application No. 2013/0124759, which later issued as the ‘528 patent, is cited on the face
`
`of the issued Google patent);
`
`(vii) U.S. Patent No. 10,412,143B2, filed June 24, 2015, titled “Methods, systems, and
`
`media for presenting content based on user preferences of multiple users in the presence
`
`of a media presentation device” (Published Application No. 2012/0272147, which later
`
`issued as the ‘289 patent, is cited on the face of the issued Google patent);
`
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`(viii) U.S. Patent No. 10,306,323B2, filed December 7, 2016, titled “Fast television
`
`channel change initiated from a second screen device” (the ‘528 patent is cited on the
`
`face of the issued Google patent);
`
`(ix) U.S. Patent No. 9,712,776B2, filed March 15, 2013, titled “Interfacing a television
`
`with a second device” (the ‘251 patent is cited on the face of the issued Google patent);
`
`(x) U.S. Patent No. 9,992,307B2, filed February 3, 2015, titled “Interoperability of
`
`discovery and connection protocols between client devices and first screen devices” (the
`
`‘251 patent and Published Application No. 2012/0272148, which later issued as the ‘251
`
`patent, are both cited on face of the issued Google patent);
`
`(xi) U.S. Patent No. 10,659,518B2, filed March 18, 2019, titled “Contextual Remote
`
`Control” (Published Application No. 2012/0272148, which later issued as the ‘251
`
`patent, is cited on face of the issued Google patent);
`
`(xii) U.S. Patent No. 10,969,950B2, filed May 19, 2015, titled “Dynamic Resizable
`
`Media Item Player” (Published Application No. 2012/0272148, which later issued as the
`
`‘251 patent, is cited on face of the issued Google patent)
`
`(xiii) International Application Publication No. WO 2015/200531, filed June 24, 2015,
`
`titled “Methods, Systems and Media for Presenting Content Based on User Preferences
`
`of Multiple Users in the Presence of a Media Presentation Device” (Published
`
`Application No. 2012/0272147, which later issued as the ‘289 patent, was cited to
`
`Google in a September 25, 2015 International Search Report);
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`(xiv) U.S. Patent Application Pub. No. 2016/0149982 A1, filed May 19, 2015, titled
`
`“Dynamic resizable media item player” (Published Application No. 2012/00272148,
`
`which later issued as the ‘251 patent, was identified by Google on July 17, 2018) (this
`
`patent application was later abandoned by Google).
`
`42.
`
`As such, Google knew about the patent applications leading to the Touchstream
`
`Patents by no later than December 2011.
`
`43.
`
`Google also knew, or at the very least should have known, of the issued
`
`Touchstream Patents on or shortly after the date each such patent was issued, beginning with the
`
`‘251 Patent that issued in January 2013.
`
`44.
`
`At no point in 2011, 2012, or 2013 did Google reach out to Touchstream about
`
`potentially acquiring a license to Touchstream’s pending or awarded patents, and to this day
`
`Google has not requested or received a license to any of the Touchstream Patents.
`
`GOOGLE UNVEILS ITS INFRINGING CHROMECAST SERVICES
`
`45.
`
`Google unveiled its Chromecast product―which performs the infringing
`
`Chromecast functionalities―in July 2013 at a price of $35 per unit.17
`
`46.
`
`As of October 4, 2017, Google announced it had sold 55 million Chromecast
`
`units.18
`
`17 Matt Burns, Google Launches The $35 Chromecast Streaming Device To Bring Chrome To
`Room,
`Tech Crunch
`(July
`24,
`2013,
`11:51 AM CDT)
`The
`Living
`https://techcrunch.com/2013/07/24/google-
`chromecast/?_ga=2.60674024.478449141.1620755451-2045144417.1620755450.
`18 Emil Protalinski, Google has sold 55 million Chromecasts, up from 30 million in July 2016,
`VentureBeat (Oct. 4, 2017) https://venturebeat.com/2017/10/04/google-has-sold-55-million-
`chromecasts-up-from-30-million-in-july-2016/.
`
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`47.
`
`Google’s financial benefit from its Chromecast product is not, however, limited to
`
`revenue from the sale Chromecast units. For instance, the accused Chromecast functionalities also
`
`increase ad revenue to Google and support the collection of data that is valuable to Google.
`
`THE ACCUSED CHROMECAST FUNCTIONALITIES
`
`48.
`
`The accused Chromecast functionalities comprise the methods performed through
`
`operation of at least the standalone Chromecast devices (e.g., the Chromecast 1st Generation,
`
`Chromecast 2nd Generation, Chromecast 3rd Generation, Chromecast Ultra, and Chromecast with
`
`Google TV), as well as devices implementing Chromecast built-in (collectively, “Chromecast” or
`
`“the Chromecast products”) described in ¶¶ 49-62, infra. The Chromecast products did provide in
`
`the past, and continue to provide, functionality and structure that facilitates the controlling of
`
`presentation content, such as audio and/or video content, on a content presentation device that
`
`loads any one of a plurality of different media players (YouTube, e.g.), for instance as illustrated
`
`below.
`
`Source: https://www.youtube.com/watch?v=GbXeZ16FoCY (2013 Google presentation on
`Chromecast functionality).
`
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`49.
`
`Upon initial operation, the Chromecast is connected to a device having a screen
`
`(e.g., a television). The Chromecast may prompt the user, via the screen, to download and open
`
`the Google Home application (or “app”) on the user’s mobile device (e.g., a smartphone or tablet).
`
`Upon opening the Google Home application on the mobile device, the user is shown the option to
`
`“Set up Chromecast.” Upon choosing this option, the Google Home application searches for
`
`devices and locates the Chromecast. The application then prompts the user to set up the
`
`Chromecast device. The mobile device and the Chromecast may be linked via a display of
`
`matching alphanumeric codes on the mobile device and display screen. The Google Home
`
`application running on the mobile device prompts for confirmation that the alphanumeric codes
`
`match. Upon receiving confirmation, the Google Home app and Chromecast are linked.
`
`50.
`
`The Chromecast prompts the user to specify the Chromecast’s location (e.g.,
`
`bedroom or living room) via the Google Home app. Upon receiving location information, the
`
`Chromecast further prompts for a “custom room name” (or “friendly name”) (e.g., “Master
`
`Bedroom” or “Living Room”), which the user provides. An example of this is provided below.
`
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`Exemplary assignment of custom room name on Chromecast 3rd Generation.
`
`That friendly name is then assigned to the Chromecast device by Google for future reference.
`
`Next, the Chromecast prompts for internet connection information (such as the user’s preferred
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`Wi-Fi network) and connects to the internet.
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`51.
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`Once connected to the internet, the Chromecast may present a tutorial screen from
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`which the user can, for instance, choose a sample video clip and learn how to cast it for playback
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`on the display screen via the Chromecast. When the user touches a video clip on the mobile device,
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`a prompt appears on the mobile device screen instructing the user to tap the “Cast” button and
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`select the Chromecast to be used for casting (e.g., “Master Bedroom”). An example of this is
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`provided below.
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`Exemplary tutorial screens on Chromecast 3rd Generation
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`Upon touching cast, a casting session is established and the video clip begins playback on the
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`display screen via the Chromecast.
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`52.
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`The Chromecast is enabled to cast content from a mobile device to a display screen
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`for thousands of both Android and iPhone applications, including video streaming services such
`
`as YouTube, Google Play, Netflix, Hulu, Prime Video, Disney Plus, as well as audio streaming
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`services such as Spotify and Pandora, as indicated e.g. on the cover of the box in which the
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`Chromecast 3rd Generation is packaged and sold:
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`By pressing the “Cast” button in any Chromecast-compatible app running on a user’s mobile
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`device, the user can stream content from the app to a selected Chromecast device and view the
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`content on a television or other display screen connected to the Chromecast.
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`53.
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`Following initial setup, Google periodically pushes software and firmware updates
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`for the Chromecast products, which are downloaded and installed automatically by the Chromecast
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`when it is powered on and connected to the internet.19 Google also requires Chromecast users and
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`developers to abide by Google’s terms of service.20
`
`54.
`
`At the outset of a casting session, the Chromecast-compatible app running on the
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`mobile device (e.g., YouTube or Netflix) causes messages to be sent from the mobile device and
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`19 See https://support.google.com/chromecast/answer/6292664?hl=en.
`20 See https://support.google.com/cast-developer/answer/4513288?hl=en;
`https://developers.google.com/cast/docs/terms; https://developers.google.com/terms/;
`https://policies.google.com/terms?hl=en-US;
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`received by a server system implemented by Google. These messages relate generally to
`
`authentication, selection of the device to cast to, and selection of the casting content.
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`55.
`
`The messages sent from the mobile device and received by the server system
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`include a “networkAddress,” such as an IP address of the Chromecast device, which is assigned to
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`and uniquely identifies the equipment. The messages also include the Chromecast’s user-
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`assignable “friendlyName,” such as “Living Room” or “Master Bedroom.”
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` The
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`“networkAddress” and “friendlyName” are locally unique to the particular Chromecast within the
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`user’s local access network. See example, below. On information and belief, the server system
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`stores a record based on these messages associating the mobile device with the Chromecast, for
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`instance so that an app running on the mobile device continually recognizes which Chromecast
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`device (e.g., “Living Room”) is currently casting and can be controlled.
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`Source: https://support.google.com/chromecast/answer/2995235?hl=en.
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`56.
`
`The messages sent from the mobile device and received by the server system
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`include messaging that specifies a media file (e.g., audio or video) to be acted upon. The media
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`file to be acted upon may be specified by providing, for instance, the uniform resource locator
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`(URL) of the media file, for instance as specified by the contentURL property of the
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`GCKMediaInformationBuilder class in the iOS Sender API,21 which class is further used to build
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`GCKMediaInformation instances that describe a media item to load.22
`
`57.
`
`The messages sent from the mobile device and received by the server system further
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`include messaging that identifies an application for playing content from the specified media file.
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`The appropriate application may be identified by providing, for instance, information about the
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`MIME type of the content to be played or by providing an app ID (“applicationID”) corresponding
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`to a particular receiver application to be used to play back the content from the media file. Google
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`uses the app ID to locate the appropriate receiver application, for example via a “resolved URL
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`associated with the app ID.”23 The receiver application may then be “downloaded from the
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`network” and loaded onto the Chromecast via the resolved URL.24 The receiver application
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`“provides an interface to display the app’s content on the TV” or other display device, and “handles
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`messages from the sender application to control content on the receiver device.”25 The messages
`
`sent from the mobile device and received by the server system also specify the accompanying
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`media codecs needed for playback of different types of content (audio, video, etc.) such as mp3,
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`HE-AAC, h.264, or VP9, as described at https://developers.google.com/cast/docs/media. On
`
`information and belief, loading the receiver app includes loading one or more corresponding
`
`21 See
`https://developers.google.com/cast/docs/reference/ios/interface_g_c_k_media_information_build
`er.
`22 https://developers.google.com/cast/docs/reference/ios/interface_g_c_k_remote_media_client
`23 See https://developers.google.com/cast/docs/caf_receiver/basic.
`24 Id.
`25 See https://developers.google.com/cast/docs/web_receiver.
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`application programming interfaces (APIs) such as the “Web Receiver API” accessed by a
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`reference in the app.26
`
`58.
`
`The Chromecast-compatible app running on the mobile device allows the user to
`
`touch “Play,” “Resume,” or equivalent on the mobile device screen so as to cast the media to the
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`Chromecast and control playback. An example is shown below.
`
`Source: https://support.google.com/chromecast/answer/2995235?hl=en.
`
`26 See https://developers.google.com/cast/docs/web_receiver/basic (“Your Web Receiver app
`accesses the Web Receiver API with the following reference: <script
`src="//www.gstatic.com/cast/sdk/libs/caf_receiver/v3/cast_receiver_framework.js"></script>”);
`see also id. at discussion of “major classes” associated with the Web Receiver SDK framework,
`including cast.framework.CastReceiverContext which “manages overall framework and loads
`any necessary libraries.”)
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`Source: https://support.google.com/chromecast/answer/2995235?hl=en.
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`Source: https://support.google.com/chromecast/answer/2995235?hl=en.
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`Source: https://support.google.com/chromecast/answer/2995235?hl=en.
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`The class GCKUIMediaController is “a controller for UI views that are used to control or display
`
`the status of media playback on a Cast receiver” such as the receiver application running on the
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`Chromecast.27 The controller “responds to touch events on the controls [e.g., on the mobile device]
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`by issuing the appropriate media commands to the receiver.”28 Among the controls associated
`
`with the controller are “a ‘play’ button” (playButton) and “a ‘pause’ button” (pauseButton).29
`
`Further, “Google Cast sender applications control the playback on the receiver device by sending
`
`messages in JSON format to the receiver application.”30 Among the JSON messages are
`
`“commands from the sender that change the player state,” including “Play” (“Begins playback of
`
`the content that was loaded with the load call, playback is continued from the current time
`
`27 See
`https://developers.google.com/cast/docs/reference/ios/interface_g_c_k_u_i_media_controller.
`28 Id.
`29 Id.
`30 See https://developers.google.com/cast/docs/reference/messages,
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`position), “Pa