DCT

1:26-cv-00613

Grecia v. Roc Nation LLC

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Key Events
Amended Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-00613, D. Del., 06/22/2026
  • Venue Allegations: The First Amended Complaint does not contain specific venue allegations, incorporating them by reference from a prior, unprovided original complaint.
  • Core Dispute: Plaintiff has filed suit for patent infringement; however, the provided First Amended Complaint does not specify the patents-in-suit or accused products, instead serving primarily to add defendants to the case.
  • Technical Context: The intellectual property provided for analysis relates to the ornamental design of animated graphical user interfaces (GUIs) for financial transaction applications on display screens.
  • Key Procedural History: The key procedural event is the filing of a First Amended Complaint for the stated purpose of adding Live Nation Entertainment, Inc. and Liberty Live Holdings, Inc. as defendants. The filing incorporates all substantive allegations from an original complaint that was not provided for this analysis.

Case Timeline

Date Event
2020-09-03 U.S. Design Patent No. D931,899 Priority Date (Filing Date)
2021-09-28 U.S. Design Patent No. D931,899 Issue Date
2026-06-22 First Amended Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

The First Amended Complaint does not explicitly identify any patents-in-suit, instead incorporating all such allegations from a prior pleading by reference Compl. ¶1 Compl. ¶13 Assuming U.S. Design Patent No. D931,899 S, provided for this analysis, is representative of the intellectual property at issue, its details are as follows.

  • Patent Identification: U.S. Design Patent No. D931,899 S ("the '899 Patent"), DISPLAY SCREEN PORTION WITH ANIMATED GRAPHICAL USER INTERFACE, issued September 28, 2021.
  • The Invention Explained:
    • Problem Addressed: As a design patent, the '899 Patent does not articulate a technical problem. Instead, it protects a new, original, and ornamental design for an article of manufacture, which in this case is a graphical user interface.
    • The Patented Solution: The patent claims the specific ornamental appearance of an animated GUI for a financial transaction, presented in two embodiments. The core design involves a sequential transition between different interface states '899 Patent, DESCRIPTION For instance, the first embodiment transitions from an initial screen showing options like "Send Request Split" ʼ899 Patent, FIG. 1 to a second screen showing a central box and a "CANCEL" option ʼ899 Patent, FIG. 2 The claimed design consists only of the elements shown in solid lines; the broken-line portions showing the display screen, text, and other GUI elements are explicitly disclaimed and form no part of the claimed design '899 Patent, DESCRIPTION
    • Technical Importance: The design addresses the user experience of mobile payment applications by providing a specific visual and animated sequence for conducting transactions.
  • Key Claims at a Glance:
    • The patent contains a single claim: "The ornamental design for a display screen portion with animated graphical user interface, as shown and described" '899 Patent, CLAIM
    • The visual elements of this design claim, as depicted in the first embodiment, include:
      • A first state comprising a rectangular input box positioned above three adjacent, smaller rectangular elements, all within the lower portion of a display screen '899 Patent, FIG. 1
      • A second state comprising a larger, square-shaped element positioned centrally above a smaller rectangular element in the lower portion of the screen '899 Patent, FIG. 2
    • The complaint does not assert any claims.

III. The Accused Instrumentality

The First Amended Complaint does not identify any accused products, methods, or services. It incorporates such allegations by reference from a prior, unprovided complaint Compl. ¶1 Compl. ¶13

IV. Analysis of Infringement Allegations

The First Amended Complaint contains no specific infringement allegations, claim charts, or factual descriptions of infringement. All such allegations are incorporated by reference from the original complaint, which was not provided for this analysis Compl. ¶13

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

For a design patent, the "claim" is understood to be the design itself as depicted in the drawings. The central analysis is not the construction of textual terms but the comparison of the overall ornamental design to that of the accused product.

  • The Term: "The ornamental design... as shown and described" '899 Patent, CLAIM
  • Context and Importance: The scope of this term is the entire basis of a design patent case. The infringement analysis will turn on the "ordinary observer" test-whether an ordinary observer, familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design. Practitioners may focus on how the disclaimed portions (e.g., text, device shape) affect the perception of the claimed solid-line design elements.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party arguing for broader scope may emphasize the overall visual impression created by the arrangement and animation of the solid-line shapes. They might argue that the core design is the general layout and transition between a multi-option input state and a single-action confirmation state, irrespective of the precise contours, as shown across the embodiments '899 Patent, FIG. 1 '899 Patent, FIG. 3
    • Evidence for a Narrower Interpretation: A party arguing for narrower scope may focus on the exact proportions, placement, and appearance of the solid-line elements as depicted in the figures '899 Patent, FIG. 1-5 They could also point to the patent's explicit disclaimers of the display screen, text, and other GUI elements as evidence that the claimed design is limited to nothing more than the specific graphical shapes shown in solid lines '899 Patent, DESCRIPTION

VI. Other Allegations

  • Indirect Infringement: The First Amended Complaint does not contain allegations of indirect infringement.
  • Willful Infringement: The First Amended Complaint does not explicitly allege willful infringement. However, it does state that the newly added defendants, Live Nation Entertainment, Inc. and Liberty Live Holdings, Inc., were "provided notice concerning Plaintiff's claims" and that written demands were transmitted Compl. ¶8 Compl. ¶9 These allegations may form a basis for a willfulness claim asserted in the original complaint or a future pleading.

VII. Analyst's Conclusion: Key Questions for the Case

As the provided First Amended Complaint is procedural and lacks substantive allegations, the primary questions are foundational.

  • A key procedural question will be establishing the alleged connections between the various defendants (PayPal, Roc Nation, Live Nation, Liberty Live) and the purported infringing activity, a matter the plaintiff notes requires discovery Compl. ¶11
  • Assuming the '899 Patent is at issue, a core issue will be one of design comparison: from the perspective of an ordinary observer familiar with the prior art, is an (as-yet-unidentified) accused graphical user interface substantially the same as the ornamental design claimed in the '899 Patent?
  • A central evidentiary question will be the content of the original complaint, which is incorporated by reference and contains the necessary factual basis for the claims, including the identity of the accused products and the specific theory of infringement Compl. ¶13
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