Boomcloud 360 Inc v. T-Mobile USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Boomcloud 360, Inc. (Delaware)
  • Defendant: T-Mobile USA, Inc. (Delaware)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 2:26-cv-00080, E.D. Tex., 01/30/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant T-Mobile maintains regular and established places of business in the district, including specifically identified retail stores, and has previously not contested venue in the district in other patent cases.
• Core Dispute: Plaintiff alleges that Defendant’s electronic devices with spatial audio capabilities infringe three U.S. patents related to improved audio rendering and spatial audio processing.
• Technical Context: The technology at issue involves digital signal processing techniques designed to create a more immersive, three-dimensional sound field from standard stereo audio outputs, such as speakers or headphones.
• Key Procedural History: The complaint alleges that the parties engaged in extensive pre-suit interactions between 2017 and 2023 under a non-disclosure agreement, which included technical demonstrations and the exchange of licensing term sheets. Plaintiff asserts that Defendant ultimately implemented the technology without a license, and these interactions form the basis of the willful infringement allegations.

Case Timeline

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

U.S. Patent No. 10,721,564 - "Subband Spatial and Crosstalk Cancellation for Audio Reproduction"

• Patent Identification: U.S. Patent No. 10,721,564, "Subband Spatial and Crosstalk Cancellation for Audio Reproduction," issued July 21, 2020 Compl. ¶20

The Invention Explained

• Problem Addressed: In standard stereo playback, sound from the left speaker reaches the right ear and vice-versa. This phenomenon, known as "crosstalk interference," can diminish the listener's ability to perceive the spatial location of sounds in the audio mix '564 Patent, col. 2:48-52 Furthermore, the digital process used to cancel this crosstalk can itself introduce undesirable "spectral defects," such as a comb-filter-like effect on the sound '564 Patent, col. 7:38-44
• The Patented Solution: The invention proposes a multi-stage process. First, a "sound field enhancement processing pipeline" preprocesses the audio, which can include enhancing its spatial components '564 Patent, col. 2:5-11 Critically, it also includes a "crosstalk compensation processor" that analyzes the input signal and generates a compensation signal designed to counteract the spectral defects that will be introduced by the subsequent cancellation step '564 Patent, col. 2:36-41 Fig. 2B This pre-compensated signal is then fed to a "crosstalk cancellation processor" to produce the final output '564 Patent, col. 8:3-17
• Technical Importance: By pre-compensating for known artifacts of the cancellation process, the invention aims to achieve the benefits of crosstalk cancellation (a wider, more immersive soundstage) without the associated degradation in audio quality. '564 Patent, col. 3:20-24

Key Claims at a Glance

• The complaint asserts infringement of claims including claim 6 Compl. ¶22 Although the complaint refers to claim 6 as independent, it is a dependent claim that adds limitations to independent claim 1.
• Essential elements of independent claim 1 include:
  • "determining a speaker parameter for the first speaker and a second speaker..."
  • "generating a compensation signal... the compensation signal removing estimated spectral defects in each frequency band from crosstalk cancellation applied to the audio signal..."
  • "precompensating the audio signal for the crosstalk cancellation by adding the compensation signal to the audio signal to generate a precompensated signal; and"
  • "performing the crosstalk cancellation on the precompensated signal... to generate a crosstalk cancelled audio signal." '564 Patent, col. 18:35-50
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 10,757,527 - "Crosstalk Cancellation B-Chain"

• Patent Identification: U.S. Patent No. 10,757,527, "Crosstalk Cancellation B-Chain," issued August 25, 2020 Compl. ¶32

The Invention Explained

• Problem Addressed: The ideal stereo listening experience assumes a listener is in a "sweet spot" equidistant from two identical, symmetrically placed speakers. In reality, listeners are often off-center, or the speakers themselves are mismatched in performance or orientation, which compromises the intended spatial effect '527 Patent, col. 1:29-51
• The Patented Solution: The patent describes a "b-chain processor" that corrects for such real-world listening conditions. The system first determines asymmetries between the left and right speakers with respect to the listener's position, analyzing differences in frequency response, time alignment (sound arrival time), and signal level (volume) '527 Patent, col. 2:1-4 It then applies corrective processing—specifically, an "N-band equalization" for frequency response, a "delay" for time alignment, and a "gain" for signal level—to one or both audio channels to restore a balanced and accurate stereo image '527 Patent, col. 2:5-11 Fig. 7
• Technical Importance: This technology aims to deliver a correct and immersive stereo soundstage even in the asymmetric listening environments common to mobile devices, laptops, and desktop setups, where speaker matching and listener position are rarely ideal. '527 Patent, col. 4:39-55

Key Claims at a Glance

• The complaint asserts infringement of claims including independent claim 21 Compl. ¶34
• Essential elements of independent claim 21 include:
  • "determine asymmetries between the left speaker and the right speaker in frequency response, time alignment, and signal level for a listening position; and"
  • "generating a left output channel for the left speaker and a right output channel for the right speaker by at least one of:"
  • "applying an N-band equalization to the input audio signal to adjust for the asymmetry in the frequency response;"
  • "applying a delay to the input audio signal to adjust for the asymmetry in the time alignment; or"
  • "applying a gain to the input audio signal to adjust for the asymmetry in the signal level." '527 Patent, col. 22:1-20
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 10,313,820 - "Sub-band Spatial Audio Enhancement"

• Patent Identification: U.S. Patent No. 10,313,820, "Sub-band Spatial Audio Enhancement," issued June 4, 2019 Compl. ¶44
• Technology Synopsis: This patent discloses a method for enhancing the spatial qualities of a stereo audio signal by processing it in separate frequency bands. The technique involves receiving a left and right input channel and processing them into a "nonspatial" component (based on the sum of the channels) and a "spatial" component (based on the difference between the channels) '820 Patent, col. 1:21-25 col. 4:35-42 The system then applies distinct "subband gains" to different frequency sub-bands of both the spatial and nonspatial components before recombining them into an enhanced stereo output, allowing for frequency-specific adjustments to the perceived width and character of the sound field '820 Patent, Abstract
• Asserted Claims: The complaint asserts infringement of claims including independent claim 1 Compl. ¶46
• Accused Features: The complaint alleges that the "spatial audio" features of Defendant's electronic devices, including a wide range of Samsung Galaxy smartphones and audio accessories, practice the claimed invention Compl. ¶45

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as a broad category of "electronic devices supporting spatial audio" sold by T-Mobile Compl. ¶21, ¶33, ¶45 This includes, but is not limited to, dozens of Samsung smartphone models such as the Galaxy S, Note, Z Flip, and Z Fold series, as well as audio accessories like the Galaxy Buds line (Compl. ¶21, ¶45).

Functionality and Market Context

The accused functionality is the "spatial audio" feature present in these devices, which purports to create a more immersive and three-dimensional audio experience for the user Compl. ¶21 The infringement allegations suggest this is achieved through digital signal processing that manipulates audio signals in a manner that falls within the scope of the asserted patents, such as by compensating for crosstalk and adjusting for speaker asymmetries. The complaint emphasizes the commercial value of this technology by noting Plaintiff has licensed it to other major technology companies, including Verizon and Qualcomm Compl. ¶3

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products directly infringe the asserted patents but incorporates by reference external claim chart exhibits that were not provided with the complaint Compl. ¶¶ 22, 34, 46 The following summarizes the narrative infringement theories based on the complaint and patent language.

'564 Patent Infringement Allegations

The complaint's infringement theory appears to be that the Accused Products' spatial audio feature practices the method of claim 1 (and dependent claim 6) by performing a specific sequence of audio processing steps Compl. ¶22 This theory suggests the devices first generate a "compensation signal" to "remov[e] estimated spectral defects" that would otherwise be caused by crosstalk cancellation. This compensation signal is then added to the audio to create a "precompensated signal," which is subsequently processed by a crosstalk cancellation algorithm '564 Patent, cl. 1 A court may need to evaluate technical evidence, such as source code or signal analysis, to determine if the accused functionality performs this specific pre-compensation step prior to cancellation, as claimed.

'527 Patent Infringement Allegations

The infringement theory for the ’527 Patent is that the Accused Products' spatial audio feature compensates for non-ideal listening conditions Compl. ¶34 The theory suggests the devices "determine asymmetries" between the left and right speakers in terms of frequency response, signal timing, or volume level relative to a listener. Based on these determined asymmetries, the devices then allegedly apply corrective processing—such as N-band equalization, delay, or gain—to one or both channels to restore a balanced stereo image '527 Patent, cl. 21 The key factual question for the court will likely be whether the accused devices actually "determine" such asymmetries, or if they apply a static, non-adaptive audio effect.

Identified Points of Contention

• Technical Questions: A primary point of contention may be the actual operational sequence of the accused spatial audio feature. For the '564 Patent, discovery will likely focus on whether the accused code performs a pre-compensation step specifically to address cancellation artifacts before the cancellation itself occurs. For the '527 Patent, the question is what evidence shows the devices "determine asymmetries" rather than applying a fixed profile.
• Scope Questions: The case may raise the question of whether loading a pre-configured device profile for a known set of mismatched internal speakers (e.g., in a smartphone) meets the "determine asymmetries" limitation of the '527 Patent's claims.

V. Key Claim Terms for Construction

• Term: "determine asymmetries" '527 Patent, cl. 21

• Context and Importance: This term is central to the infringement analysis for the '527 Patent. The definition will dictate the evidence required to prove infringement. Practitioners may focus on this term because its construction will clarify whether infringement can be found based on a device using pre-set correction profiles for its own known hardware, or if it requires active, dynamic sensing of the user's environment.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent states that "speaker asymmetry may be pre-defined for a particular set of speakers," which could support an argument that "determine" includes loading a pre-existing configuration file for the device's specific hardware '527 Patent, col. 15:21-24
  • Evidence for a Narrower Interpretation: The patent also describes adjusting the processing "according to a change in the listening position" and mentions a system using a camera or sensor to "determine the location of the listener's head" '527 Patent, col. 16:7-13 This language may support a narrower construction requiring active or dynamic sensing of the listening environment.

• Term: "removing estimated spectral defects" '564 Patent, cl. 1

• Context and Importance: This term defines the function of the "compensation signal." Its construction is critical because it distinguishes the claimed invention from generic audio equalization. Infringement requires showing that the accused processing is not just general audio sweetening, but is a targeted correction for artifacts specifically caused by crosstalk cancellation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes the defects as a "comb filter-like frequency response" '564 Patent, col. 7:40-44 A party could argue that any filter that smooths the frequency response in a manner that counteracts this effect is "removing" the defect.
  • Evidence for a Narrower Interpretation: The specification describes using a processor to "compensate for the estimated peaks or troughs" in the frequency response '564 Patent, col. 12:10-15 This could support a reading that requires a specific, targeted process of identifying and inverting the specific artifacts caused by the cancellation algorithm, rather than general equalization.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that T-Mobile provides "user manuals and instruction materials on its website" that instruct and encourage customers to use the accused spatial audio features in an infringing manner Compl. ¶¶ 23, 35, 47

Willful Infringement

The complaint alleges willful infringement based on T-Mobile's purported pre-suit knowledge of the asserted patents. This knowledge is alleged to have been gained during extensive licensing discussions, technical demonstrations, and the exchange of term sheets between the parties from 2017 to 2023. The complaint claims T-Mobile's subsequent infringement was in "conscious disregard of Boomcloud's patent rights" Compl. ¶¶ 7, 25, 37, 49

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

1. A question of technical evidence: Can Plaintiff produce technical evidence, likely through reverse engineering or source code review, to demonstrate that the accused spatial audio software performs the specific, ordered steps required by the claims? In particular, does the software pre-compensate for cancellation artifacts before cancellation as in the '564 patent, and does it actively "determine asymmetries" as required by the '527 patent?
2. A question of claim construction: The dispute may turn on the definition of "determine asymmetries" ('527 Patent). A core issue will be whether this limitation can be met by a device that simply loads a pre-configured profile for its own known hardware, or if it requires a more dynamic process of sensing the listener or the acoustic environment.
3. A question of intent: Given the complaint's detailed narrative of prolonged pre-suit licensing negotiations, a central question for willfulness and potential enhanced damages will be whether T-Mobile's actions constituted "conscious disregard" of known patent rights, or if it developed its technology independently with a good-faith belief of non-infringement.