Boomcloud 360 Inc v. AT&T Services Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Boomcloud 360, Inc. (Delaware)
  • Defendant: AT&T Services, Inc., AT&T Mobility, LLC and AT&T Corp. (Delaware, Delaware, New York)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: Boomcloud 360, Inc. v. AT&T Services, Inc., 2:26-cv-00082, E.D. Tex., 01/30/2026
• Venue Allegations: Plaintiff alleges venue is proper because AT&T resides in the district, has committed acts of infringement there, and maintains a regular and established place of business, including operating cellular base stations and advertising its wireless network availability within the district.
• Core Dispute: Plaintiff alleges that Defendant’s sale of electronic devices supporting spatial audio infringes three patents related to improved audio rendering, crosstalk cancellation, and spatial audio enhancement.
• Technical Context: The technology at issue involves digital audio signal processing designed to create a more immersive, three-dimensional listening experience from stereo speakers by manipulating the spatial characteristics of the sound and correcting for non-ideal listening environments.
• Key Procedural History: The complaint alleges a prolonged history between the parties, including entering into a Non-Disclosure Agreement in September 2017 and engaging in technical demonstrations and licensing discussions regarding Boomcloud’s patented technology on "numerous occasions" between January 2015 and May 2023. No licensing agreement was reached. The complaint also notes that Boomcloud has licensed its technology to other major companies, including Verizon and Qualcomm.

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"

The Invention Explained

• Problem Addressed: In stereophonic sound reproduction, sound from a speaker on one side reaches the ear on the opposite side (a 'contralateral sound component'), creating crosstalk interference that can degrade the listener's ability to perceive the spatial location of sound sources ('564 Patent, col. 1:38-52).
• The Patented Solution: The invention describes a multi-stage audio processing system. First, a 'sound field enhancement processing pipeline' preprocesses the signal, in part by enhancing its spatial qualities in different frequency subbands. This is then combined with a 'crosstalk compensation' signal designed to preemptively correct for artifacts that will be introduced later. Finally, a 'crosstalk cancellation processing pipeline' processes the resulting signal to reduce the undesirable contralateral sound components, with the entire system being adaptive to speaker parameters. '564 Patent, Abstract; col. 2:4-54 Fig. 2B
• Technical Importance: This adaptive, multi-pipeline approach aims to produce a more immersive listening experience by actively managing and correcting for both crosstalk and the artifacts created by crosstalk cancellation itself '564 Patent, col. 3:25-30

Key Claims at a Glance

• The complaint asserts independent claim 6 Compl. ¶25
• Essential elements of claim 6, a method for crosstalk processing, include:
  • determining one or more speaker parameters for a first and second speaker, the parameters including a listening angle;
  • removing spectral defects of crosstalk processing applied to the audio signal based on applying a filter, with the filter's configuration determined based on the speaker parameters; and
  • applying the crosstalk processing on the audio signal.
• The complaint reserves the right to assert additional claims Compl. ¶25

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

The Invention Explained

• Problem Addressed: The ideal 'sweet spot' for stereo listening is often not met in real-world situations due to factors like a listener being off-center, or the use of physically 'un-matched' speakers with different performance characteristics, which creates asymmetries that degrade the audio experience ('527 Patent, col. 1:21-46).
• The Patented Solution: The patent discloses a 'b-chain processor' that corrects for asymmetries between left and right speakers. It determines differences in frequency response, time alignment, and signal level for a specific listening position. It then applies corrective processing—specifically, an N-band equalization, a delay, and a gain—to a spatially enhanced audio signal to compensate for these asymmetries and restore a balanced stereo image. '527 Patent, Abstract; col. 2:1-14 Fig. 2
• Technical Importance: This 'b-chain' technology allows for the restoration of an ideal stereo sound stage even in sub-optimal listening environments, making a high-quality spatial audio experience more robust and accessible '527 Patent, col. 3:40-58

Key Claims at a Glance

• The complaint asserts independent claim 21 Compl. ¶37
• Essential elements of claim 21, a method for enhancing an audio signal, include:
  • determining asymmetries between a left and right speaker in frequency response, time alignment, and signal level for a listening position; and
  • generating left and right output channels by applying an N-band equalization to adjust for frequency response asymmetry, a delay to adjust for time alignment asymmetry, and a gain to adjust for signal level asymmetry.
• The complaint reserves the right to assert additional claims Compl. ¶37

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

Technology Synopsis

This patent describes a method to enhance the spatial characteristics of a stereo audio signal. The system processes the left and right input channels to derive a 'spatial component' (the difference signal) and a 'nonspatial component' (the sum signal), applies distinct subband gains to each component to modify their characteristics across different frequency ranges, and then recombines them into an enhanced stereo output signal ('820 Patent, Abstract).

Asserted Claims

The complaint asserts independent claim 1 Compl. ¶49

Accused Features

The complaint accuses the spatial audio functionality of various electronic devices, including smartphones and audio accessories, sold by Defendant Compl. ¶48

III. The Accused Instrumentality

Product Identification

• The complaint identifies the 'Accused Products' as a broad category of "electronic devices supporting spatial audio" sold by AT&T Compl. ¶24, ¶36, ¶48 This includes, but is not limited to, numerous models of Samsung Galaxy smartphones (S-series, Note-series, Z-series) and Galaxy Buds audio accessories (Compl. ¶24, ¶48).

Functionality and Market Context

• The complaint alleges these products incorporate 'spatial audio' technology Compl. ¶24 The complaint provides a screenshot of an AT&T wireless coverage map for Marshall, Texas, to support its venue allegation that AT&T provides services and has an established place of business in the district Compl. ¶17, p. 6 The complaint also states that as of March 2022, AT&T had over 196 million subscribers, highlighting its significant role in the distribution and sale of the Accused Products Compl. ¶18

IV. Analysis of Infringement Allegations

The complaint alleges infringement of the '564, '527, and '820 patents but states that claim charts comparing the asserted claims to a representative Accused Product are attached as exhibits Compl. ¶25, ¶37, ¶49 These exhibits were not provided with the complaint document. The complaint's narrative theory is that the 'spatial audio' features of the Accused Products practice the methods claimed in the asserted patents. Without the claim charts, the specific mapping of accused functionality to claim elements is not detailed in the public document.

• Identified Points of Contention:
  • Evidentiary Proof: A central issue for the court will be whether the Plaintiff can produce sufficient technical evidence through discovery to show that the accused 'spatial audio' functionality in Defendant's products actually performs the specific, multi-step methods recited in the asserted claims. The current complaint's allegations are conclusory and depend on the unprovided exhibits.
  • Scope and Technical Match ('564 Patent): The infringement analysis for the '564 patent will likely raise the question of whether the accused products' audio processing includes a step equivalent to 'removing spectral defects of crosstalk processing' that is specifically determined by 'speaker parameters,' as required by claim 6.
  • Functional Operation ('527 Patent): A key technical question for the '527 patent will be whether the accused products actively 'determine asymmetries' in frequency, time, and level for a given listening position and then apply corresponding, distinct corrections (equalization, delay, gain). The court may need to consider whether a generic 'spatial audio' effect without this specific diagnostic and corrective feedback loop falls within the scope of claim 21.

V. Key Claim Terms for Construction

• Term: 'removing spectral defects of crosstalk processing' '564 patent, claim 6

  • Context and Importance: This term defines the core compensatory action of the claimed method. The outcome of the infringement analysis will heavily depend on whether the accused functionality can be characterized as 'removing defects' as opposed to general audio enhancement.
  • Evidence for a Broader Interpretation: The specification describes this function in the context of a processor that "performs a preprocessing to precompensate for any artifacts" that may be introduced by a subsequent cancellation process '564 Patent, col. 7:27-31 This could support an interpretation covering various forms of preemptive signal conditioning.
  • Evidence for a Narrower Interpretation: The specification details that these artifacts often manifest as a "comb filter-like frequency response" '564 Patent, col. 7:31-40 A defendant may argue this term is limited to the targeted correction of such specific, identifiable artifacts, not general equalization.

• Term: 'determine asymmetries between the left speaker and the right speaker' '527 patent, claim 21

  • Context and Importance: This term is the predicate for the corrective actions of equalization, delay, and gain. Practitioners may focus on this term because the infringement question may turn on whether the accused devices perform an active, diagnostic 'determination' or simply apply a static audio profile.
  • Evidence for a Broader Interpretation: The patent abstract states the "b-chain processor determines asymmetries... and generates a left output channel... and a right output channel... by: applying an N-band equalization... applying a delay... and applying a gain" '527 Patent, Abstract This could suggest that any process which results in the application of these corrections for a known or assumed asymmetry satisfies the 'determine' step.
  • Evidence for a Narrower Interpretation: The specification illustrates various scenarios causing asymmetry, such as a listener's head being laterally offset or the use of unmatched speakers '527 Patent, Fig. 1B-1E An argument could be made that 'determine' requires an active measurement or sensor-based identification of the specific listening condition, rather than the application of a predefined, one-size-fits-all effect.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for all three patents, asserting that Defendant's user manuals and instructions encourage customers to use the infringing 'spatial audio' features of the Accused Products Compl. ¶26, ¶38, ¶50
• Willful Infringement: The complaint alleges that Defendant's infringement has been willful. This allegation is based on alleged pre-suit knowledge of the Asserted Patents and their relevance, gained through "licensing discussions," "technical demonstrations," and multiple NDAs with Boomcloud between 2015 and 2023 Compl. ¶5-8, ¶28, ¶40, ¶52

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

1. Evidentiary Burden: A primary question is one of evidentiary proof: can Boomcloud, through discovery and technical analysis, demonstrate that the accused 'spatial audio' features perform the specific, and often complex, multi-step methods required by the asserted claims, moving beyond the conclusory allegations in the complaint?
2. Technical and Definitional Scope: A key issue will be one of technical mapping: do the accused products' audio processing systems operate in a manner consistent with the patent claims? For instance, does the system actively 'determine asymmetries' and apply specific corrections as claimed in the '527 patent, or does it use a different, more generalized enhancement technique that falls outside the claim scope?
3. Willfulness and Intent: Given the complaint's detailed allegations of a multi-year history of licensing discussions and technical demonstrations, a central question for the court will be one of willfulness. If infringement is established, the nature and extent of Defendant's alleged pre-suit knowledge will be critical in determining whether the conduct rises to the level of willful infringement, which could expose Defendant to enhanced damages.