Control Sync Systems LLC v. Sharp Electronics Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Control Sync Systems, LLC (Wyoming)
  • Defendant: Sharp Electronics Corporation (New York)
  • Plaintiff’s Counsel: Direction IP Law
• Case Identification: 7:26-cv-00034, W.D. Tex., 01/30/2026
• Venue Allegations: Venue is alleged based on Defendant maintaining a regular and established place of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s commercial displays, which utilize the HDMI-CEC standard, infringe a patent related to the synchronous control of a display device and a separate media play device.
• Technical Context: The technology addresses the common problem of controlling multiple, interconnected home theater or presentation devices, aiming to unify control through a single interface rather than multiple remotes.
• Key Procedural History: The complaint does not reference any prior litigation involving the patent-in-suit, any post-grant proceedings at the USPTO, or any known licensing history.

Case Timeline

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

U.S. Patent No. 7,812,889 - "CONTROL SYSTEM FOR SYNCHRONOUSLY CONTROLLING DISPLAY DEVICE AND PLAY DEVICE"

• Patent Identification: U.S. Patent No. 7,812,889, "CONTROL SYSTEM FOR SYNCHRONOUSLY CONTROLLING DISPLAY DEVICE AND PLAY DEVICE," issued October 12, 2010.

The Invention Explained

• Problem Addressed: The patent's background section describes the "inconvenient and troublesome" user experience of managing separate audio/video systems, such as a projector and a DVD player, each with its own remote control and on-screen display (OSD). A user might, for example, lower the volume using the DVD player's remote, only to find the overall sound is still too loud because the projector's volume is set high, requiring the use of a second, separate remote control. (’889 Patent, col. 1:40-54).
• The Patented Solution: The invention proposes a control system where the display device and play device are connected by a "bus". When a user provides an input to one device (e.g., via a remote control), an "encoding/decoding module" converts this OSD signal into a data signal, transmits it over the bus to the other device, which then decodes the signal to synchronously update its own parameters. This architecture, illustrated in Figure 2 of the patent, allows control actions on one device to be mirrored on the other, unifying the control experience. ’889 Patent, col. 2:5-40 Fig. 2
• Technical Importance: The described solution sought to streamline the user interface for multi-component media systems, a significant usability challenge in consumer and professional electronics before the widespread adoption of integrated control standards. ’889 Patent, col. 1:55-58

Key Claims at a Glance

• The complaint asserts independent claim 1. Compl. ¶14
• The essential elements of independent claim 1 include:
  • A control system for controlling a display device and a play device.
  • An on-screen display (OSD) system on the display device for receiving a first OSD signal.
  • An encoding/decoding module on the display device for encoding the first OSD signal into a first data signal.
  • A bus connected to the display device for sending the first data signal to the play device.
  • Wherein the play device decodes the first data signal to control its video and audio parameters.
• The complaint reserves the right to assert infringement of other claims. Compl. p. 29

III. The Accused Instrumentality

Product Identification

• The complaint identifies Defendant’s "M and ME Series large format display" products, using the 65” PN-ME652 as an exemplary "Accused Product." Compl. ¶¶14-15

Functionality and Market Context

• The accused products are commercial displays that incorporate HDMI-CEC (High-Definition Multimedia Interface - Consumer Electronics Control), a feature advertised as "CEC Support through all HDMI Connections." Compl. ¶¶15, 21 This industry-standard protocol enables a user to command and control multiple connected devices (e.g., a Blu-ray player) using a single remote control through the HDMI cable connection. Compl. ¶15 The complaint includes a screenshot from the product's user manual showing that when CEC is enabled, the display's remote can control functions of a connected media player. Compl. ¶6

IV. Analysis of Infringement Allegations

’889 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: Claim 1 recites a "control system" comprising both a display and a play device. A question for the court will be whether Defendant, by selling only the display device, can be found to infringe a claim for the entire system, particularly when the final claimed step of "decoding" occurs on a third-party device. The complaint alleges that the Accused Product's remote control can be used to control a connected media player's functions, as depicted in a user manual excerpt. Compl. p. 6
  • Technical Questions: The complaint maps the patent's generic "encoding/decoding module" and "bus" to the specific implementation of the HDMI-CEC standard. A technical question will be whether the operation of the HDMI-CEC protocol, including its "Deck Control" feature for controlling playback, is structurally and functionally equivalent to the system described and claimed in the patent. The complaint provides a diagram from the HDMI specification showing the "Deck Control" message flow between a TV and a Playback Device. Compl. p. 8

V. Key Claim Terms for Construction

• The Term: "control system"

• Context and Importance: This term is critical because Defendant sells the "display device," not the "play device" required to complete the claimed system. Practitioners may focus on this term because its construction will determine whether selling a single component that is configured to work within a larger infringing combination can constitute direct infringement, a central issue in divided infringement jurisprudence.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent claims "A control system used for controlling..." without requiring that all components be sold by a single entity. Plaintiff may argue that the "control system" is fully embodied by the display device, which is designed with the purpose of controlling an external play device in the claimed manner.
  • Evidence for a Narrower Interpretation: The patent's Figure 2 depicts the "Control system (30)" as an apparatus that explicitly includes modules within both the "Displayer (32)" and the "Player (34)." ’889 Patent, Fig. 2 This may support an argument that the term requires, at a minimum, both the display and play devices to be present to form the complete "system."

• The Term: "encoding... the first OSD signal... into a first data signal"

• Context and Importance: This term defines the core function of the display-side module. The infringement theory depends on mapping this function to the operation of the HDMI-CEC protocol. Practitioners may focus on this term because the defense could argue that the standardized CEC command set is not an "encoding" of the "OSD signal" itself, but rather a separate command protocol triggered by an OSD selection.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the function broadly, stating the module is "for encoding the first OSD signal received by the OSD system 40 into a first data signal." ’889 Patent, col. 4:28-31 This lack of specific implementation detail could support a broader functional definition.
  • Evidence for a Narrower Interpretation: The flow chart in Figure 4 shows a direct sequence: "receive the first OSD signal" leads to "encode the first OSD signal into the first data signal." ’889 Patent, Fig. 4, S32, S34 This could be used to argue for a direct conversion process, which may differ from how the HDMI-CEC protocol is technically implemented.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement to infringe by asserting that Defendant's product documentation, such as user manuals, instructs customers on how to connect and use the HDMI-CEC feature to control external media devices, thereby causing them to assemble and operate the infringing system as claimed. Compl. ¶¶15, 21
• Willful Infringement: The complaint does not plead specific facts to support pre-suit knowledge of the ’889 patent or other conduct that would form the basis for a willfulness claim.

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

• A core issue will be one of divided infringement: can Sharp be held directly liable for infringing a system claim when it manufactures and sells only the display device, and the final claimed step of "decoding" is performed by a third-party product that Sharp does not make or sell? The resolution may depend on whether Sharp's actions are found to direct or control its customers in a manner sufficient to attribute their actions to Sharp.
• A second key issue will be one of claim scope: can the patent's general terms, such as "control system" and "encoding/decoding module", which were drafted before the HDMI-CEC standard was widely adopted, be construed to cover the specific, complex, and standardized implementation of the HDMI-CEC protocol in the accused products?
• A central evidentiary question will be one of technical equivalence: does the functionality of the accused products, which operate according to the HDMI-CEC standard, perform the same function in substantially the same way to achieve the same result as the system recited in the asserted claims, or is there a fundamental mismatch in their technical operation?