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Last week, the U.S. Court of Appeals for the Federal Circuit issued a precedential opinion in <a href="https://www.cafc.uscourts.gov/opinions-orders/24-1092.OPINION.1-29-2026_2640097.pdf"><em>Sound View Innovations, LLC v. Hulu, LLC</em>, No. 2024-1092 (Jan. 29, 2026)</a>, affirming summary judgment of noninfringement entered by the U.S. District Court for the Central District of California on a single asserted method claim.

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Sound View sued Hulu alleging infringement of six patents. Only Claim 16 of U.S. Patent No. 6,708,213 titled “Method for Streaming Multimedia Information over Public Networks” remained in issue at the time of judgment. The ’213 Patent addresses methods for reducing latency in streaming media by using intermediate helper servers to cache content, coordinate distribution, and adjust data transfer rates. Sound View argued Hulu infringed Claim 16 by directing or controlling the content delivery networks to allocate a local buffer on the helper servers to cache a portion of a Hulu video while concurrently pre-fetching another portion of the same video. The district court granted summary judgment because Hulu’s helper servers do not download and retrieve subsequent portions of the same SM object in the same buffer. On an earlier appeal, the Federal Circuit vacated-in-part the district court’s summary judgment order and remanded with instructions to construe the term “buffer.” On remand, the district court construed the term “buffer” to mean “short term storage associated with said requested SM object.” The district court further concluded that (1) the first limitation of Claim 16 must be performed before the second limitation, and (2) Claim 16 requires a specialized buffer, not a generic one. Because the accused method did not satisfy these requirements, the district court granted Hulu’s motion for summary judgment. Sound View appealed.

The Federal Circuit affirmed. The Court concluded that the district court erred by narrowing the claim term “buffer” to require a specialized, SM‑object‑specific buffer, but that the error was harmless because Claim 16 independently requires the first two steps to be performed in the order written. The Court held that Claim 16’s first two steps carry an implicit order: the method must first “receiv[e] a request for an SM object” and then “allocat[e] a buffer … to cache … said requested SM object.” The claim creates an antecedent relationship—“requested SM object” presupposes receipt of a request—so the buffer cannot be allocated to cache an object not yet “requested.” Because Hulu’s systems do not perform the steps in the required order, the judgment was affirmed.

CAFC Affirms District Court’s Summary Judgment of Noninfringement

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