The Federal Circuit Court of Appeals affirmed a lower court's ruling in favor of streaming service Hulu, LLC in a patent infringement case brought by Sound View Innovations, LLC. The decision, issued Jan. 29, 2026, upholds a district court's summary judgment finding that Hulu's streaming technology does not infringe Sound View's patent claims.
Circuit Judge Chen wrote the opinion affirming the U.S. District Court for the Central District of California's September 2023 ruling. The case centered on whether Hulu's streaming platform infringed method claim 16 of U.S. Patent No. 6,708,213, titled "Method for Streaming Multimedia Information over Public Networks."
The district court had granted summary judgment of noninfringement in favor of Hulu after determining that the streaming service's accused products failed to meet two critical patent claim requirements. First, the court found that Hulu's products do not perform the claim limitations in the required sequence specified in the patent. Second, the court ruled that Hulu's technology lacks the claimed specialized buffer described in Sound View's patent.
The '213 patent, which has since expired, disclosed methods for streaming multimedia information over public networks. Sound View had argued that Hulu's streaming technology infringed on these patented methods, leading to litigation that began in 2017 in the Central District of California under Judge John A. Kronstadt.
On appeal, the Federal Circuit focused specifically on the sequential performance requirement of the patent claims. Circuit Judge Chen wrote that the court agreed with the district court's interpretation that claim 16 requires its first two steps to be performed in the specific order that they appear in the claim language.
This sequential requirement proved fatal to Sound View's infringement case. The appeals court determined that Hulu's accused streaming products do not perform the claimed steps in the required order, making it impossible for the technology to literally infringe the patent claims.
The case highlights ongoing challenges in patent litigation involving streaming technology, where companies must navigate complex technical requirements and precise claim language. Patent holders seeking to enforce their rights against streaming platforms face the burden of proving that accused technologies meet all elements of their patent claims, including any sequential or structural requirements.
Sound View was represented by Frederick Ding and Alan Kellman of Desmarais LLP in New York. Hulu's defense team included Bradley M. Berg of O'Melveny & Myers LLP in Newport Beach, California, along with Cameron William Westin, Brett Johnston Williamson, John C. Kappos from Dallas, and Jason Zarrow from Los Angeles.
The three-judge Federal Circuit panel included Chief Judge Kimberly Prost, Judge Peter Wallach, and Judge Pauline Chen. The Federal Circuit has exclusive jurisdiction over patent appeals from federal district courts, making it the final arbiter for most patent disputes unless the Supreme Court agrees to review a case.
The decision reinforces the importance of precise claim drafting in patent applications, particularly for technology patents where method claims must specify exact sequences of steps. Patent prosecutors and inventors must carefully consider whether their claims require specific ordering of steps and whether such requirements are necessary for their inventions.
For the streaming industry, the ruling provides some clarity on how courts will interpret patent claims involving multimedia streaming technology. Companies developing streaming platforms can take note of how courts analyze the technical requirements of patent claims against accused products.
The case also demonstrates the Federal Circuit's continued emphasis on literal claim interpretation in patent infringement analysis. When patent claims include specific sequential requirements, accused products must perform those steps in the claimed order to constitute literal infringement.
Sound View's unsuccessful appeal means the company cannot pursue damages against Hulu for alleged infringement of the '213 patent. The ruling may also impact any other potential infringement claims Sound View might have against other streaming services using similar technology.
The decision adds to the body of Federal Circuit precedent addressing patent infringement in the digital streaming space, an area that has seen increased litigation as streaming services have proliferated and patent holders have sought to monetize their intellectual property rights.
With the '213 patent now expired, the immediate impact of this ruling is limited to the parties involved. However, the court's interpretation of sequential claim requirements will likely influence future patent disputes involving method claims in streaming technology and other technical fields.
The case underscores the challenges patent holders face when asserting infringement claims against major technology companies with sophisticated legal defense teams. Sound View's inability to prove that Hulu's technology met all claim limitations demonstrates the high burden of proof required in patent infringement cases.