AK Meeting IP, LLC v. Epic Games, Inc.

CourtDistrict Court, S.D. New York
DecidedJuly 7, 2025
Docket1:23-cv-08214
StatusUnknown

This text of AK Meeting IP, LLC v. Epic Games, Inc. (AK Meeting IP, LLC v. Epic Games, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AK Meeting IP, LLC v. Epic Games, Inc., (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOC #: _________________ ----------------------------------------------------------------------- X DATE FILED: 7/7/2025 : AK MEETING IP, LLC, : : Plaintiff, : 1:23-cv-8214-GHW : -against- : MEMORANDUM OPINION : & ORDER EPIC GAMES, INC., : : Defendant. : : ----------------------------------------------------------------------- X GREGORY H. WOODS, District Judge: Defendant Epic Games, Inc. is the developer of Fortnite, an online video game. In Fortnite Battle Royale, up to 100 players connect their computers to Fortnite’s servers and compete live against each other until only the winner remains. Plaintiff AK Meeting IP, LLC owns U.S. Patent No. 8,627,211 (the “’211 Patent”). The ’211 Patent provides a visualization of a player’s “network latency”—that is, the time it takes for a user’s inputs on their own computer to be sent to a network’s servers and back again. Claim 1 of the ’211 Patent recites the display on a user’s computer, in addition to the user’s own cursor, of a secondary “pointer” that reflects the user’s cursor inputs after they make the roundtrip between their computer and the server. The “pointer” generally trails the user’s cursor, and the more the pointer trails the cursor, the greater the user’s network latency. Both sides agree that at least three essential elements are found in Claim 1: (1) the cursor; (2) the pointer; and (3) the display of the pointer on the user’s computer. Plaintiff claims that Fortnite Battle Royale infringes Claim 1 of the ’211 Patent. Plaintiff’s second theory of infringement is now before the Court. The Court dismissed the infringement theory in Plaintiff’s prior complaint because it failed to plausibly allege, among other things, that an in-game avatar facing the user’s screen was the user’s “cursor” and that a different avatar facing away from the user’s screen was a “pointer” reflecting the user’s network latency. The Court granted Plaintiff leave to amend its complaint, Plaintiff did so, and Defendant has moved to dismiss Plaintiff’s amended complaint for failure to state a claim. Plaintiff’s new theory of infringement alleges that an avatar in Fortnite Battle Royale begins as the user’s cursor, but that when the user manipulates their game controller, that avatar ceases to

be a cursor and instead becomes a “pointer.” This theory contradicts the ’211 Patent, which provides for the simultaneous display of the cursor and the pointer on a user’s display. It also utterly contradicts Plaintiff’s prior theory of infringement, which alleged that the cursor and the pointer were two different avatars. Because Plaintiff’s theory of infringement contradicts the ’211 Patent, and because there is no indication that further amendment of Plaintiff’s complaint would yield a plausible theory of infringement, Plaintiff’s infringement claims are again dismissed, this time without further leave to amend. I. BACKGROUND1 A. The ’211 Patent Plaintiff AK Meeting IP LLC owns the ’211 Patent. Dkt. No. 52 ¶ 6 (“SAC”); Dkt. No. 52- 1 (’211 Patent). The ’211 Patent is entitled “Method, Apparatus, System, Medium, and Signals for Supporting Pointer Display in a Multiple-Party Communication.” ’211 Patent at 1. It contains 150

claims, but both parties agree that only Claim 1 is relevant here. SAC ¶ 9; Dkt. No. 59 at 4 (“Memorandum”); Dkt. No. 62 at 4 (“Opposition”); Dkt. No. 63 at 3 (“Reply”). In full, Claim 1

1 The facts are taken from the Second Amended Complaint, Dkt. No. 52, and are accepted as true for the purposes of this motion. See, e.g., Town of Babylon v. Fed. Hous. Fin. Agency, 699 F.3d 221, 227 (2d Cir. 2012). However, “[t]he tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

Because Plaintiff’s claims allege infringement of the ’211 Patent, Dkt. No. 52-1, the Court has also considered the ’211 Patent, including its “claims and . . . patent specification.” Secured Mail Sols. LLC v. Universal Wilde, Inc., 873 F.3d 905, 913 (Fed. Cir. 2017). claims: A method for supporting multiple-party communications in a computer network including a server and at least one client computer, the method comprising: receiving a first cursor message at the server from the client computer, said first cursor message representing a change in a position of a first cursor associated with the client computer in response to user input received from a user of the client computer; producing a first pointer message in response to said first cursor message, said first pointer message representing said change in said position of said first cursor provided by said first cursor message and being operable to cause display of a pointer on the client computer; and transmitting said first pointer message to said client computer.

’211 Patent, col. 65, ll. 15–29. Both parties agree that at least three claim elements are found within Claim 1: (1) a “cursor associated with the client computer”; (2) a “pointer”; and (3) the “display of [the] pointer on [the] client computer.” Id.; Memorandum at 5; Opposition at 1. The ’211 Patent specification describes the “cursor” as “the client computer cursor” on the client computer’s display, which moves based on “user input signals for moving a cursor” from the client computer’s “pointing device.” ’211 Patent, col. 15, ll. 27–28; id., col. 16, ll. 44–45. Examples of a client computer’s pointing device include “a computer mouse” or a “stylus for providing user input on a touch sensitive display.” Id., col. 15, ll. 24–26. When a user moves their pointing device, a “cursor message” is created, “represent[ing] a change in a position of the cursor in response to the user input.” Id., col. 16, ll. 12–15. The specification describes the “pointer” as “a secondary pointer, which is also displayed on the . . . client computer[].” Id., col. 16, ll. 46–48. The “cursor” and “pointer” are distinct, and they are both displayed on the user’s client computer at the same time. “[U]sers are able to view their own real time cursor and their own and other user’s [sic] pointers on their respective displays.” Id., col. 16, ll. 36–38.2

2 In the case of “handheld client computer[s],” which are operated with a stylus rather than a separate “pointing device,” the display of the cursor may be replaced by “the tip of the stylus,” “since the tip of the stylus provides a visual indication of the cursor position.” ’211 Patent, col. 26, ll. 66–67; id., col. 27, ll. 1–2. This case does not involve One of the advantages of the ’211 Patent is that it provides a “view of network latency for the user” of a computer that is communicating with a “server through a network such as the internet or an intranet.” Id., col. 34, l. 34; id., col. 15, ll. 16–17. As the patent specification explains, “there is a latency that occurs due to the round-trip time required for a cursor message transmitted by . . . the client computer[] . . . to reach the server, to be retransmitted by the server, and to be received back from the server at the client computer[].” Id., col. 16, ll. 20–24. “A feature of the system is that

while user input, such as movements of the pointing device at the client computer, . . . are reflected almost immediately on the display as a corresponding change in position of the cursor, the client computer also transmits a cursor message to the server to elicit a pointer message from the server.” Id., col. 16, ll. 6–12.

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Bluebook (online)
AK Meeting IP, LLC v. Epic Games, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ak-meeting-ip-llc-v-epic-games-inc-nysd-2025.