Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 1 of 13
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`CELLULAR SOUTH, INC.
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`Plaintiff,
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`v.
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`GOOGLE, LLC
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`Defendant.
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`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`Civil Action No. 6:24-cv-00245-DAE
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`JURY TRIAL DEMANDED
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`Trial Date: Not Set
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`PLAINTIFF CELLULAR SOUTH’S OPPOSITION TO DEFENDANT’S
`MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM UNDER RULE 12(B)(6)
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 001
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`

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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 2 of 13
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`I.
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`INTRODUCTION
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`
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`Defendant Google, LLC (“Google”) moves to dismiss the Complaint on the grounds that
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`Plaintiff Cellular South, Inc. (“CSI”) fails to state a plausible claim for patent infringement.
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`Google’s position is without merit. With regard to the ’853 Patent, Google would have the Court
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`adopt wholesale Google’s preferred (and unsupported) construction of the term “fractal” before
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`either side has begun any claim construction discovery. Google hinges its argument on its
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`improper, untimely construction and provides no other basis for its claim that the ’853
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`infringement allegations are insufficient to satisfy the requirements of Fed. R. Civ. P. 12(b)(6).
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`With regard to the ’954 and ’972 Patents, Google suggests that the factual support cited in
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`the Complaint contradicts the conclusion that Google’s Cloud Video Intelligence (“Video
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`Intelligence”) software “cross-references” extracted audio text with video data. Notably, Google
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`stops short of stating whether or not Video Intelligence does in fact cross-reference extracted audio
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`data with video data. This is unsurprising, because a live demonstration of the product from the
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`same video that Google cites shows Video Intelligence performing this function.
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`The Complaint far exceeds the minimum pleading standard under Iqbal/Twombly and
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`provides detailed, element-by-element allegations, even though such detail is not required. Google
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`does not claim that the Complaint fails to notify it of which products are accused, but instead
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`complains that CSI has not explained precisely how Google’s own, non-public software operates.
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`Because CSI’s allegations specifically allege factual content to support its claims that Google
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`infringes each of the Patents-in-Suit, 1 and because Google’s arguments that the Complaint’s
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`allegations contradict those facts are without merit, the Court should deny the motion.
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`
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`1 U.S. Patent Nos. 10,218,954 (“’954 Patent”), 9,940,972 (“’972 Patent”), and 11,126,853 (“’853
`Patent”).
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`1
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 002
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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 3 of 13
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`II.
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`FACTUAL BACKGROUND
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`
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`On May 9, 2024, CSI filed the instant lawsuit alleging that Google infringes the Patents-
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`in-Suit. ECF No. 1 (“Compl.”) at ¶ 1. The Complaint alleges that Video Intelligence—a video
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`classification system that Google makes and uses in various forms for various purposes—infringes
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`each of the Patents-in-Suit. Id. at ¶¶ 39, 80, 124. Google moved to dismiss on the basis that the
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`Complaint fails to state a plausible claim for relief. ECF No. 26 (“Mot.”).
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`Google asserts that the Complaint fails to state a plausible claim for infringement of the
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`’853 Patent. Claim 1 of the ’853 Patent recites, in relevant part: “A system for generating data
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`from a video, comprising . . . an object recognizer configured to compare the image of the object
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`to a fractal, wherein the fractal includes a representation of the object based on the landmarks
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`associated with the object, wherein the recognizer is further configured to update the fractal with
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`the image.” Compl. at ¶ 122; ECF No. 1-3 (’853 Patent), claim 1. In support of its contention that
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`Google infringes this claim element, CSI alleges that “Video Intelligence may be used to perform
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`facial recognition for images extracted from a video using detected attributes of a face” (Compl.
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`at ¶ 136), and that Google “maintains a curated collection of image data for celebrities that can be
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`used for facial recognition with Video Intelligence” (id. at ¶ 137). The Complaint cites additional
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`Google public documents and presentations to show Google is “constantly improving” the video
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`recognition models. Compl. at ¶¶137–138.
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`Google further asserts that the Complaint fails to state a plausible claim for infringement
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`of the ’954 and ’972 Patents.2 Claim 1 of the ’954 Patent recites, in relevant part, “A method to
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`generate video data from a video comprising . . . cross-referencing the text and the video data with
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`2 Google’s motion addresses the ’954 and ’972 Patents together—for clarity, and for purposes of
`this Opposition only, Plaintiff does the same.
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`2
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 003
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`

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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 4 of 13
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`the video to determine contextual topics.” ECF No. 1-1 (“’954 Patent”) at claim 1. Claim 1 of the
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`’972 Patent recites, in relevant part, “A method to generate video data from a video comprising
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`. . . cross-referencing the text and the video data based on the generated topical meta-data to
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`determine topics.” ECF No. 1-2 (“’972 Patent”) at claim 1. In support of its contention that the
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`accused products perform each of these claim limitations, CSI alleges, inter alia, that “Video
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`Intelligence extracts audio data and converts that data into text,” (Compl. at ¶¶ 47, 89), and uses
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`an “aggregating video classifier that combines the outputs of the analyzed video image data and
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`audio, text, subtitle or other data to determine a contextual topic.” Id. at ¶ 58; ¶¶ 59–60, 100–101.
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`Google requests the Court take judicial notice of two YouTube videos cited in the
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`Complaint. See Mot. at 7–8. These videos, the “2017 YouTube Video” and “2023 YouTube
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`Video,”
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`are
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`available
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`at
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`https://www.youtube.com/watch?v=y-k8oelbmGc
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`and
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`https://www.youtube.com/watch?v=F4YKREYPkEI, respectively.3
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`III. LEGAL STANDARD
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`In deciding a Rule 12(b)(6) motion to dismiss for failure to state a claim, the court “accepts
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`all well-pleaded facts as true, viewing them in the light most favorable to the plaintiff.” Bell Atl.
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`Corp. v. Twombly, 550 U.S. 544, 570 (2007); see also, Repairify, Inc. v. Keystone Auto. Indus.,
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`Inc., 610 F. Supp. 3d 897, 899 (W.D. Tex. July 6, 2022) (“When considering such motions, this
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`Court . . . draws all reasonable inferences in the plaintiff’s favor.”). “To survive a motion to
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`dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to
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`relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl.
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`Corp. v. Twombly, 550 U.S. at 570). “A claim has facial plausibility when the plaintiff pleads
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`
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`3 CSI does not oppose Google’s request that judicial notice be taken of these videos for purposes
`of deciding the instant motion.
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`3
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 004
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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 5 of 13
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`factual content that allows the court to draw the reasonable inference that the defendant is liable
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`for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. at 678. The plausibility standard is not a
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`probability requirement; “it simply calls for enough fact to raise a reasonable expectation that
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`discovery will reveal evidence to support the plaintiff’s allegations.” Bell Atl. Corp., 550 U.S. at
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`556. “Review is limited to the contents of the complaint and matters properly subject to judicial
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`notice.” Castro v. Bexar County, 2024 WL 3071571, at *2 (W.D. Tex. May 14, 2024) (citing
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`Tellabs, Inc v. Makor Issues & Rts., Ltd., 551 U.S. 308, 322 (2007)).
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`A patent plaintiff need not “prove its case at the pleading stage[,]” nor is it required to plead
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`infringement “on an element-by-element basis.” Bot M8 LLC v. Sony Corp. of Am., 4 F.4th 1342,
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`1352 (Fed. Cir. 2021). But, “[t]here must be some factual allegations that, when taken as true,
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`articulate why it is plausible that the accused product infringes the patent claim.” Id. at 1353.
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`Specific facts are not necessary; it is enough “that a complaint place the alleged infringer ‘on notice
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`of what activity . . . is being accused of infringement.’” Id. (quoting Lifetime Indus., Inc. v. Trim-
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`Lok, Inc., 869 F.3d 1372, 1379 (Fed. Cir. 2017) (citations omitted)). “The adequacy of the facts
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`pleaded depends on the breadth and complexity of both the asserted patent and the accused product
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`or system and the nature of the defendant’s business activities.” K-Tech Telecomms., Inc. v. Time
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`Warner Cable, Inc., 714 F.3d 1277, 1286 (Fed. Cir. 2013).
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`IV. ARGUMENT
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`A.
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`Google’s Challenge to the Adequacy of the ’853 Patent Infringement
`Allegations is an Improper Attempt at Early Claim Construction
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`Google asserts that CSI’s allegations fail to state a plausible claim for relief because they
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`do not explicitly state that Video Intelligence uses “fractals” or that it updates the image with
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`“fractals.” This argument fails for four reasons: (1) claim construction is improper at this stage;
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`(2) Google’s proposed construction relies solely on unsupported attorney argument; (3) Google’s
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`4
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 005
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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 6 of 13
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`proposed construction is inconsistent with the ’853 Patent’s description (which aligns with the
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`Complaint’s allegations); and (4) even assuming Google’s construction were correct, the
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`allegations are sufficient in light of the non-public nature of the accused systems.
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`First, Google’s position is an untimely attempt to circumvent a proper claim construction
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`process. See Repairify, Inc., 610 F. Supp. 3d at 902–903 (denying motion to dismiss that “hinge[d]
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`on this Court adopting [the defendant’s] proposed constructions”); see also, Unification Techs.
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`LLC v. Dell Techs., Inc., No. 6:20-cv-00499-ADA, 2021 WL 1343188, at *3 (W.D. Tex. Jan. 28,
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`2021) (“a 12(b)(6) motion is not the appropriate procedure for identifying inconsistent direct
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`infringement contentions. Those are . . . best addressed in claim construction or non-infringement
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`positions.”). As in Repairify, neither party here has conducted any claim construction discovery,
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`and the Court has not even scheduled a claim construction hearing. The Court, therefore, lacks
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`sufficient information on the underlying patent and its prosecution history necessary to properly
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`construe this claim limitation. As explained further herein, a plain reading of the claim shows that
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`the allegations—viewed in the light most favorable to CSI—easily satisfy the plausibility standard.
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`Second, Google’s argument is unsupported. Google cites no authority for its definition of
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`“fractal” as “a repeating pattern that looks substantially similar at different size scales, and can be
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`used to describe an object.” Mot. at 3. Nor does Google point to anything in the Complaint, the
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`’853 Patent or its prosecution history to support this interpretation. Id. Such unsupported attorney
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`argument would be improper even if timely raised during claim construction proceedings. See,
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`e.g., Visible Connections, LLC v. Zoho Corp., 418 F. Supp. 3d 155, 159 (W.D. Tex. Nov. 26, 2019)
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`(“[C]onclusory, unsupported assertions by experts as to the definition of a claim term are not useful
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`to a court.”). It is even more improper on a motion to dismiss, which is intended to test the
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`sufficiency of the pleadings, not to decide the merits. See Nalco Co. v. Chem-Mod, LLC, 883 F.3d
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`5
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 006
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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 7 of 13
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`1337, 1350 (Fed. Cir. 2018) (upheld sufficiency of the complaint, explaining that defendant’s
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`claim construction argument “is particularly inappropriate in the Rule 12(b)(6) context.”).
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`Third, Google’s overly restrictive construction of “fractal” is inconsistent with the way
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`that term is used in the ’853 Patent. Google seeks to limit “fractal” to the type of self-repeating,
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`periodic patterns discussed in the broad fields of mathematics and geometry. See Mot. at 1
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`(depicting a Sierpinski triangle). The ’853 Patent uses the term “fractal” approximately 58 times,
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`but never in the context of geometric “repeating patterns.” For instance, the term “fractal” is used:
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`in the context of identifying unknown objects (id. at 21:2–13, discussing a “ghost fractal” for
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`identifying a submarine); with reference to information with metadata that is “stored in a reference
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`dataset” (id. at 18:38–40); and as a reference dataset itself (id. at 18:48–50). The only excerpt that
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`even remotely relates to Google’s construction appears in column 15, where the patent explains
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`that a “human face is a surface lying in the fractal space,” that exhibits many “self-similar”
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`parameters. Id. at 15:39–47. A human face, of course, is not a self-repeating pattern similar to a
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`Serpinski triangle. As a result, Google’s interpretation cannot be correct.
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`The ’853 Patent also states with regard to fractals, “the system can utilize facial recognition
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`algorithms to identify facial fractals by extracting landmarks from an image of the subject’s face.
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`For example, the algorithm can analyze the relative position, size, and/or shape of the eyes, nose,
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`cheekbones, and jaw.” Id. at 13:53–57. This description of “fractal” closely aligns with claim 1
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`and the allegations in the Complaint. Claim 1 simply states that “the fractal includes a
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`representation of an object [e.g., a face] based on the landmarks associated with the object.” Id. at
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`claim 1 (emphasis added). The Complaint similarly alleges that the accused products perform
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`facial recognition for images extracted from a video using detected attributes of a face (Compl. at
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`¶ 136) and that Google “maintains a curated collection of image data for celebrities that can be
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`6
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 007
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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 8 of 13
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`used for facial recognition with Video Intelligence.” Id. at ¶ 137.
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`Fourth, Google asserts that the cited videos and documentation in the Complaint do not
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`specifically mention the term “fractal” in connection with Video Intelligence—if this were the
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`standard, then very few complaints would satisfy Rule 12. But CSI need not prove its case at this
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`stage, and Google cannot immunize itself from an infringement suit by keeping information about
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`the accused products secret. See K-Tech Telecomms., Inc., 714 F.3d at 1286 (“A defendant cannot
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`shield itself from a complaint for direct infringement by operating in such secrecy that the filing
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`of a complaint itself is impossible.”). In such circumstances, courts employ a flexible approach to
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`the pleading standard. Id. (“The adequacy of the facts pleaded depends on the breadth and
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`complexity of both the asserted patent and the accused product or system and the nature of the
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`defendant’s business activities.”); Repairify, Inc., 610 F. Supp. 3d at 900 (deciding the sufficiency
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`of the pleadings requires a “flexible approach” based on multiple factors such as the complexity
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`of the technology and nature of the accused product).
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`Viewing the facts in the light most favorable to CSI, the Complaint’s allegations that (1)
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`Video Intelligence applies facial recognition (a form of object recognition); (2) using “detected
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`attributes of a face,” and that Google (3) maintains a “curated collection” of facial recognition
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`data, and (4) is “constantly updating” its recognition models—more than satisfies the requirement
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`to show a plausible claim that the accused products comprise “an object recognizer configured to
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`compare an image to a fractal, wherein the fractal includes a representation of the object based on
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`the landmarks associated with the object, wherein the recognizer is further configured to update
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`the fractal with the image.” Compl. at ¶ 122.
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`B.
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`The Complaint Properly Alleges Infringement of the ’954 and ’972 Patents
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`Google next contends that the Complaint fails to allege that the extracted audio text is used
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`in the “cross-referencing” steps of the ’954 and ’972 Patents. Mot. at 5. Further, Google contends
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`7
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 008
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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 9 of 13
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`that the allegations suggest that Video Intelligence does not consider the audio signal in the cross-
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`referencing step. As support, Google cites to two YouTube videos referenced in the Complaint.
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`Id. at 7–8. The referenced YouTube videos, however, further confirm that Video Intelligence
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`comprises an “aggregating classifier” that cross-references video and audio data.
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`1.
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`The 2023 YouTube Video
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`The 2023 YouTube Video clearly shows that Video Intelligence does consider audio
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`signals together with video data. The video contains a demonstration of the accused video
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`classification system, that begins at approximately 11 minutes and 30 seconds. See Compl. at
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`¶¶ 53, 103 (citing 2023 YouTube Video at 11:32–12:16). The video used for the product
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`demonstration is publicly available at https://www.youtube.com/watch?v=DVn-tBeX7w4.4 The
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`output of the video classification system is displayed at 11 minutes and 49 seconds, shown below.
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`2023 YouTube Video at 11:49 (generated video description at 00:15 indicated by red box, which
`has been enlarged to more clearly show its text)
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`As the presenter explains, “[f]or every 15-second chunk, it gives you a description.”
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`Compl. at ¶¶ 53, 103. As shown above, the generated video description at 00:15 seconds states:
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`A man talking about a company called Google. He talks about how Google is a
`company that is always looking for ways to improve and make things better. He
`also talks about how Google is a company that is always looking for ways to make
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`4 CSI requests that the Court take judicial notice of this video, titled “Leading Companies Build
`with Generative AI,” which is referenced by filename in the 2023 YouTube Video at 11:38–12:07.
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`8
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 009
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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 10 of 13
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`things easier for people.
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`By paraphrasing what “the man is talking about,” this example indicates that the accused product
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`is considering both visual and audio signals. Indeed, review of the video used for this demo
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`confirms that there are no visual cues that could plausibly lead to the generated description of what
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`the man says. This demonstration alone—which is specifically cited in the Complaint—confirms
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`that the allegations state a plausible claim that the accused product infringes the “cross-
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`referencing” elements.
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`Google’s assertion that the 2023 YouTube Video suggests the accused product “is not
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`speech-to-text or closed captioning,” (Mot. at 7) are taken out of context. These statements do not
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`imply that the accused product is not using speech-to-text or closed captioning for video
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`classification, but suggest only that the accused product involves more than either of these
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`technologies individually.5 Moreover, the assertion that Video Intelligence does not consider audio
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`signals is plainly contradicted by the live demonstration as discussed above.
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`2.
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`The 2017 YouTube Video
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`Google argues that the 2017 YouTube Video, and particularly the underlined sentence
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`below, shows that Video Intelligence does not “cross-reference” audio data with video data.
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`So far I’ve only talked about the visual features, but we are also considering adding
`audio or motion or speech or subtitles to this classifier and do a final fusion in this
`aggregating classifier. So that you don’t assume that you have a video of an
`animated music video. It will be sad if we give you a label saying it’s an animated
`cartoon. You definitely want your audio signal in there. So we are looking at
`various audio signals to improve the accuracy of the model.
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`See Mot. at 6 (underlining added); see also, Compl. at ¶¶ 48, 90, 96.
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`Google’s argument relies heavily the specific words chosen by the speaker. But the
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`5 Additionally, as set forth in the Complaint, Google’s documentation for the Video Intelligence
`product describes “SPEECH_TRANSCRIPTION” features. Compl. at ¶¶ 47, 89, 94.
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`9
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 0010
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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 11 of 13
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`speaker’s word choice is often fragmented and grammatically incorrect, as may be expected in
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`everyday speech. For instance, Google argues that the speaker’s statement, “we are looking at
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`various audio signals. . .” merely suggests a desire to implement such a feature. Mot. at 6. But an
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`equally plausible interpretation of this statement is that the accused product is presently looking at
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`said audio signals. Similarly, it is equally plausible that the statement, “we are also considering
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`adding. . .,” viewed in context as statements made during a live product presentation to potential
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`customers, indicates that the system is actively considering audio information. At a minimum, such
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`statements provide plausible support for allegations that Google was actively experimenting with
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`the use of audio signals in the accused product—this, by itself, constitutes an infringing use.
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`Indeed, such interpretation of these statements aligns with the broader focus of the discussion—
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`that is, the importance of including audio information in Video Intelligence to ensure accuracy.
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`The allegations pertaining to the 2017 YouTube Video statements—viewed in the light
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`most favorable to CSI—support a plausible claim that the accused system performs the “cross-
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`referencing” step. See Repairify, Inc., 610 F. Supp. 3d at 899 (“When considering such motions,
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`this Court . . . draws all reasonable inferences in the plaintiff’s favor.”). Even if the statements in
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`the 2017 YouTube Video are considered purely aspirational in nature (a conclusion that would be
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`preemptive at this stage), the 2023 YouTube Video clearly shows Google did in-fact go on to
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`implement the “cross-referencing” of audio and video data in Video Intelligence.
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`V.
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`CONCLUSION
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`CSI respectfully requests that the Court deny Google’s Motion to Dismiss.
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`10
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 0011
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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 12 of 13
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`DATED:
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`July 29, 2024
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`Respectfully submitted,
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`
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`/s/ Robert S. Hill
`Robert S. Hill, TX Bar No. 24050764
`robert.hill@hklaw.com
`David C. Schulte, TX Bar No. 24037456
`david.schulte@hklaw.com
`Sara S. Staha, TX Bar No. 24088368
`Sara.staha@hklaw.com
`Morgan J. Delabar, TX Bar No. 24116625
`morgan.delabar@hklaw.com
`HOLLAND & KNIGHT LLP
`1722 Routh St., Suite 1500
`Dallas, Texas 75201
`Telephone: (214) 964-9500
`Facsimile:
`(214) 964-9501
`
`Robert K. Jain TX Bar No. 24139315
`robert.jain@hklaw.com
`HOLLAND & KNIGHT LLP
`98 San Jacinto Boulevard, Suite 1900
`Austin, Texas 78701
`Telephone: (512) 472-1081
`Facsimile:
`(512) 472-7473
`
`Jacob W. S. Schneider (pro hac vice pending)
`MA Bar No. 675315
`jacob.schneider@hklaw.com
`Allison M. Lucier (pro hac vice pending)
`MA Bar No. 569193
`allison.lucier@hklaw.com
`HOLLAND & KNIGHT LLP
`10th St. James Avenue, 11th Floor
`Boston, MA 02116
`Telephone: (617) 523-2700
`Facsimile:
`(617) 523-6850
`
`Anthony J. Fuga (pro hac vice pending)
`IL Bar No. 6301658
`anthony.fuga@hklaw.com
`Tiffany Lee (pro hac vice pending)
`IL Bar No. 6342343
`tiffany.lee@hklaw.com
`HOLLAND & KNIGHT LLP
`150 North Riverside Plaza, Suite 2700
`Chicago, IL 60606
`Telephone: (312) 263-3600
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`11
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`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 0012
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`Case 6:24-cv-00245-DAE Document 28 Filed 07/29/24 Page 13 of 13
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`(312) 578-6666
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`Facsimile:
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`Deron R. Dacus, TX Bar No. 00790553
`ddacus@dacusfirm.com
`THE DACUS FIRM, P.C.
`821 E. SE Loop 323, Suite 430
`Tyler, TX 75701
`Telephone: (903) 705-7233
`Facsimile:
`(903) 581-2543
`
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`ATTORNEYS FOR PLAINTIFF CELLULAR
`SOUTH, INC.
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`CERTIFICATE OF SERVICE
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`Pursuant to the Federal Rules of Civil Procedure and Local Rule CV-5, I hereby certify
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`that, on July 29, 2024, all counsel of record who have appeared in this case are being served with
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`a copy of the foregoing via the Court’s ECF system.
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`/s/ Robert S. Hill
` Robert S. Hill
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`12
`
`Google Exhibit 1017 - Google v. CSI
`IPR2025-00877 - Page 0013
`
`