DCT

2:20-cv-01650

Olati LLC v. Haas Automation Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:20-cv-01650, C.D. Cal., 02/20/2020
  • Venue Allegations: Venue is alleged to be proper because Defendant is a California corporation with its principal place of business and a regular and established place of business within the judicial district, and has allegedly committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s closed-loop Computer Numerical Control (CNC) lathes infringe a patent related to real-time monitoring and adjustment of machining parameters using a sensor-based feedback system.
  • Technical Context: The technology concerns automated process control in precision manufacturing, where sensors measure a tool's operating conditions to allow for real-time adjustments, aiming to improve quality and repeatability.
  • Key Procedural History: The complaint asserts that the patented technology was developed to solve repeatability issues in high-precision manufacturing, such as for aerospace components. Subsequent to the filing of this complaint, an inter partes review (IPR) proceeding was initiated against the patent-in-suit (IPR2021-00146). The IPR resulted in a certificate, issued April 1, 2024, cancelling all claims (1-8) of the patent. This post-filing cancellation of the asserted claim fundamentally alters the posture of the case.

Case Timeline

Date Event
2006-06-12 ’432 Patent Priority Date
2012-03-20 ’432 Patent Issue Date
2020-02-20 Complaint Filing Date
2020-11-06 IPR Petition Filed against ’432 Patent
2024-04-01 IPR Certificate Issued, Cancelling Claims 1-8

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

  • Patent Identification: U.S. Patent No. 8,136,432, CLOSED-LOOP CNC MACHINE SYSTEM AND METHOD, issued March 20, 2012.

The Invention Explained

  • Problem Addressed: The patent describes that industrial controls for manufacturing have not kept pace with advances in computer technology and still rely on basic algorithms from the 1950s and 60s (’432 Patent, col. 2:7-17). This creates challenges in CNC machining, where factors like tool wear, material hardness, and vibrations can degrade the quality of finished parts, requiring a machinist to perform manual, trial-and-error adjustments to optimize parameters like cutting speed and feed rate (’432 Patent, col. 1:52-67).
  • The Patented Solution: The invention proposes a closed-loop feedback control system to automate this optimization process (’432 Patent, Abstract). The system uses at least one sensor associated with the cutting tool to measure its physical properties—such as force, deflection, or vibration—in real-time during the machining operation (’432 Patent, col. 2:20-22). This data is processed by a signal analyzer, and a controller then automatically adjusts the machine’s operating parameters (e.g., spindle speed or feed rate) based on the sensor feedback, thereby compensating for variations and improving quality without manual intervention (’432 Patent, Fig. 6; col. 2:56-col. 3:3).
  • Technical Importance: This technology aimed to increase the autonomy and productivity of CNC equipment by enabling it to self-correct for dynamic conditions, which is particularly important for complex, high-precision operations like inside turning ("boring") where tool rigidity is limited (’432 Patent, col. 7:15-24).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 1 (Compl. ¶19).
  • The essential elements of Claim 1 include:
    • A machine with a workpiece holder, a tool holder, a spindle drive system, and a feed drive system
    • A tool
    • At least one sensor operatively associated with the tool
    • At least one signal converter, signal analyzer, and controller
    • The sensor receives a signal from the tool, which the converter changes to digital parameters
    • The signal analyzer determines in real-time at least one of the force, deflection, or vibration of the tool
    • The controller adjusts the power of the spindle or feed drive system in real-time based on the analyzer's determination

III. The Accused Instrumentality

Product Identification

The complaint identifies "closed-loop CNC lathes," including the ST Series, Dual-Spindle Series, Toolroom Lathes Series, and Chucker Lathe Series (collectively, "Haas Lathes") (Compl. ¶19).

Functionality and Market Context

The accused Haas Lathes are described as "closed-loop feedback control machining systems" that utilize a proprietary "machining algorithm" (Compl. ¶¶5, 20). This algorithm allegedly prevents "starving the machine," a term the complaint defines as operating the tool at a speed inappropriate for the load (Compl. ¶¶8-11). The system is alleged to work by using an encoder on a servo motor to sense the force on the tool; this "force-on-tool" information is then converted to a digital signal and processed by the algorithm to make real-time adjustments to the machining process (Compl. ¶¶26-28, 32). A labeled diagram from a Haas operator's manual identifies key mechanical components of a lathe, such as the spindle motor (1), tool turret assembly (2), and feed drive system (3) (Compl. p. 7).

IV. Analysis of Infringement Allegations

’432 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a machine comprising: a workpiece holder; a tool holder; a spindle drive system... and a feed drive system... The Haas Lathes are machines that include a workpiece holder, a tool holder, a spindle drive system for rotation, and a feed drive system for translational movement. ¶¶21-24 col. 6:46-52
a tool The Haas Lathes are sold with removable tools, such as bits. ¶25 col. 7:21
at least one sensor operatively associated with the tool An encoder associated with the servo motor functions as a sensor by sensing the force on the tool. ¶26 col. 6:53-54
at least one signal converter operatively associated with the at least one sensor A controller board includes an analog-to-digital converter that receives the analog signal from the encoder. ¶27 col. 6:54-56
at least one signal analyzer operatively associated with the at least one signal converter A "machining algorithm" running on the Main Control Panel acts as the signal analyzer. ¶28 col. 6:56-58
at least one controller operatively associated with the... signal analyzer and... drive system... The Haas Lathe controller is in electrical communication with the signal analyzer and the spindle and feed drive systems. ¶29 col. 6:58-61
the at least one sensor receives a signal from the tool... The encoder receives a signal indicating the "force-on-tool" while the tool is in use. ¶30 col. 6:60-62
the at least one signal converter converts the received signal to a set of digital parameters... The analog-to-digital converter converts the analog force-on-tool signal into a digital signal (a set of digital parameters). ¶31 col. 6:62-65
the at least one signal analyzer determines in real-time at least one of the elements selected from the group consisting of: the force on the tool... The "machining algorithm" uses sensed force-on-tool data to determine in real-time the force on the tool in order to prevent "starving the machine." ¶32 col. 6:65-col. 7:1
the at least one controller adjusts the power exerted by at least one of the spindle drive system and the feed drive system in real-time... The controller receives information from the signal analyzer and adjusts the power of the machine's drive systems to change the tool load. ¶33 col. 7:1-3

Identified Points of Contention

  • Scope Questions: A central dispute may arise over whether an "encoder associated with the servo motor" (Compl. ¶26) satisfies the claim limitation of a "sensor operatively associated with the tool." The defense may argue that this claim language, in light of the patent's focus on sensors embedded in or on the tool itself (’432 Patent, col. 7:51-56), requires a more direct physical association than inferring force from a motor's electrical load.
  • Technical Questions: The complaint alleges that Haas's feature for preventing "starving the machine" determines the "force on the tool" (Compl. ¶32). A photograph of a Haas machine's graphical user interface and control panel, which the complaint alleges can display "load" information, is provided as evidence (Compl. p. 9). A technical question for the court will be whether monitoring motor "load" is technically equivalent to "determin[ing]... the force on the tool" as that phrase would be understood by a skilled artisan in the context of the patent.

V. Key Claim Terms for Construction

  • The Term: "sensor operatively associated with the tool"

    • Context and Importance: The infringement theory hinges on construing this term to cover an encoder on a drive motor, which is physically separate from the tool. Practitioners may focus on this term because its breadth will determine whether the accused system's indirect method of sensing falls within the claim scope.
    • Intrinsic Evidence for a Broader Interpretation: The claim uses the general term "operatively associated," which does not explicitly require physical contact. The specification notes that the sensor may be located "in the tool itself, on the tool holder, or somewhere inside the machine" (’432 Patent, col. 7:49-51), potentially supporting an association that is functional rather than strictly physical.
    • Intrinsic Evidence for a Narrower Interpretation: The patent’s preferred embodiments and technical descriptions repeatedly emphasize direct measurement of the tool's state, such as using fiber optic sensors "embedded in the tool" to measure "deflection, force and vibration" (’432 Patent, col. 7:51-56). This context could support a narrower construction requiring the sensor to measure a physical property of the tool itself, not an electrical property of its drive motor.

  • The Term: "determines in real-time... the force on the tool"

    • Context and Importance: This term is critical because the complaint equates determining "force on the tool" with monitoring motor "load" to prevent "starving the machine" (Compl. ¶32). The viability of the infringement claim depends on whether these two functions are legally and technically the same.
    • Intrinsic Evidence for a Broader Interpretation: The patent does not specify the method of "determination." An argument could be made that "determines" includes calculating or inferring a value (force) from a closely related, measurable proxy (motor load).
    • Intrinsic Evidence for a Narrower Interpretation: The specification discusses measuring physical properties like "deflection, forces and vibrations of the tool" directly (’432 Patent, col. 7:35-38). This may suggest that "determines" requires a more direct quantification of the physical force, as distinct from monitoring an electrical load value that may be influenced by other factors beyond the tool-workpiece interaction.

VI. Other Allegations

  • Indirect Infringement: The complaint makes a passing allegation of indirect infringement (Compl. ¶35) but does not provide sufficient detail for analysis of inducement or contributory infringement, such as specific facts supporting knowledge and intent.
  • Willful Infringement: The complaint does not contain a specific allegation of willful infringement or plead facts indicating pre-suit knowledge of the ’432 patent. It includes a prayer for treble damages, but without supporting factual allegations in the body of the complaint, the basis for willfulness is not established (Compl., Prayer for Relief ¶D).

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

  • Effect of Claim Cancellation: The primary question in this case is a legal one: what is the effect of the post-complaint cancellation of all asserted patent claims in an IPR proceeding? This development will be central to arguments over whether any damages can be recovered for the period of infringement prior to the cancellation and renders any request for prospective injunctive relief moot.
  • Definitional Scope: Should the case proceed on pre-cancellation damages, a core issue will be one of definitional scope: can the term "sensor operatively associated with the tool," which the patent illustrates with sensors embedded in the tool, be construed to cover an encoder on a servo motor that indirectly infers tool load from the drive system?
  • Technical Operation: A key evidentiary question will be one of functional equivalence: does the accused system’s monitoring of motor "load" to prevent "starving the machine" constitute a "determination of... the force on the tool" as required by Claim 1, or is there a fundamental mismatch in the technical operation being performed versus the one claimed in the patent?