DCT
2:25-cv-04151
Spin Screen Inc v. Holofan Co LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Spin Screen, Inc. (Florida)
- Defendant: Holofan Co., LLC (California)
- Plaintiff’s Counsel: houstonip
- Case Identification: 2:25-cv-04151, C.D. Cal., 05/08/2025
- Venue Allegations: Venue is alleged to be proper as Defendant is a resident of the Central District of California and a substantial part of the alleged infringement occurs in the district.
- Core Dispute: Plaintiff alleges that Defendant’s holographic fan displays infringe two patents related to rotational "Persistence of Vision" (POV) technology that enables the display of clear, undistorted images.
- Technical Context: The technology involves rapidly rotating arrays of light-emitting diodes (LEDs) to create the illusion of a solid, floating two-dimensional or three-dimensional image.
- Key Procedural History: The complaint details the prosecution history of the patents-in-suit, noting arguments made to overcome prior art rejections. Specifically, the applicant argued that prior art did not teach a system capable of displaying text and graphics "without bending the text and graphics around the axis of rotation" or "across a flat datum line," a distinction central to the current infringement allegations.
Case Timeline
| Date | Event |
|---|---|
| 2004-07-21 | Earliest Priority Date for ’214 & ’108 Patents |
| 2012-10-09 | U.S. Patent No. 8,284,214 Issues |
| 2013-04-02 | U.S. Patent No. 8,411,108 Issues |
| 2025-05-08 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,284,214 - "Rotational Display System"
The Invention Explained
- Problem Addressed: The patent addresses limitations in early-2000s POV display technology, where images were typically monochromatic, low-resolution, and suffered from severe circular distortion (Compl. ¶¶70, 76). This distortion caused images and text to "twist the (normally horizontal) ground plane...around the axis of rotation," making them appear bent or "spiraled in a blender" and difficult to read (Compl. ¶¶88-89; ’214 Patent, col. 5:10-16). Existing devices also lacked the ability to display user-selected, high-quality color images or video from external sources (Compl. ¶77).
- The Patented Solution: The invention provides a system that processes image data to correct for rotational distortion, enabling a clear, stable image to be displayed "without bending the horizontal ground plane" (’214 Patent, Claim 1). This is achieved by converting image data from standard rectangular (Cartesian X,Y) coordinates into polar coordinates (radius and angle) suitable for a rotating display, a process the complaint alleges was a novel solution at the time (Compl. ¶¶96, 118-119; ’214 Patent, col. 12:40-52). The system integrates a computer for storing image data, a controller to receive that data, and a rotatable assembly of illuminating elements to display the corrected image (Compl. ¶108; ’214 Patent, Fig. 5).
- Technical Importance: This approach aimed to transform POV devices from simple novelties displaying pre-programmed text into versatile displays capable of rendering high-quality, user-provided images and video equivalent to a conventional monitor (Compl. ¶95).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (Compl. ¶177).
- The essential elements of Claim 1 include:
- a computer for storage and recall of data representing at least one visual image;
- a controller in wireless communication with the computer and operable to receive at least some of said data;
- a rotatable assembly for displaying an image...including an illuminating assembly...including at least one illuminating element, said rotatable assembly being constructed and arranged for attachment to a support for rotation about an axis;
- a power delivery means for providing power to said rotatable assembly; and
- an image...displayed without bending the horizontal ground plane around said axis.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 8,411,108 - "Rotational Display System"
The Invention Explained
- Problem Addressed: As a continuation-in-part sharing a substantially similar specification with the ’214 Patent, the ’108 Patent addresses the same technical problem of circular distortion in prior art POV displays and their inability to render high-quality, user-selected images (Compl. ¶71, n.1; ’108 Patent, col. 5:16-34).
- The Patented Solution: The ’108 Patent discloses the same core solution: a system architecture that uses a computer, controller, and rotatable illuminating assembly to display images that have been mathematically processed to appear level and undistorted (Compl. ¶¶118-119; ’108 Patent, col. 6:53-7:14). The specification describes the process of converting image data from Cartesian to polar coordinates to enable a stable display on a circular plane (’108 Patent, col. 13:33-14:40).
- Technical Importance: The invention is presented as enabling POV systems to overcome prior limitations and function as high-definition visual displays for a wide range of applications, from vehicle wheels to standalone advertising devices (Compl. ¶95; ’108 Patent, col. 6:32-53).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 16 (Compl. ¶200).
- The essential elements of Claim 16 include:
- a computer for storage and recall of data representing at least one visual image;
- a controller in electrical communication with the computer and operable to receive at least some of said data;
- a rotatable assembly for displaying an image...including an illuminating assembly...including at least one illuminating element, said rotatable assembly being constructed and arranged for attachment to a support for rotation about an axis;
- a power delivery means for providing power to said rotatable assembly; and
- an image...displayed without bending the horizontal ground plane around said axis.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The accused products include the "Holofan 3D Hologram Fan Device," "Holofan Handheld Device," "Holototem Device," and related products, along with the associated "Holofan Mobile Application" and "Holofan PC Application" (collectively, the "Holographic display systems") (Compl. ¶¶178, 201).
Functionality and Market Context
The accused products are described as fan-like devices with blades containing RGB LEDs that rotate at high speed to create "jaw-dropping holographic presentations" that appear to float in mid-air (Compl. ¶63, p. 63). Users can connect a computer or mobile device (e.g., smartphone) to the Holofan device via Wi-Fi or other means to upload, store, and display custom images and videos (Compl. ¶¶182, 185; p. 64). The complaint presents evidence that these devices are marketed as creating "impeccable," "sharp and smooth" visuals without the blur or distortion of older technologies (Compl. ¶113, p. 113). The complaint includes an image from Defendant's materials showing a user transferring a visual of a brain scan from a phone to the rotating display (Compl. ¶187, p. 97).
IV. Analysis of Infringement Allegations
U.S. Patent No. 8,284,214 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a computer for storage and recall of data representing at least one visual image | The system uses a computing device, such as a smartphone or PC, running Defendant’s software to store and recall image and video files for display. An image shows visual contents stored on a phone. | ¶¶182-184; p. 71 | col. 9:62-10:12 |
| a controller in wireless communication with the computer and operable to receive at least some of said data | The Holofan device contains a controller that receives image data from the user’s computer or smartphone via a wireless connection, such as Wi-Fi. | ¶¶185-186 | col. 10:12-25 |
| a rotatable assembly for displaying an image...including an illuminating assembly...including at least one illuminating element, said rotatable assembly being...for attachment to a support for rotation... | The accused product is a fan with rotating blades ("rotatable assembly") containing LEDs ("illuminating elements") that display the image. The assembly is attached to a support structure such as a tripod or stand. | ¶¶187-189; p. 105 | col. 10:25-53 |
| a power delivery means for providing power to said rotatable assembly | The accused devices contain a built-in battery or can be connected to an AC power source to power the rotating assembly and its electronics. | ¶190; p. 109 | col. 11:53-12:24 |
| an image represented by said data...displayed by said rotatable assembly during rotation...said image displayed without bending the horizontal ground plane around said axis. | Defendant’s products are alleged to display clear, stable, and level images that do not exhibit the circular bending or distortion characteristic of prior art devices. An image shows a non-bending visual of a shoe. | ¶191; p. 112 | col. 12:36-13:40 |
U.S. Patent No. 8,411,108 Infringement Allegations
| Claim Element (from Independent Claim 16) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a computer for storage and recall of data representing at least one visual image | The system uses a smartphone or PC with Defendant’s app to store and recall visual data. | ¶¶205-207 | col. 9:62-10:12 |
| a controller in electrical communication with the computer and operable to receive at least some of said data | The Holofan device’s controller establishes electrical communication with the user's computing device via wireless protocols (e.g., Wi-Fi, Bluetooth) or wired protocols (e.g., USB). | ¶¶208-209 | col. 10:12-25 |
| a rotatable assembly for displaying an image...including an illuminating assembly...including at least one illuminating element, said rotatable assembly being...for attachment to a support for rotation... | The accused product consists of a fan with rotating LED blades ("rotatable assembly") mounted to a base or tripod ("support"). An image depicts a device with a collapsible extension pole and foldable tripod. | ¶¶210-212; p. 164 | col. 10:25-53 |
| a power delivery means for providing power to said rotatable assembly | The accused devices are powered by an internal battery or an external power source, such as an AC adapter or a portable power bank. | ¶213; p. 168 | col. 11:53-12:24 |
| an image represented by said data...displayed by said rotatable assembly during rotation...said image displayed without bending the horizontal ground plane around said axis. | The complaint alleges the accused devices, through high-speed rotation and processing, create "impeccable" and "smooth" visuals that are displayed levelly and without the bending distortion seen in earlier technologies. | ¶214; pp. 171-172 | col. 12:36-13:40 |
Identified Points of Contention
- Scope Questions: The dispute may center on the meaning of "without bending the horizontal ground plane around said axis." A key question will be whether this phrase is limited to the specific Cartesian-to-polar mathematical conversion methods disclosed in the specification, or if it more broadly covers any resulting image that appears visually level and undistorted to an observer.
- Technical Questions: An evidentiary question may arise regarding how the accused systems technically achieve their stable images. The analysis may explore whether the accused software and hardware perform the specific trigonometric conversions described in the patents or utilize an alternative, non-infringing technical method to correct for rotational distortion. The arguments made during prosecution to distinguish prior art that also created rotational displays will be a central focus.
V. Key Claim Terms for Construction
- The Term: "without bending the horizontal ground plane around said axis"
- Context and Importance: This limitation appears in the asserted independent claims of both patents-in-suit and is presented in the complaint as the key inventive concept distinguishing the patents from prior art that produced circularly distorted images. The construction of this term will likely be determinative of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification contrasts the invention with prior art that "twist the (normally horizontal) ground plane of the image or text around the axis of rotation" (’108 Patent, col. 5:16-20). This framing may support an interpretation based on the functional result: an image that appears level to a viewer, as if on a flat plane, rather than one that visually wraps around the center point. The "Summary of the Invention" describes the capability of producing a "clear, bright, high definition image that is equivalent to that of a modern day TV or high-quality computer monitor" (’108 Patent, col. 6:49-53), which may also support a broader, results-oriented definition.
- Evidence for a Narrower Interpretation: The detailed description explains that achieving an unbent image requires converting Cartesian (X,Y) coordinates to polar coordinates (’108 Patent, col. 13:33-55). A party might argue the claim term should be limited to systems that perform this specific type of mathematical transformation. The complaint itself details the use of the Pythagorean theorem and arctan2 function as the disclosed process (Compl. ¶¶120-121). This explicit disclosure of a specific mathematical method could be used to argue for a narrower construction tied to that implementation.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement based on Defendant providing instructions, software applications, and user manuals that allegedly direct and encourage customers to operate the Holographic display systems in a manner that directly infringes the patents-in-suit (Compl. ¶¶193, 216). Contributory infringement is also alleged, based on the assertion that the accused systems are especially made for an infringing use and are not staple articles of commerce (Compl. ¶¶194, 217).
- Willful Infringement: The willfulness allegations are based on alleged post-notice conduct. The complaint contends that after being made aware of the patents by the lawsuit, Defendant's continued alleged infringement will be willful, wanton, and egregious (Compl. ¶¶197, 220).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the phrase "without bending the horizontal ground plane," which is rooted in overcoming the specific circular distortion of early POV devices, be construed to cover the allegedly stable, high-frame-rate images produced by the accused modern holographic fans, or is it limited to the specific mathematical conversion algorithms detailed in the patent specifications?
- A key question of fact and validity will be whether the technology used in the accused Holofan systems is coextensive with the claimed invention or if it represents a different technical solution. This will likely involve an examination of whether the underlying principle of converting Cartesian image data to polar coordinates, as taught by the patents, was truly a non-obvious solution to the distortion problem at the time of the invention in 2004.