DCT
8:17-cv-00382
Redcom Inc v. Jinni Tech Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: RED.COM, INC., dba RED DIGITAL CINEMA (Washington)
- Defendant: Jinni Tech, Ltd. (United Kingdom) and Bruce Royce (individual)
- Plaintiff’s Counsel: WEEKS NELSON
- Case Identification: 8:17-cv-00382, C.D. Cal., 03/02/2017
- Venue Allegations: Venue is based on Defendant Jinni Tech conducting business and making, using, offering for sale, or selling accused products within the judicial district. Venue for Defendant Royce is based on consent to exclusive jurisdiction in the district through a prior agreement with the Plaintiff.
- Core Dispute: Plaintiff alleges that Defendant’s third-party camera memory cards, marketed as "JinniMag," infringe a patent related to the high-speed capture and storage of compressed raw digital video data.
- Technical Context: The technology concerns high-performance, solid-state memory devices for professional digital cinematography cameras, a market where data integrity and sustained write-speeds are critical for high-budget productions.
- Key Procedural History: The complaint alleges that Defendant Bruce Royce is a prior customer of the Plaintiff and is bound by "Terms & Conditions of Sale" that prohibit reverse engineering or the development of non-approved products for use with Plaintiff's cameras.
Case Timeline
| Date | Event |
|---|---|
| 2007-04-11 | U.S. Patent No. 9,596,385 Priority Date |
| 2017-03-02 | Complaint Filing Date |
| 2017-03-14 | U.S. Patent No. 9,596,385 Issue Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,596,385 - "ELECTRONIC APPARATUS"
The Invention Explained
- Problem Addressed: The patent describes a market need for digital video cameras that can replace traditional film cameras in high-end productions like major motion pictures. It notes that while some digital cameras offer high resolution, their onboard image compression techniques are often too "lossy," eliminating too much raw image data to be acceptable for professional post-production work (’385 Patent, col. 1:29-40).
- The Patented Solution: The invention is an electronic apparatus and method for capturing and storing high-resolution raw or "substantially raw" video data at high frame rates (e.g., at least 2k resolution at 23 frames per second) (’385 Patent, col. 1:41-50). A key technique to enable this involves transforming the image data prior to compression by subtracting green channel information from the red and blue channels, which leverages the human eye's greater sensitivity to green to enhance data compressibility without significant visual loss (’385 Patent, col. 2:31-60). This allows for high compression ratios (e.g., 6:1 or greater) while the data remains "visually lossless."
- Technical Importance: This approach allows digital cameras to record data that retains the richness of raw sensor information, making it suitable for the demanding editing and color grading processes of professional filmmaking, thereby bridging the quality gap with traditional motion picture film (’385 Patent, col. 1:45-48).
Key Claims at a Glance
- The complaint asserts at least independent claim 7 (’385 Patent, col. 16:55-17:41; Compl. ¶46).
- The essential elements of independent claim 7, an apparatus claim, are:
- A housing configured to couple to a motion video imaging device.
- A communication interface configured to receive compressed mosaiced image data at a frame rate of at least 23 frames per second from the imaging device.
- The interface is also configured to output the compressed data.
- The data is described as being generated from a sensor with a resolution of at least 4k, by pre-emphasizing the data, transforming it (by subtracting an average of adjacent green pixel data from red/blue pixel data), and then compressing it with a lossy wavelet compression.
- A non-transitory computer readable storage medium configured to store the compressed data at a rate of at least 23 frames per second.
- The complaint alleges infringement of "one or more claims," reserving the right to assert others (Compl. ¶15).
III. The Accused Instrumentality
Product Identification
The accused products are memory devices marketed and sold under the name "JinniMag" (Compl. ¶15).
Functionality and Market Context
The complaint alleges that JinniMag devices are third-party solid-state memory cards designed to be "fully compatible" with Plaintiff's RED digital cinema cameras (Compl. ¶¶15, 17). Plaintiff asserts that Defendants market the JinniMag as a high-performance, lower-cost alternative to RED's own "Mini-Mag" media (Compl. ¶17). However, the complaint provides performance test data, illustrated in a graph plotting write speed over time, which allegedly shows that a JinniMag 480GB drive fails to sustain its write performance, dropping frames and producing an error after the drive is approximately 60% full (Compl. ¶18, p. 7). The complaint also presents a screenshot from a RED camera's user interface, which allegedly shows that a 480GB JinniMag device identifies itself to the camera system as a "RED 512GB V4" drive with an authentic RED serial number, a practice Plaintiff characterizes as "spoofing" (Compl. ¶33, p. 13).
IV. Analysis of Infringement Allegations
'385 Patent Infringement Allegations
| Claim Element (from Independent Claim 7) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An apparatus capable of receiving and storing compressed mosaiced image data...comprising: a housing configured to couple to a motion video imaging device... | The JinniMag memory devices have a housing configured to couple to a motion video imaging device, such as a RED camera. | ¶46 | col. 16:55-61 |
| a communication interface supported by the housing...configured to receive compressed mosaiced image data at a frame rate of at least about 23 frames per second from the motion video imaging device... | The JinniMag devices have a communication interface that receives compressed mosaiced image data from a compatible RED camera at a rate of at least 23 frames per second. | ¶46 | col. 16:62-66 |
| wherein mosaiced image data used to generate the compressed mosaiced image data is generated by an image sensor...at least by: pre-emphasizing...transforming...compressing the pre-emphasized, transformed mosaiced image data with a mathematically lossy wavelet compression... | The complaint alleges that RED cameras compatible with JinniMag devices perform these processing steps to generate the compressed data that the JinniMag is designed to receive and store. | ¶46 | col. 17:5-24 |
| a non-transitory computer readable storage media...configured to store the compressed mosaiced image data at a frame rate of at least about 23 frames per second. | The JinniMag device contains a non-transitory storage medium (an SSD) that stores the compressed image data from the RED camera. | ¶46, ¶17:11-14 | col. 17:35-41 |
- Identified Points of Contention:
- Scope Questions: The infringement theory rests on an apparatus claim (for a memory device) where the key data-processing limitations (e.g., "transforming," "compressing") describe actions performed not by the accused device itself, but by the host camera it couples with. The case may therefore raise the question of whether a third-party peripheral, which does not independently perform the inventive processing steps, can be said to be the claimed "apparatus" simply because it is designed to store the resulting data from a system that does.
- Technical Questions: The complaint alleges that the JinniMag fails to reliably operate at the claimed data rates (Compl. ¶18). This raises a factual question: if a device consistently drops frames and produces errors under the specified conditions, is it truly "configured to store" data at that rate as required by the claim, or does its operational failure place it outside the claim's scope?
V. Key Claim Terms for Construction
- The Term: "configured to" (e.g., "configured to receive," "configured to store")
- Context and Importance: This term appears repeatedly in claim 7 and is central to the infringement analysis. Practitioners may focus on this term because the dispute centers on whether a device that is compatible with a system but allegedly fails to perform reliably can be considered "configured" for that system's functions. The definition will determine whether the accused product's alleged performance failures are relevant to infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a camera system capable of certain functions and frame rates (’385 Patent, col. 1:48-50). A party could argue that any device designed with a housing and interface to be interoperable with that system is necessarily "configured" for its operations, and that operational success is a question of quality or damages, not claim scope.
- Evidence for a Narrower Interpretation: The patent emphasizes the goal of creating a camera suitable for high-end productions, where reliability is paramount (’385 Patent, col. 1:45-48). A party could argue that "configured to" implies a state of being suitable and capable of performing the function successfully and that a device that demonstrably fails does not meet this requirement.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendants market and sell the JinniMag devices with the knowledge and intent that customers will use them in an infringing manner with RED cameras and that they provide instructions for such use (Compl. ¶44). It also alleges contributory infringement, asserting the JinniMag is not a staple article of commerce and is especially made for use in an infringing manner (Compl. ¶45).
- Willful Infringement: Willfulness is alleged based on Defendants having at least constructive notice of the patent and continuing to infringe. The complaint notes that Defendants are aware of the '385 patent "at least by the service of this Complaint" (Compl. ¶¶44, 48).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope for apparatus claims: Can an "apparatus" claim directed to a memory device be infringed by a product that does not itself perform the inventive data transformations, but is merely configured to couple with and store data from a separate device (a camera) that does perform them?
- A key evidentiary question will be one of operational capability: Does the accused product's alleged failure to reliably sustain the claimed data rates, as depicted in the complaint's performance graphs, constitute a failure to meet the "configured to store" limitation of the claim, presenting a potential non-infringement defense?
- The case will likely examine the interplay of patent and non-patent claims: How will evidence of non-patent allegations, such as the "spoofing" of the device's identity to the camera and alleged false advertising about performance, influence the patent-specific issues of intent for indirect and willful infringement, as well as potential damages?