Motiverse Inc v. Corsair Gaming Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Motiverse Inc. (South Korea)
  • Defendant: Corsair Gaming, Inc. (Delaware)
  • Plaintiff’s Counsel: Broadview IP LAW, PC
• Case Identification: 8:25-cv-01593, C.D. Cal., 07/22/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business in the district, including warehousing facilities and distribution centers in California, and has transacted substantial business within the district.
• Core Dispute: Plaintiff alleges that Defendant’s optical gaming mice, which feature "Lift Off Distance" technology, infringe a patent related to preventing erroneous cursor movement when a mouse is lifted from a surface.
• Technical Context: The technology addresses a common issue in early optical mice where lifting and repositioning the device could cause unintended cursor drift due to out-of-focus image capture.
• Key Procedural History: The complaint notes the patent-in-suit expired on September 4, 2024. Plaintiff seeks damages for past infringement. The complaint also details a chain of assignments for the patent, culminating in its transfer to Plaintiff Motiverse Inc. on May 1, 2025.

Case Timeline

Date	Event
2002-07-30	'338 Patent Priority Date (Korean Application 10-2002-0045093)
2003-07-28	'338 Patent Application Filing Date
2006-08-08	'338 Patent Issue Date
2024-09-04	'338 Patent Expiration Date
2025-07-22	Complaint Filing Date

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

• Patent Identification: U.S. Patent No. 7,088,338, "Optical Mouse and Method for Preventing an Erroneous Operation thereof," issued August 8, 2006.

The Invention Explained

• Problem Addressed: The patent describes a problem with conventional optical mice where, if the mouse is lifted from its operating surface, the image sensor captures an out-of-focus image, which is misinterpreted as movement and causes the on-screen cursor to move erroneously despite no actual horizontal travel of the mouse (’338 Patent, col. 1:43-59).
• The Patented Solution: The invention proposes an optical mouse with additional components to detect a "pick-up" event. It uses a "statistic value calculator" to analyze the image data from the A/D converter (e.g., by calculating an average pixel value) and a "pick-up state discriminator" to determine if the mouse has been lifted based on that statistic. When a pick-up is detected, a signal is generated that forces the mouse’s reported moving value to "0", preventing unwanted cursor movement (’338 Patent, col. 3:12-29; Fig. 3).
• Technical Importance: This approach provided a method to distinguish intentional movement from the spurious signals generated during a "lift-off" event, a critical feature for users who frequently lift and reposition their mouse, such as gamers using low-sensitivity settings.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 and dependent claim 2 (Compl. ¶14).
• Independent Claim 1, as corrected by the Certificate of Correction, contains the following essential elements:
  • An optical mouse comprising:
  • an image sensor, consisted of a plurality of pixels, for outputting signals accumulated in a given time as a pixel unit;
  • an A/D converter for receiving the output of the image sensor and converting the output into a digital signal format;
  • an image data processor for receiving the output of the A/D converter and calculating a moving value of the optical mouse;
  • a system controller for controlling data flow with an external system and receiving the image data processor;
  • a statistic value calculator for receiving the output of the A/D converter and calculating a statistic value; and
  • a pick-up state discriminator for receiving the output of the statistic value calculator and generating a pick-up state signal,
  • wherein the pick-up state signal is used to make the moving value "0".

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Corsair’s wired and wireless optical gaming mice that feature "Lift Off Distance" (LOD) technology (Compl. ¶¶7, 24). Specific product families named include NIGHTSWORD, IRONCLAW, DARK CORE, and SCIMITAR (Compl. ¶37).

Functionality and Market Context

• The complaint alleges that the accused mice are equipped with optical sensors from PixArt Imaging Inc., including models PMW3391, PMW3392, PMW3367, and others which are allegedly based on the PMW3360 and/or PMW3389 architecture (Compl. ¶¶26-28).
• The relevant functionality is described as "Lift Off Distance" (LOD), which the complaint defines as the point at which a lifted mouse stops tracking movement (Compl. ¶24). The complaint alleges that the underlying PixArt sensors perform this lift detection by finding an "average raw data value of an image frame" and comparing it to a threshold to determine if a "lift state" has occurred, thereby preventing cursor movement (Compl. ¶¶29-30).
• The complaint frames low LOD as a very important feature for gamers, who often need to reposition their mouse without interrupting gameplay (Compl. ¶15).

IV. Analysis of Infringement Allegations

The complaint states that a claim chart is attached as Exhibit C; however, this exhibit was not provided with the filing (Compl. ¶36). The infringement theory, as articulated in the body of the complaint, is summarized below.

No probative visual evidence provided in complaint.

The core of the infringement allegation is that the "Lift Off Distance" (LOD) feature in Corsair's gaming mice operates in a manner that meets the limitations of the ’338 Patent’s claims (Compl. ¶25). The complaint alleges that the PixArt optical sensors (e.g., PMW3360, PMW3389) used in the Accused Products perform the functions recited in the claims (Compl. ¶¶28-30). Specifically, Plaintiff alleges the sensors determine a lift has occurred by "comparing the average of the pixels of the acquired image against a predetermine[d] threshold value," which is then used to "prevent cursor movement" (Compl. ¶¶30, 10). This functionality is alleged to correspond to the claimed "statistic value calculator" and "pick-up state discriminator" that generates a signal to make the moving value "0" (Compl. ¶¶19, 30). The complaint asserts infringement of at least claims 1 and 2 of the '338 patent (Compl. ¶37).

• Identified Points of Contention:
  • Technical Question: What specific algorithm do the accused PixArt sensors use for lift detection? The case may require discovery into whether the sensors' method of finding an "average raw data value" and comparing it to a "predetermine[d] threshold value" (Compl. ¶¶29-30) is technically equivalent to the patent’s description of calculating a "statistic value" and using a "discriminator" to judge if the value is "below the reference level continuously" (’338 Patent, col. 3:55-59).
  • Scope Question: Does the accused functionality of determining a "lift state" (Compl. ¶29) correspond to the claim limitation of generating a "pick-up state signal" that is "used to make the moving value '0'"? The analysis will likely focus on the precise mechanism by which the accused mice stop reporting movement and whether that mechanism falls within the scope of the claim language.

V. Key Claim Terms for Construction

• The Term: "statistic value calculator"

• Context and Importance: This term defines the component that processes the raw image data to enable lift detection. The infringement case rests on the allegation that the accused sensors' calculation of an "average raw data value" (Compl. ¶29) is a "statistic value." Practitioners may focus on this term because its breadth will determine if it covers only the specific "average value" embodiment or a wider range of statistical methods.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term "statistic value" is not explicitly defined, suggesting it could be given its plain and ordinary meaning, which might encompass various statistical measures beyond a simple average.
  • Evidence for a Narrower Interpretation: The patent repeatedly references an "average value calculator" in the detailed description (’338 Patent, col. 3:21) and the abstract. Further, dependent claim 2 explicitly limits the "statistic value" to one "obtained by averaging the pixel value" (’338 Patent, col. 6:28-30), which could be used to argue the 'statistic' in claim 1 should be interpreted consistently with this more specific disclosure.

• The Term: "pick-up state discriminator"

• Context and Importance: This is the core functional element that makes the decision to halt cursor movement. The central dispute will be whether the accused products' "lift detection" mechanism (Compl. ¶30) is the same as the claimed "discriminator."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term itself is functional. A party could argue it covers any component that distinguishes between a normal operating state and a "pick-up" state based on the calculated statistic.
  • Evidence for a Narrower Interpretation: The specification provides a specific functional description: it "judges whether the optical mouse is spaced apart from the operating surface when an average value of pixels in one sampling period becomes below the reference level continuously" (’338 Patent, col. 3:55-59). An opposing party could argue that this "continuously" requirement imposes a temporal or sequential condition that the accused products' simple threshold comparison (Compl. ¶30) may not meet.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), stating that Corsair’s marketing materials, technical specifications, data sheets, and user manuals encourage and instruct customers to use the accused LOD features (Compl. ¶¶39-40). It also pleads contributory infringement under § 271(c), alleging the Accused Products are specially made for infringement and are not staple articles of commerce with substantial non-infringing uses (Compl. ¶41).
• Willful Infringement: Willfulness is not explicitly pleaded as a separate count, but the complaint alleges Corsair "knew, or should have known" its actions constituted infringement and acted with "specific intent to induce" (Compl. ¶40). The complaint establishes post-suit knowledge by stating "Corsair has knowledge of the '338 patent based on the filing and service of this Complaint" (Compl. ¶35).

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

1. A central issue will be one of claim construction: how broadly will the court define the terms "statistic value calculator" and "pick-up state discriminator"? The outcome may depend on whether these terms are limited to the specific embodiment of an "average value" checked "continuously," as described in the specification, or if they encompass any statistical threshold test for lift detection.

2. A key evidentiary question will be one of technical operation: does the accused lift-off detection (LOD) functionality in the PixArt sensors, which allegedly compares an "average of the pixels" to a "predetermine[d] threshold value," perform the same function in the same way to achieve the same result as the system claimed in the '338 patent? Discovery into the precise algorithms of the accused sensors will be critical to resolving this question.