DCT
2:24-at-01391
Carbon Autonomous Robotic Systems Inc v. Laudando & Associates
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Carbon Autonomous Robotic Systems, Inc. (Delaware)
- Defendant: Laudando & Associates LLC (California)
- Plaintiff’s Counsel: Fish & Richardson P.C.
- Case Identification: 2:24-cv-01391, E.D. Cal., 10/31/2024
- Venue Allegations: Venue is asserted based on Defendant’s incorporation in California and its principal place of business in Chico, California, which is within the Eastern District. The complaint further alleges that Defendant has committed infringing acts and maintains a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s L&Aser weeder products infringe two patents related to autonomous, laser-based weed eradication systems.
- Technical Context: The technology operates in the agricultural robotics field, using computer vision, artificial intelligence, and lasers to precisely target and eliminate weeds, offering a non-chemical alternative to traditional herbicides and reducing manual labor.
- Key Procedural History: The complaint alleges that Defendant's founder publicly discussed Plaintiff's technology and patents on social media prior to the lawsuit. It also notes that a patent application by Plaintiff's founder was cited as prior art against Defendant's own patent application for similar technology, suggesting a competitive history and potential foreknowledge of Plaintiff's intellectual property.
Case Timeline
| Date | Event |
|---|---|
| 2019-09-17 | Earliest Priority Date for ’752 and ’547 Patents |
| 2023-09-19 | Defendant L&A announces Accused Product |
| 2024-10-08 | U.S. Patent No. 12,108,752 Issues |
| 2024-10-22 | Interview with L&A's founder discussing Accused Product |
| 2024-10-29 | U.S. Patent No. 12,127,547 Issues |
| 2024-10-31 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,108,752 - Autonomous Laser Weed Eradication, issued October 8, 2024
The Invention Explained
- Problem Addressed: The patent addresses the economic and environmental drawbacks of traditional weed control, such as labor-intensive hand cultivation and the use of chemical herbicides which can contaminate groundwater and pose health risks (’752 Patent, col. 6:4-13).
- The Patented Solution: The invention is an automated system that uses an optical control system to identify and eliminate weeds. It employs a camera to capture an image of a surface, a computing system to identify a weed within that image and determine its target location, and an emitter (e.g., a laser) that is aimed via steerable reflective elements to kill or damage the identified weed (’752 Patent, Abstract; col. 2:37-51). The system is designed to operate autonomously, providing a precise, non-chemical method for weed eradication.
- Technical Importance: This technology represents a shift toward automated, precision agriculture, aiming to reduce reliance on herbicides, lower labor costs, and improve crop yields through targeted, mechanical action (’752 Patent, col. 6:13-21).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶27).
- The essential elements of claim 1 include:
- A first camera to image a surface.
- An emitter to emit a beam toward the surface.
- A computing system that receives an image, identifies a region with a weed, determines the weed's target location, aligns an optical path to that location, and causes the emitter to fire, thereby killing or damaging the weed.
- The complaint alleges infringement of "one or more claims... including at least claim 1" (Compl. ¶27), preserving the option to assert other claims.
U.S. Patent No. 12,127,547 - Autonomous Laser Weed Eradication, issued October 29, 2024
The Invention Explained
- Problem Addressed: Similar to its companion patent, the ’547 Patent addresses the inefficiencies and environmental concerns of conventional weeding methods (’547 Patent, col. 1:15-21).
- The Patented Solution: The invention builds on the same core concept of a camera-and-laser system but introduces a specific method for operating on a moving platform. The asserted claim requires not only identifying and targeting a weed but also correcting the target location based on the motion of the camera relative to the surface. This correction mechanism is designed to maintain accuracy while the system is in motion (’547 Patent, col. 2:5-13; Claim 1).
- Technical Importance: This innovation is critical for the practical application of laser weeding in real-world agricultural settings, where the equipment is typically mounted on a moving vehicle and must compensate for its own movement to hit small targets accurately (’547 Patent, col. 11:45-12:4).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶58).
- The essential elements of claim 1 include:
- A first camera, an emitter, and a computing system.
- The computing system performs steps of receiving an image, identifying a weed, projecting a target location based on the identified region, aligning the emitter's optical path, correcting the target location based on camera motion, and causing the emitter to fire.
- The complaint alleges infringement of "one or more claims... including at least claim 1" (Compl. ¶58).
III. The Accused Instrumentality
Product Identification
The "L&Aser weeder" and "Rugged L&Aser™ Module" (Compl. ¶13; Exhibit G).
Functionality and Market Context
- The Accused Product is marketed as the "first purpose-built laser for weeding & thinning crops" and is designed as a module for agricultural equipment (Compl. ¶21; Exhibit G).
- Its technical specifications, as alleged in the complaint's exhibits, include a "2.35 MP RGB 8mm @ 126 FPS" imaging component, an NVIDIA Jetson Orin AGX 32Gb compute module, and a proprietary laser source and scanner system (Compl. ¶¶ 37, 39, 42; Exhibit G). A marketing flyer for the Accused Product shows a specification table listing these components (Compl. ¶37; Exhibit G).
- The complaint alleges that the Accused Product is a direct competitor to Plaintiff's "LaserWeeder" and that Defendant's founder has publicly acknowledged Plaintiff's role in the market while promoting the Accused Product (Compl. ¶¶ 6, 25; Exhibit M).
IV. Analysis of Infringement Allegations
’752 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first camera configured to image a surface; | The Accused Product includes a "2.35MP RGB 8mm @ 126FPS" imaging component. | ¶37 | col. 8:65-9:4 |
| an emitter configured to emit a beam toward the surface; | The Accused Product includes a proprietary laser source, driver, and scanner. | ¶39 | col. 6:50-58 |
| a computing system in communication with the first camera and the emitter... | The Accused Product uses an NVIDIA Jetson Orin AGX 32Gb computer. | ¶42 | col. 11:28-34 |
| receiving, from the first camera, an image of the surface, the image comprising a weed on the surface, | A LinkedIn post allegedly shows the Accused Product receiving images of a surface with weeds. | ¶44 | col. 2:51-57 |
| identifying a region in the image that includes the weed, | A YouTube video allegedly demonstrates the Accused Product identifying regions that include weeds. A screenshot from this video shows weed identification (Compl. p. 13). | ¶46 | col. 2:61-65 |
| determining a target location of the weed based on the identified region in the image, | The same YouTube video allegedly shows the determination of a target location based on the identified weed region. | ¶48 | col. 15:58-63 |
| aligning an optical path of the beam based on the target location of the weed... | An annotated image of the L&Aser module's interior shows a laser source and two galvo mirrors that allegedly direct the optical path to the weed (Compl. p. 15, Exhibit R). | ¶51 | col. 8:5-10 |
| wherein emitting the beam towards the weed kills or damages the weed. | A YouTube video allegedly shows the Accused Product emitting a beam that kills or damages a weed. | ¶53 | col. 6:29-36 |
’547 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| ...projecting a target location of the weed on the surface based on the identified region in the first image, | The complaint alleges this functionality based on YouTube videos showing targeting and refers to Defendant's own patent publication describing determining a target's location. | ¶¶ 48-49, 71 | col. 17:1-6 |
| ...correcting the target location based on a motion of the first camera relative to the surface, | Defendant's own published patent application allegedly describes a system that may "predict where a target will be between frames," using sensors to track ground speed to enable this prediction. | ¶73 | col. 11:24-44 |
| causing the emitter to emit the beam toward the weed when the optical path is aligned with the weed. | The complaint alleges this functionality by referring to evidence from the '752 patent infringement count, which includes videos of the product firing its laser. | ¶¶ 53-54, 74 | col. 17:21-25 |
Identified Points of Contention
- Evidentiary Basis for Motion Correction: For the ’547 Patent, the complaint heavily relies on statements from Defendant’s own published patent application to allege the "correcting the target location based on a motion" element (Compl. ¶73). A primary point of contention will be whether Plaintiff can produce evidence that the accused product itself actually performs this specific function, as opposed to it merely being described in a related patent filing.
- Scope of "Projecting" vs. "Determining": The ’752 Patent claims "determining a target location," while the ’547 Patent claims "projecting a target location." A dispute may arise over whether "projecting" requires a forward-looking calculation or prediction that is distinct from simply "determining" a present location, a distinction that could be critical to differentiating the two patents and their respective infringement analyses.
V. Key Claim Terms for Construction
The Term: "correcting the target location based on a motion of the first camera relative to the surface" ('547 Patent, Claim 1)
- Context and Importance: This limitation is the central inventive concept of the asserted claim of the ’547 Patent. The infringement case for this patent hinges on whether the Accused Product performs this function. Practitioners may focus on this term because the complaint's evidence for it is indirect, relying on Defendant's patent publication rather than direct observation of the product.
- Evidence for a Broader Interpretation: The claim language itself is functional and does not specify a particular method. The specification describes using an Inertial Measurement Unit (IMU) or GPS as examples, but does not appear to limit the claim to only these methods, potentially allowing for any form of motion compensation to fall within its scope (’547 Patent, col. 11:30-44).
- Evidence for a Narrower Interpretation: A defendant could argue that the term should be limited by the embodiments described, which involve specific components like an IMU, GPS, or INS to "determine a magnitude and a direction of motion over an elapsed time" (’547 Patent, col. 11:30-44). This could support an interpretation requiring a system that calculates velocity and predicts future position, not just a simple offset.
The Term: "projecting a target location" ('547 Patent, Claim 1)
- Context and Importance: This term, when read in conjunction with the motion-correction element, distinguishes the '547 patent's claim from the '752 patent's claim, which uses "determining." Its construction will be key to establishing the unique scope of the '547 patent.
- Evidence for a Broader Interpretation: The specification may use terms like "locate," "determine," and "project" in a general sense, suggesting they are largely interchangeable ways of identifying a target on a surface.
- Evidence for a Narrower Interpretation: The context of a system that corrects for motion suggests "projecting" implies a forward-looking calculation to a future point in time or space, rather than simply "determining" the current location. The specification discusses determining a "future target location" based on predicted motion, which could support a narrower, predictive meaning (’547 Patent, col. 12:1-4).
VI. Other Allegations
Indirect Infringement
The complaint alleges that Defendant induces infringement by providing customers with "educational and promotional materials, support activities, as well as its service and consulting activities" that instruct on how to use the Accused Product in an infringing manner (Compl. ¶¶ 30, 61).
Willful Infringement
The complaint alleges that Defendant had pre-suit knowledge of the patents and Plaintiff's technology. The allegations are based on public LinkedIn posts by Defendant’s founder mentioning Plaintiff's technology, and a third-party prior art submission against Defendant’s own patent application that cited a patent by Plaintiff’s founder (Compl. ¶¶ 24-25; Exhibits M, N). The complaint further alleges that infringement continues after the issuance of the patents, which occurred just prior to the filing of the suit (Compl. ¶56).
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of demonstrated functionality: Can the Plaintiff prove that the Defendant's commercial "L&Aser weeder" actually performs the "correcting...based on a motion" step required by the '547 patent, or does the evidence remain confined to descriptions in the Defendant's own patent application?
- A core issue will be one of definitional scope: Will the court construe "projecting a target location" ('547 Patent) as requiring a forward-looking, predictive calculation that is technically distinct from "determining a target location" ('752 Patent), or will the terms be treated as largely synonymous?
- A central factual question for the jury will be one of intent: Do the alleged public statements by Defendant's founder and the prosecution history of Defendant's own patent application establish pre-suit knowledge of Plaintiff's technology sufficient to support a finding of willful infringement?