DCT
2:24-cv-03012
Carbon Autonomous Robotic Systems Inc v. Laudando & Assoc LLC
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Carbon Autonomous Robotic Systems Inc. (Delaware)
- Defendant: Laudando & Associates LLC (California)
- Plaintiff’s Counsel: Sterne, Kessler, Goldstein & Fox P.L.L.C.
- Case Identification: 2:24-cv-03012, E.D. Cal., 04/03/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a California corporation with its principal place of business in the district, where it has allegedly committed acts of infringement and maintains a regular and established place of business.
- Core Dispute: Plaintiff alleges that Defendant’s laser-based agricultural weeding systems infringe four patents related to autonomous weed identification, targeting, motion compensation, and high-intensity illumination.
- Technical Context: The technology lies at the intersection of agricultural technology (AgTech) and robotics, using AI-powered computer vision and lasers to automate weed removal, offering a potential alternative to chemical herbicides and manual labor.
- Key Procedural History: The complaint alleges that Defendant’s founder has repeatedly mentioned Plaintiff, its technology, and its patents on social media, which may be used to support allegations of willful infringement. It also notes that Defendant's own patent application for similar technology was filed after the priority dates of the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2019-09-17 | Priority Date for ’752, ’547, and ’948 Patents |
| 2021-11-02 | Priority Date for ’372 Patent |
| 2022-02-01 | Plaintiff launches LaserWeeder G1 product |
| 2023-09-19 | Defendant first announces Accused Products |
| 2024-10-08 | U.S. Patent No. 12,108,752 issues |
| 2024-10-22 | Defendant’s founder discusses strategic plans in interview |
| 2024-10-29 | U.S. Patent No. 12,127,547 issues |
| 2025-01-01 | Plaintiff launches LaserWeeder G2 product |
| 2025-02-11 | U.S. Patent No. 12,219,948 issues |
| 2025-03-04 | U.S. Patent No. 12,240,372 issues |
| 2025-03-24 | Defendant references upcoming U.S. deployments on LinkedIn |
| 2025-04-03 | Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,108,752 - "Autonomous Laser Weed Eradication"
The Invention Explained
- Problem Addressed: The patent’s background section identifies the economic and environmental drawbacks of traditional weed control methods, which rely on either labor-intensive hand cultivation or chemical herbicides (’752 Patent, col. 6:5-12).
- The Patented Solution: The invention proposes an automated system that uses a camera to capture an image of a surface, a computing system to identify a weed within that image, and an emitter (such as a laser) to direct a beam at the identified weed to kill or damage it. The system's core function is to autonomously locate, target, and eradicate weeds without manual intervention or chemicals (’752 Patent, Abstract; col. 2:37-50).
- Technical Importance: The technology offers a method for automated, chemical-free weed control, which could increase agricultural efficiency and reduce environmental impact (’752 Patent, col. 6:12-21).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶38).
- Essential elements of Claim 1 include:
- A first camera configured to image a surface;
- An emitter configured to emit a beam toward the surface; and
- A computing system that performs operations comprising: receiving an image from the camera containing a weed, identifying a region with the weed, determining the weed's target location, aligning the beam's optical path with the target, and causing the emitter to fire the beam to kill or damage the weed.
U.S. Patent No. 12,127,547 - "Autonomous Laser Weed Eradication"
The Invention Explained
- Problem Addressed: Like its related patents, the ’547 Patent addresses the inefficiency and environmental concerns associated with traditional manual and chemical weeding methods (’547 Patent, col. 18:5-12).
- The Patented Solution: This invention builds upon the basic concept of automated laser weeding by explicitly adding an "actuator" to direct the beam and, critically, a processing step for "correcting the target location based on a motion of the first camera relative to the surface." This feature is designed to allow the system to maintain accuracy while moving across a field (’547 Patent, Abstract; col. 21:30-41). The process logic also includes deactivating the beam after a sufficient time to damage the weed (’547 Patent, Abstract).
- Technical Importance: The introduction of motion correction is a key enabler for using such a system on a mobile platform in a real-world agricultural setting, where the device must operate effectively while in motion (’547 Patent, col. 21:6-12).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶70).
- Essential elements of Claim 1 include:
- A first camera, an emitter, an actuator to direct the beam, and a computing system;
- The computing system performs operations comprising: receiving an image, identifying a weed, determining its target location, aligning the beam by adjusting the actuator, correcting the target location based on camera motion, causing the emitter to fire the beam, and causing the emitter to deactivate the beam after a sufficient time.
U.S. Patent No. 12,219,948 - "Autonomous Laser Weed Eradication"
Technology Synopsis
This patent specifies a more detailed hardware configuration for a laser weeding system, claiming a control system that comprises a "first actuator and a first mirror" and a "second actuator and a second mirror" for directing the light beam. It further claims the use of a "neural network" to differentiate between weeds and crops and an operation of "predicting a target location" at a future time to account for the camera's motion relative to the weed (’948 Patent, Abstract; col. 17:1-col. 18:61).
Asserted Claims
Independent claim 1 is asserted (Compl. ¶90).
Accused Features
The complaint alleges that Defendant's products, which are marketed as using an AI model and a "gimble [sic] that's steering the laser beam" with "two large mirrors," infringe this patent (Compl. ¶¶108, 115, 133).
U.S. Patent No. 12,240,372 - "High Intensity Illumination Systems and Methods of Use Thereof"
Technology Synopsis
This patent addresses the technical challenge of obtaining consistent, high-quality images for automated object detection in variable outdoor lighting. The invention is a "lighting array" that illuminates a target area with an intensity "brighter than ambient illumination" (e.g., sunlight), which reduces shadows and allows for the use of very short camera exposure times. This combination is intended to produce clear, motion-blur-free images regardless of the time of day or weather conditions (’372 Patent, Abstract; col. 1:15-24).
Asserted Claims
Independent claim 1 is asserted (Compl. ¶151).
Accused Features
The complaint alleges that Defendant's marketing materials disclose the use of "external lighting" on its products, which allegedly functions as the claimed lighting array to reduce shadows and enable reliable imaging for its detection system (Compl. ¶¶158, 160).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant's "L&Aser Module" and "AgCeption" software, which are offered in various configurations, including a "Carrot Implement," a "High Density Implement," and a self-propelled "L&Aser Robot" (Compl. ¶13).
Functionality and Market Context
- The Accused Products are marketed as "laser-based weeder and thinner solutions" and the "first purpose-built laser for weeding & thinning crops" (Compl. ¶¶13, 28). Technical specifications provided in the complaint indicate the products use a "2.35 MP RGB 8mm @ 126 FPS" camera, an "NVIDIA Jetson Orin AGX 32Gb" computer, a "Proprietary L&Aser™ Cube" laser source, and a "High Moments of Inertia Scanning Galvanometer" to direct the laser beam (Compl. ¶¶48, 50, 53, 116; Compl. Ex. I). The complaint alleges Defendant has offered these products for sale in the United States (Compl. ¶26).
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 Products include a "2.35 MP RGB 8mm @ 126 FPS" imaging component. | ¶48 | col. 8:62-65 |
| an emitter configured to emit a beam toward the surface | The Accused Products include a "Proprietary L&Aser™ Cube" laser source. | ¶50 | col. 6:50-53 |
| a computing system in communication with the first camera and the emitter... | The Accused Products use an "NVIDIA Jetson Orin AGX 32Gb" processor for their computer. | ¶53 | col. 12:28-33 |
| receiving, from the first camera, an image of the surface, the image comprising a weed on the surface | A LinkedIn post for the Accused Products shows the system capturing images of a field containing weeds, as depicted in Exhibit W of the complaint. | ¶55 | col. 15:56-60 |
| identifying a region in the image that includes the weed | A YouTube video allegedly shows the Accused Products' software identifying and highlighting weeds in a captured image. | ¶57 | col. 15:58-62 |
| determining a target location of the weed based on the identified region in the image | A YouTube video allegedly demonstrates the Accused Products determining a target location for the identified weed. | ¶59 | col. 15:62-64 |
| aligning an optical path of the beam based on the target location of the weed | An image of the Accused Products' internal components, provided as Exhibit X in the complaint, shows two galvo mirrors allegedly used to direct the laser's optical path. | ¶62 | col. 16:6-14 |
| causing the emitter to emit the beam toward the weed... | A YouTube video allegedly shows the Accused Products firing a laser beam at a plant. | ¶64 | col. 16:10-14 |
| wherein emitting the beam towards the weed kills or damages the weed | The same YouTube video allegedly shows the laser destroying the plant, with a video description stating the system "completely eliminates the weed." | ¶64 | col. 16:14-16 |
- Identified Points of Contention:
- Scope Questions: The term "aligning an optical path" is broadly claimed. A dispute may arise over whether this functional language should be limited to the specific actuator-and-mirror embodiments described in the patent's specification, or if it reads on any functionally equivalent beam-steering mechanism, such as the accused scanning galvanometer system.
- Technical Questions: The complaint relies on marketing materials and demonstration videos as evidence of infringement. A key question for the court will be whether the Accused Products, in their commercial operation, consistently perform each claimed step—particularly whether the laser energy delivered in real-world field conditions is always sufficient to "kill or damage" the weed as required by the final limitation of the claim.
'547 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an actuator configured to direct an optical path of the beam | The Accused Products include a "High Moments of Inertia Scanning Galvanometer" and a "Scanner Driver" which allegedly function as the claimed actuator. | ¶79 | col. 17:46-51 |
| aligning the optical path...by adjusting a position of the actuator | The complaint alleges that videos and diagrams of the accused galvo mirror system demonstrate the adjustment of the actuator's position to direct the beam. | ¶84 | col. 18:8-11 |
| correcting the target location based on a motion of the first camera relative to the surface | The complaint alleges infringement by citing Defendant’s own patent application, which allegedly explains that its system may "predict where a target will be between frames" to account for the cultivator's movement. | ¶85 | col. 21:6-12 |
| causing the emitter to deactivate the beam after a length of time sufficient to damage or kill the weed | The complaint does not provide sufficient detail for analysis of this element. | col. 18:19-22 |
- Identified Points of Contention:
- Scope Questions: The central dispute for this patent may revolve around the "correcting the target location based on a motion" limitation. The analysis will raise the question of whether the accused system's method for tracking moving targets is functionally the same as the specific "correction" method claimed, or if it represents a distinct technical approach. The complaint's use of Defendant's patent application to allege infringement of this element suggests a potential point of contention regarding the actual operation of the accused product versus what is described in a pending application.
- Evidentiary Questions: The complaint does not appear to provide specific factual allegations demonstrating how the Accused Products meet the limitation of "causing the emitter to deactivate the beam after a length of time sufficient to damage or kill the weed." This raises an evidentiary question about what proof, if any, supports the allegation that the accused system performs this specific deactivation step.
V. Key Claim Terms for Construction
The Term: "aligning an optical path" (’752 Patent, Claim 1)
- Context and Importance: This term defines the core targeting action of the invention. Its construction is critical because it will determine whether the claim is broad enough to cover a variety of beam-steering technologies, including the scanning galvanometer system allegedly used in the Accused Products, or if it is limited to the specific mechanisms detailed in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses broad functional language. The specification supports this by describing the function generally, stating that actuators may control reflective elements to "cause a translation of the position at which the beam encounters the surface" (’752 Patent, col. 8:23-25).
- Evidence for a Narrower Interpretation: The specification provides detailed illustrations of systems using one or two distinct mirrors controlled by separate actuators (e.g., ’752 Patent, Fig. 1A, elements 110, 111, 105, 106). A party could argue that "aligning" should be interpreted in light of these specific disclosed embodiments rather than as any generic method of aiming a beam.
The Term: "correcting the target location based on a motion of the first camera" (’547 Patent, Claim 1)
- Context and Importance: This limitation is a key point of novelty for the ’547 Patent, addressing operation on a moving platform. Infringement will likely depend on whether the accused system's motion compensation method falls within the scope of this "correcting" language.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes this function in general terms, explaining that a "pose and motion correction system" may use an IMU or GPS to "determine a corrected location of the target on the surface" (’547 Patent, col. 21:64-67). This suggests the claim covers any process that uses motion data to update target coordinates.
- Evidence for a Narrower Interpretation: The specification describes a specific logical process: determining an "amount of time that has elapsed since the image was captured," measuring the "magnitude and direction of motion," and integrating these to find a "corrected location" (’547 Patent, col. 21:56-64). A party may argue that the term requires this explicit sequence of calculating and applying a correction, rather than a more general predictive tracking algorithm that implicitly accounts for motion.
VI. Other Allegations
- Indirect Infringement: For all asserted patents, the complaint alleges induced infringement, stating that Defendant instructs and encourages its customers to use the Accused Products in an infringing manner through its "educational and promotional materials, support activities, as well as its service and consulting activities" (Compl. ¶¶40, 72, 92, 153). It also pleads contributory infringement, alleging the products are especially adapted for infringement and have no substantial non-infringing use (Compl. ¶¶41, 73, 93, 154).
- Willful Infringement: Willfulness is alleged for the ’752, ’948, and ’372 patents based on Defendant's alleged awareness of the patents since their issuance dates (Compl. ¶¶67, 148, 168). The complaint further alleges general knowledge of Plaintiff's technology and patent portfolio based on social media posts by Defendant’s founder, which may be used to argue for pre-suit knowledge and egregious conduct (Compl. ¶33).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central technical issue will be one of functional operation versus claim language: does the accused system's method for tracking targets while in motion perform the specific step of "correcting the target location based on a motion of the first camera" as required by the '547 patent, or does it employ a predictive algorithm that is technically distinct from the claimed "correction" method?
- A key question of definitional scope will concern the hardware claims of the '948 patent: can the claim language reciting a "first actuator and a first mirror" and a "second actuator and a second mirror" be construed to read on the accused product's integrated scanning galvanometer system, or is there a fundamental structural mismatch?
- The dispute over the '372 patent will likely raise an evidentiary question of purpose and effect: is the "external lighting" on the accused product merely incidental illumination, or does it function as a "lighting array" that is configured to, and in practice actually does, produce an "illuminance that is brighter than ambient illumination" for the specific purpose of reducing shadows and motion blur as claimed?