Corephotonics Ltd v. Apple Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Corephotonics, Ltd. (Israel)
  • Defendant: Apple Inc. (California)
  • Plaintiff’s Counsel: Russ, August & Kabat
• Case Identification: 3:19-cv-04809, N.D. Cal., 08/14/2019
• Venue Allegations: Venue is alleged in the Northern District of California on the basis that Apple resides in the district, maintains a regular and established place of business there, and has committed the alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s iPhone 7 Plus, 8 Plus, X, Xs, and Xs Max models, which feature dual-camera systems, infringe ten U.S. patents related to miniature telephoto lens assemblies and computational methods for providing zoom functionality.
• Technical Context: The technology at issue involves using two fixed-focal-length cameras in a smartphone—one wide-angle and one telephoto—to achieve optical zoom effects and advanced computational photography features that were previously difficult to implement in thin mobile devices.
• Key Procedural History: The complaint details extensive pre-suit interactions between the parties from 2012 to 2017, including technology demonstrations, exchanges of technical information, and licensing negotiations. The complaint also notes that Corephotonics filed two prior lawsuits against Apple in 2017 and 2018, which are currently stayed pending the resolution of inter partes review (IPR) proceedings initiated by Apple against those earlier-asserted patents.

Case Timeline

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

U.S. Patent No. 9,661,233 - "Dual Aperture Zoom Digital Camera"

• Issued: May 23, 2017

The Invention Explained

• Problem Addressed: The patent background describes the difficulty of implementing true optical zoom in thin mobile devices, which forces reliance on resolution-degrading digital zoom (U.S. Patent No. 10,015,408, col. 1:40-54). Prior dual-camera solutions for video required significant processing resources and power consumption because both cameras were fully operational (U.S. Patent No. 10,015,408, col. 2:30-34).
• The Patented Solution: The invention proposes a dual-aperture camera system with wide-angle and telephoto lenses that achieves smooth zoom in video mode without computationally expensive image fusion. When a user zooms, the system switches between the video output of the wide camera and the telephoto camera. To prevent a jarring "jump" at the moment of switching, a camera controller executes registration to perform position matching between the two images, creating the effect of a continuous zoom while conserving power (U.S. Patent No. 10,015,408, Abstract; col. 4:50-56).
• Technical Importance: This approach provided a power-efficient method for delivering smooth optical zoom in video on mobile devices, a feature that enhances user experience without the battery drain and processing load of continuous dual-image fusion (Compl. ¶23).

Key Claims at a Glance

• The complaint asserts independent Claim 1 (Compl. ¶59).
• Essential elements of Claim 1 include:
  • A multiple aperture zoom digital camera
  • A Wide imaging section with a Wide sensor and fixed focal length Wide lens
  • A Tele imaging section with a Tele sensor and fixed focal length Tele lens with a narrower field of view (POV)
  • A camera controller configured to reduce an image jump effect in video by executing registration between the Wide and Tele images for position matching when switching between the outputs of the two imaging sections.
• The complaint reserves the right to assert additional claims (Compl. ¶60).

U.S. Patent No. 10,230,898 - "Dual Aperture Zoom Camera With Video Support And Switching / Non-Switching Dynamic Control"

• Issued: March 12, 2019

The Invention Explained

• Problem Addressed: In a dual-camera system, there are situations (e.g., low light, a close-up subject) where the telephoto lens cannot produce a high-quality image. Switching from a high-quality digitally zoomed wide-angle image to a poor-quality telephoto image would degrade the user experience (U.S. Patent No. 10,230,898, col. 10:1-5).
• The Patented Solution: The invention describes a camera controller with dynamic control logic. The controller evaluates a "no-switching criterion" to determine if conditions are unsuitable for the telephoto lens. If the criterion is met, the controller will not switch to the telephoto camera, even if the user zooms past the normal transition point, and will instead continue to provide a digitally-zoomed image from the wide-angle camera. If the criterion is not met, the system switches to the telephoto camera as expected (U.S. Patent No. 10,230,898, Abstract; col. 10:5-15).
• Technical Importance: This control logic allows a dual-camera system to intelligently select the best image source based on environmental conditions, preventing an automatic switch to a lens that would produce a worse image and thereby improving the reliability and quality of the zoom feature (Compl. ¶74).

Key Claims at a Glance

• The complaint asserts independent Claim 1 (Compl. ¶73).
• Essential elements of Claim 1 include:
  • A zoom digital camera with Wide and Tele imaging sections
  • A camera controller operatively coupled to both sections
  • The controller is configured to evaluate if a "no-switching criterion" is fulfilled
  • If the criterion is fulfilled during a zoom-in operation, the controller outputs a zoom video image that includes only digitally-zoomed Wide image data
  • If the criterion is not fulfilled, the controller outputs a zoom video image that includes only digitally-zoomed Tele image data.
• The complaint reserves the right to assert additional claims (Compl. ¶74).

U.S. Patent No. 10,288,840 - "Miniature Telephoto Lens Module And A Camera Utilizing Such A Lens Module"

• Patent Identification: U.S. Patent No. 10,288,840, Issued May 14, 2019.
• Technology Synopsis: This patent details the specific physical construction of a miniature telephoto lens module designed to have a total track length (TTL) to effective focal length (EFL) ratio of less than one, making it compact enough for thin mobile devices. The claims recite specific arrangements of multiple lens elements, the use of different polymer materials with distinct Abbe numbers to reduce chromatic aberrations, and the grouping of lenses to create a telephoto optical effect (U.S. Patent No. 10,288,840, Abstract).
• Asserted Claims: Independent Claim 1 (Compl. ¶88).
• Accused Features: The physical construction of the telephoto camera in the iPhone X, including its TTL/EFL ratios, the number and arrangement of its lens elements, and the use of different polymer materials for those elements (Compl. ¶89).

U.S. Patent No. 10,317,647 - "Miniature Telephoto Lens Assembly"

• Patent Identification: U.S. Patent No. 10,317,647, Issued June 11, 2019.
• Technology Synopsis: The patent describes a specific five-element optical lens assembly for a telephoto camera. The claims define the assembly by the optical power (positive or negative) and focal lengths of the first three lens elements, requiring them to satisfy a specific mathematical relationship (1.2×|f3|>|f2|>1.5×f1). The claims also require the overall assembly to have a TTL of 6.5mm or less and a TTL/EFL ratio of less than 1.0 (U.S. Patent No. 10,317,647, Abstract).
• Asserted Claims: Independent Claim 1 (Compl. ¶99).
• Accused Features: The five-element telephoto camera lens assembly in the iPhone X, which is alleged to have lens elements with focal lengths that satisfy the claimed mathematical relationship and to meet the claimed TTL and TTL/EFL ratio constraints (Compl. ¶100).

U.S. Patent No. 10,324,277 - "Miniature Telephoto Lens Assembly"

• Patent Identification: U.S. Patent No. 10,324,277, Issued June 18, 2019.
• Technology Synopsis: This patent claims a lens assembly with specific physical and optical parameters. It requires a plurality of refractive lens elements, at least one of which is aspheric, a TTL of 6.5mm or less, and a TTL/EFL ratio less than 1.0. A key limitation requires the focal length of the first lens element (f1) to be smaller than half the total track length (TTL/2) (U.S. Patent No. 10,324,277, Abstract).
• Asserted Claims: Independent Claim 1 (Compl. ¶110).
• Accused Features: The telephoto lens assembly of the iPhone 7 Plus, which is alleged to have five lens elements, an aspheric first lens, and meet the claimed constraints on TTL, TTL/EFL ratio, and the relationship between the first element's focal length and the total track length (Compl. ¶111).

U.S. Patent No. 10,330,897 - "Miniature Telephoto Lens Assembly"

• Patent Identification: U.S. Patent No. 10,330,897, Issued June 25, 2019.
• Technology Synopsis: The patent describes a lens assembly with a TTL of 6.5mm or less and a TTL/EFL ratio less than 1.0. The claims require the lens elements to be arranged in two distinct groups separated by a gap that is larger than twice any other gap between lens elements within the groups. The claims also specify the refractive powers of particular lens elements within these groups (U.S. Patent No. 10,330,897, Abstract).
• Asserted Claims: Independent Claim 1 (Compl. ¶121).
• Accused Features: The telephoto camera of the iPhone X, which is alleged to have a lens assembly arranged in two groups separated by a large air gap and to meet the other claimed structural and optical parameters (Compl. ¶122).

U.S. Patent No. 10,225,479 - "Dual Aperture Zoom Digital Camera"

• Patent Identification: U.S. Patent No. 10,225,479, Issued March 5, 2019.
• Technology Synopsis: This patent claims a dual-aperture camera system where the telephoto lens has an EFL-to-TTL ratio greater than 1. The claims further require distinct autofocus (AF) mechanisms for the wide and telephoto lenses and a camera controller that processes images from both to calculate depth information and create a fused image for "portrait photos" with a shallow depth of field (U.S. Patent No. 10,225,479, Abstract).
• Asserted Claims: Independent Claim 19 (Compl. ¶132).
• Accused Features: The rear-facing dual camera system of the iPhone X, which is alleged to have the claimed EFL/TTL ratio for its telephoto lens, separate AF mechanisms, and a controller (the A11 Bionic SOC) that processes images to generate "Portrait Mode" photos with blurred backgrounds (Compl. ¶133).

U.S. Patent No. 10,015,408 - "Dual Aperture Zoom Digital Camera"

• Patent Identification: U.S. Patent No. 10,015,408, Issued July 3, 2018.
• Technology Synopsis: The patent describes a zoom digital camera where the telephoto lens includes exactly five lens elements with a specific sequence of positive and negative optical powers. A key structural limitation is that the largest distance between any two consecutive lens elements is the distance between the fourth and fifth elements (U.S. Patent No. 10,015,408, Abstract).
• Asserted Claims: Independent Claim 5 (Compl. ¶143).
• Accused Features: The telephoto camera of the iPhone X, which is alleged to contain a five-element lens assembly meeting the claimed sequence of optical powers and having the largest inter-element distance between its fourth and fifth lenses (Compl. ¶144).

U.S. Patent No. 10,356,332 - "Dual Aperture Zoom Camera With Video Support And Switching / Non-Switching Dynamic Control"

• Patent Identification: U.S. Patent No. 10,356,332, Issued July 16, 2019.
• Technology Synopsis: This patent is a continuation of the '898 patent, also directed to a camera controller that evaluates a "no-switching criterion." This patent's claims define the zoom factor transition point (ZFT) with a specific formula based on the fields of view of the wide and telephoto lenses. The logic of switching or not switching is claimed relative to this mathematically defined transition point (U.S. Patent No. 10,356,332, Abstract).
• Asserted Claims: Independent Claim 1 (Compl. ¶154).
• Accused Features: The camera controller (A12 Bionic SoC) in the iPhone X, which is alleged to implement the claimed no-switching logic relative to the zoom factor transition point between the wide and telephoto cameras (Compl. ¶155).

U.S. Patent No. 10,326,942 - "Dual Aperture Zoom Digital Camera"

• Patent Identification: U.S. Patent No. 10,326,942, Issued June 18, 2019.
• Technology Synopsis: This patent is related to the '233 patent and claims a method for reducing the "image jump" effect when switching between cameras in video mode. It specifically claims reducing the jump by shifting one image relative to the other based on the distance to an object in a region of interest (ROI), which can be determined using the cameras' focus mechanisms (U.S. Patent No. 10,326,942, Abstract).
• Asserted Claims: Independent Claim 1 (Compl. ¶169).
• Accused Features: The camera controller (A10 SoC) and software in the iPhone 7 Plus, which is alleged to reduce the image jump effect by shifting the image from one camera relative to the other based on object distance derived from the cameras' focus mechanisms (Compl. ¶170).

III. The Accused Instrumentality

Product Identification

• Apple's iPhone 7 Plus, iPhone 8 Plus, iPhone X, iPhone Xs, and iPhone Xs Max (collectively, the "Accused Products") (Compl. ¶13).

Functionality and Market Context

• The complaint alleges that the relevant functionality of the Accused Products is their rear-facing dual-camera systems, which include both a wide-angle and a telephoto camera (Compl. ¶¶60, 74). This system is allegedly used to provide enhanced zoom capabilities. For video, the products are alleged to provide a continuous zoom with a reduced "jump" effect by using registration and image shifting when switching between the two cameras (Compl. ¶¶60, 170). The complaint further alleges the products employ a dynamic control system that evaluates conditions such as low light or close focus to determine whether to use the telephoto lens or to continue using a digitally-zoomed image from the wide-angle lens (Compl. ¶¶74, 155). The complaint also provides detailed allegations regarding the physical construction of the telephoto lens assemblies, including specific TTL/EFL ratios, f-numbers, the number and arrangement of lens elements, and the materials used (Compl. ¶¶89, 100, 111, 122). The complaint asserts that Apple specifically touted the telephoto camera as a key feature upon its introduction (Compl. ¶41).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,661,233 Infringement Allegations

U.S. Patent No. 10,230,898 Infringement Allegations

Identified Points of Contention

• Scope Questions: For the hardware patents, a central question will be whether the specific numerical limitations recited in the claims (e.g., TTL/EFL ratios, focal length relationships, Abbe numbers) literally read on the measured physical characteristics of Apple's lens components. For the software patents, a key issue may be whether Apple's method of smoothing the transition between lenses constitutes "registration for performing position matching" as that term is used in the '233 Patent.
• Technical Questions: A primary technical question will be the precise operation of Apple's camera control software. The complaint provides a table comparing the F-numbers and pixel sizes of the wide and telephoto cameras in the iPhone X (Compl. ¶133, p. 38). What evidence will show that this hardware, controlled by the A11/A12 Bionic chips, performs the specific evaluation and switching logic claimed in the '898 and '332 patents, particularly concerning the conditions that constitute a "no-switching criterion"?

V. Key Claim Terms for Construction

The Term: "executing registration between the Wide and Tele images for performing position matching" (’233 Patent, Claim 1)

• Context and Importance: This term is the core functional element of Claim 1 of the '233 Patent. The infringement case depends on whether Apple's method for creating a smooth zoom transition in video is properly characterized by this term. Practitioners may focus on this term because its definition will determine whether a wide range of smoothing algorithms fall within the claim's scope, or if it is limited to a specific technical approach.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification may describe "registration" in general terms as a process to align or map images to correct for differences in position or perspective, potentially supporting a construction that covers various alignment techniques (U.S. Patent No. 10,015,408, col. 9:48-51).
  • Evidence for a Narrower Interpretation: The specification describes a detailed multi-step process for registration involving rectification, mapping, and resampling (U.S. Patent No. 10,015,408, col. 9:42-54; FIG. 5). A defendant may argue these specific steps define and limit the scope of the term "registration."

The Term: "no-switching criterion" (’898 Patent, Claim 1)

• Context and Importance: This term is central to the '898 patent's inventive concept. The dispute will likely center on whether the real-world conditions under which the accused iPhones choose not to use the telephoto lens (e.g., low light, close focus) meet the definition of this claimed "criterion."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the criterion in functional terms, relating it to conditions where switching would result in a lower quality image, suggesting any such condition could qualify (U.S. Patent No. 10,230,898, col. 10:1-5). The complaint alleges infringement based on such functional conditions (Compl. ¶74).
  • Evidence for a Narrower Interpretation: The specification provides specific examples of conditions that could form such a criterion, such as a shift calculated by global registration exceeding a threshold or the effective resolution of the Tele image being lower than the Wide image (U.S. Patent No. 10,230,898, col. 10:6-21). A defendant could argue that the term is limited to these or similar objectively measurable parameters, and not merely a subjective assessment of image quality.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement across all asserted patents. The basis for these allegations is that Apple provides promotional materials (e.g., product descriptions, launch event videos) and instructional information (e.g., "how-to video tutorials") that encourage and instruct customers to use the accused dual-camera zoom features in an infringing manner (Compl. ¶¶68, 83, 164, 178).

Willful Infringement

• The complaint makes extensive allegations of willful infringement. The basis is an alleged long history of pre-suit knowledge, beginning with meetings in 2012 where Corephotonics disclosed its technology and intent to patent it (Compl. ¶28). The allegations include that Apple received detailed technical presentations, physical samples, and software simulators (Compl. ¶¶30, 32, 33), and engaged in licensing discussions before negotiations were halted (Compl. ¶¶35, 37). The complaint further alleges that Apple was aware of Corephotonics' patent families through its own patent prosecution efforts (Compl. ¶¶55-56) and received specific notice of infringement via letters and prior lawsuits before continuing its accused conduct (Compl. ¶¶44-52).

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

• A central issue will be one of historical knowledge and intent: Given the extensive pre-suit relationship and multiple notices alleged in the complaint, what was Apple's state of mind regarding Corephotonics' patent portfolio during the development and sale of the accused iPhones? The resolution of this question will be critical to the claim of willfulness.
• A key technical question will be one of functional operation: Does the software on Apple's A-series processors perform the specific logical steps of "evaluating a no-switching criterion" as claimed in the '898 and '332 patents, or does it use a fundamentally different decision-making process for selecting between the wide and telephoto cameras?
• The case will also involve a significant question of physical correspondence: Do the precise physical dimensions, material properties, and optical parameters of the lens elements in the accused iPhone cameras fall within the specific numerical ranges and relationships required by the asserted hardware patents (e.g., '840, '647, '277, '897)? This will likely depend on claim construction and detailed expert analysis of the physical components.