DCT

3:24-cv-02466

Panasonic Entertainment & Communication Co Ltd v. Optimum Imaging Tech LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:24-cv-02466, N.D. Cal., 04/25/2024
  • Venue Allegations: Plaintiff Panasonic asserts venue is proper in the Northern District of California because the sole named inventor of the patents-in-suit and sole managing member of Defendant OIT, Neal Solomon, resides and has worked in the district for over 20 years, where the inventions were allegedly conceived and where OIT conducts its business, including patent prosecution and prior litigation activities.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its LUMIX digital cameras and lenses do not infringe four patents owned by Defendant related to in-camera systems for correcting optical and digital aberrations in images.
  • Technical Context: The patents concern methods and systems within a digital camera for automatically identifying and correcting image flaws, such as distortion and vignetting, using specialized hardware, software, and stored lens-correction data.
  • Key Procedural History: This declaratory judgment action was filed in response to a patent infringement complaint OIT filed against "Panasonic Corporation" in the Eastern District of Texas on October 18, 2023, asserting the same four patents. The current Plaintiff, Panasonic Entertainment & Communication Co., Ltd., argues it is the correct entity that designs and manufactures the accused cameras and that OIT sued the wrong Panasonic entity. The complaint also notes that OIT previously litigated two of the patents-in-suit (’805 and ’339) against Canon Inc. in the Eastern District of Texas, in a case filed in July 2019.

Case Timeline

Date Event
2006-07-11 Earliest Patent Priority Date (Provisional App. 60/807,065)
2009-11-03 U.S. Patent No. 7,612,805 Issues
2013-05-28 U.S. Patent No. 8,451,339 Issues
2019-07-08 OIT files complaint against Canon Inc. in E.D. Tex.
2020-12-22 U.S. Patent No. 10,873,685 Issues
2020-12-29 U.S. Patent No. 10,877,266 Issues
2023-10-18 OIT files complaint against Panasonic Corp. in E.D. Tex.
2024-04-25 Panasonic files this Declaratory Judgment Complaint in N.D. Cal.

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

U.S. Patent No. 7,612,805 - "Digital Imaging System and Methods for Selective Image Filtration"

  • Patent Identification: U.S. Patent No. 7612805, titled “Digital Imaging System and Methods for Selective Image Filtration,” issued November 3, 2009 (the “’805 Patent”).

The Invention Explained

  • Problem Addressed: The patent’s background section describes the challenges in correcting optical aberrations (e.g., distortion, vignetting) in lenses for single-lens reflex (SLR) cameras, as well as digital imaging artifacts (e.g., moiré patterns, noise) that degrade image quality. (’805 Patent, col. 3:41-5:61).
  • The Patented Solution: The invention proposes an automated, in-camera digital imaging system that corrects for these aberrations. The system uses a microprocessor, a digital signal processor (DSP), and an application-specific integrated circuit (ASIC) to analyze a captured image. (’805 Patent, Fig. 1). It then accesses a database management system (DBMS) containing pre-calculated correction data for specific lenses and applies digital filters to the image file before it is stored in memory. (’805 Patent, Abstract; col. 10:45-55).
  • Technical Importance: This approach sought to automate complex and time-consuming post-production editing, thereby improving image quality directly from the camera and potentially enabling the use of less expensive optics. (’805 Patent, col. 7:12-25).

Key Claims at a Glance

  • The complaint filed by OIT in the Eastern District of Texas asserts independent claims 1 and 9 of the ’805 Patent (Compl. Ex. A, ¶22).
  • Independent Claim 1 recites a digital imaging system for image filtration comprising:
    • a digital camera mechanism, optical lens mechanism, digital sensor, microprocessor, digital signal processor, application specific integrated circuit, system software, a database management system, and a memory storage sub-system;
    • wherein the optical lens mechanism is a fixed focal length;
    • wherein aberrations are corrected by applying digital filtration using the ASIC and DSP;
    • wherein the microprocessor provides data to the DSP;
    • wherein software is organized to identify aberrations and access the database for corrections;
    • wherein the DSP selects a procedure to optimize and correct the image; and
    • wherein a modified data file is stored in memory.
  • Independent Claim 9 recites a similar digital imaging system wherein:
    • the lens type is a zoom lens;
    • the lens focal length alternates from specific fixed focal length lens settings in a succession of steps; and
    • optical aberrations are corrected with digital filtration to modify multiple images from different focal lengths in a succession of data files.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,451,339 - "Digital Imaging System for Correcting Image Aberrations"

  • Patent Identification: U.S. Patent No. 8451339, titled “Digital Imaging System for Correcting Image Aberrations,” issued May 28, 2013 (the “’339 Patent”).

The Invention Explained

  • Problem Addressed: As a continuation of the ’805 Patent, the ’339 Patent addresses the same technical problems of optical and digital aberrations in photography that limit final image quality. (’339 Patent, col. 3:49-4:49).
  • The Patented Solution: The patent describes a similar in-camera system that corrects aberrations by using a microprocessor with system software to access a database. The system identifies at least one optical aberration, uses the database to identify a corresponding correction algorithm, and applies that algorithm to the image file using a digital signal processor. (’339 Patent, Abstract; col. 10:49-11:1).
  • Technical Importance: The invention provides a framework for automating lens-specific corrections within the camera itself, aiming to supplant film-era photography by delivering superior digital image quality without manual post-processing. (’339 Patent, col. 7:48-52).

Key Claims at a Glance

  • The complaint filed by OIT in the Eastern District of Texas asserts independent claims 1 and 14 of the ’339 Patent (Compl. Ex. A, ¶47).
  • Independent Claim 1 recites a digital imaging system for correcting image aberrations comprising:
    • a digital camera mechanism, optical lens mechanism, digital sensor, microprocessor, DSP, system software, database management system, and memory storage;
    • wherein the optical lens mechanism is a fixed focal length lens;
    • wherein a microprocessor uses system software to identify at least one optical aberration by accessing the database;
    • wherein the microprocessor uses the database to identify at least one algorithm to correct the aberration;
    • wherein the image file is corrected by applying digital filtration using the algorithm in the DSP; and
    • wherein the modified digital file is stored in memory.
  • Independent Claim 14 recites a similar digital imaging system wherein:
    • the optical lens mechanism is a zoom lens; and
    • the microprocessor uses system software to access the database to identify at least one optical aberration in the image file at any focal length of a zoom lens configuration.
  • The complaint does not explicitly reserve the right to assert dependent claims.

Multi-Patent Capsule: U.S. Patent No. 10,873,685

  • Patent Identification: U.S. Patent No. 10873685, titled “Digital Imaging System for Correcting Video Image Aberrations,” issued December 22, 2020 (the “’685 Patent”).
  • Technology Synopsis: This patent extends the core aberration-correction technology to the domain of digital video. It describes an in-camera system that identifies and corrects optical aberrations in at least one frame of a digital video by using software to access a database of optical image aberration corrections. (’685 Patent, Abstract; col. 37:58-38:2).
  • Asserted Claims: OIT’s complaint asserts at least Claim 1 (Compl. Ex. A, ¶73, 83).
  • Accused Features: The accused features are the in-camera software and image processing engines in the Panasonic LUMIX cameras that perform "Lens Compensation" to correct aberrations in videos. (Compl. Ex. A, ¶16, 74, 82).

Multi-Patent Capsule: U.S. Patent No. 10,877,266

  • Patent Identification: U.S. Patent No. 10877266, titled “Digital Camera with Wireless Image Transfer,” issued December 29, 2020 (the “’266 Patent”).
  • Technology Synopsis: This patent claims a method of processing images with a digital camera. The method involves using in-camera hardware and software to perform image correction algorithms, process correction data stored in a database system, receive updated software and correction data, and wirelessly transmit the corrected images. (’266 Patent, Abstract; col. 39:66-40:11).
  • Asserted Claims: OIT’s complaint asserts at least Claim 1 (Compl. Ex. A, ¶94, 105).
  • Accused Features: The accused features include the LUMIX cameras' in-camera image processing, the "Lens Compensation" function, the ability to receive firmware updates via download, and the capability to wirelessly transmit images via Wi-Fi and Bluetooth. (Compl. Ex. A, ¶100, 101, 103).

III. The Accused Instrumentality

  • Product Identification: A range of Panasonic LUMIX digital cameras (including models S1, S5M2, GH5, G9) and associated lenses are accused of infringement (the "Accused Products") (Compl. ¶31).
  • Functionality and Market Context: The Accused Products are digital cameras that include a feature called “Lens Compensation,” which automatically corrects for optical aberrations such as vignetting, color shading, and diffraction (Compl. Ex. A, ¶16, 32). OIT's complaint alleges this functionality is implemented by an in-camera image processing engine, such as Panasonic’s “Venus engine,” which it characterizes as an application-specific integrated circuit (ASIC) and digital signal processor (Compl. Ex. A, ¶31). The Venus Engine is described as a chip that results from a marriage of a CMOS sensor with the processing engine. (Compl. Ex. A, ¶33, 31). The complaint further alleges that the cameras use stored database data for lens aberration correction and that the system software and associated database can be updated via firmware downloads from Panasonic’s website (Compl. Ex. A, ¶16, 29). The products are also alleged to be capable of wirelessly transmitting corrected images to devices like smartphones (Compl. Ex. A, ¶103). A screenshot from the LUMIX S5II Owner's Manual shows the menu for the accused "Lens Compensation" feature, which includes options for Vignetting, Color Shading, and Diffraction Compensation (Compl. Ex. A, p. 28).

IV. Analysis of Infringement Allegations

’805 Patent Infringement Allegations

Claim Element (from Independent Claim 9) Alleged Infringing Functionality Complaint Citation Patent Citation
a digital imaging system for image filtration comprising: a digital camera mechanism...a microprocessor, a digital signal processor, an application specific integrated circuit, system software, a database management system and a memory storage sub-system The accused LUMIX cameras contain all these components, with the "Venus engine" serving as the image processor (ASIC/DSP) and onboard software managing lens correction data (database). ¶25, 30, 31 col. 10:45-50
wherein the aberrations from the optical lens mechanism are corrected by applying digital filtration by using the application specific integrated circuit and the digital signal processor The LUMIX S5M2 and other accused cameras contain an image processing engine (e.g., Venus engine) that allegedly implements this functionality to correct aberrations. ¶26, 30, 31 col. 10:56-61
wherein the system software is organized to identify specific optical aberrations and to access the database to identify specific corrections to the aberrations The cameras' "Lens Compensation" feature automatically corrects optical aberrations based on the lens being used, which allegedly requires using database data stored on the camera. ¶26, 29, 32 col. 10:45-50
wherein the lens type is a zoom lens The accused cameras are compatible with and used with a variety of zoom lenses. ¶27 col. 11:15-17
wherein the lens focal length alternates from specific fixed focal length lens settings in a succession of steps The "Lens Compensation" software directs the processor to correct aberrations, and when a zoom lens is used, this necessarily involves modifying aberrations at different focal lengths. ¶32 col. 11:18-20
wherein optical aberrations are corrected with digital filtration to modify multiple images from different focal lengths in a succession of data files The "Lens Compensation" function allegedly performs this by correcting aberrations such as vignetting at different focal lengths chosen when using a zoom lens. ¶32 col. 11:21-24
wherein the modified data file...is stored in memory The accused cameras automatically record the corrected images to memory cards. ¶35 col. 11:27-30

’339 Patent Infringement Allegations

Claim Element (from Independent Claim 14) Alleged Infringing Functionality Complaint Citation Patent Citation
a digital imaging system for correcting image aberrations comprising: a digital camera mechanism...a microprocessor, a digital signal processor, system software, a database management system and a memory storage sub-system The accused LUMIX cameras are digital imaging systems containing these hardware and software components. ¶50, 54-58 col. 16:21-27
wherein the optical lens mechanism is a zoom lens The accused cameras are used with compatible zoom lenses. ¶52 col. 17:5-6
wherein the microprocessor uses system software to access the database to identify at least one optical aberration in the image file at any focal length of a zoom lens configuration The "Lens Compensation" feature allegedly uses system software to access a database of lens data to automatically correct for aberrations specific to the attached lens at its current focal length. ¶51, 57, 59 col. 17:11-15
wherein the microprocessor accesses the database to obtain at least one filtration correction algorithm...and forwards the at least one filtration algorithms to the digital signal processor The accused cameras' microprocessor allegedly uses the database to identify the correct algorithm for the detected aberration and provides it to the image processor (e.g., Venus engine). ¶59, 54, 55 col. 17:16-20
wherein the image file is forwarded to the digital signal processor which applies at least one filtration algorithm to...corrects the at least one optical aberration at the specific focal length The camera's CMOS sensor data is necessarily forwarded to the image processor (e.g., Venus engine), which applies the "Lens Compensation" algorithm to correct aberrations. ¶59, 60 col. 17:21-26
wherein the modified image file...is stored in memory The LUMIX cameras automatically record the corrected images to memory cards. ¶61 col. 17:30-34
  • Identified Points of Contention:
    • Scope Questions: Panasonic’s central non-infringement argument is that its products lack a “database management system” as required by the claims (Compl. ¶50, 56, 62, 68). The dispute may focus on whether the firmware and stored lens correction profiles in the accused cameras meet the proper construction of this term, or if the term requires a more complex, user-interactive software architecture not present in the products.
    • Technical Questions: Panasonic also argues its products lack the claimed functionality of correcting aberrations by "applying digital filtration by using the application specific integrated circuit and digital signal processor" (Compl. ¶50). A key technical question will be whether Panasonic’s integrated “Venus engine” (Compl. Ex. A, p. 27) performs the specific functions of both an ASIC and a DSP in the manner claimed, or if the claims require distinct components performing separate steps that do not map onto the operation of the accused processor.

V. Key Claim Terms for Construction

  • The Term: "a database management system"

  • Context and Importance: This term appears in the independent claims of all four patents-in-suit. Panasonic’s complaint for declaratory judgment identifies this element as missing from its products for every asserted independent claim, making its construction a dispositive issue for the case (Compl. ¶50, 56, 62, 68).

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification refers to the "DBNS" (190 in Fig. 1) as a system where lens-specific aberration data and correction information are stored and can be accessed by the microprocessor (’805 Patent, col. 10:45-55). This could support a broad interpretation covering any organized, accessible collection of data, such as the firmware-based lens profiles allegedly used by the accused cameras (Compl. Ex. A, ¶29, 57).
    • Evidence for a Narrower Interpretation: The term "database management system" in the relevant technical field could imply a more complex software system than a simple look-up table. The patent does not explicitly define the term, which may allow for an argument that the plain and ordinary meaning requires a more sophisticated data management architecture than what is allegedly present in the accused products.

  • The Term: "an integrated circuit including; a digital signal processor configured to access a database management system" (’685 Patent, Claim 1)

  • Context and Importance: This term from the ’685 Patent (and similar terms in the other patents) links the hardware components to the database. Panasonic alleges its products lack "an integrated circuit including a digital signal processor configured to access a database management system" (Compl. ¶62). The dispute will concern how the accused Venus engine interacts with the stored lens data and whether that interaction meets this claim limitation.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent specification describes the ASIC (195) and DSP (195) as processing image data and interacting with the database (190) (’685 Patent, Fig. 1). OIT argues the Venus engine is an integrated circuit that performs these functions (Compl. Ex. A, ¶31). This could support a reading where any integrated processor that uses stored lens data for correction satisfies the claim.
    • Evidence for a Narrower Interpretation: The use of distinct terms "integrated circuit" and "digital signal processor" could imply they are separate components or have distinct functionalities. Panasonic may argue that its integrated Venus engine does not contain a component that is properly characterized as a "digital signal processor" that is "configured to access" a "database management system" under the proper construction of those terms.

VI. Other Allegations

  • Indirect Infringement: OIT's complaint alleges active inducement of infringement under 35 U.S.C. § 271(b). The allegations are based on Panasonic providing user manuals, such as for the LUMIX S5M2, that allegedly instruct customers in the United States on how to use the infringing "Lens Compensation" features (Compl. Ex. A, ¶38, 64, 85, 107).
  • Willful Infringement: OIT alleges that infringement was, is, and continues to be deliberate and willful. This allegation is based on purported pre-suit knowledge. OIT claims that Panasonic had actual notice of the parent ’805 Patent family at least as early as December 17, 2014, because the family was cited by the patent examiner during the prosecution of Panasonic's own Japanese Patent, JP 5643153 B2 (Compl. Ex. A, ¶42, 68, 89, 111).

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

  • A core issue will be one of definitional scope: Can the term “database management system,” as used across the asserted patents, be construed to cover the accused cameras’ system of storing and accessing lens-specific correction profiles within their firmware, or does the term require a more complex data management architecture?
  • A key evidentiary question will be one of technical operation: Does the accused "Venus engine" image processor function in the specific manner required by the claims, particularly concerning the claimed relationship between an "application specific integrated circuit" and a "digital signal processor" that work together to "apply digital filtration"? The outcome will depend on a factual comparison of how the accused products work against the court's construction of the claim language.
  • A threshold procedural question will be one of proper parties and jurisdiction: The dispute over whether OIT sued the correct Panasonic entity in the Eastern District of Texas will likely influence early case strategy and potential motions practice regarding jurisdiction, venue, and case consolidation or transfer.