DCT
3:24-cv-07542
Carbon Autonomous Robotic Systems Inc v. Laudando & Associates LLC
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: 3:24-cv-07542, N.D. Cal., 10/30/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a California corporation with a regular and established place of business in the district and has committed alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s laser-weeding products infringe patents related to autonomous, real-time weed identification and laser eradication.
- Technical Context: The technology at issue involves AI-powered robotics for agriculture, aiming to provide a high-precision, chemical-free alternative to traditional herbicides and manual labor for weed control.
- Key Procedural History: The complaint alleges that Defendant's founder publicly discussed Plaintiff's technology and pending patents on social media prior to the patents-in-suit issuing. It also notes that Defendant's own patent application, which allegedly describes infringing technology, was filed after the priority date of Plaintiff's patents.
Case Timeline
| Date | Event |
|---|---|
| 2019-09-17 | Earliest Priority Date for '752 and '547 Patents |
| 2022-01-01 | Plaintiff Carbon launches its LaserWeeder product (approximate date) |
| 2023-09-19 | Defendant L&A announces the Accused Product |
| 2024-10-08 | U.S. Patent No. 12,108,752 ('752 Patent) issues |
| 2024-10-29 | U.S. Patent No. 12,127,547 ('547 Patent) issues |
| 2024-10-30 | 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 identifies the drawbacks of traditional weed control methods, namely that hand cultivation is labor-intensive and costly, while chemical herbicides can have negative environmental and health impacts ('752 Patent, col. 6:7-14).
- The Patented Solution: The invention is a targeting system that uses a camera to capture an image of an agricultural surface, a computing system to analyze the image to identify a weed and determine its precise location, and a laser emitter. The system then aligns the laser's optical path with the identified weed and fires a beam to kill or damage it, providing an automated, chemical-free solution ('752 Patent, Abstract; Fig. 9).
- Technical Importance: This approach automates the highly precise task of in-field weed removal, offering a way to reduce reliance on chemical herbicides and decrease labor costs in agriculture ('752 Patent, col. 6:13-20).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶28).
- Essential elements of claim 1 include:
- A first camera configured to image a surface.
- An emitter configured to emit a beam toward the surface.
- A computing system capable of performing a series of operations.
- Operations include: receiving an image containing a weed; identifying a region in the image with the weed; determining the weed's target location; aligning the beam's optical path to the target location; and causing the emitter to fire, wherein the beam kills or damages the weed.
- The complaint does not explicitly reserve the right to assert other claims but seeks relief for infringement of "one or more claims" (Compl. p. 20 ¶(a)).
U.S. Patent No. 12,127,547, "Autonomous Laser Weed Eradication," issued October 29, 2024
The Invention Explained
- Problem Addressed: The patent addresses the same fundamental problem of inefficient and environmentally harmful weed control methods ('547 Patent, col. 2:13-20).
- The Patented Solution: This invention builds upon the '752 Patent's system by adding a motion-correction capability. After identifying a weed, the system not only determines a target location but also actively corrects that location based on the motion of the camera relative to the ground. This is designed to maintain targeting accuracy even when the system is mounted on a moving vehicle traversing a field ('547 Patent, col. 4:5-14; col. 17:18-21).
- Technical Importance: This motion-correction function is crucial for the practical application of laser weeding on mobile platforms, as it addresses the challenge of hitting a small, stationary target from a moving, vibrating vehicle.
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶59).
- Essential elements of claim 1 include:
- A camera, emitter, and computing system, similar to the '752 Patent.
- Operations include: receiving an image with a weed; identifying a region with the weed; projecting a target location based on that region; aligning the emitter's optical path with the projected location; correcting the target location based on a motion of the first camera relative to the surface; and causing the emitter to fire.
- The complaint seeks relief for infringement of "one or more claims" (Compl. p. 20 ¶(a)).
III. The Accused Instrumentality
- Product Identification: The "L&Aser weeder" and the "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" (Compl. ¶21; Exhibit G). It is a modular system intended for mounting on agricultural equipment (Compl. Exhibit F). Based on the complaint's allegations and supporting exhibits, the product incorporates an imaging component ("2.35 MP RGB 8mm @ 126 FPS"), a processing unit ("NVIDIA Jetson Orin AGX 32Gb"), and a proprietary laser source and scanner to identify and eradicate weeds in real-time (Compl. ¶37, 42; Exhibit G). An annotated image from Defendant's LinkedIn page shows a laser source and two mirrors allegedly used to direct the laser's optical path (Compl. ¶51; Exhibit R).
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 L&Aser Module includes a "2.35 MP RGB 8mm @ 126 FPS" imaging component. A marketing flyer shows this camera configured to image a surface (Compl. ¶37; Exhibit G). | ¶36-37 | col. 15:50-51 |
| an emitter configured to emit a beam toward the surface | The product includes a proprietary "Laser Source" and "Laser Driver" configured to emit a laser beam. YouTube videos allegedly show the module emitting a beam towards a surface (Compl. ¶40). | ¶39-40 | col. 15:52 |
| a computing system...capable of performing operations | The product's specifications list a "NVIDIA Jetson Orin AGX 32Gb" compute module (Compl. ¶42; Exhibit G). | ¶42 | col. 15:53-56 |
| receiving, from the first camera, an image of the surface, the image comprising a weed on the surface | A LinkedIn post from Defendant allegedly shows the Accused Product receiving an image of a surface containing weeds, used for its "weed detection model" (Compl. ¶44; Exhibit Q). | ¶44 | col. 15:57-59 |
| identifying a region in the image that includes the weed | A YouTube video screenshot allegedly demonstrates the Accused Product identifying a region of an image that includes a weed (Compl. ¶46). | ¶46 | col. 15:60-61 |
| determining a target location of the weed based on the identified region in the image | A YouTube video screenshot allegedly demonstrates the product determining a target location for the identified weed (Compl. ¶48). | ¶48 | col. 15:62-63 |
| aligning an optical path of the beam based on the target location of the weed, and causing the emitter to emit the beam... | An annotated image from Defendant's LinkedIn page allegedly shows two mirrors that "direct the optical path of the laser to the weed" (Compl. ¶51; Exhibit R). | ¶50-51 | col. 15:64-66 |
| wherein emitting the beam towards the weed kills or damages the weed | A YouTube video allegedly shows the product emitting a beam that kills or damages a weed, with a video description stating it "completely eliminates the weed" (Compl. ¶53; p. 16). | ¶53 | col. 16:1-3 |
- Identified Points of Contention: The infringement theory for the '752 Patent appears to map directly onto the Defendant's marketing materials and product specifications. A potential point of contention may arise over the precise interpretation of the operational steps, such as "identifying a region" and "determining a target location." The defense may argue that its methods, while achieving a similar outcome, do not operate in the specific manner required by a narrower construction of the claims.
'547 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| ...[a-e, similar to '752 Patent]... | ...[Allegations for these elements are incorporated by reference from paragraphs 36-47 of the complaint]... | ¶66-70 | col. 17:2-10 |
| projecting a target location of the weed on the surface based on the identified region | The complaint alleges this is satisfied by the same evidence for "determining a target location," pointing to YouTube videos demonstrating targeting (Compl. ¶48). | ¶71 | col. 17:11-13 |
| aligning an optical path of the emitter with the projected target location | The complaint alleges this is satisfied by the same evidence for aligning the optical path, pointing to the annotated image of the module's mirrors (Compl. ¶51, Exhibit R). | ¶72 | col. 17:14-16 |
| correcting the target location based on a motion of the first camera relative to the surface | The complaint cites Defendant's own patent publication ('597 publication), which allegedly explains that the system may "predict where a target will be" between frames and use "target velocity sensors to track the speed of the targets and/or the speed of the ground" (Compl. ¶73; Exhibit L at [0100]). | ¶73 | col. 17:18-20 |
| causing the emitter to emit the beam toward the weed... | The complaint alleges this is satisfied by the same evidence of the laser firing and killing the weed (Compl. ¶53). | ¶74 | col. 17:21-23 |
- Identified Points of Contention: The central dispute for the '547 Patent will likely concern the "correcting... based on a motion" element. Plaintiff's primary evidence is Defendant's own patent application. The key question will be whether the Accused Product, as sold, actually implements this motion-correction functionality. Additionally, the distinction between "determining" a location ('752 Patent) and "projecting" a location ('547 Patent) may become a focus of claim construction arguments.
V. Key Claim Terms for Construction
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 term is the core technical distinction of the '547 Patent and is essential for its asserted novelty over the base invention. Infringement of this patent hinges on whether the Accused Product performs this specific function.
- Intrinsic Evidence for a Broader Interpretation: A party might argue the plain language is broad, covering any adjustment made to account for the vehicle's movement, however simple. The claim language does not specify the method of correction, only that it is "based on a motion" ('547 Patent, col. 17:18-20).
- Intrinsic Evidence for a Narrower Interpretation: A party could argue the term should be limited by the detailed embodiments, which describe using specific hardware like an Inertial Measurement Unit (IMU), GPS, or Internal Navigation System (INS) to calculate and apply a correction vector ('547 Patent, col. 11:25-63).
Term: "projecting a target location" ('547 Patent, Claim 1) vs. "determining a target location" ('752 Patent, Claim 1)
- Context and Importance: Practitioners may focus on these terms because their definitions are critical to differentiating the two patents and assessing infringement of each. The court will need to decide if "projecting" implies a forward-looking or predictive step that is absent from merely "determining."
- Intrinsic Evidence for a Broader Interpretation (i.e., treating them as similar): One could argue that in the context of the system, any "determination" of a location on the ground from a camera image is inherently a "projection" from a 2D image plane to 3D world coordinates.
- Intrinsic Evidence for a Narrower Interpretation (i.e., treating them as distinct): One could argue "projecting" is tied more closely to the motion-correction step that follows it, implying a predictive calculation of where the target will be, whereas "determining" could simply be locating where the target was at the moment the image was captured ('547 Patent, col. 17:11-20).
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by providing "educational and promotional materials, support activities, as well as its service and consulting activities," which allegedly instruct customers on how to use the Accused Product in an infringing manner (Compl. ¶30, 61).
- Willful Infringement: The complaint alleges willfulness based on Defendant's continued infringement after the patents issued (Compl. ¶56). It further supports this by alleging significant pre-suit knowledge of Plaintiff's specific technology and patent portfolio, evidenced by public LinkedIn posts from Defendant’s founder that explicitly mention "Carbon robotics patents" and acknowledge that Carbon was "first to slap commercially available lasers onto a massive toolbar" (Compl. ¶24-25, Exhibit M).
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of functional implementation: Can the plaintiff prove that the defendant's commercial product actually performs the "correcting the target location based on a motion" function required by the '547 patent? The plaintiff's current reliance on the defendant's own patent publication for this element will likely require substantiation with technical evidence from the accused device itself.
- A central legal issue will be one of claim scope: How will the court construe the operational steps of the claims, particularly the distinction between "determining a target location" in the '752 patent and the combination of "projecting" and "correcting" in the '547 patent? The outcome of this construction will be pivotal to whether infringement is found on one or both patents.
- The case presents a significant question of willfulness: Given the defendant's alleged pre-issuance awareness of the plaintiff's technology and patent applications, as documented in public social media posts, a core issue for trial will be whether this conduct, combined with post-issuance infringement, constitutes the type of egregious behavior required to support an award of enhanced damages.