DCT
4:24-cv-06514
Mielikuva Solutions LLC v. Rokid Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Mielikuva Solutions, LLC (Texas)
- Defendant: Rokid, Inc. (California)
- Plaintiff’s Counsel: Bradford Black P.C.
- Case Identification: 3:24-cv-06514, N.D. Cal., 09/17/2024
- Venue Allegations: Venue is alleged to be proper in the Northern District of California because Defendant maintains a regular and established place of business in the district, and a substantial part of the events giving rise to the claim allegedly occurred there.
- Core Dispute: Plaintiff alleges that Defendant’s Rokid AR Lite augmented reality glasses infringe a patent related to methods and systems for transitioning a head-mounted display between transparent, opaque, and intermediate viewing states.
- Technical Context: The technology at issue addresses user experience challenges in head-mounted displays (HMDs) by managing how digital information is presented against a user's view of the real world to improve image quality and reduce motion sickness.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of the asserted patent via a letter dated August 5, 2024, a fact which may be used to support allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2010-09-09 | '005 Patent Priority Date (Application Filed) |
| 2013-12-31 | '005 Patent Issue Date |
| 2024-08-05 | Plaintiff sends pre-suit notice letter to Defendant |
| 2024-09-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,619,005 - "Switchable Head-Mounted Display Transition"
- Patent Identification: U.S. Patent No. 8,619,005, issued December 31, 2013.
The Invention Explained
- Problem Addressed: The patent's background section describes shortcomings of prior art head-mounted displays (HMDs). Immersive (opaque) displays could cause motion sickness when the displayed image movement lagged behind the user's head movement, while see-through augmented-reality displays suffered from poor image quality and contrast due to competing light from the real-world environment ('005 Patent, col. 1:40-65).
- The Patented Solution: The invention is a switchable HMD that can operate in three states: a fully transparent state for viewing the real world, an opaque "information" state for viewing digital content, and a transitional "intermediate state" ('005 Patent, col. 4:40-57). The system can switch between these states in response to a stimulus, such as the user turning their head, by dynamically panning, compressing, or fading digital information to smoothly blend the digital and real-world views, thereby mitigating motion sickness ('005 Patent, col. 6:28-48; Figs. 4A-4E).
- Technical Importance: The technology aimed to solve a primary usability problem in HMDs by creating a more comfortable and visually coherent experience, allowing a device to serve as both an immersive viewer and a practical augmented reality tool without the drawbacks of either single-purpose approach ('005 Patent, col. 3:32-37).
Key Claims at a Glance
- The complaint asserts independent method claim 19 and dependent apparatus claim 22 ('005 Patent, col. 14:1-48, col. 15:12-14; Compl. ¶35). The allegations are primarily mapped to the elements of independent apparatus claim 21, from which claim 22 depends.
- Independent Claim 21 (Apparatus):
- A head-mounted display with a switchable viewing area containing independently controllable portions, switched between a transparent state and an opaque information state.
- A controller that switches the viewing state to an intermediate state (and back) by "successively switching spatially adjacent independently controllable portions."
- The intermediate state is defined as one where a portion of the viewing area is in the information state, a different portion is in the transparent state, and information is displayed over a smaller spatial area than in the full information state.
- The complaint reserves the right to assert additional claims ('005 Patent, Prayer for Relief).
III. The Accused Instrumentality
Product Identification
- The Rokid AR Lite glasses and associated hardware and software, collectively referred to as the "Rokid Accused Products" (Compl. ¶27).
Functionality and Market Context
- The complaint describes the Rokid AR Lite as an "advanced lightweight spatial computing pair of glasses" with see-through lenses (Compl. ¶24). Its core function is to create a "spatial multi-screen" or "spatial office" environment, where multiple digital application windows can be viewed simultaneously, appearing overlaid on the user's real-world surroundings (Compl. ¶¶ 30-31). This marketing image from the complaint shows the Rokid AR Lite displaying multiple application windows in the user's field of view (Compl. p. 8). The complaint alleges the device uses a Qualcomm Snapdragon processor to act as the controller for switching viewing states (Compl. ¶32).
- The complaint positions the product as a tool for productivity and multitasking, allowing users to interact with digital content while remaining aware of their physical environment (Compl. ¶¶ 30-31).
IV. Analysis of Infringement Allegations
'005 Patent Infringement Allegations (based on Claim 21)
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a head-mounted display... including a switchable viewing area having independently controllable portions that is switched between a transparent viewing state and an information viewing state... | The Rokid AR Lite is a head-mounted display with see-through lenses that have "independently controllable portions" capable of displaying opaque digital content (information state) while other portions remain see-through (transparent state). This screenshot shows digital content displayed over a real-world background. | ¶¶29, 31 | col. 14:50-54 |
| a controller for switching the viewing state to an intermediate state... by successively switching spatially adjacent independently controllable portions... | The Rokid AR Lite's Qualcomm Snapdragon processor allegedly functions as the controller that switches the viewing state to an intermediate state. The complaint provides this image of the processor. | ¶¶32, 33 | col. 14:60-65 |
| wherein the intermediate state is a state in which a portion of the switchable viewing area is in the information viewing state and a different portion... is in the transparent viewing state and in which information is displayed... over a smaller spatial area... | The complaint alleges that when the user moves their head, the device enters an intermediate state where part of the screen displays digital content (information state) and another part is transparent, with the digital content occupying a smaller area than it would in a fully immersive mode. | ¶¶33, 34 | col. 15:4-11 |
Identified Points of Contention
- Scope Questions: The case may turn on the definition of "intermediate state." A central question is whether the Rokid AR Lite’s display of persistent, spatially-anchored digital windows against a transparent background constitutes the "intermediate state" contemplated by the patent. The patent specification frequently describes this state as part of a dynamic transition (e.g., panning an image off-screen) in response to a stimulus, which raises the question of whether a more static augmented reality layout falls within the claim's scope ('005 Patent, col. 7:15-30).
- Technical Questions: A key factual dispute may involve the mechanism of "successively switching spatially adjacent independently controllable portions." The complaint must provide evidence that the accused device's processor actually performs this sequential switching operation to transition between states, rather than using an alternative, non-infringing rendering technique to achieve the visual effect of co-existing transparent and opaque areas ('005 Patent, col. 14:62-64).
V. Key Claim Terms for Construction
"intermediate state"
- Context and Importance: This term is the lynchpin of the invention and the infringement case. The definition will determine whether the accused product's fundamental mode of operation—displaying application windows in an augmented reality view—is covered by the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself provides a structural definition: "a state in which a portion of the switchable viewing area is in the information viewing state and a different portion... is in the transparent viewing state" ('005 Patent, col. 15:4-8). This language could be argued to cover any HMD view that simultaneously includes both opaque information and a transparent view of the real world.
- Evidence for a Narrower Interpretation: The specification repeatedly ties the "intermediate state" to a transitional process, such as panning information in response to head movement (as shown in Figures 4A-4E), or as a temporary step between fully opaque and fully transparent modes ('005 Patent, col. 6:28-35). This context suggests the term may be limited to a dynamic, temporary condition rather than a persistent, static layout.
"successively switching spatially adjacent independently controllable portions"
- Context and Importance: This phrase defines the specific technical mechanism required to enter and exit the "intermediate state." Plaintiff must prove the accused product uses this method. Practitioners may focus on this term because if the Rokid AR Lite achieves its display through a different rendering method, infringement may be avoided.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue this language covers any software-controlled process that results in adjacent portions of the display being in different states, without requiring a specific, observable, step-by-step physical switching sequence.
- Evidence for a Narrower Interpretation: The word "successively" strongly implies a temporal, sequential action. The patent's description and associated figures (e.g., Figs. 11A-11H) illustrate a clear, step-by-step process of activating adjacent display segments over time ('005 Patent, col. 9:4-14). This could support a narrower construction requiring proof of such a sequential mechanism.
VI. Other Allegations
Indirect Infringement
- The complaint alleges that Rokid induced infringement by its customers and users. It asserts that Rokid intended for users to operate the products in an infringing manner and was aware that such use would constitute infringement (Compl. ¶¶ 37-38). The complaint does not, however, cite specific evidence such as user manuals or marketing materials that instruct on the infringing use.
Willful Infringement
- The willfulness allegation is predicated on alleged pre-suit knowledge of the '005 Patent, stemming from a notice letter Plaintiff's counsel sent to Rokid on August 5, 2024 (Compl. ¶36). Continued alleged infringement after this date forms the basis of the claim.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "intermediate state", which the patent repeatedly describes in the context of a dynamic transition between viewing modes, be construed to cover the accused product's more static function of displaying persistent application windows in an augmented reality view?
- A key evidentiary question will be one of technical mechanism: what proof will be offered that the Rokid AR Lite's processor performs the specific, sequential operation of "successively switching spatially adjacent independently controllable portions" to create its display, as the claims require, versus achieving a visually similar result through a different, non-infringing rendering architecture?