DCT

3:25-cv-00221

Clear Imaging Research LLC v. Google LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-00221, S.D. Cal., 01/30/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Southern District of California because Google maintains a regular and established place of business in the district, including an office in San Diego that posts job openings related to the accused image processing technology.
  • Core Dispute: Plaintiff alleges that Defendant’s Google Pixel smartphones and tablets infringe seven U.S. patents related to digital image processing, including methods for correcting image blur using motion sensors and combining multiple images to enhance sharpness or create artistic effects.
  • Technical Context: The technologies at issue relate to computational photography, a critical feature set in the competitive smartphone market for improving image and video quality beyond the physical limits of small camera sensors.
  • Key Procedural History: The complaint details an extensive history of pre-suit communications between the parties, beginning in July 2017. Plaintiff alleges it provided Google with notice letters, slide presentations, and multiple claim charts identifying the asserted patents and accused products over a period of more than seven years. Plaintiff also notes that its patent portfolio has been licensed by 13 other companies, including Samsung.

Case Timeline

Date Event
2004-03-25 Earliest Priority Date for Asserted Patents
2015-04-21 U.S. Patent No. 9,013,587 Issues
2017-07-20 First notice letter sent to Google regarding '788 Patent
2017-10-24 U.S. Patent No. 9,800,788 Issues
2018-01-02 U.S. Patent No. 9,860,450 Issues
2019-01-01 U.S. Patent No. 10,171,740 Issues
2019-01-04 Notice letter sent to Google regarding '740 & '587 Patents
2021-02-22 Notice letter sent to Google regarding '450 Patent
2021-11-02 U.S. Patent No. 11,165,961 Issues
2022-09-27 U.S. Patent No. 11,457,149 Issues
2023-01-10 Notice letter sent to Google regarding '961, '149 & '583 Patents
2023-02-28 U.S. Patent No. 11,595,583 Issues
2025-01-30 Complaint Filed

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

U.S. Patent No. 9,800,788 - "Method and apparatus for using motion information and image data to correct blurred images"

  • Issued: October 24, 2017

The Invention Explained

  • Problem Addressed: The patent addresses image blur caused by relative motion between a camera and a subject, particularly the "shaking" of a camera when a slow shutter speed is used (U.S. Patent No. 10,171,740, col. 1:52-62). It notes that prior electro-mechanical "image stabilization" systems built into lenses are often expensive, bulky, and can compromise image quality ('740 Patent, col. 2:19-28).
  • The Patented Solution: The invention proposes a method to correct blur using digital processing. Motion sensors (e.g., accelerometers) detect and record the camera's motion while an image is being captured (U.S. Patent No. 10,171,740, col. 5:24-30). This motion data is used to derive a mathematical "transfer function" that models the blur. The system then computes an inverse "transfer function" and applies it as a corrective filter to the blurred image, thereby recovering a sharper, "true" image ('740 Patent, Abstract; col. 2:42-53).
  • Technical Importance: This technology represents a computational approach to image stabilization, which can potentially offer a more cost-effective and flexible alternative to purely mechanical, hardware-based solutions in lenses ('740 Patent, col. 2:25-28).

Key Claims at a Glance

  • The complaint asserts independent claim 8 (Compl. ¶25).
  • The complaint does not provide the text of the asserted claims.

U.S. Patent No. 9,860,450 - "Method and apparatus to correct digital video to counteract effect of camera shake"

  • Issued: January 2, 2018

The Invention Explained

  • Problem Addressed: This patent addresses the same fundamental problem as the ’788 Patent—image degradation from camera shake—but applies the concept to digital video, which is a sequence of images (U.S. Patent No. 9,860,450, Abstract).
  • The Patented Solution: The invention uses motion sensors to detect camera movement during video capture. This motion data is used to determine a corrective process that is applied to the sequence of images (the video frames) to counteract the effect of the camera shake, resulting in a stabilized final video (U.S. Patent No. 9,860,450, Abstract; U.S. Patent No. 11,165,961, col. 5:35-50).
  • Technical Importance: The invention provides a method for digital video stabilization that relies on processing motion sensor data, a technique that has become central to modern smartphone video capabilities ('961 Patent, col. 1:43-46).

Key Claims at a Glance

  • The complaint asserts independent claim 14 (Compl. ¶36).
  • The complaint does not provide the text of the asserted claims.

U.S. Patent No. 9,013,587 - "Method and apparatus to correct digital image blur by combining multiple images"

  • Issued: April 21, 2015

Technology Synopsis

This patent describes a technique to reduce blur by capturing multiple images at a high shutter speed and then combining them into a single, sharper image. The process involves designating a main subject within the images and shifting the captured frames to align that subject before combination, resulting in a corrected image where the main subject is blur-free ('587 Patent, Abstract; col. 2:48-67).

Asserted Claims

Independent claim 15 (Compl. ¶47).

Accused Features

The complaint alleges that Google's "Super Res Zoom" and "Night Sight" camera functionalities infringe this patent (Compl. ¶49).

U.S. Patent No. 11,595,583 - "Method and apparatus for capturing digital video"

  • Issued: February 28, 2023

Technology Synopsis

This patent extends the concept of multi-image combination to video. It discloses a method where a sequence of images is captured, a main subject is determined, and frames are combined to create a modified sequence of images where the main subject is blur-free and the background is blurred. This sequence is then used to produce a final video with an artistic depth-of-field effect ('583 Patent, Abstract).

Asserted Claims

Independent claim 15 (Compl. ¶58).

Accused Features

The complaint alleges infringement by Google's "Super Res Zoom" and "Night Sight" functionalities (Compl. ¶60).

U.S. Patent No. 10,171,740 - "Method and apparatus to correct blur in all or part of a digital image by combining plurality of images"

  • Issued: January 1, 2019

Technology Synopsis

This patent describes a method for creating an image with a selectively focused subject, commonly known as a "portrait mode" effect. The method involves designating a first subject to be kept blur-free, capturing a plurality of images, and combining them such that the first subject is sharp while a second subject (or background) is blurred compared to the first ('740 Patent, Abstract; col. 12:46-67).

Asserted Claims

Independent claim 20 (Compl. ¶69).

Accused Features

The complaint alleges that Google's "Portrait Mode" infringes this patent (Compl. ¶71).

U.S. Patent No. 11,165,961 - "Method and apparatus for capturing digital video"

  • Issued: November 2, 2021

Technology Synopsis

This patent covers a method for producing digital video with a depth effect. It involves capturing a sequence of images, determining a main subject and a background, and then combining frames to generate a sequence of modified images where the main subject is blur-free and the background is blurred. This modified sequence is then combined to create the final video ('961 Patent, Abstract).

Asserted Claims

Independent claim 8 (Compl. ¶80).

Accused Features

The complaint alleges infringement by Google's "Cinematic Blur" digital video functionality (Compl. ¶82).

U.S. Patent No. 11,457,149 - "Method and apparatus for capturing digital video"

  • Issued: September 27, 2022

Technology Synopsis

Similar to the '961 and '583 patents, this invention relates to capturing digital video with a selective focus effect. It describes a method of capturing a sequence of images, determining a main subject and background, obtaining a sequence of modified images where the subject is blur-free and the background is blurred, and combining them into a final video ('149 Patent, Abstract).

Asserted Claims

Independent claim 21 (Compl. ¶91).

Accused Features

The complaint alleges infringement by Google's "Portrait Mode" digital camera functionality (Compl. ¶93).

III. The Accused Instrumentality

Product Identification

Google's Pixel 9 Pro Fold, Pixel 9 Pro, Pixel 9, Pixel 9 Pro XL, Pixel 8 Pro, Pixel 8, Pixel 8a, Pixel 7a, Pixel 7, Pixel 7 Pro, Pixel Fold, Pixel 6a, Pixel 6 Pro, Pixel 5a, Pixel 5, Pixel 4a, Pixel 4, Pixel 4 XL, Pixel 3a, Pixel 3a XL, Pixel 3, Pixel 3XL, Pixel 2, Pixel 2 XL, and Pixel Tablet (collectively, the "Accused Products") (Compl. ¶¶24, 35, 46).

Functionality and Market Context

  • The complaint accuses specific computational photography features within the Accused Products. These include various video stabilization modes ("Fused Video Stabilization," "Cinematic Pan Video Stabilization," "Active Video Stabilization"), multi-frame enhancement technologies ("Super Res Zoom," "Night Sight"), and artistic effect modes ("Portrait Mode," "Cinematic Blur") (Compl. ¶¶27, 49, 71, 82).
  • These software-driven features are central to the marketing and user experience of modern smartphones, allowing users to capture high-quality, stable, and artistically styled photos and videos in a variety of conditions, such as low light or while in motion (Compl. ¶¶49, 71).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits for each asserted patent but does not attach them. Therefore, a detailed element-by-element analysis is not possible based on the provided document. The infringement theories are summarized below in prose.

No probative visual evidence provided in complaint.

'788 Patent Infringement Allegations

The complaint alleges that the Accused Products' video stabilization functionalities, such as "Fused Video Stabilization" and "Active Video Stabilization," directly infringe one or more claims of the '788 Patent (Compl. ¶¶25, 27). The underlying theory suggests these features use motion information to correct for blur in images, as claimed in the patent.

'450 Patent Infringement Allegations

The complaint asserts that the same video stabilization features in the Accused Products infringe one or more claims of the '450 Patent (Compl. ¶¶36, 38). The theory of infringement appears to be that these features apply a process of correcting for camera shake in a sequence of digital images (i.e., a video), as claimed.

Identified Points of Contention

  • Technical Questions: A primary point of contention for the '788 and '450 patents will likely be the specific technical mechanism by which Google's stabilization features operate. The case may turn on what evidence is presented to show whether the accused software actually calculates a "transfer function" from sensor data and applies its "inverse" to correct frames, or if it uses an alternative stabilization method not covered by the claims (e.g., electronic image stabilization based on cropping and re-centering frames).

V. Key Claim Terms for Construction

The complaint does not provide the text of the asserted claims for U.S. Patent Nos. 9,800,788 and 9,860,450, precluding an analysis of key claim terms.

VI. Other Allegations

Indirect Infringement

For each asserted patent, Plaintiff alleges both induced and contributory infringement. Inducement is based on allegations that Google actively encourages infringement by advertising the accused features and providing user manuals and online instructions on how to use them (e.g., Compl. ¶¶27, 38). Contributory infringement is based on allegations that the specific software components implementing the accused features (e.g., "Portrait Mode," "Super Res Zoom") are material parts of the inventions, are not staple articles of commerce, and are especially made or adapted for infringement (e.g., Compl. ¶¶28, 39).

Willful Infringement

Plaintiff alleges that Google's infringement has been and continues to be willful and deliberate for all asserted patents. The basis for this allegation is the extensive history of pre-suit notice, including letters, calls, and claim charts that allegedly informed Google of the patents and its infringement, beginning as early as July 20, 2017 (Compl. ¶¶9-18, 31, 42). The complaint also asserts that Google’s knowledge of the patents by way of the complaint itself supports a finding of ongoing willful infringement (Compl. ¶31).

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

This litigation will likely center on the resolution of two main categories of questions, one technical and one legal, in addition to the valuation of any potential damages.

  • A core issue will be one of technical implementation: For the asserted patents covering motion-sensor-based deblurring ('788 and '450), what is the precise algorithm used by Google's video stabilization features? The case will require a deep dive into the accused software's source code and operation to determine if it performs the claimed steps of deriving and applying an inverse transfer function, or if it utilizes a non-infringing alternative.
  • A second key question will be one of claim scope and functional mapping: For the patents related to multi-image combination ('587, '583, '740, '961, and '149), can the specific claim limitations regarding subject designation, image alignment, and frame combination be mapped onto the functionality of accused features like "Super Res Zoom," "Night Sight," and "Portrait Mode"? This will involve claim construction to define the boundaries of the patented methods, followed by a factual comparison to the accused processes.
  • Finally, a significant question for damages will be willfulness: Given the multi-year history of detailed pre-suit notice alleged by the Plaintiff, the court will need to examine whether Google's conduct rises to the level of egregious behavior that would warrant an award of enhanced damages should infringement be found.