DCT

1:17-cv-00594

Honeywell Intl Inc v. Code Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:17-cv-00594, D. Del., 05/23/2017
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation and conducts business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s handheld barcode scanners infringe six patents related to technologies for optical imaging, data formatting, and automatic exposure control.
  • Technical Context: The technology at issue involves image-based barcode scanners, which use camera-like sensors and processing to read 1D and 2D barcodes, a technology widely used in sectors such as healthcare and logistics.
  • Key Procedural History: No prior litigation, Inter Partes Review (IPR) proceedings, or licensing history between the parties is mentioned in the complaint.

Case Timeline

Date Event
2000-09-30 ’923 Patent Priority Date
2001-06-26 ’725 Patent Priority Date
2004-11-15 ’206 Patent Priority Date
2004-12-21 ’725 Patent Issued
2006-12-12 ’923 Patent Issued
2008-10-31 ’969 Patent Priority Date
2009-05-05 ’206 Patent Issued
2011-08-31 ’572 Patent Priority Date
2011-09-30 ’692 Patent Priority Date
2013-08-20 ’572 Patent Issued
2014-02-11 ’692 Patent Issued
2016-04-26 ’969 Patent Issued
2017-05-23 Complaint Filing Date

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

U.S. Patent No. 6,832,725 - "Optical Reader Comprising Multiple Color Illumination"

  • Issued: December 21, 2004

The Invention Explained

  • Problem Addressed: The patent’s background section notes that while durable, image-sensor-based readers were superior to fragile laser-based scanners for reading 2D barcodes, users of laser scanners preferred the "neat and clean aiming and illumination pattern" that laser scanners projected. (’725 Patent, col. 2:5-18). The technical challenge was to replicate the distinct aiming pattern of a laser scanner within a solid-state, image-based reader.
  • The Patented Solution: The invention uses a two-board architecture to physically separate the aiming and illumination functions. A first circuit board holds the image sensor and the aiming light-emitting diodes (LEDs), while a second circuit board, spaced forward of the first, holds the illumination LEDs. (’725 Patent, col. 2:44-52). The aiming LEDs are selected to emit light of a different visible color than the illumination LEDs, creating a distinct color contrast between the aiming pattern and the general illumination field, thereby providing a clear visual target for the user. (’725 Patent, col. 3:15-19).
  • Technical Importance: This design allowed image-based scanners to offer the functional benefits of 2D scanning and durability while providing the clear, intuitive aiming feedback that users had come to expect from laser-based scanners. (Compl. ¶25).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 4-6 (Compl. ¶38).
  • The essential elements of independent claim 1 are:
    • A first circuit board carrying a two-dimensional image sensor.
    • A second circuit board spaced forwardly of the first, with a support assembly between them.
    • An aiming system with aiming LEDs mounted on the first circuit board.
    • An illumination system with illumination LEDs mounted on the second circuit board.
    • The aiming LEDs emit light in a different visible color from the illumination LEDs, creating a color contrast between the aiming and illumination patterns.

U.S. Patent No. 8,511,572 - "Encoded Information Reading Terminal With Data Formatting Functionality"

  • Issued: August 20, 2013

The Invention Explained

  • Problem Addressed: The patent addresses the need for barcode readers to do more than simply output the raw data from a scanned symbol. (’572 Patent, col. 1:35-42). In complex environments, it is often necessary to filter, modify, or format the scanned data before it is sent to a host system, without requiring complex software changes on the host itself. (Compl. ¶27).
  • The Patented Solution: The invention describes an Encoded Information Reading (EIR) terminal that can read an encoded message (e.g., a barcode), decode it into a character string, and then apply one or more "formatting commands" to produce a final output string. (’572 Patent, Abstract). A key command described is a "Discard Data formatting command," which allows the terminal to be configured to exclude data from a specific barcode type (symbology) from the final output, effectively filtering the data at the point of capture. (’572 Patent, col. 2:18-21).
  • Technical Importance: This technology gives users and system integrators the flexibility to customize the data output of a scanner to fit specific workflow requirements, such as ignoring extraneous barcodes on a package or conforming to a host system’s data entry format. (Compl. ¶27).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-4 and 6-10 (Compl. ¶56).
  • The essential elements of independent claim 1 are:
    • A terminal with a microprocessor, memory, communication interface, and an EIR device (e.g., barcode reader) coupled to a system bus.
    • The terminal is configured to read an encoded message and produce a decoded character string.
    • The terminal is further configured to produce an output character string by applying one or more formatting commands to the decoded string.
    • The formatting includes excluding a symbol of a specified encoding type from the output string, according to a "Discard Data formatting command."

U.S. Patent No. 7,148,923 - "Methods and Apparatus for Automatic Exposure Control"

  • Issued: December 12, 2006 (Compl. ¶29)
  • Technology Synopsis: The patent is directed to automated, real-time exposure control for imagers in multi-tasking environments. (’923 Patent, Abstract). The system uses a high-priority software module for real-time imager control (e.g., setting exposure) and a lower-priority module that analyzes captured image data to provide feedback to the high-priority module for future adjustments. (’923 Patent, col. 2:50-60; Compl. ¶72).
  • Asserted Claims: Independent claim 10 is asserted (Compl. ¶72).
  • Accused Features: The CR2600's multi-tasking processor is alleged to execute high- and low-priority software modules to dynamically set the imager's gain and exposure based on environmental conditions (Compl. ¶76). The complaint provides metadata from the device showing changes in "Exposure Time" and "Gain Global" values between two images taken in different conditions as evidence. (Compl. Fig. 7).

U.S. Patent No. 7,527,206 - "Method of Setting the Time Duration of Illumination From an LED-Based Illumination Array..."

  • Issued: May 5, 2009 (Compl. ¶31)
  • Technology Synopsis: The patent describes a system for automatically setting the duration of illumination from an LED array in a barcode reader. (’206 Patent, Abstract). It uses an illumination measurement subsystem to determine the required illumination duration to achieve a desired image intensity and an illumination control subsystem to control how long the LEDs are driven. (’206 Patent, col. 2:53-62; Compl. ¶85).
  • Asserted Claims: Independent claim 11 is asserted (Compl. ¶85).
  • Accused Features: The CR2600 is alleged to contain subsystems that automatically measure illumination levels and control the duration of LED illumination. (Compl. ¶¶ 90-91). An oscilloscope graph is provided, allegedly showing the device detecting an object and increasing the illumination "Pulse Width" from 0.25 us to 1.35 us. (Compl. Fig. 8).

U.S. Patent No. 8,646,692 - "Devices and Methods Employing Dual Target Auto Exposure"

  • Issued: February 11, 2014 (Compl. ¶33)
  • Technology Synopsis: The patent relates to acquiring different sets, or "pluralities," of images using different control parameters, such as exposure settings. (’692 Patent, Abstract). The device is configured to acquire a first set of images based on a first control parameter and a second set based on a different parameter, with the two sets of images being interspersed during capture. (’692 Patent, col. 2:3-13; Compl. ¶101).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶101).
  • Accused Features: The CR2600 is accused of being configured to acquire first and second pluralities of images, each with a separate and adjusted control parameter. (Compl. ¶¶ 105-106). This is allegedly evidenced by graphs showing the device adjusting illumination, capture time, and exposure time in response to changing light conditions. (Compl. Figs. 9, 10).

U.S. Patent No. 9,323,969 - "Indicia Reading Terminal Including Frame Quality Evaluation Processing"

  • Issued: April 26, 2016 (Compl. ¶35)
  • Technology Synopsis: The patent describes a method for concurrently evaluating image frame quality while decoding a previous frame. (’969 Patent, Abstract). The processor evaluates the quality of a current frame based on metrics like edge sharpness and, if it meets a predetermined criterion, ceases the attempt to decode the previous frame, presumably to begin work on the higher-quality current frame. (’969 Patent, col. 2:42-50; Compl. ¶115).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶115).
  • Accused Features: The CR2600's processor is alleged to perform this concurrent processing, capturing and evaluating frames for quality while decoding a previous frame. (Compl. ¶119). A graph is offered showing the device's "Edge Score" and other parameters stabilizing after a change in lighting, which is alleged to demonstrate the processor ceasing to decode a previous frame once a new frame satisfies a quality criterion. (Compl. Fig. 11).

III. The Accused Instrumentality

Product Identification

The complaint identifies The Code Reader™ 2600 ("CR2600") as the representative accused product (Compl. ¶21).

Functionality and Market Context

The CR2600 is a handheld, image-based barcode scanner marketed for its ability to decode all 1D, 2D, and Postal barcode symbologies (Compl. ¶61; Fig. 5). The complaint alleges the device includes a multi-tasking processor, memory, an imager, and a communication interface (Compl. ¶58; Fig. 1). Functionality relevant to the infringement allegations includes its use of separate, different-colored LEDs for aiming and illumination; its user-configurable data formatting software, CortexTools™; and its systems for automatic, real-time control of image capture parameters such as gain, exposure, and illumination duration (Compl. ¶¶ 48, 63, 76, 90). The complaint contends that Code has entered the healthcare scanner market and competes with Honeywell by incorporating Honeywell's patented technology (Compl. ¶¶ 20-21).

IV. Analysis of Infringement Allegations

’725 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a) a first circuit board carrying a two dimensional image sensor; The CR2600 includes a first circuit board with an image sensor, identified within an annotated photograph. ¶41; Fig. 1 col. 2:45-47
b) a second circuit board spaced forwardly of said first circuit board; a support assembly at least partially interposed between said first circuit board and said second circuit board; The device contains a second circuit board spaced in front of the first, with a support system between them. ¶42; Fig. 1 col. 2:47-52
c) an aiming system for projecting an aiming line comprising aiming LEDs, said aiming LEDs being mounted on said first circuit board; The aiming system LEDs are part of the imaging engine, which is alleged to reside on the first circuit board. ¶¶43-44; Figs. 1-2 col. 2:45-47
d) an illumination system for projecting a substantially uniform illumination pattern on a target area, said illumination system comprising illumination LEDs mounted on said second circuit board; The illumination system LEDs are located on the second circuit board. ¶46; Fig. 3 col. 2:47-48
e) wherein said aiming LEDs are selected to emit light in a different visible color relative to a visible color emitted by said illumination LEDs so that said aiming pattern is in color contrast relative to said illumination pattern. The CR2600 produces a red illumination field and a blue aiming line, resulting in color contrast. An annotated photograph shows the device in operation projecting these two distinct colors. ¶48; Fig. 4 col. 3:15-19
  • Identified Points of Contention:
    • Scope Questions: What is the scope of the term "mounted on" in elements (c) and (d)? The complaint uses annotated photographs to show the general location of components (Compl. Figs. 1-3). A potential issue for the court is whether the aiming LEDs are "mounted on" the first circuit board in the manner required by the claim, or if they are mounted on a separate sub-assembly that is merely housed with the first board's components.
    • Technical Questions: What evidence does the complaint provide that the illumination pattern is "substantially uniform" as required by element (d)? The complaint asserts this and provides a photograph of the pattern in use (Compl. ¶48; Fig. 4), but the question of what constitutes "substantially uniform" may require further technical evidence and claim construction.

’572 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a. a microprocessor communicatively coupled to a system bus; a memory communicatively coupled to said system bus; a communication interface coupled to said system bus; an EIR device communicatively coupled to said system bus, The CR2600 contains a processor, memory unit, communication interface, and an imager (EIR device), which are communicatively coupled through circuits on printed circuit boards. ¶58; Fig. 1 col. 1:49-53
b. the EIR device selected from the group consisting of: a bar code reading device... The CR2600 is marketed and functions as a "durable barcode reader." ¶60; Fig. 5 col. 2:11-12
c. wherein said EIR terminal is configured... to produce a decoded message character string by decoding said encoded message; The device is described as reading and decoding 1D, 2D, and Postal barcode symbologies. ¶61; Fig. 5 col. 2:13-15
d. wherein said EIR terminal is further configured to produce an output character string by formatting said decoded message character string according to one or more formatting commands; The device uses CortexTools™ software to configure its operations, including formatting barcode data according to user-selected commands. ¶¶62-63; Fig. 6 col. 2:15-18
e. wherein said formatting comprises excluding from said output character string a symbol of a specified encoding type according to a Discard Data formatting command. A screenshot of the CortexTools™ software shows a user configuring the device with a "Do Not Transmit" operation for a specific symbology ("Code 39"), which is alleged to be a "Discard Data formatting command." ¶63; Fig. 6 col. 2:18-21
  • Identified Points of Contention:
    • Scope Questions: Does the "Do Not Transmit" option in the accused CortexTools™ software (Compl. Fig. 6) constitute a "Discard Data formatting command" as that term is used in the patent? The analysis may turn on whether the term requires a specific type of software instruction or simply the function of excluding data based on its encoding type.
    • Technical Questions: Is the formatting configured via CortexTools™ performed by the "EIR terminal" itself, as required by the claim? A question may arise as to whether the scanner itself performs the filtering or if the configuration is applied by software on a connected host computer.

V. Key Claim Terms for Construction

For the ’725 Patent

  • The Term: "mounted on"
  • Context and Importance: The claim requires aiming LEDs on a first circuit board and illumination LEDs on a second. Infringement hinges on this specific physical arrangement. Practitioners may focus on this term because the complaint's photographic evidence shows component locations generally but may not definitively establish the precise nature of the "mounting" for each set of LEDs.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification's general description focuses on the functional separation onto two boards to achieve color contrast, which could support a reading where "mounted on" includes being part of a sub-assembly located on or attached to the specified board. (’725 Patent, col. 2:44-55).
    • Evidence for a Narrower Interpretation: The figures in the patent, such as Fig. 1h, depict distinct LEDs physically placed on the surfaces of the respective circuit boards, which could support an argument that "mounted on" requires direct physical and electrical connection to the board itself, not an associated module.

For the ’572 Patent

  • The Term: "Discard Data formatting command"
  • Context and Importance: This is the sole formatting function recited in the independent claim, making its definition central to the infringement analysis. The dispute may center on whether the accused product's feature of not transmitting certain data is technically equivalent to the claimed "command."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's abstract defines the function as "excluding from the output string a symbol of a specified encoding type." (’572 Patent, Abstract). This functional description could be argued to read directly on the "Do Not Transmit" feature shown in the complaint (Compl. Fig. 6).
    • Evidence for a Narrower Interpretation: The specification may describe specific software implementations or command structures. A defendant could argue that "command" implies a specific instruction processed by the terminal's firmware, rather than a filtering rule set in a graphical user interface, suggesting a narrower scope.

VI. Other Allegations

  • Indirect Infringement: For all asserted patents, the complaint alleges both induced and contributory infringement. The inducement allegations are based on Defendant manufacturing and selling the CR2600 and providing "instructions, documentation, ... product manuals, advertisements, and online documentation" that allegedly instruct customers on how to use the products in an infringing manner (e.g., Compl. ¶52).
  • Willful Infringement: The complaint alleges that Defendant has had "knowledge and notice" of each asserted patent "at least as early as the filing of this Complaint" (e.g., Compl. ¶51). The prayer for relief requests a finding that the infringement was willful, suggesting a theory of infringement based on post-filing knowledge (Compl. p. 32).

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

  • A core issue will be one of structural correspondence: does the physical architecture of the CR2600's imaging module, particularly the placement and mounting of its aiming and illumination LEDs relative to its two primary circuit boards, align with the specific structural limitations recited in Claim 1 of the ’725 patent?
  • A second central question will be one of functional definition: do the software-configurable features of the CR2600, such as the "Do Not Transmit" option or its dynamic exposure adjustments, perform the specific functions of a "Discard Data formatting command" (’572 patent) and a "high priority/low priority" software module architecture (’923 patent), or is there a fundamental mismatch in technical operation and definition?
  • A key evidentiary question will be the interpretation of performance data: can the various oscilloscope graphs and metadata charts provided in the complaint be definitively shown to evidence the specific, multi-step logical processes claimed in the patents for automatic illumination control and frame quality evaluation (’206, ’692, ’969 patents), or could these outputs result from alternative, unclaimed methods?