Deshodax LLC v. Lenovo United States Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Deshodax LLC (Texas)
  • Defendant: Lenovo (United States), Inc. (Delaware)
  • Plaintiff’s Counsel: Devlin Law Firm LLC; Corcoran IP Law, PLLC
• Case Identification: 1:17-cv-00804, D. Del., 06/22/2017
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant conducts business, derives revenue, and allegedly committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that certain Lenovo and Motorola smartphones infringe a patent related to methods for controlling power to a motor system within an image processing device.
• Technical Context: The technology concerns selectively applying different electrical loads to a motor based on its required operating speed, aiming to improve power efficiency and reduce waste heat in devices like document scanners.
• Key Procedural History: The complaint was filed on June 22, 2017. Subsequent to this filing, an Inter Partes Review (IPR) proceeding, IPR2018-00280, was initiated against the patent-in-suit on December 12, 2017. The IPR concluded with a certificate issued on May 26, 2020, canceling all claims (1-12) of the patent. The cancellation of the asserted claim post-dates the filing of the complaint and is a central development for the viability of the case.

Case Timeline

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

U.S. Patent No. 7,307,398 - Image Processing Device and Method for Controlling a Motor System

• Patent Identification: U.S. Patent No. 7,307,398, issued December 11, 2007.

The Invention Explained

• Problem Addressed: The patent describes a problem in conventional image processing devices like scanners, where the motor system is powered by a fixed loading circuit designed to supply the maximum power needed for the fastest operational mode (e.g., low-resolution scanning). When the device operates at a slower speed (e.g., for high-resolution scanning), this configuration supplies excess power, which is dissipated as heat and can gradually damage the motor. (’398 Patent, col. 1:56 - col. 2:5).
• The Patented Solution: The invention proposes a motor system with a "plurality of loading circuits" and a "selector." This allows the device to select an appropriate loading circuit based on the operational requirements. For slower, high-resolution tasks, a different loading circuit is selected to provide a more appropriate, lower level of power, thereby increasing efficiency and reducing heat-related damage. (’398 Patent, Abstract; col. 3:7-25; Fig. 2).
• Technical Importance: This design provides a method for dynamically matching the power supplied to a motor with the power required for a specific task, aiming to improve the operational lifespan and efficiency of electromechanical systems in multi-function peripherals. (’398 Patent, col. 4:50-58).

Key Claims at a Glance

• The complaint asserts independent method claim 8. (Compl. ¶14).
• Claim 8 requires:
  • A method for controlling a motor system of an image processing device, the device comprising a first module and a motor system with a plurality of loading circuits.
  • The method comprises the step of: "selecting a loading circuit among the plurality of loading circuits and setting the selected loading circuit as a loading of the motor system for controlling power provided to the motor system." (’398 Patent, col. 6:8-17).
• The complaint notes that Plaintiff reserves the right to modify its infringement theory as discovery progresses. (Compl. ¶17).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Lenovo Phab 2 and Phab 2 Pro smartphones and its Motorola g4 Plus smartphone" as the Accused Products. (Compl. ¶11).

Functionality and Market Context

• The complaint alleges that these smartphone products infringe the ’398 patent. (Compl. ¶10). The specific technical explanation of how the accused smartphones allegedly infringe is referenced as being "explained in Exhibit B." (Compl. ¶14). As this exhibit was not attached to the publicly filed complaint, the complaint itself does not provide sufficient detail for analysis of the specific accused functionality.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of at least claim 8 of the ’398 patent but refers to an external, unprovided exhibit for its detailed infringement contentions. (Compl. ¶14). A claim chart cannot be constructed based on the allegations within the body of the complaint.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: The patent’s specification consistently describes the "image processing device" in the context of scanners and multi-function peripherals that physically move a scanning module across a document (’398 Patent, col. 1:12-15, 28-30). A central question is whether the term "image processing device" can be construed to read on a smartphone, and whether the claim term "pushing the first module to move forward" (recited in claim 1, from which method claim 8 may draw context) can be construed to cover the micro-movements of a camera lens assembly for functions like autofocus or optical image stabilization.
• Technical Questions: The invention’s core is the selection from a "plurality of loading circuits" to modulate power. A key technical question is whether the accused smartphones’ camera power management systems contain a structure that meets this limitation. The infringement analysis would depend on whether the devices use distinct, selectable loading circuits as depicted in the patent's embodiments (e.g., Fig. 2), or if they employ a different architecture, such as a single variable power management integrated circuit (PMIC), that may not map onto the claim language. The complaint does not provide evidence on this point.

V. Key Claim Terms for Construction

• The Term: "image processing device"

  • Context and Importance: The applicability of the patent to the accused smartphones hinges on the construction of this term. Practitioners may focus on this term because the patent’s specification appears to ground it in a different technical field (office peripherals) than that of the accused products (smartphones).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue for a broad, plain-meaning interpretation, where any device that processes images, including a smartphone, would be covered.
    • Evidence for a Narrower Interpretation: The "Description of the Prior Art" section exclusively discusses devices such as "computer printing devices, photocopiers, scanners and multi-functional peripherals (MFP)." (’398 Patent, col. 1:12-15). The embodiments described further reinforce this context. (’398 Patent, col. 2:56-59).

• The Term: "plurality of loading circuits"

  • Context and Importance: This term defines the central mechanism of the claimed invention. The infringement case depends on finding this specific architecture within the accused smartphones.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "loading circuit," which could allow a party to argue that different power-delivery modes or pathways within a modern, complex power management chip constitute a "plurality of loading circuits."
    • Evidence for a Narrower Interpretation: The patent’s figures depict distinct, separate loading circuits (e.g., 2241 and 2242) that are chosen by a selector. (’398 Patent, Fig. 2). This could support an argument that the term requires discrete hardware structures or pathways, not merely different software-controlled voltage or current outputs from a single, variable regulator.

VI. Other Allegations

Willful Infringement

• The complaint does not allege pre-suit willfulness. It does allege that Defendant has had knowledge of infringement "Since at least the date that Defendant was served with a copy of this Complaint," which may form a basis for seeking enhanced damages for post-suit conduct. (Compl. ¶18). The prayer for relief also requests a finding that the case is "exceptional" under 35 U.S.C. § 285. (Compl., Prayer for Relief ¶D).

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

1. Viability of the Asserted Claim: The most significant issue is the post-filing cancellation of all claims of the ’398 patent, including asserted claim 8, by the U.S. Patent and Trademark Office during an inter partes review. The central question for the court will be the legal effect of this cancellation on the litigation, which raises a substantial threat to the continuation of the infringement claim.

2. Definitional Scope Mismatch: Should the claim be considered, a primary issue will be one of claim scope: can terms like "image processing device" and concepts like a motor "pushing" a module, which are described in the patent in the context of document scanners, be interpreted to cover the components and micro-movements within a modern smartphone camera assembly?

3. Evidentiary Support for Technical Infringement: A key evidentiary question will be whether the accused smartphones contain the specific technical architecture required by claim 8—namely, a "plurality of loading circuits" that are selected from to control motor power. The complaint’s reliance on an unprovided exhibit leaves this foundational infringement allegation unsubstantiated in the pleading itself.