DCT
1:18-cv-00265
Genedics LLC v. Leap Motion Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Genedics, LLC (Massachusetts)
- Defendant: Leap Motion, Inc. (Delaware)
- Plaintiff’s Counsel: THE deBRUIN FIRM, LLC; Rubin and Rudman, LLP (Of Counsel)
- Case Identification: 1:18-cv-00265, D. Del., 02/15/2018
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Leap Motion, Inc. is a Delaware corporation.
- Core Dispute: Plaintiff alleges that Defendant’s hand and finger tracking sensor systems, when used with associated software, infringe patents related to manipulating digital images in a three-dimensional user interface.
- Technical Context: The technology at issue involves using sensors to determine the position and movement of a user's hands in 3D space, allowing for the direct, gestural manipulation of on-screen or holographic objects, a key component of virtual and augmented reality systems.
- Key Procedural History: The complaint states that on August 24, 2017, Plaintiff sent Defendant a notice letter identifying the patents-in-suit and providing claim charts alleging infringement. This pre-suit notice is the foundation for the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2007-10-31 | Priority Date for ’773 and ’225 Patents |
| 2012-11-27 | U.S. Patent No. 8,319,773 Issued |
| 2014-12-02 | U.S. Patent No. 8,902,225 Issued |
| 2017-08-24 | Plaintiff sends notice of infringement to Defendant |
| 2018-02-15 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,319,773: Method and Apparatus for User Interface Communication with an Image Manipulator (Issued Nov. 27, 2012)
The Invention Explained
- Problem Addressed: The patent identifies a need to move beyond user interfaces that, despite appearing three-dimensional, operate on a two-dimensional plane. It asserts that existing systems do not take advantage of a "full three dimensional coordinate system," limiting the intuitiveness of user interactions (Compl. ¶24; ’773 Patent, col. 2:5-14).
- The Patented Solution: The invention proposes a system for manipulating a 3D image where sensors detect a user's interaction (e.g., a hand gesture) within a 3D coordinate system. This detection is based on "quadrilateral angle navigation" to determine a "touch point" in space. A processor then correlates the interaction with the image and projects an updated, "distorted" version of the image reflecting the user's manipulation, such as twisting or squeezing (’773 Patent, Abstract; col. 4:40-55).
- Technical Importance: This technology aims to create a more immersive and natural user interface by allowing direct, real-time manipulation of 3D digital objects, mirroring how humans interact with objects in the physical world (’773 Patent, col. 2:15-24).
Key Claims at a Glance
- The complaint asserts independent claims 9 (a system claim) and 17 (a non-transient computer program product claim) (Compl. ¶20).
- Independent claim 9 recites the core elements of the system:
- At least one sensor configured to sense a user interaction based on "quadrilateral angle navigation" to determine a "touch point position" in a 3D coordinate system, where the image is displayed and matched to this system.
- A "correlation unit" to correlate the sensed interaction with the 3D coordinate system.
- A "projecting unit" that displays an updated image based on the correlation, where the updated image is equivalent to the original image manipulated by a "distortion."
- The complaint reserves the right to assert dependent claims (Compl. ¶20).
U.S. Patent No. 8,902,225: Method and Apparatus for User Interface Communication with an Image Manipulator (Issued Dec. 2, 2014)
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’773 Patent, the ’225 Patent addresses the same technical problem: the limitations of 2D interfaces for interacting with 3D content and the need for a "true 3-D technology" to create a more realistic computing environment (Compl. ¶65; ’225 Patent, col. 2:15-24).
- The Patented Solution: The solution is substantively identical to that of the parent ’773 Patent. It describes a system comprising a projecting unit, sensors using "quadrilateral angle navigation" to detect user interaction in 3D space, and a correlation unit to process the interaction and update the displayed image with a corresponding manipulation or distortion (’225 Patent, Abstract; col. 4:40-54).
- Technical Importance: The invention contributes to the field of advanced human-computer interaction by detailing a method for enabling gestural control over digital objects in a 3D environment (’225 Patent, col. 2:15-24).
Key Claims at a Glance
- The complaint asserts independent claim 9 (a system claim) (Compl. ¶61).
- Independent claim 9 breaks down the system into the following key components:
- A "projecting unit" that renders an initial image.
- At least one sensor configured to sense user interaction with the image in a 3D coordinate system, with the sensing "based on quadrilateral angle navigation."
- A "correlation unit" that correlates the interaction with the 3D coordinate system and the initial image to implement a "manipulation."
- The projecting unit is responsive to the correlation unit to project an "updated image" reflecting the manipulation.
- The complaint reserves the right to assert dependent claims (Compl. ¶61).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "Leap Motion-based computer user interface systems" which comprise Leap Motion controllers (including Leap Motion software), a computer processor, the Unity 3D software engine, and potentially other third-party application software (Compl. ¶¶10, 21, 62).
Functionality and Market Context
The Leap Motion controller is described as a sensor device that performs hand and finger tracking, which allows users to "manipulate digital objects with their hands" (Compl. ¶¶10-11). The complaint alleges that Leap Motion provides developer kits and encourages the creation of Virtual Reality applications for its platform, which in turn "spur the market for Leap Motion's controllers" (Compl. ¶¶40, 56). The accused system allegedly operates by having the Leap Motion controller's sensor array provide coordinate information to a computer processor running the Unity 3D engine, which then correlates the interaction and projects an updated image (Compl. ¶¶46, 87).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
’773 Patent Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A user interface system for manipulating an original image, the system comprising: at least one sensor configured to sense, based on quadrilateral angle navigation to determine a touch point position within a three dimensional coordinate system, a user interaction with the image... | The Leap Motion controllers include sensor arrays alleged to be "configured to sense based on quadrilateral angle navigation to determine a touchpoint position within a three dimensional coordinate system." | ¶46 | col. 8:65-col. 9:9 |
| a correlation unit executed by the computer processor and configured to correlate the sensed user interaction with the three dimensional coordinate system; and | A computer processor running the Unity 3D software engine allegedly "correlates the sensed user interaction within the three dimensional coordinate system." | ¶46 | col. 9:10-13 |
| a projecting unit responsive to the correlation unit and configured to project an updated image based on the correlated user interaction, the updated image being equivalent to the original image manipulated by a distortion. | An updated digital image is projected based on the computer processor and Unity 3D software engine, which is alleged to be based on the correlated user interaction. | ¶46 | col. 9:14-19 |
- Identified Points of Contention:
- Scope Questions: The complaint alleges the Leap Motion controller uses "quadrilateral angle navigation" (Compl. ¶25). A primary dispute may be whether the controller's actual sensing methodology, which likely involves stereo infrared cameras and complex algorithms, falls within the scope of this term as it is used and described in the patent, particularly in light of figures showing a distinct four-point sensor arrangement (’773 Patent, Fig. 3).
- Technical Questions: The complaint makes a conclusory allegation that the accused device uses "quadrilateral angle navigation" but provides no specific evidence as to how. The technical operation of the Leap Motion controller will be a central factual question.
’225 Patent Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A user interface system, comprising: a projecting unit rendering a display of an initial image; | The system projects a digital image via a computer processor running the Unity 3D software engine (Compl. ¶87). | ¶87 | col. 8:65-col. 9:1 |
| at least one sensor configured to sense a user interaction with the displayed initial image, the user interaction being in a three dimensional coordinate system and sensing being based on quadrilateral angle navigation... | The Leap Motion controllers include a sensor array alleged to be "configured to sense based on quadrilateral angle navigation to determine a touchpoint position." | ¶87 | col. 9:2-15 |
| a correlation unit configured to correlate the sensed user interaction... and correlate the three dimensional coordinate system with the initial image in a manner implementing a manipulation... | A computer processor running the Unity 3D software engine allegedly "correlates the sensed user interaction within the three dimensional coordinate system." | ¶87 | col. 9:16-22 |
| wherein the projecting unit is responsive to the correlation unit and configured to project an updated image resulting from the manipulation of the initial image, the updated image being equivalent to the initial image manipulated by a distortion... | An updated digital image is projected based on the computer processor and Unity 3D engine, which is alleged to be the result of the manipulation. | ¶87 | col. 9:23-28 |
- Identified Points of Contention:
- Scope Questions: As with the ’773 Patent, the meaning of "quadrilateral angle navigation" will be critical. The complaint characterizes this feature as an "unconventional configuration of sensor(s)" (Compl. ¶66), suggesting Plaintiff may argue for a specific interpretation that it believes reads on the accused product.
- System vs. Component Questions: The asserted claim is for a "user interface system." The complaint alleges infringement by a system comprising Defendant's controller plus third-party components (computer, Unity engine). This raises the question of whether Defendant can be held liable for direct infringement of the entire system claim, as it does not make or sell the complete combination.
V. Key Claim Terms for Construction
The Term: "quadrilateral angle navigation"
- Context and Importance: This term is the central technical limitation in the independent claims of both patents and is designated by the Plaintiff as an "unconventional configuration" (Compl. ¶¶25, 66). The entire infringement case may hinge on whether the Leap Motion controller's sensing technology is found to perform this specific function.
- Intrinsic Evidence for a Broader Interpretation: The patent specification does not provide an explicit definition. A party could argue the term functionally describes any process that determines a point in 3D space by referencing its angular position relative to multiple sensors, not necessarily requiring a specific four-sensor hardware structure.
- Intrinsic Evidence for a Narrower Interpretation: The specification heavily links the term to the embodiment in Figure 3, which explicitly depicts a "QUADRILATION OF SENSOR DEVICE" using four distinct laser sensors (320a-d) to define a "quadrant 310" (’773 Patent, col. 4:38-55). A party could argue this disclosure limits the term to a geometric determination based on a four-cornered sensor field.
The Term: "user interface system"
- Context and Importance: The asserted independent claims are for a "system." The infringement allegations rely on combining Defendant's product with third-party products (a PC, Unity 3D engine) to meet all claim limitations. The definition of the "system" and who "makes" or "uses" it will be critical for determining direct infringement.
- Intrinsic Evidence for a Broader Interpretation: The claims themselves list the components functionally (a sensor, a correlation unit, a projecting unit) without specifying that they must be contained in a single, pre-integrated device sold by one entity.
- Intrinsic Evidence for a Narrower Interpretation: A defendant could argue that for direct infringement, a single party must control or provide all elements of the claimed system. The complaint's theory appears to be that Leap Motion's customers assemble the system, which may point more toward indirect infringement rather than direct infringement by Leap Motion itself.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement.
- Inducement: It is alleged that Leap Motion had knowledge of the patents as of August 25, 2017, and actively encouraged infringement by selling its controllers, providing developer kits, and instructing customers and developers to combine its product with computers and the Unity 3D engine to create the allegedly infringing systems (Compl. ¶¶37-43, 78-84).
- Contributory: It is alleged that the Leap Motion controller is a material part of the invention, is specially made or adapted for use in an infringing system, and has no substantial non-infringing uses because it requires a computer and specific software to perform its intended function (Compl. ¶¶46, 49, 87, 90).
- Willful Infringement: The willfulness allegations are based on Leap Motion’s alleged continuation of its infringing activities after receiving Plaintiff's notice letter and claim charts on August 25, 2017, which allegedly provided actual knowledge of the patents and the infringement (Compl. ¶¶55-57, 96-98).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "quadrilateral angle navigation," which is illustrated in the patent with a specific four-point sensor geometry, be construed to cover the sophisticated algorithmic methods of hand-and-finger tracking employed by the accused Leap Motion controller?
- A second central question will address liability for a multi-component system: given that the asserted claims are for a "user interface system," and the Defendant sells only the sensor component of that system, can the Plaintiff prove direct infringement by the Defendant, or will the case turn entirely on theories of indirect infringement based on the actions of end-users and developers?
- A key evidentiary question will be one of technical proof: what evidence will be presented to substantiate the complaint's conclusory allegation that the accused product's internal sensing method is, in fact, "based on quadrilateral angle navigation" as required by the claims? The outcome may depend heavily on expert analysis of the accused device's operational principles.