DCT

1:19-cv-00997

Cedar Lane Tech Inc v. Teledyne Digital Imaging US Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:19-cv-00997, D. Del., 05/30/2019
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in Delaware and has allegedly committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s digital imaging products, including industrial cameras and X-ray reconstruction technology, infringe five patents related to image processing, sensor interfaces, and panoramic image creation.
  • Technical Context: The patents address foundational technologies in digital imaging, focusing on efficient data handling between sensors, memory, and processors, as well as methods for creating panoramic images.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
1999-06-01 Priority Date for U.S. Patent No. 6,473,527
1999-08-20 Priority Date for U.S. Patent Nos. 7,292,261 and 8,031,223
2000-01-21 Priority Date for U.S. Patent Nos. 6,972,790 and 8,537,242
2002-10-29 U.S. Patent No. 6,473,527 issues
2005-12-06 U.S. Patent No. 6,972,790 issues
2007-11-06 U.S. Patent No. 7,292,261 issues
2011-10-04 U.S. Patent No. 8,031,223 issues
2013-09-17 U.S. Patent No. 8,537,242 issues
2019-05-30 Complaint filed

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

U.S. Patent No. 6,473,527 - Module and method for interfacing analog/digital converting means and JPEG compression means

The Invention Explained

  • Problem Addressed: The patent describes that conventional systems for JPEG image compression required an extra, external memory component (e.g., RAM) to buffer image data between the analog-to-digital (A/D) converter and the dedicated JPEG compression hardware. This added cost and complexity to devices like scanners and digital cameras (’527 Patent, col. 1:29-57).
  • The Patented Solution: The invention proposes an interface module that eliminates the need for this extra memory. The module includes its own memory device sized to hold a specific number of image lines (e.g., eight lines). It reads these lines from the A/D converter, and then, when enough data for a compression block (e.g., 8x8 pixels) is stored, it sends that block directly to the JPEG compression device's own built-in memory. This process is illustrated in the patent's functional block diagram, Figure 2 (’527 Patent, Abstract; col. 3:1-17).
  • Technical Importance: The described solution aimed to reduce the component cost and hardware complexity of digital imaging devices by streamlining the data pathway for compression (’527 Patent, col. 2:22-24).

Key Claims at a Glance

  • The complaint asserts independent claim 8 (’Compl. ¶19).
  • The essential elements of claim 8, a method claim, include:
    • sequentially reading a predetermined number of image lines from an A/D converter's output;
    • storing those lines in a memory means capable of holding the same number of lines as a JPEG compressor's built-in memory; and
    • sequentially reading a predetermined size image block from that memory means to the built-in memory device when the data is to be compressed.
  • The complaint reserves the right to assert other claims (’Compl. ¶19).

U.S. Patent No. 6,972,790 - Host interface for imaging arrays

The Invention Explained

  • Problem Addressed: The patent notes a fundamental incompatibility between the "video style" data output of an image sensor, which operates at its own clock speed, and the data interface of a commercial microprocessor. Bridging this gap conventionally required "additional glue logic," which undermined the cost and integration advantages of CMOS image sensor technology (’790 Patent, col. 1:38-59).
  • The Patented Solution: The invention proposes an interface, preferably integrated on the same silicon die as the image sensor, that acts as a buffer. It uses a memory (such as a FIFO buffer) to receive and store image data at the sensor's native rate. In response to the quantity of data in the memory reaching a certain level, a signal generator alerts the main processor system (e.g., via an interrupt), which can then read out the buffered data at its own, different rate (’790 Patent, Abstract; col. 2:4-13). This architecture is shown in Figure 2 of the patent.
  • Technical Importance: This interface allows a CMOS image sensor to connect efficiently to a host processor, reducing the need for external components and advancing the "system-on-a-chip" design paradigm for imaging devices (’790 Patent, col. 1:60-66).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (’Compl. ¶28).
  • The essential elements of claim 1, an apparatus claim, include:
    • a memory (e.g., a FIFO buffer) for storing imaging array data and clocking signals at a rate determined by the clocking signals;
    • a signal generator that generates a signal for the processor system "in response to the quantity of data in the memory"; and
    • a circuit for controlling the transfer of data from the memory at a rate determined by the processor system.
  • The complaint reserves the right to assert other claims (’Compl. ¶28).

U.S. Patent No. 8,537,242 - Host interface for imaging arrays

  • Technology Synopsis: As a divisional of the '790 Patent, the ’242 Patent addresses the same technical problem of efficiently interfacing an image sensor with a host processor system. It claims an integrated circuit that includes the image sensor and an interface with a memory buffer to manage the different data rates between the sensor and the host processor, allowing the processor to access image data directly (’242 Patent, col. 1:9-12; col. 2:1-12).
  • Asserted Claims: The complaint asserts independent claims 1 and 8 (Compl. ¶37).
  • Accused Features: The complaint alleges that Teledyne's Genie TS GigE Vision Camera products infringe the ’242 Patent (Compl. ¶37).

U.S. Patent No. 7,292,261 - Virtual reality camera

  • Technology Synopsis: The patent addresses the difficulty photographers face in aligning sequential shots to create a seamless panoramic image (’261 Patent, col. 2:14-25). The invention is a camera that assists the user by displaying a live viewfinder that composites a strip of the previously captured image over the current view. This visual aid allows the photographer to perfectly align the new shot with the old one before capture, facilitating the creation of panoramic images without a specialized tripod (’261 Patent, Abstract; col. 3:1-13).
  • Asserted Claims: The complaint asserts independent claim 38 (Compl. ¶46).
  • Accused Features: The complaint alleges that Teledyne's Xineos X-Ray Image Reconstruction Technology infringes the ’261 Patent (Compl. ¶46).

U.S. Patent No. 8,031,223 - Virtual reality camera

  • Technology Synopsis: As a continuation of the '261 Patent, the ’223 Patent covers similar technology for creating panoramic images. It describes a camera that acquires and combines multiple frames, assisting the user in aligning adjacent fields of view to create a final panoramic product directly within the camera, eliminating the need for a separate computer and software for "stitching" (’223 Patent, col. 1:5-8; col. 2:60-65).
  • Asserted Claims: The complaint asserts independent claim 36 (Compl. ¶55).
  • Accused Features: The complaint alleges that Teledyne's Xineos X-Ray Image Reconstruction Technology infringes the ’223 Patent (Compl. ¶55).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies two categories of accused products:
    1. Teledyne's Genie TS GigE Vision Camera products (the "Exemplary Genie Camera Products"), accused of infringing the ’527, ’790, and ’242 patents (Compl. ¶19, ¶28, ¶37).
    2. Teledyne's Xineos X-Ray Image Reconstruction Technology (the "Exemplary Xineos Technology Products"), accused of infringing the ’261 and ’223 patents (Compl. ¶46, ¶55).
  • Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the specific functionalities of the accused products. The allegations are made on "information and belief" and identify the products by name without describing their internal architecture, data processing methods, or market context (Compl. ¶19, ¶46). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits 6-10) that purportedly compare the asserted claims to the accused products (Compl. ¶24, ¶33, ¶42, ¶51, ¶60). However, these exhibits were not filed with the complaint and are not available for analysis. The infringement theory is therefore summarized below in prose based on the allegations in the complaint.

  • ’527 Patent Infringement Allegations: The complaint alleges that the Exemplary Genie Camera Products practice the method claimed in at least exemplary claim 8 of the ’527 Patent, thereby directly infringing (Compl. ¶19). It states that the referenced claim charts in Exhibit 6 set forth how the products "satisfy all elements" of the asserted claims (Compl. ¶24).
  • ’790 Patent Infringement Allegations: The complaint alleges that the Exemplary Genie Camera Products directly infringe at least exemplary claim 1 of the ’790 Patent (Compl. ¶28). It similarly relies on the referenced, but unavailable, claim charts in Exhibit 7 to allege that the products "practice the technology claimed" and "satisfy all elements" of the asserted claims (Compl. ¶33).
  • Identified Points of Contention:
    • Scope Questions: For the ’261 and ’223 patents, a central question may be one of technological scope: Does "X-Ray Image Reconstruction Technology" perform the functions of a "virtual reality camera" as described in the patents? The patents focus on a consumer or professional photography use case for creating visual panoramas, which raises the question of whether this technology is applicable to the domain of medical or industrial X-ray imaging.
    • Technical Questions: For the ’527 patent, a key technical question will be whether the accused cameras perform the specific method of transferring a "predetermined size of image block" directly from an intermediate memory to a "built-in memory device" of a JPEG compressor, as required by claim 8. For the ’790 patent, the dispute may center on whether the accused camera interface generates a signal to the processor specifically "in response to the quantity of data in the memory," as required by claim 1, or if its signaling is triggered by other events.

V. Key Claim Terms for Construction

  • ’527 Patent, Claim 8

    • The Term: "sequentially reading a predetermined size of image block from said memory means to said built-in memory device"
    • Context and Importance: This phrase defines the specific data-transfer step that is central to the patented method. The infringement analysis will depend on whether the accused camera's data flow constitutes a direct transfer of a discrete "image block" to the JPEG compressor's own internal memory, as opposed to a more general data streaming or buffering process.
    • Intrinsic Evidence for a Broader Interpretation: The term "image block" is not explicitly defined, which may support an argument that it is not limited to a specific pixel dimension and can cover various data chunk sizes (’527 Patent, col. 4:8-11).
    • Evidence for a Narrower Interpretation: The specification repeatedly uses the example of an "8x8 pixels" block, which is standard for JPEG compression, and explicitly links the memory's storage capacity to this unit (’527 Patent, col. 1:36-39, col. 3:6-8). This context may support a narrower construction tied to the requirements of the JPEG algorithm.

  • ’790 Patent, Claim 1

    • The Term: "a signal generator for generating a signal... in response to the quantity of data in the memory"
    • Context and Importance: This limitation requires a causal link between the amount of data in the buffer and the signal sent to the processor. Practitioners may focus on this term because infringement will hinge on whether the accused camera's processor is alerted based on a data-fill level (e.g., a buffer-high watermark) or based on some other condition (e.g., end-of-frame or a fixed timer).
    • Intrinsic Evidence for a Broader Interpretation: The patent discloses multiple embodiments for the signal, including an "interrupt signal" and a "bus request signal," suggesting the term is not limited to a single implementation (’790 Patent, Abstract; col. 2:14-17).
    • Evidence for a Narrower Interpretation: The detailed description links the signal generation to a direct comparison between the FIFO counter output (Sc) and a limit value (S1), stating that the generator asserts the signal if "Sc ≥ S1" (’790 Patent, col. 6:12-15). This could support an interpretation requiring a specific threshold-based triggering mechanism.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all five patents-in-suit. The inducement allegation is based on the claim that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" the patents (e.g., Compl. ¶21, ¶30).
  • Willful Infringement: The complaint alleges that its filing constitutes "notice and actual knowledge" for the defendant (e.g., Compl. ¶20, ¶29). It further alleges that "Despite such actual knowledge, Defendant continues to make, use, test, sell, offer for sale, market, and/or import" the accused products, forming a basis for post-filing willful infringement (e.g., Compl. ¶21, ¶30). No allegations of pre-suit knowledge are made.

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

  1. Evidentiary Sufficiency: As the complaint was filed without the referenced claim chart exhibits, the primary question for the case is whether Cedar Lane can produce technical evidence—likely from product teardowns or testing—that is sufficient to prove the internal operations of Teledyne's products meet the specific limitations of the asserted claims.
  2. Technical Applicability: For the '261 and '223 patents, a core issue will be whether the "Virtual Reality Camera" technology, described for creating panoramic visual images, can be read onto the accused "Xineos X-Ray Image Reconstruction Technology." The court will have to determine if there is a fundamental mismatch in the technological field and application.
  3. Claim Construction: The dispute will likely turn on the construction of key functional terms. A central question will be one of functional equivalence: does the general-purpose data buffering and signaling within the accused Genie cameras perform the specific, narrowly-defined functions required by the claims of the '527 and '790 patents, or is there a material difference in their technical operation?