Cedar Lane Tech Inc v. BAE Systems Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: BAE Systems, Inc. (Delaware)
  • Plaintiff’s Counsel: Gawthrop Greenwood, PC; Rabicoff Law LLC
• Case Identification: 1:21-cv-01759, D. Del., 12/16/2021
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is incorporated in Delaware and has an established place of business in the District.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe two patents related to an interface for transferring data from an image sensor to a processor system.
• Technical Context: The patents address the technical challenge of efficiently managing data flow between high-speed image sensors and general-purpose computer processors, a fundamental issue in digital imaging systems.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patents-in-suit. U.S. Patent No. 8,537,242 is a divisional of the application that resulted in U.S. Patent No. 6,972,790.

Case Timeline

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

U.S. Patent No. 6,972,790 - "Host interface for imaging arrays," Issued December 6, 2005

The Invention Explained

• Problem Addressed: The patent’s background section describes an incompatibility between the continuous, high-speed "video style output" of integrated circuit image sensors and the data interface of commercial microprocessors, which are designed for random access to memory. This mismatch requires "additional glue logic" and interface circuitry, diminishing the cost and integration benefits of CMOS imaging technology (’790 Patent, col. 1:38-53).
• The Patented Solution: The invention proposes an integrated interface on the same semiconductor die as the image sensor. This interface uses an on-chip memory, such as a First-In First-Out (FIFO) buffer, to receive data at the sensor's rate and store it. The interface then signals a host processor system when a certain amount of data is available, allowing the processor to read the data from the memory at its own rate, thereby decoupling the two systems (’790 Patent, col. 2:4-14; Fig. 2). This architecture aims to eliminate the need for external interface components.
• Technical Importance: This approach facilitates the creation of more compact and cost-effective "system-on-a-chip" digital cameras and imaging devices by integrating the sensor, data buffer, and processor interface onto a single piece of silicon (’790 Patent, col. 1:29-33).

Key Claims at a Glance

• The complaint asserts at least claim 1 of the ’790 Patent (Compl. ¶12).
• Independent Claim 1:
  • An interface for receiving data from an image sensor having an imaging array and a clock generator for transfer to a processor system comprising:
  • a memory for storing imaging array data and clocking signals at a rate determined by the clocking signals;
  • a signal generator for generating a signal for transmission to the processor system in response to the quantity of data in the memory; and
  • a circuit for controlling the transfer of the data from the memory at a rate determined by the processor system.
• The complaint does not explicitly reserve the right to assert dependent claims but refers to infringement of "one or more claims" (Compl. ¶12).

U.S. Patent No. 8,537,242 - "Host interface for imaging arrays," Issued September 17, 2013

The Invention Explained

• Problem Addressed: As a divisional of the ’790 Patent, the ’242 Patent addresses the same fundamental problem of mediating data transfer between an image sensor and a host processor (’242 Patent, col. 1:39-54).
• The Patented Solution: The ’242 Patent claims a method of operating the interface described in the ’790 Patent. The claimed method involves storing image data in a FIFO memory, using a counter to track the amount of data in the memory, comparing that count to a predetermined limit, and generating an interrupt signal for the processor when the limit is reached. This allows the processor to be notified and initiate a data transfer (’242 Patent, col. 7:56-col. 8:2).
• Technical Importance: This method provides a specific, event-driven protocol for managing the data buffer, allowing the host processor to perform other tasks until a sufficient amount of image data has been captured and is ready for processing (’242 Patent, col. 6:3-8).

Key Claims at a Glance

• The complaint asserts at least claim 1 of the ’242 Patent (Compl. ¶21).
• Independent Claim 1:
  • A method of processing imaging signals, the method comprising:
  • receiving image data from an imaging array;
  • storing the image data in a FIFO memory;
  • updating a FIFO counter to maintain a count of the image data in the FIFO memory in response to memory reads and writes;
  • comparing the count of the FIFO counter with a FIFO limit;
  • generating an interrupt signal to request a processor to transfer image data from the FIFO memory in response to an interrupt enable signal being valid and the count of the FIFO counter having a predetermined relationship to the FIFO limit; and
  • transferring image data from the FIFO memory to the processor in response to the interrupt signal.
• The complaint refers to infringement of "one or more claims" of the ’242 Patent (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

• The complaint does not specifically name any accused products. It refers generally to "Exemplary Defendant Products" that are identified in claim charts attached as Exhibits 3 and 4 (Compl. ¶12, ¶21). These exhibits were not filed with the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It alleges in a conclusory manner that the unspecified products "practice the technology claimed" by the patents-in-suit (Compl. ¶17, ¶26).

IV. Analysis of Infringement Allegations

The complaint does not contain substantive infringement allegations in its body. Instead, it incorporates by reference claim chart exhibits (Exhibits 3 and 4) that were not included with the filed pleading (Compl. ¶18, ¶27). The complaint alleges that these charts demonstrate how the "Exemplary Defendant Products satisfy all elements of the Exemplary [...] Patent Claims" (Compl. ¶17, ¶26). Without these exhibits, a detailed analysis of the infringement theory is not possible based on the complaint alone.

• Identified Points of Contention:
  • Evidentiary Questions: A primary question will be what evidence Plaintiff provides to show that the unnamed "Exemplary Defendant Products" perform each step of the asserted claims. The complaint's reliance on external, unfiled documents for its core allegations suggests that the factual basis for infringement will be a central point of discovery and dispute.
  • Scope Questions (’790 Patent): The infringement analysis may turn on the scope of several terms. A key question is whether the accused products contain a "memory for storing imaging array data and clocking signals" that operates as claimed, and a "signal generator" that generates a signal "in response to the quantity of data in the memory" (’790 Patent, col. 8:7-14). The dispute could focus on whether the accused architecture directly maps onto this claimed structure.
  • Technical Questions (’242 Patent): For the method claims of the ’242 Patent, a central issue may be whether the accused products perform the specific step of "generating an interrupt signal [...] in response to an interrupt enable signal being valid and the count of the FIFO counter having a predetermined relationship to the FIFO limit" (’242 Patent, col. 8:62-67). The analysis will require a technical examination of the logic and conditions under which the accused products notify a processor about available data.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

For the ’790 Patent:

• The Term: "a signal generator for generating a signal for transmission to the processor system in response to the quantity of data in the memory"
• Context and Importance: This term is critical because it defines the mechanism that bridges the image sensor's data buffer with the host processor. The definition will determine what kind of notification or signaling mechanism in an accused product meets this limitation. Practitioners may focus on this term because modern systems use varied and complex signaling protocols, and the correspondence between an accused protocol and this claim language could be a central point of dispute.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is functional and does not specify the type of signal (e.g., interrupt, bus request). The specification discloses multiple embodiments, including an "interrupt generator" (Fig. 2) and a "bus request generator" (Fig. 7), which may support a construction that covers any signal serving the claimed function of alerting the processor system (’790 Patent, col. 2:14-18).
  • Evidence for a Narrower Interpretation: The detailed description repeatedly frames the signal in the context of specific hardware signals. For instance, it describes an "interrupt generator 48" that "asserts the interrupt signal Sᵢ to the CPU 10 via the interrupt bus 17" (’790 Patent, col. 5:12-15). An argument could be made that the term should be limited to the types of direct hardware signals disclosed, such as interrupts or bus requests, rather than higher-level software notifications.

For the ’242 Patent:

• The Term: "updating a FIFO counter to maintain a count of the image data"
• Context and Importance: This step defines how the system tracks the buffer's status. Its construction is important for determining whether an accused device that tracks data quantity through a different mechanism (e.g., pointers, status flags) infringes. The dispute will likely focus on whether "updating a FIFO counter" requires a literal hardware counter that increments and decrements, or if it can cover any logical process that achieves the same result.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The purpose of the step is to "maintain a count." An argument could be made that any mechanism that logically tracks the quantity of data in the buffer meets the spirit of this limitation, even if it is not a dedicated, incrementing hardware counter. The claim requires the function of maintaining a count, not necessarily a specific structure for doing so.
  • Evidence for a Narrower Interpretation: The specification discloses a specific embodiment: an "increment/decrement counter 54 is used to count the occurrences of FIFO buffer 44 writes and FIFO buffer 44 reads" (’242 Patent, col. 5:17-20; Fig. 5). This explicit disclosure of a structural counter could be used to argue that the claim term should be construed more narrowly to require a similar implementation, rather than any abstract method of tracking data quantity.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents. The basis for inducement is the allegation that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a way that infringes (Compl. ¶15, ¶24).
• Willful Infringement: The complaint alleges knowledge of infringement "at least since being served by this Complaint" (Compl. ¶16, ¶25). This framing suggests the willfulness claim is based on alleged post-suit conduct rather than pre-suit knowledge. The complaint asserts that service of the complaint itself provides "actual knowledge" (Compl. ¶14, ¶23).

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

1. An Evidentiary Question of Infringement: Given that the complaint's infringement allegations are made entirely through conclusory statements and incorporation of unfiled exhibits, a central question will be whether Plaintiff can produce sufficient technical evidence to demonstrate that the accused products actually perform the specific functions and possess the structures required by each element of the asserted claims.
2. A Question of Definitional Scope: The case may turn on claim construction, specifically whether the term "signal generator" (’790 Patent) is broad enough to cover modern, potentially software-driven, notification systems, or if it is limited to the specific hardware-level interrupt and bus request signals disclosed in the specification.
3. A Question of Functional Equivalence: For the method claims of the ’242 Patent, a key issue will be whether the accused products' method for tracking data in a buffer is equivalent to "updating a FIFO counter." The dispute will likely center on whether a literal counter structure is required, or if any logical process that maintains a data count suffices.