DCT
1:22-cv-01406
Cedar Lane Tech Inc v. Vantage Robotics LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Cedar Lane Technologies Inc. (Canada)
- Defendant: Vantage Robotics, LLC (Delaware)
- Plaintiff’s Counsel: Napoli Shkolnik LLC; Rabicoff Law LLC
- Case Identification: 1:22-cv-01406, D. Del., 10/26/2022
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation and has committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe patents related to a hardware interface for managing the transfer of data from an imaging array to a processor system.
- Technical Context: The technology concerns a specialized interface on an image sensor chip that buffers image data, mediating between the sensor's constant data stream and a processor's on-demand access, a foundational process in in digital imaging devices.
- Key Procedural History: U.S. Patent No. 8,537,242 is a divisional of the application that resulted in U.S. Patent No. 6,972,790. The '242 patent is subject to a terminal disclaimer over the '790 patent, which may be relevant to the scope of recoverable damages. The complaint does not mention any other prior litigation, licensing history, or administrative proceedings involving the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2000-01-21 | Earliest Priority Date for '790 & '242 Patents |
| 2000-12-21 | '790 Patent Application Filed |
| 2005-10-27 | '242 Patent Application Filed |
| 2005-12-06 | '790 Patent Issued |
| 2013-09-17 | '242 Patent Issued |
| 2022-10-26 | Complaint Filed |
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 a fundamental incompatibility between the "video style output" of conventional IC image sensors and the data interface of commercial microprocessors, which are designed to randomly access data in memory (Compl. ¶9; ’790 Patent, col. 1:38-54). This mismatch requires "additional glue logic," which undermines the cost and integration benefits of using CMOS imaging technology (’790 Patent, col. 1:47-54).
- The Patented Solution: The invention proposes an on-chip interface that receives data from the imaging array, stores it in a local memory (such as a FIFO buffer), and then transfers that data to the main processor system at a rate determined by the processor, not the sensor (’790 Patent, Abstract). The interface includes a signal generator that alerts the processor, for instance via an interrupt, when a sufficient quantity of data has been buffered and is ready for transfer (’790 Patent, col. 2:4-14, Fig. 2).
- Technical Importance: This architecture decouples the image sensor's rigid, high-speed data generation from the processor's more flexible, task-driven data consumption, thereby simplifying system design and more fully realizing the integration potential of CMOS sensors (’790 Patent, col. 1:60-67).
Key Claims at a Glance
- The complaint does not identify specific asserted claims, instead referencing "Exemplary '790 Patent Claims" in an external exhibit not attached to the complaint (Compl. ¶12, ¶17). Independent claim 1 is representative of the invention's scope.
- Independent Claim 1: An interface 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.
U.S. Patent No. 8,537,242 - Host interface for imaging arrays, issued September 17, 2013
The Invention Explained
- Problem Addressed: The '242 patent addresses the same technical problem as its parent '790 patent: the incompatibility between an image sensor's continuous data stream and a microprocessor's address-based data access (Compl. ¶10; ’242 Patent, col. 1:35-50).
- The Patented Solution: This patent claims a method for processing imaging signals, rather than the interface apparatus itself. The method involves the steps of receiving and storing image data in a FIFO memory, using a counter to track the amount of stored data, comparing that count to a predefined limit, and, based on that comparison, generating an interrupt signal to the processor to initiate the data transfer (’242 Patent, Abstract, Claim 1).
- Technical Importance: By claiming the operational method, the patent protects the specific sequence of actions performed by the interface, complementing the apparatus claims of the parent patent and capturing the dynamic aspect of the invention (’242 Patent, col. 2:1-10).
Key Claims at a Glance
- The complaint does not identify specific asserted claims, referring to "Exemplary '242 Patent Claims" in an external exhibit not attached to the complaint (Compl. ¶21, ¶26). Independent claim 1 is representative.
- Independent Claim 1: A method comprising the steps of:
- 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;
- 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; and
- transferring the image data from the FIFO memory to the processor in response to the interrupt signal.
III. The Accused Instrumentality
Product Identification
- The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are purportedly detailed in external claim chart exhibits, which were not filed with the complaint (Compl. ¶12, ¶21).
Functionality and Market Context
- The complaint does not provide any description of the technical functionality, features, or market context of the accused products. It makes only conclusory allegations that the products practice the claimed technology (Compl. ¶17, ¶26). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint does not contain claim charts or specific factual allegations detailing infringement. It incorporates charts by reference to Exhibits 3 and 4, which were not provided with the filed complaint (Compl. ¶18, ¶27). The following summary is based on the representative independent claims and the complaint's general allegations.
'790 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a memory for storing imaging array data and clocking signals at a rate determined by the clocking signals | The complaint alleges, without providing specific facts, that the accused products contain a memory that performs this function. | ¶17 | col. 2:7-9 |
| a signal generator for generating a signal...in response to the quantity of data in the memory | The complaint alleges, without providing specific facts, that the accused products contain a signal generator that performs this function. | ¶17 | col. 2:9-12 |
| a circuit for controlling the transfer of the data from the memory at a rate determined by the processor system | The complaint alleges, without providing specific facts, that the accused products contain a control circuit that performs this function. | ¶17 | col. 2:12-14 |
'242 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving image data from an imaging array; | The complaint alleges, without providing specific facts, that the accused products perform this method step. | ¶26 | col. 7:56-57 |
| storing the image data in a FIFO memory; | The complaint alleges, without providing specific facts, that the accused products perform this method step. | ¶26 | col. 7:58-59 |
| updating a FIFO counter to maintain a count of the image data...; | The complaint alleges, without providing specific facts, that the accused products perform this method step. | ¶26 | col. 7:60-63 |
| comparing the count of the FIFO counter with a FIFO limit; | The complaint alleges, without providing specific facts, that the accused products perform this method step. | ¶26 | col. 7:64 |
| generating an interrupt signal to request a processor to transfer image data...; | The complaint alleges, without providing specific facts, that the accused products perform this method step. | ¶26 | col. 8:1-6 |
| transferring image data from the FIFO memory to the processor...; | The complaint alleges, without providing specific facts, that the accused products perform this method step. | ¶26 | col. 8:7-8 |
- Identified Points of Contention:
- Scope Questions: A central question will concern the definition of the claimed "interface." The patent describes a dedicated hardware block integrated on the same die as the image sensor (’790 Patent, col. 2:25-30). The dispute may focus on whether this term can be construed to read on a more generalized, software-based data management system that might be present in a modern device.
- Technical Questions: Due to the lack of factual allegations, a primary technical question is what evidence exists that the accused products actually contain a dedicated "signal generator" that operates "in response to the quantity of data," as required by claim 1 of the '790 patent. Similarly, for the '242 patent, it is an open question whether the accused products perform the specific, ordered method steps of updating a counter, comparing it to a limit, and then generating an interrupt, or if they use a different logical process for data transfer.
V. Key Claim Terms for Construction
The Term: "signal generator"
Context and Importance: This term is critical because it requires a specific causal link: the generator must act "in response to the quantity of data in the memory" ('790 Patent, cl. 1). Practitioners may focus on this term because its construction will determine whether a general-purpose processor polling a memory buffer falls within the claim, or if a more specific, dedicated hardware trigger is required.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "signal generator" is not explicitly defined, which may support an argument for its plain and ordinary meaning, potentially encompassing any component (hardware or software) that produces a signal to initiate data transfer.
- Evidence for a Narrower Interpretation: The specification's only detailed embodiment shows a specific "Interrupt Generator" (48) that functions by comparing a FIFO counter's output to a pre-set limit value (’790 Patent, Fig. 2; col. 6:11-17). This could support a narrower construction limited to a hardware comparator circuit that actively monitors the buffer's fill level.
The Term: "memory"
Context and Importance: The type and implementation of the "memory" is a core component of the claimed interface. Its construction is important for determining whether the claims are limited to specific on-chip hardware buffers or can read on more general system memory.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the "memory may be a first-in first-out (FIFO) buffer or an addressable memory" (’790 Patent, col. 2:12-14). This explicit alternative could support a construction that is not limited to one specific type of memory architecture.
- Evidence for a Narrower Interpretation: The preferred embodiment heavily details a FIFO buffer constructed from a "shift register series" (’790 Patent, Fig. 5; col. 5:11-14). An argument could be made that the invention's contribution is this specific, efficient hardware implementation, suggesting the term should be construed in light of this detailed disclosure rather than covering any generic memory.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement for both patents, asserting that Defendant distributes "product literature and website materials" that instruct end users to operate the products in a manner that infringes the claims (Compl. ¶15, ¶24). However, it refers to external exhibits, not provided, for evidentiary support.
- Willful Infringement: The complaint alleges that Defendant has had "actual knowledge" of infringement since, at the latest, the service of the complaint (Compl. ¶14, ¶23). It further alleges that Defendant's continued infringement "despite such actual knowledge" provides a basis for enhanced damages (Compl. ¶15, ¶24). The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285 (Compl. Prayer ¶G.i).
VII. Analyst’s Conclusion: Key Questions for the Case
- Evidentiary Sufficiency: The complaint's primary characteristic is its lack of factual detail regarding the accused products. A threshold issue for the case will be what evidence Plaintiff can produce to substantiate its conclusory allegations that the accused products, once identified, actually contain the specific hardware architecture of the '790 patent or perform the precise method steps of the '242 patent.
- Definitional Scope: The case will likely turn on a question of claim construction: can the patent term "interface," which is described in the specification as a discrete, integrated hardware block, be interpreted to cover the potentially more software-centric data handling solutions found in modern electronics? The outcome may depend on whether the accused functionality is achieved by the specific structures disclosed in the patents or by a general-purpose processor executing software instructions.
- Patent Family Damages: With claims asserted from both a parent patent and a divisional patent subject to a terminal disclaimer, a key legal question will concern damages. The parties and the court will need to address how to properly apportion or limit damages to avoid the potential for impermissible double recovery for infringement of two patents protecting the same core invention.