DCT
1:22-cv-01407
Cedar Lane Tech Inc v. Teal Drones Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Cedar Lane Technologies Inc. (Canada)
- Defendant: Teal Drones, Inc. (Delaware)
- Plaintiff’s Counsel: Napoli Shkolnik LLC
- Case Identification: 1:22-cv-01407, D. Del., 10/26/2022
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation with an established place of business in the district, has allegedly committed acts of infringement there, and has caused Plaintiff harm in the district.
- Core Dispute: Plaintiff alleges that Defendant’s drone products infringe two patents related to a host interface for managing the transfer of data from an imaging array to a processor system.
- Technical Context: The technology addresses the incompatibility between the fixed-rate data output of image sensors and the variable-rate data processing capabilities of microprocessors by using an on-chip buffer.
- Key Procedural History: The '242 Patent is a divisional of the application that resulted in the '790 Patent. The complaint asserts that its service provides Defendant with actual knowledge of infringement, forming the basis for allegations of post-suit induced and willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2000-01-21 | '790 and '242 Patents Priority Date |
| 2000-12-21 | '790 Patent Application Filing Date |
| 2005-10-27 | '242 Patent Application Filing Date |
| 2005-12-06 | '790 Patent Issue Date |
| 2013-09-17 | '242 Patent Issue Date |
| 2022-10-26 | Complaint Filing Date |
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 how the "video style output" of conventional CMOS image sensors, which provide a constant stream of pixel data, is incompatible with the data interfaces of commercial microprocessors that access data asynchronously. This mismatch traditionally required "additional glue logic," diminishing the cost and integration benefits of CMOS technology (ʼ790 Patent, col. 1:46-67).
- The Patented Solution: The invention proposes an on-chip interface that sits between the imaging array and the host processor system. This interface uses a memory, such as a First-In First-Out (FIFO) buffer, to store image data from the sensor. This buffer decouples the sensor's fixed data-capture rate from the processor's data-access rate. The interface includes a signal generator that alerts the processor when a sufficient quantity of data has been stored, allowing the processor to then read the data from the buffer at its own pace (ʼ790 Patent, col. 2:3-14; Fig. 2).
- Technical Importance: This design allows for a more direct and efficient connection between an image sensor and a processor, enabling more compact and cost-effective system-on-a-chip (SoC) implementations for devices like digital cameras (ʼ790 Patent, col. 1:26-31).
Key Claims at a Glance
- The complaint asserts infringement of one or more claims, including at least those identified in an exhibit not publicly filed with the complaint (Compl. ¶12). Independent claim 1 is representative of the apparatus claims.
- Independent Claim 1: An interface for transferring data from an image sensor 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 reserves the right to assert additional claims, including dependent 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's application, the '242 Patent addresses the same problem of reconciling the different data rates of image sensors and host processors ('242 Patent, col. 1:43-54).
- The Patented Solution: The '242 Patent claims a method for processing imaging signals using the interface architecture. The method involves receiving and storing image data in a FIFO memory, using a counter to track the amount of data in that memory, comparing the count to a predetermined limit, and then generating an interrupt signal to the processor to initiate a data transfer when that limit is reached ('242 Patent, col. 8:55-68, Claim 1). This process is illustrated in the interaction between the FIFO buffer (44), its counter (54), and the interrupt generator (48) shown in Figure 2 of the patent.
- Technical Importance: This method provides a specific algorithm for managing the data buffer, which can reduce processor overhead and ensure efficient data handling in real-time imaging applications ('242 Patent, col. 6:1-12).
Key Claims at a Glance
- The complaint asserts infringement of one or more claims, including at least those identified in an exhibit not publicly filed with the complaint (Compl. ¶21). Independent claim 1 is representative of the method claims.
- Independent Claim 1: A method of processing imaging signals, 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 data in response to the count having a predetermined relationship to the limit; and
- transferring the data from the FIFO memory to the processor.
- The complaint reserves the right to assert additional claims (Compl. ¶21).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" made, used, and sold by Teal Drones, Inc. (Compl. ¶1, ¶12). The specific product models are identified in exhibits that were not filed on the public docket (Compl. ¶17).
Functionality and Market Context
- The complaint alleges that the accused drone products "practice the technology claimed by the '790 Patent" and "'242 Patent" (Compl. ¶17, ¶26). However, the complaint provides no specific technical details regarding the internal architecture or operation of the accused products' image processing systems. The allegations rely entirely on claim chart exhibits which are incorporated by reference but not publicly available (Compl. ¶18, ¶27). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint references but does not include the claim chart exhibits (Exhibits 3 and 4) that detail its infringement theories. The analysis below is based on the asserted claims and the complaint's general allegations incorporating those exhibits.
'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 the accused products include a memory for storing image data received from an image sensor (Compl. ¶17). | ¶17, ¶18 | col. 7:55-58 |
| a signal generator for generating a signal for transmission to the processor system... | The complaint alleges the accused products contain a signal generator that sends a signal to the system's processor (Compl. ¶17). | ¶17, ¶18 | col. 8:8-10 |
| ...in response to the quantity of data in the memory | The complaint alleges the signal is generated based on the amount of image data stored in the memory (Compl. ¶17). | ¶17, ¶18 | col. 8:10-12 |
| a circuit for controlling the transfer of the data from the memory at a rate determined by the processor system | The complaint alleges the products have a control circuit that manages the data transfer from the memory to the processor (Compl. ¶17). | ¶17, ¶18 | col. 8:13-16 |
- Identified Points of Contention:
- Technical Questions: Since the complaint offers no public evidence, a central question is whether discovery will reveal that the accused drones actually contain the specific architecture claimed. Plaintiff will need to demonstrate that the drones' processors are alerted to new image data via a signal that is specifically triggered by the buffer's fill level, rather than by another timing mechanism.
- Scope Questions: The dispute may turn on whether the accused drones' components, which may be standard off-the-shelf parts, collectively constitute the claimed integrated "interface."
'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 the accused products receive image data from an imaging array as part of their normal operation (Compl. ¶26). | ¶26, ¶27 | col. 4:10-14 |
| storing the image data in a FIFO memory; | The complaint alleges the accused products store this image data in a FIFO-type memory (Compl. ¶26). | ¶26, ¶27 | col. 5:6-10 |
| updating a FIFO counter to maintain a count of the image data... | The complaint alleges the accused products use a counter to track the amount of data in the memory (Compl. ¶26). | ¶26, ¶27 | col. 5:18-21 |
| generating an interrupt signal...in response to...the count of the FIFO counter having a predetermined relationship to the FIFO limit | The complaint alleges the products generate an interrupt when the data count reaches a set limit (Compl. ¶26). | ¶26, ¶27 | col. 6:11-17 |
| transferring the image data from the FIFO memory to the processor in response to the interrupt signal | The complaint alleges the products transfer the stored data to a processor after the interrupt is generated (Compl. ¶26). | ¶26, ¶27 | col. 6:30-37 |
- Identified Points of Contention:
- Technical Questions: A key evidentiary hurdle will be proving the existence and operation of the claimed "FIFO counter" and its comparison to a "FIFO limit." Plaintiff must show that the accused method uses this specific logic, rather than an alternative buffering scheme.
- Scope Questions: The analysis will question whether the sequence of operations performed by the accused drones' software and hardware constitutes the specific, ordered steps of the claimed method.
V. Key Claim Terms for Construction
The Term: "interface"
- Context and Importance: This term defines the overall apparatus. Its construction is critical because it will determine whether a collection of discrete hardware and software components within the accused drones can be considered the single, integrated "interface" taught by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The Summary of the Invention describes the invention functionally as "an interface for receiving data from an image sensor... and for transferring the data to a processor system" ('790 Patent, col. 2:3-6), which may support a construction not strictly limited by a particular physical arrangement.
- Evidence for a Narrower Interpretation: The specification repeatedly emphasizes a key benefit is integrating the interface "on the same die as the image sensor" ('790 Patent, col. 2:29-31). A defendant may argue this preference for a system-on-a-chip (SoC) design limits the term to single, integrated semiconductor circuits.
The Term: "in response to the quantity of data in the memory"
- Context and Importance: This limitation from claim 1 of the '790 patent requires a specific causal relationship. Infringement requires proof that the signal to the processor is triggered by the data level in the buffer, not by another event like a timer. Practitioners may focus on this term because it goes to the heart of the claimed control mechanism.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify the mechanism of the response, potentially allowing for any system where the signal generation is logically dependent on the data quantity.
- Evidence for a Narrower Interpretation: The detailed description discloses a specific embodiment where an "interrupt generator 48 compares the FIFO counter output Sc and the FIFO limit SL" and asserts the signal if the count is greater than or equal to the limit ('790 Patent, col. 6:11-15). This could support a narrower construction requiring a direct comparison to a threshold.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement based on Defendant's distribution of "product literature and website materials" that allegedly instruct end users to operate the accused drones in a manner that infringes the patents (Compl. ¶15, ¶24).
- Willful Infringement: The complaint bases its willfulness allegations on knowledge obtained by Defendant "at least since being served by this Complaint" (Compl. ¶16, ¶25). This framing supports a claim for post-suit willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A Core Evidentiary Question: What is the actual internal architecture of the accused drones? The complaint lacks any public-facing technical evidence, meaning the case will hinge on information revealed in discovery about how the drones' hardware and software manage the flow of data from their image sensors to their processors.
- A Definitional Scope Question: Can the term "interface", which the patent describes as preferably integrated onto a single semiconductor die, be construed to read on a system potentially composed of multiple discrete components within the accused drones? The outcome of this claim construction issue could be dispositive.
- A Functional Causality Question: Does the accused system's signal generator operate "in response to the quantity of data in the memory" as claimed? Establishing this specific triggering mechanism, as opposed to a different control logic (e.g., timed polling), will be a critical and fact-intensive point of proof for the plaintiff.