Cedar Lane Tech Inc v. Boston Dynamics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Boston Dynamics, Inc. (Delaware)
  • Plaintiff’s Counsel: Napoli Shkolnik LLC; Rabicoff Law LLC
• Case Identification: 1:22-cv-01410, D. Del., 10/26/2022
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in Delaware, has an established place of business in the District, has committed alleged acts of infringement in the District, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe two patents related to an interface for transferring data from a digital image sensor to a processor system.
• Technical Context: The patents address methods for efficiently managing the flow of data from a constantly-running image sensor to a host processor, a fundamental challenge in digital imaging systems from cameras to robotics.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit. U.S. Patent No. 8,537,242 is a divisional of the application that led to U.S. Patent No. 6,972,790.

Case Timeline

Date	Event
2000-01-21	Priority Date for '790 and '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 states that image sensors, particularly CMOS sensors, traditionally produce a continuous, video-style stream of pixel data. This output is described as "incompatible with the data interface of commercial microprocessors" without requiring "additional glue logic," which diminishes the cost and integration benefits of CMOS technology (ʼ790 Patent, col. 1:46-54). A processor in such a system cannot "directly receive imaging data" in a way that aligns with its own processing schedule (ʼ790 Patent, col. 1:64-67).
• The Patented Solution: The invention proposes an interface, preferably integrated onto the same semiconductor die as the image sensor, to act as an intermediary ('790 Patent, col. 2:25-33). This interface uses a memory, such as a First-In First-Out (FIFO) buffer, to temporarily store image data as it arrives from the sensor ('790 Patent, Abstract). A signal generator then monitors the amount of data in the memory and, when a certain threshold is reached, sends a signal (e.g., an interrupt) to the host processor, which can then read the data from the memory at its own pace ('790 Patent, col. 2:7-14). This decouples the fixed data rate of the sensor from the asynchronous access needs of the processor.
• Technical Importance: This architecture allows a general-purpose processor to multitask and handle other operations, only servicing the image sensor when a significant chunk of data is ready, rather than being continuously occupied with managing a real-time data stream ('790 Patent, col. 6:15-19).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" and "Exemplary '790 Patent Claims" but does not specify them in the body of the complaint (Compl. ¶12). Claim 1 is the first independent apparatus claim.
• Independent Claim 1:
  • An interface for receiving data from an image sensor... and 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.

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 technical problem: the mismatch between the continuous data output of a CMOS image sensor and the data input requirements of a general-purpose microprocessor ('242 Patent, col. 1:42-53).
• The Patented Solution: The '242 patent claims a method of processing imaging signals that embodies the same operational concept as the '790 patent's interface. The claimed method involves 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 then generating an interrupt signal to a processor to initiate a data transfer ('242 Patent, col. 8:56-68).
• Technical Importance: This method provides a defined process for implementing the '790 patent's system, allowing a processor to efficiently acquire image data without being locked to the sensor's clock cycle ('242 Patent, col. 6:1-5).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" and "Exemplary '242 Patent Claims" but does not specify them (Compl. ¶21). Claim 1 is the first independent method claim.
• 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 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... 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 does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers to "at least the Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')" (Compl. ¶12, ¶21). However, the referenced exhibits containing these charts (Exhibits 3 and 4) were not filed with the complaint.

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed" by the patents and "satisfy all elements" of the exemplary claims (Compl. ¶17, ¶26). It also alleges that Defendant's employees "internally test and use these Exemplary Products" (Compl. ¶13, ¶22). The complaint does not provide any specific details about the functionality, operation, or market context of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim chart exhibits (Exhibits 3 and 4) that were not provided with the public filing (Compl. ¶18, ¶27). The complaint's narrative infringement theory is limited to the conclusory statement that the "Exemplary Defendant Products practice the technology claimed" and "satisfy all elements of the Exemplary... Patent Claims" (Compl. ¶17, ¶26). Without the claim charts or more detailed factual allegations, a summary table cannot be constructed.

Identified Points of Contention

• Factual Basis: A primary question will be what evidence Plaintiff can marshal to show that Defendant’s products—once identified—actually contain the specific components or perform the specific methods required by the claims. The complaint itself provides no such evidence.
• Technical Questions ('790 Patent): Does an accused product contain a dedicated "interface" with a "memory," a "signal generator," and a "circuit" that operate as distinct logical or physical components corresponding to the claim elements? For example, does the system generate a signal "in response to the quantity of data in the memory," or does it use another trigger mechanism?
• Scope Questions ('242 Patent): Do the accused products perform the specific steps of "updating a FIFO counter" and "comparing the count... with a FIFO limit"? The dispute may center on whether the accused products' buffer management architecture, whatever it may be, can be characterized as performing these exact method steps, or if it achieves a similar result through a technically different process.

V. Key Claim Terms for Construction

For the '790 Patent:

• The Term: "interface" (Claim 1)

• Context and Importance: The patent’s claims are directed to an "interface." The definition of this term will be critical to determining what constitutes an infringing apparatus. Practitioners may focus on this term because its scope—whether it is limited to a single, integrated hardware component or can cover functionality distributed across software and multiple hardware components—will be central to the infringement analysis.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims describe the interface functionally, in terms of what it comprises (a memory, a signal generator, a circuit) and what it does (receives data, stores it, generates a signal, controls transfer), which may support a construction not strictly limited to a single physical structure.
  • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes the benefit of integrating the interface "on the same die as the image sensor" ('790 Patent, col. 2:29-30, col. 3:27-29). This could be used to argue that the invention is tied to a physically co-located, hardware-based implementation distinct from the main processor.

• The Term: "memory for storing imaging array data and clocking signals" (Claim 1)

• Context and Importance: This limitation requires the memory to store not only pixel data but also "clocking signals." Whether the accused products' memories are configured to do this will be a key factual question.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language does not specify how the signals must be stored. An argument could be made that any form of storage, including embedding timing information as metadata within a data packet, satisfies this limitation.
  • Evidence for a Narrower Interpretation: The specification describes bundling the image data output, row clock, and frame clock "onto a single bus... for storage in the buffer" ('790 Patent, col. 5:11-14). This could support an argument that the claim requires the literal clock signals themselves, or direct representations thereof, to be stored alongside the pixel data.

For the '242 Patent:

• The Term: "updating a FIFO counter to maintain a count of the image data" (Claim 1)
• Context and Importance: This term recites a specific mechanism for buffer management. The infringement analysis for this method claim will hinge on whether the accused system uses a "counter" that is "updated" in response to reads and writes.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff might argue that any software or hardware mechanism that tracks the fill level of a buffer—such as by monitoring read/write pointers and calculating the difference—is equivalent to "updating a... counter to maintain a count."
  • Evidence for a Narrower Interpretation: The patent depicts a specific "increment/decrement counter" (element 54) that directly counts write and read events ('242 Patent, Fig. 5; col. 5:17-21). A defendant could argue this implies a specific hardware or logical implementation that is distinct from other buffer management schemes.

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 on how to use the products in an infringing manner (Compl. ¶15, ¶24). Knowledge for inducement is alleged to exist "at least since being served by this Complaint" (Compl. ¶16, ¶25).
• Willful Infringement: Willfulness is predicated on Defendant’s alleged continuation of infringing activities despite having "actual knowledge" of the patents from the service of the complaint (Compl. ¶14-15, ¶23-24). The prayer for relief requests a finding that the case is exceptional under 35 U.S.C. § 285 (Compl. ¶G.i).

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

1. Evidentiary Sufficiency: The central threshold question is whether the plaintiff's infringement theories, currently contained entirely within unfiled exhibits, can be substantiated with specific factual evidence mapping features of identified Boston Dynamics products to the discrete elements of the patent claims. The current complaint's lack of specificity may itself become a focus of early disputes.
2. Technical Equivalence: A core technical question will be whether the sophisticated imaging and data-processing systems in modern robotics operate in the specific manner claimed by these 20-year-old patents. The case will likely turn on whether the accused systems use a "counter" and "interrupt" mechanism as claimed, or if they employ a more advanced, structurally different architecture for managing data flow from sensors to processors.
3. Claim Scope and Modern Systems: A key legal issue will be one of definitional scope: can the term "interface," as described in a patent from the year 2000 focused on single-chip integration, be construed to read on the potentially distributed, software-heavy processing architectures of complex modern robots? The outcome may depend on whether the claims are interpreted as being tied to their described embodiments or are broad enough to cover later-developed technologies that solve the same general problem.