DCT
1:25-cv-00348
VTT Technical Research Centre Of Finland Ltd v. Teledyne FLIR LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: VTT Technical Research Centre of Finland Ltd. (Finland)
- Defendant: Teledyne FLIR, LLC (Delaware) and Teledyne Technologies Incorporated (Delaware)
- Plaintiff’s Counsel: Farnan LLP
- Case Identification: 1:25-cv-00348, D. Del., 06/25/2025
- Venue Allegations: Venue is asserted based on Defendants’ incorporation in the State of Delaware.
- Core Dispute: Plaintiff alleges that Defendants’ Boson and Boson+ thermal camera modules infringe a patent related to a bolometer circuit configuration designed to amplify signals at the sensor level.
- Technical Context: Bolometers are sensors that measure the power of incident electromagnetic radiation; they are foundational components in thermal imaging systems used in military, industrial, and security applications.
- Key Procedural History: The complaint alleges a history of pre-suit knowledge, beginning with Defendant Teledyne FLIR citing the patent-in-suit in an Information Disclosure Statement (IDS) in March 2020 during the prosecution of its own patent. This was followed by a formal notice letter from Plaintiff in June 2024, which led to correspondence between the parties that did not resolve the dispute.
Case Timeline
| Date | Event |
|---|---|
| 2007-02-16 | '369 Patent Priority Date |
| 2011-11-22 | '369 Patent Issue Date |
| 2020-03-26 | Teledyne FLIR allegedly cites '369 Patent in an IDS for its own patent |
| 2021 | Teledyne Technologies acquires Teledyne FLIR |
| 2024-06-18 | Plaintiff VTT sends formal notice letter to Defendants |
| 2024-12-24 | Plaintiff VTT sends final pre-litigation letter to Defendants |
| 2025-03-20 | Original Complaint filed |
| 2025-06-25 | First Amended Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,063,369 - "Bolometer Element, Bolometer Cell, Bolometer Camera and Method" (issued Nov. 22, 2011)
The Invention Explained
- Problem Addressed: The patent describes a central challenge in creating high-resolution thermal cameras: reading the signals from a large matrix of individual sensor elements without degrading the signal-to-noise ratio or requiring extremely complex and noisy electronics ('369 Patent, col. 2:5-15).
- The Patented Solution: The invention proposes a novel bolometer element that achieves signal amplification directly at the sensor level. This is accomplished by connecting two bolometers in series. The first bolometer senses radiation, and its heating resistance is biased by a voltage passed through the heating resistance of the second bolometer. This "resistance-biasing" configuration amplifies the detected radiation signal before it is sent to external readout circuits, providing negative feedback that stabilizes the system ('369 Patent, Abstract; col. 2:63-65).
- Technical Importance: This approach allows for the creation of more sensitive thermal imaging arrays with simplified readout electronics, making high-performance thermal cameras more practical and scalable (Compl. ¶19).
Key Claims at a Glance
- The complaint asserts infringement of at least claim 1 (Compl. ¶43).
- Independent Claim 1 requires:
- A first bolometer with a first heating resistance for sensing radiation power.
- A second bolometer with a second heating resistance.
- An electrical connection between the first and second bolometers arranged so that the first bolometer's heating resistance can be biased by a voltage through the second bolometer's heating resistance, in order to amplify the detected radiation power.
- The complaint indicates it is asserting "one or more claims," reserving the right to assert others (Compl. ¶42).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Teledyne's "Boson and Boson+ thermal camera modules," as well as any other Teledyne bolometer-based products incorporating the allegedly infringing technology (Compl. ¶42).
Functionality and Market Context
- The Boson and Boson+ products are described as longwave infrared (LWIR) thermal camera modules that utilize uncooled microbolometer arrays to detect infrared radiation and produce thermal images (Compl. ¶6). The complaint alleges these products are sold across military, industrial, and commercial sectors (Compl. ¶7). The core accused functionality is the use of "bolometer elements configured with a first and second bolometer electrically connected in such a way that the heating resistance of the first bolometer is biased through the heating resistance of the second bolometer to amplify detected radiation power" (Compl. ¶42).
IV. Analysis of Infringement Allegations
The complaint alleges that the Accused Instrumentalities incorporate the circuitry claimed in the '369 Patent. As evidence, the complaint references a figure from one of Defendants' own patents. The complaint highlights that Figure 2A of Teledyne’s U.S. Patent No. 11,012,647 ('647 patent) allegedly depicts a circuit where an active bolometer is biased through a second bolometer to amplify the detected signal (Compl. ¶30). The complaint further alleges that the Boson family of products, which are marked with the '647 patent, incorporate this circuitry (Compl. ¶30).
'369 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first bolometer having a first heating resistance for sensing radiation power directed at the element, and conductors attached to the first bolometer, for detecting electrically the radiation power directed at the element | The Accused Instrumentalities allegedly contain bolometer elements with a first bolometer that senses radiation power. | ¶42 | col. 2:58-62 |
| a second bolometer having a second heating resistance | The Accused Instrumentalities allegedly contain a second bolometer element with a heating resistance. | ¶42 | col. 2:62-63 |
| wherein the first and the second bolometers are electrically connected to each other in such a way that the heating resistance of the first bolometer can be biased with the aid of a voltage through the heating resistance of the second bolometer in order to amplify the radiation power detected with the aid of the connection | The Accused Instrumentalities allegedly connect the first and second bolometers in a configuration where the first is biased through the second to amplify the detected radiation signal. | ¶42 | col. 2:63-65 |
Identified Points of Contention
- Scope Questions: A central question may be whether the second resistive element in the accused products qualifies as a "bolometer" as that term is used in the patent, or if it is a different type of component (e.g., a simple resistor or switch) that falls outside the claim's scope.
- Technical Questions: The analysis may turn on whether the accused circuit's operation meets the functional requirement to "amplify the radiation power." The complaint notes that during pre-suit correspondence, Teledyne specifically invited VTT to clarify its position regarding this amplification function, suggesting this will be a key point of dispute (Compl. ¶31).
V. Key Claim Terms for Construction
The Term: "amplify the radiation power"
- Context and Importance: This functional limitation is the central purpose of the claimed invention. The dispute will likely focus on whether the accused devices perform this function in the manner claimed. Practitioners may focus on this term because Defendants' pre-suit communications specifically questioned Plaintiff's infringement theory regarding this function (Compl. ¶31).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification introduces the invention with the general statement that it is "based on the idea of exploiting power amplification of a bolometer when reading the signal" ('369 Patent, col. 2:31-33). This could support a construction covering any circuit that produces power gain at the sensor.
- Evidence for a Narrower Interpretation: The patent describes the specific mechanism for achieving this amplification as "resistance-biasing," which creates "negative feedback" making the system "stable" ('369 Patent, col. 2:58-65; col. 4:63-65). This could support a narrower construction limited to amplification achieved via this specific biasing technique.
The Term: "bolometer"
- Context and Importance: The claim requires both a "first bolometer" and a "second bolometer." The definition of this term is critical, as a non-infringement defense could arise if the second component in the accused circuit is not technically a "bolometer."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent provides a broad, functional definition: "a means, the thermal power absorbed by which can be measured through the detection of a change in the electrical resistance of the means (thermo-resistivity)" ('369 Patent, col. 4:34-37).
- Evidence for a Narrower Interpretation: The specification heavily emphasizes preferred embodiments using specific, advanced structures like "transition-edge superconducting (TES) bolometers" or "SIN-junction" bolometers, particularly for the second bolometer which also functions as a switch ('369 Patent, col. 4:50-54; col. 3:17-22). This might be used to argue the term implies more than a simple thermo-resistive element.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), stating that Defendants provide "website materials, instructions, datasheets, [and] promotional materials" that instruct customers and end-users on how to use the Accused Instrumentalities in an infringing manner (Compl. ¶46).
- Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge. The complaint asserts Teledyne FLIR had knowledge since at least March 26, 2020, from citing the '369 patent in an IDS for its own patent application (Compl. ¶26). It further alleges Teledyne Technologies gained knowledge upon acquiring Teledyne FLIR in 2021 (Compl. ¶27). Knowledge for both defendants is also alleged based on receipt of a formal notice letter with a claim chart on June 18, 2024 (Compl. ¶29).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of functional performance: Does the accused circuit in the Boson and Boson+ products "amplify the radiation power" in the specific manner required by Claim 1? The case may depend on evidence demonstrating not only that a signal gain exists, but that it is achieved through the "resistance biasing" mechanism described in the patent.
- Another key issue will be one of definitional scope: Does the second circuit component in the accused products meet the patent's definition of a "bolometer," or can Defendants show it is a distinct component (such as a conventional switch or resistor) that lacks the necessary thermo-resistive properties, thereby placing it outside the claim's scope?
- A significant evidentiary question may arise from the complaint's allegation that Defendants' own patent ('647 patent) discloses the infringing circuit. The degree to which the circuitry in the commercial Boson products matches the diagrams in the '647 patent will likely be a central factual dispute.