DCT

1:25-cv-00366

ImmerVision Inc v. Apple Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: ImmerVision, Inc. v. Apple Inc., 1:25-cv-00366, D. Del., 03/25/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant Apple Inc. has a regular and established place of business in the district.
  • Core Dispute: Plaintiff alleges that the ultra-wide camera lens systems in certain Apple iPhone models infringe a patent related to miniature wide-angle imaging lenses.
  • Technical Context: The technology concerns compact, high-performance, wide-angle lens assemblies designed for consumer electronics like smartphones, where physical space is highly constrained.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of U.S. Patent Application Publication No. 2023/0236391 on August 18, 2023. The complaint states the claims of this publication are "substantially identical" to those of the subsequently issued patent-in-suit. This allegation may form the basis for claims of pre-suit knowledge and enhanced damages.

Case Timeline

Date Event
2015-12-23 ’525 Patent Priority Date (earliest listed)
2019-09-20 Accused Product Launch (iPhone 11)
2020-10-23 Accused Product Launch (iPhone 12)
2021-09-24 Accused Product Launch (iPhone 13)
2022-09-16 Accused Product Launch (iPhone 14)
2023-03-28 ’525 Patent Application Filing Date
2023-07-27 Parent Application Publication Date
2023-08-18 Plaintiff allegedly notifies Defendant of patent publication
2023-09-22 Accused Product Launch (iPhone 15)
2025-03-25 ’525 Patent Issue Date
2025-03-25 Complaint Filing Date

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

U.S. Patent No. 12,259,525 - "Miniature Wide-Angle Imaging Lens" (Issued: Mar. 25, 2025)

The Invention Explained

  • Problem Addressed: The patent’s background section identifies a challenge in designing miniature wide-angle lenses for devices like smartphones. As image sensors have become larger and their pixels smaller, it has become increasingly difficult to maintain high image quality (e.g., brightness and sharpness) across the entire wide-angle field of view, particularly at the edges, while keeping the lens assembly extremely compact. (’525 Patent, col. 1:30-44, 1:56-2:6).
  • The Patented Solution: The invention claims a miniature wide-angle lens apparatus characterized by a very low "miniaturization ratio" (a measure of its compactness) and a "non-linear targeted resolution." This resolution scheme is designed to counteract the natural drop-off in image quality at the edges of a wide-angle image by using more sensor pixels to capture those areas. This effectively trades resolution in the center of the image for better overall quality across the entire frame. (’525 Patent, Abstract; col. 2:51-65). Figure 7 of the patent illustrates an exemplary non-linear resolution curve that increases from the center of the field of view towards the edge before changing direction. (’525 Patent, Fig. 7).
  • Technical Importance: This approach allows for the creation of very compact lens systems capable of capturing a wide field of view without the significant degradation in brightness or sharpness at the periphery that typically affects such designs. (’525 Patent, col. 2:10-18).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 7 and alleges damages from infringement of Claim 1. (Compl. ¶21-22). Both are independent claims.
  • Independent Claim 1:
    • A miniature wide-angle optical apparatus comprising six optical elements arranged along an optical axis.
    • A total field of view over 100°.
    • A "miniaturization ratio" with a value less than 2.0.
    • A "non-linear targeted resolution" with a magnified zone where the object to image magnification is higher compared to a linear resolution.
    • A modulation transfer function (MTF) value that is lower within the magnified zone than outside of it.
  • Independent Claim 7:
    • A miniature wide-angle optical apparatus comprising a plurality of optical elements.
    • A total field of view over 100°.
    • A "miniaturization ratio" with a value less than 2.0.
    • A "non-linear targeted resolution" with a magnified zone that includes the maximum field angle, where magnification is higher than at the center of the field of view.
    • An MTF value that is lower within the magnified zone than outside of it.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused products are the "Apple iPhone 11, 11 Pro, 11 Pro Max, 12, 12 Mini, 12 Pro, 12 Pro Max, 13, 13 Mini, 14, 14 Plus, 15, and 15 Plus smartphones." (Compl. ¶17).

Functionality and Market Context

The complaint alleges that the accused iPhones "all contain the same ultra wide lens design." (Compl. ¶20). The relevant functionality is the wide-angle camera system incorporated into these widely sold consumer smartphones. The complaint does not provide further technical details regarding the operation or construction of the accused lens systems.

IV. Analysis of Infringement Allegations

The complaint alleges that the accused iPhone models infringe at least claim 7 of the '525 Patent, referencing an "Exhibit A" to show the infringement. (Compl. ¶21). However, Exhibit A was not filed with the complaint. As such, a detailed claim chart summary cannot be constructed.

The narrative theory of infringement is that the physical construction and optical performance of the "ultra wide lens design" in the accused products meet all limitations of the asserted claims. (Compl. ¶20-21). This includes the structural arrangement of lens elements, the wide-angle field of view, the specific "miniaturization ratio" of less than 2.0, and the functional performance characteristics related to "non-linear targeted resolution" and modulation transfer function (MTF). (Compl. ¶21; ’525 Patent, cl. 7).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

  • The Term: "non-linear targeted resolution"

    • Context and Importance: This term appears to be the central inventive concept distinguishing the patent from prior art. The infringement analysis for both asserted independent claims will hinge on whether the accused iPhone camera systems implement a resolution scheme that meets the definition of this term. Practitioners may focus on this term because it is a functional limitation defined by performance characteristics (e.g., magnification, MTF) rather than purely physical structures.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the purpose of this feature is to "compensate for the drop of relative illumination" or to "compensate for the drop of MTF" at the edge of the field of view. (’525 Patent, col. 6:19-26). This could support an interpretation that covers any resolution mapping deliberately distorted from linear to improve perceived image quality at the periphery.
      • Evidence for a Narrower Interpretation: The patent describes specific embodiments, such as in Figure 7, showing a particular resolution curve that rises from the center to a maximum value and then changes direction. (’525 Patent, col. 6:35-56). A defendant may argue that the term should be limited to resolution profiles that exhibit this specific multi-part shape, rather than any non-linear profile.

  • The Term: "miniaturization ratio"

    • Context and Importance: This term provides a specific, objective, and numerical boundary (< 2.0) for the scope of the claims. The infringement determination will depend on the precise physical measurement and calculation of this ratio for the accused lenses.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The parties are unlikely to dispute the patent's explicit definition: "a ratio of the total track length divided by the image circle diameter." (’525 Patent, cl. 1). The dispute is more likely to be factual.
      • Evidence for a Narrower Interpretation: The definition is precise, but its application could be contested. The patent defines "total track length" as the distance "from the center of the first surface to the focal plane." (’525 Patent, col. 7:27-28). The parties may dispute the exact physical locations of the "first surface" and "focal plane" in the as-built accused products, which could affect the calculated ratio.

VI. Other Allegations

Willful Infringement

The complaint does not explicitly use the word "willful," but it alleges facts that may support such a claim. Plaintiff alleges it "notified Apple of the '391 Publication on August 18, 2023," which contained claims "substantially identical" to the '525 Patent. (Compl. ¶11, 13). This alleges pre-suit knowledge of the technology and pending patent rights. The prayer for relief requests a finding that the case is "exceptional" and an award of attorneys' fees, which is consistent with an allegation of willful infringement. (Compl. ¶(d)).

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

  • A key evidentiary question will be one of technical characterization: Does the physical "ultra wide lens design" in the accused iPhone models, upon measurement and testing, actually possess a "miniaturization ratio" of less than 2.0 and the specific "non-linear targeted resolution" and MTF performance profiles required by the asserted claims?
  • A core issue for claim construction will be one of definitional scope: Is the term "non-linear targeted resolution" broad enough to encompass any software or hardware-based image processing that intentionally allocates more pixels to the periphery of an image, or is it limited to the specific multi-stage resolution curve shape detailed in the patent’s preferred embodiments?
  • A third question concerns damages and intent: Did Apple have pre-suit knowledge of the patent's subject matter via the 2023 notification, and if so, would its continued sales of the accused products constitute the kind of egregious conduct necessary to support a finding of willfulness and an award of enhanced damages or attorneys' fees?