Mowry v. NVIDIA Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Craig P. Mowry
  • Defendant: NVIDIA Corporation (Delaware)
  • Plaintiff’s Counsel: Not specified in provided documents.
• Case Identification: 1:25-cv-01353, D. Del., 11/06/2025
• Venue Allegations: Venue is based on Defendant's incorporation in Delaware.
• Core Dispute: Plaintiff alleges that Defendant infringes two U.S. patents related to systems and methods for generating modified imagery by combining visual data from image sensors with auxiliary spatial data.
• Technical Context: The technology lies in the field of computational photography, where data from multiple sensor types (e.g., cameras and distance sensors) are fused to create enhanced or multi-dimensional images that can be manipulated after capture.
• Key Procedural History: The patents-in-suit claim priority through a long and complex chain of continuation and provisional applications, indicating a lengthy period of invention and prosecution. The complaint itself references confidential exhibits that are not part of the public filing.

Case Timeline

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

U.S. Patent No. 11,632,498 - "Multi-dimensional imaging system and method," issued April 18, 2023

The Invention Explained

• Problem Addressed: The patent background section describes a need in the art for digital imaging systems that can match or exceed the quality of traditional 35mm film while leveraging the flexibility of digital processing (’498 Patent, col. 4:13-19).
• The Patented Solution: The invention is a system that combines data from two different types of sources: a plurality of traditional image sensors that capture a visual of a scene, and a "spatial data device" that measures the position of objects in that scene by transmitting a signal and receiving its reflection (’498 Patent, Abstract; FIG. 1). A processor then uses both the visual data and the spatial position data to generate a primary image, and can later generate a second, modified image using the original captured data combined with new information, enabling post-capture manipulation (’498 Patent, col. 4:35-40).
• Technical Importance: This approach of fusing visual data with explicit spatial data enables advanced computational photography techniques, such as creating 3D models from 2D images, post-capture refocusing, and generating composite images from multiple sources with dimensional accuracy (’498 Patent, col. 7:10-20; col. 8:62-65).

Key Claims at a Glance

• The complaint does not identify specific asserted claims, but Claim 1 is the patent's sole independent claim.
• The essential elements of Claim 1 are:
  • An image capture device with multiple image sensors to capture distinct visuals of a scene.
  • A spatial data device that transmits a signal, receives its reflection from objects, and conveys information about the objects' positions.
  • At least one processor configured to generate a first image using both the captured visual(s) and a measurement from the spatial data device.
  • The processor is also configured to generate a second image at a later time using the original captured visual and second information corresponding to object positions.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,785,351 - "Multi-dimensional imaging system and method," issued October 10, 2023

The Invention Explained

• Problem Addressed: The ’351 Patent is a continuation of the application that led to the ’498 Patent and addresses the same technical problem: improving digital imaging systems to match film quality while adding digital flexibility (’351 Patent, Related U.S. Application Data).
• The Patented Solution: The abstract of the ’351 Patent is identical to that of the ’498 Patent, describing a system that uses one or more image sensors in conjunction with a spatial data device to generate an image (’351 Patent, Abstract). The processor uses both visual data and spatial measurements, allowing for the generation of a modified image at a later time.
• Technical Importance: As part of the same patent family, the technical importance is congruent with that of the ’498 Patent, focusing on enabling advanced computational photography by fusing different sensor data types.

Key Claims at a Glance

• The full text of the ’351 Patent was not provided, precluding a detailed analysis of its claims. The complaint asserts the patent and its dependent claims are valid and enforceable (Compl. p. 1).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused NVIDIA products, methods, or services (Compl. p. 1).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It states that details are included in confidential Exhibits 1, 2, and 3, which were not provided for this analysis (Compl. p. 1).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint broadly alleges infringement of the patents-in-suit but does not provide a claim chart or a narrative theory of infringement in the public document (Compl. p. 1). The substantive allegations appear to be contained within confidential exhibits filed under seal. Lacking specific infringement contentions, a direct analysis is not possible. However, based on the technology of the ’498 Patent and Defendant NVIDIA's known work in computational imaging, graphics processing, and AI, potential areas of dispute may emerge concerning the alignment between the patent's claims and modern imaging technologies.

For example, a central dispute may involve whether NVIDIA's methods for generating 3D or depth-enabled imagery (which may use techniques like AI-based depth estimation or stereoscopic imaging from multiple cameras) meet the specific limitations of the claims. The infringement analysis will likely depend on evidence obtained during discovery regarding the architecture and data processing workflows of NVIDIA's software and hardware platforms.

V. Key Claim Terms for Construction

Analysis is based on Independent Claim 1 of the ’498 Patent, as it is the only independent claim.

• The Term: "spatial data device"

  • Context and Importance: This term is fundamental to the invention's structure. Its construction will determine whether the claims cover modern methods of depth-sensing that may not involve a distinct piece of hardware that actively transmits and receives a signal. Practitioners may focus on this term because NVIDIA’s technologies could use passive techniques (e.g., stereoscopic analysis) or AI-driven inference rather than an active transmitter/receiver.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language is functional, defining the device by what it does: "generate and transmit a signal, and to receive reflections...and to convey information corresponding to respective positions" (’498 Patent, Claim 1). The specification provides a non-exhaustive list of technologies, including "Sonar, radar and other methods" (’498 Patent, col. 13:55-56), which could support arguing that any technology performing this function is covered.
    • Evidence for a Narrower Interpretation: The embodiments pictured in the specification depict a physically distinct hardware component for this task, separate from the primary image capture devices (e.g., item 104B in FIG. 1; "Sender" and "Receiver" in FIG. 4). A party could argue the term is limited to devices that perform active signal transmission and reception, such as LiDAR or radar, and does not read on passive depth-inference techniques.

• The Term: "generate at a later time a second image"

  • Context and Importance: This limitation requires a specific two-step workflow where an initial set of data is re-processed to create a new output. Infringement will depend on whether an accused feature, such as a post-capture editing tool, performs this claimed re-generation or simply manipulates a previously rendered image file.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim requires generating a second image "using the at least one captured visual of the scene and using second information" (’498 Patent, Claim 1). This could be argued to cover any post-capture process that revisits the original sensor data to create a new visual output based on different parameters (e.g., changing the focus point in a portrait mode photo).
    • Evidence for a Narrower Interpretation: The limitation could be construed to require a full re-rendering process from the raw visual and spatial data, as opposed to a simpler modification of a rendered image. A defendant might argue that features like applying filters or adjusting brightness do not constitute "generat[ing]...a second image" in the manner claimed.

VI. Other Allegations

The provided complaint does not contain specific allegations of indirect or willful infringement.

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

1. A core issue will be one of definitional scope: can the term "spatial data device," which is described in the patent with examples of active signal transmission and reception, be construed to cover modern computational techniques that derive spatial information passively, such as through AI-based depth estimation or stereoscopic analysis from multiple camera feeds?

2. A key evidentiary question will be one of technical implementation: does the accused NVIDIA system perform the specific, two-step process of generating an initial image and then "generat[ing] at a later time a second image" by re-processing the original sensor and spatial data, or do its post-capture editing features operate on an already-rendered image in a way that falls outside the claimed method?

3. An overarching procedural question will be the extent to which the confidential exhibits, which appear to contain the entirety of the infringement allegations, define the boundaries of the dispute and reveal the specific NVIDIA products and technologies at issue.