DCT
1:22-cv-02521
Lumintec LLC v. Motorola Mobility LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lumintec, LLC. (Texas)
- Defendant: Motorola Mobility, LLC (Delaware)
- Plaintiff’s Counsel: Dunlap, Bennett, and Ludwig; Hudnell Law Group P.C.
- Case Identification: 1:22-cv-02521, N.D. Ill., 06/22/2022
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant has its principal place of business in the district, is registered to do business there, and has allegedly committed acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Motorola Moto X (2nd Gen) and Google Nexus 6 smartphones infringe a patent related to the physical structure of a camera flash assembly.
- Technical Context: The lawsuit concerns the design of camera flash modules in handheld electronic devices, specifically the use of a ring-shaped flash structure intended to provide more even illumination for photography.
- Key Procedural History: The complaint alleges that the patent’s inventors provided written notice of the patent to a related entity, Motorola China, on April 22, 2015, and attempted to negotiate a license, which was refused. This alleged pre-suit knowledge forms the basis for the willfulness claim.
Case Timeline
| Date | Event |
|---|---|
| 2011-11-10 | '983 Patent Priority Date |
| 2014-05-13 | '983 Patent Issue Date |
| 2014-09-05 | Motorola Moto X (2nd Gen) Announced |
| 2014-10-15 | Google Nexus 6 Announced |
| 2015-04-22 | Alleged notice of '983 Patent sent to Motorola China |
| 2022-06-22 | Second Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,724,983 - "Flash Structure for the Camera Function of a Handheld Electronic Device"
- Patent Identification: U.S. Patent No. 8,724,983, “Flash Structure for the Camera Function of a Handheld Electronic Device,” issued May 13, 2014.
The Invention Explained
- Problem Addressed: The patent addresses the problem of conventional smartphone flashes, which are typically positioned to the side of the camera lens. This placement often results in an "uneven distribution of light," which "diminishes the anticipated quality of resulting pictures or videos" (’983 Patent, col. 1:50-53; Compl. ¶21).
- The Patented Solution: The invention proposes a flash structure where light-emitting elements are arranged around the camera lens. This is achieved using an "annular reflector" with a "through-slot" for embedding the light sources, and a "light diffuser" placed around the lens to create a uniform, ring-like flash, thereby improving image quality (’983 Patent, Abstract; col. 2:9-25). The structure is designed to be simple and not increase manufacturing costs (Compl. ¶25).
- Technical Importance: The design aims to bring the benefits of a "ring flash," a tool used in professional photography for even, shadowless lighting, to the integrated camera module of a consumer handheld device (Compl. ¶21).
Key Claims at a Glance
- The complaint asserts infringement of "one or more claims" of the '983 Patent (Compl. ¶41). Independent claim 1 is representative of the core invention.
- Independent Claim 1 requires:
- A flash structure for a handheld electronic device comprising an outer cover with a through-hole.
- An "annular reflector" with a "ring-shape" that is embedded on the device's baseboard and situated around the camera module.
- The annular reflector has at least one "through-slot."
- At least one "fixed light-emitting element" is embedded in the through-slot and positioned around the camera lens.
- At least a "light diffuser" is provided on the annular reflector and encircles the camera lens.
- The complaint reserves the right to assert other claims, which may include dependent claims narrowing these elements (Compl. ¶41).
III. The Accused Instrumentality
Product Identification
- The Motorola Moto X (2nd Gen) smartphone and the Google Nexus 6 smartphone (the "Accused Products") (Compl. ¶31).
Functionality and Market Context
- The complaint alleges that both the Moto X and Nexus 6 phones include a camera module positioned on the back of the phone (Compl. ¶38). The infringement allegations center on the physical assembly of the flash components relative to the camera lens in these devices.
- The complaint asserts that these products were manufactured by Motorola after the '983 Patent issued (Compl. ¶31). The Moto X was announced on September 5, 2014, and the Nexus 6 was announced on October 15, 2014 (Compl. ¶34).
IV. Analysis of Infringement Allegations
The complaint does not contain claim charts, instead referring to Exhibits 2-3, which are not attached to the filing (Compl. ¶43). The following chart summarizes the infringement theory based on the complaint's narrative description of the invention, which it alleges is practiced by the Accused Products.
No probative visual evidence provided in complaint.
'983 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an annular reflector, having a ring-shape, embedded on the baseboard of the handheld electronic device and situated around the camera module ... wherein said annular reflector further has at least a through-slot provided thereat | The Accused Products allegedly include an annular reflector with a through-slot for the light-emitting elements, arranged around the camera lens. | ¶26, ¶41 | col. 3:36-40 |
| at least a fixed light-emitting element being embedded in said through-slot of said annular reflector, wherein said fixed light-emitting element is positioned around the camera lens | The Accused Products allegedly have one or more fixed light-emitting elements embedded in the through-slot of the annular reflector. | ¶26, ¶41 | col. 3:41-45 |
| at least a light diffuser provided on said annular reflector and situated outside said fixed light-emitting element to encircle around the camera lens of the camera module | The Accused Products allegedly possess a light diffuser disposed outside the annular reflector and positioned around the camera lens. | ¶26, ¶41 | col. 3:40-42 |
- Identified Points of Contention:
- Structural Questions: A central question will be whether the physical components of the Accused Products' flash assemblies meet the specific structural and relational limitations of the claims. For example, do the devices contain a distinct component that functions as an "annular reflector" with a "through-slot," or is the function achieved through a different configuration?
- Scope Questions: The analysis will question whether the components in the Moto X and Nexus 6, as actually constructed, fall within the scope of the claim terms. For instance, what is the precise structure of the component alleged to be the "light diffuser," and does it "encircle" the camera lens as required by the claim?
- Evidentiary Questions: The complaint relies on unavailable exhibits for its detailed infringement contentions (Compl. ¶43). A key question is what specific evidence Plaintiff will produce to demonstrate that the internal, physical structure of the Accused Products maps onto each element of the asserted claims.
V. Key Claim Terms for Construction
The Term: "annular reflector"
Context and Importance: This term is foundational to the claim, defining the core ring-shaped structure around the lens. The dispute will likely center on whether the accused component has the specific "ring-shape" and reflective properties required. Practitioners may focus on this term because its construction will determine whether a variety of surrounding structures in a camera module meet this limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states the reflector is "preferably mirror surface, white color, or silver color," which may suggest that a specific mirrored quality is not strictly required and other reflective surfaces could suffice ('983 Patent, col. 3:51-53).
- Evidence for a Narrower Interpretation: Claim 1 explicitly defines the term as "having a ring-shape" ('983 Patent, col. 4:55-56). The figures consistently depict a distinct, continuous or near-continuous ring structure (e.g., ’983 Patent, Fig. 2, item 12), which could support an argument that a non-contiguous or fragmented set of reflective surfaces does not meet the limitation.
The Term: "embedded in said through-slot"
Context and Importance: This term dictates the physical relationship between the light source and the reflector. The infringement analysis will depend on whether the light-emitting elements in the Accused Products are physically "embedded in" a slot on the reflector, or merely adjacent to it.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not provide a specific definition of "embedded," which might allow for an argument that placing a component within the confines of a slot or opening constitutes embedding.
- Evidence for a Narrower Interpretation: The figures appear to show the light-emitting elements (14) sitting within a defined slot (121) in the reflector (12) ('983 Patent, Fig. 4). This could support a narrower construction requiring the light source to be recessed or physically set into the reflector material itself.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), asserting that Motorola knowingly and intentionally encouraged infringement by selling the Accused Products and providing "promotional and marketing materials, supporting materials, instructions, product manuals, and/or technical information" that instruct on their use (Compl. ¶46). It also alleges contributory infringement under § 271(c), stating the accused components are a material part of the invention and not staple articles of commerce (Compl. ¶48).
- Willful Infringement: Willfulness is alleged based on pre-suit knowledge of the '983 Patent. The complaint specifically claims that the patent's inventors sent written notice to "Motorola China," an entity related to the Defendant, on or about April 22, 2015, and that Motorola subsequently "refused a license" but continued to infringe (Compl. ¶¶ 28-29, 44-45).
VII. Analyst’s Conclusion: Key Questions for the Case
A primary issue will be one of structural correspondence: Does the physical construction of the camera flash assembly in the Motorola Moto X (2nd Gen) and Google Nexus 6 phones incorporate the specific combination of an "annular reflector" with a "through-slot" and a separate "light diffuser," as strictly defined by the patent's claims and specification?
A second key issue will be one of willfulness and knowledge: Can Plaintiff prove that the alleged notice provided to a related foreign entity, Motorola China, constitutes pre-suit knowledge for the U.S. defendant, Motorola Mobility, LLC, and that Defendant’s subsequent conduct was egregious enough to support a finding of willful infringement?