DCT
1:25-cv-11798
Hisense USA Corp v. Baker Laser Technology LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Hisense USA Corporation (Georgia)
- Defendant: Baker Laser Technology, LLC (Massachusetts)
- Plaintiff’s Counsel: Perkins Coie LLP
- Case Identification: 1:25-cv-11798, D. Mass., 06/20/2025
- Venue Allegations: Venue is asserted based on Defendant Baker Laser Technology, LLC’s residence within the District of Massachusetts.
- Core Dispute: Plaintiff Hisense seeks a declaratory judgment that its laser television products do not infringe Defendant Baker's patent directed to laser projection systems.
- Technical Context: The dispute concerns technology in the field of laser-based video projection, which is utilized in consumer and commercial products such as home theater systems.
- Key Procedural History: The complaint notes that this declaratory judgment action follows pre-suit communications, including a letter from Baker to Hisense in January 2022 that included an "exemplary infringement analysis claim chart." The complaint also notes that Baker has filed separate infringement lawsuits asserting the same patent against Seiko Epson Corporation and Samsung Electronics America, Inc.
Case Timeline
| Date | Event |
|---|---|
| 2006-08-19 | '373 Patent Priority Date |
| 2015-11-10 | '373 Patent Issue Date |
| 2022-01-13 | Baker sends letter to Hisense alleging infringement |
| 2024-11-13 | Baker sues Seiko Epson Corporation over '373 Patent |
| 2025-04-25 | Baker sues Samsung Electronics America, Inc. over '373 Patent |
| 2025-06-20 | Hisense files Complaint for Declaratory Judgment |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 9,185,373, titled "Laser Projection System," issued November 10, 2015.
U.S. Patent No. 9,185,373 - "Laser Projection System"
The Invention Explained
- Problem Addressed: The patent’s background section identifies the problem of conventional video projectors being heavy, bulky, and inconvenient for portable use (e.g., in a briefcase or pocket) ('373 Patent, col. 1:64-68).
- The Patented Solution: The invention claims to solve this problem with a compact projection device that uses semiconductor lasers to generate pulses of light. These light pulses are directed through a rotating disk containing numerous lenses. As the disk spins, the lenses scan the light pulses across a surface to form a complete video image, with the laser pulsing synchronized to the disk's rotation to place each pixel correctly ('373 Patent, col. 2:28-35; Fig. 5).
- Technical Importance: This approach sought to enable the miniaturization of projectors by replacing the complex optics of traditional bulb-based systems with a solid-state laser and a rotating lens assembly ('373 Patent, col. 1:66-68).
Key Claims at a Glance
- The complaint identifies independent claims 1 (a device) and 8 (a method) as having been asserted by Baker against Hisense (Compl. ¶¶18, 20).
- Independent Claim 1 (device) requires:
- An interface for connecting to a video generating device
- The interface receiving instructions that specify a video image
- The instructions being reformatted into instructions for activating semiconductor lasers to form light pulses
- The pulses of light being sent through a rotating disk
- Projecting the video image onto a surface
- Independent Claim 8 (method) requires:
- Generating a beam of light using semiconductor lasers
- The beam consisting of a stream of pulses to display on a surface
- Transmitting the pulses through a rotating disk
- Synchronizing the rotating disk with the lasers so that the pulses are modified to form an image on the surface
- The complaint seeks a declaration of non-infringement of "any asserted claims of the '373 patent" (Compl. ¶26).
III. The Accused Instrumentality
- Product Identification: The accused instrumentality is identified as "Hisense's 4K UHD Smart Laser TV" (Compl. ¶10).
- Functionality and Market Context: The complaint describes the accused product as being in the "laser projector markets" (Compl. ¶10). It does not provide technical details on the product's internal operation. Instead, the complaint's allegations focus on functions the product purportedly does not perform, as described in Section IV below (Compl. ¶¶19, 21). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following tables summarize Hisense's specific denials of infringement for the elements it highlights.
U.S. Patent No. 9,185,373 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| said instructions reformatted by the light projecting device into instructions for activating two or more semiconductor lasers, said lasers energized and de-energized to form pulses of light | The complaint alleges that Hisense's products do not perform this function of receiving and reformatting instructions to activate lasers as required by the claim. | ¶19 | col. 2:28-31 |
U.S. Patent No. 9,185,373 Infringement Allegations
| Claim Element (from Independent Claim 8) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| synchronizing said rotating disk with the lasers such that the pulses of light are modified such that an image is formed on the surface | The complaint alleges that Hisense's products do not perform this function of synchronizing a rotating disk with lasers to form an image as required by the claim. | ¶21 | col. 2:32-35 |
- Identified Points of Contention:
- Technical Question (Claim 1): A central dispute concerns the accused product's signal processing architecture. The complaint’s denial raises the question of whether the Hisense TV receives video "instructions" and then "reformats" them into separate laser activation instructions as recited in the claim, or if it employs a different data processing pathway (Compl. ¶19).
- Technical Question (Claim 8): The infringement analysis for this claim appears to turn on the core image formation technology. The complaint puts at issue whether the Hisense TV utilizes a "rotating disk" that is "synchroniz[ed]" with lasers to "paint" an image, as required by the claim, or if it uses an alternative projection mechanism (Compl. ¶21).
V. Key Claim Terms for Construction
The Term: "instructions reformatted"
- Context and Importance: This term is critical to the dispute over Claim 1, as Hisense's non-infringement defense is based on its products not performing this specific data conversion step (Compl. ¶19). Practitioners may focus on this term because its construction could determine whether the signal processing in the Hisense TV falls within the scope of the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the invention as "transform[ing]" an "electronic representation of an image... into pulses of light" (ʼ373 Patent, col. 2:29-31) and "converting the information received into signals to energize or deenergize" lasers ('373 Patent, col. 4:41-44). This language could support an interpretation where "reformatted" covers a wide range of video signal processing.
- Evidence for a Narrower Interpretation: The claim's structure—"receiving instructions... said instructions reformatted"—could support an argument that two distinct steps are required: receipt of a specific type of data ("instructions") followed by a separate "reformatting" process. This may be contrasted with a single, integrated process of converting a raw video stream.
The Term: "synchronizing said rotating disk with the lasers"
- Context and Importance: Hisense's denial of infringement for Claim 8 centers on this limitation (Compl. ¶21). The definition of "synchronizing" in the context of the patent will be pivotal in determining whether the timing and control system in the Hisense product infringes.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent summary states broadly that "the pulses of light are synchronized with the rotating disk such that the pulses of light form a visible representation of the image" ('373 Patent, col. 2:32-35). This could be argued to cover any method of timing the laser firing relative to the disk's position to produce an image.
- Evidence for a Narrower Interpretation: A specific embodiment describes a "sensor 407 monitoring the rotating lens 305 so that the firing of the lasers... can be synchronized" ('373 Patent, col. 4:45-49; Fig. 5). A party could argue this disclosure limits the term "synchronizing" to a system that uses a feedback sensor on the disk itself to control laser timing.
VI. Other Allegations
- Indirect Infringement: The complaint preemptively seeks a declaration of non-infringement for indirect infringement, arguing that there can be no induced or contributory infringement because there is no underlying direct infringement by any party. It further alleges that Hisense has not acted with the specific intent required for inducement or sold products "knowing the same to be especially made or especially adapted for use in an infringement" for contributory infringement (Compl. ¶¶23-24).
- Willful Infringement: This is a declaratory judgment action filed by the accused infringer; no allegations of willfulness are made in the complaint.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central question will be one of technical mechanism: Does the Hisense Laser TV employ a "rotating disk" whose rotation is "synchronized" with laser pulses to form an image, as recited in the patent? Or does the accused product utilize a different projection technology (e.g., a Digital Micromirror Device (DMD) or Liquid Crystal on Silicon (LCoS)) that operates on a fundamentally different principle than that claimed?
- The case will also likely turn on a question of claim scope: How broadly will the court construe the term "instructions reformatted"? The resolution will depend on whether the term encompasses any conversion of a video signal into laser-driving commands, or if it requires a more specific, multi-step process of receiving discrete "instructions" and then separately converting them, as Hisense's pleading suggests may not be present in its products.