Solos Technology Ltd v. Meta Platforms Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Solos Technology Limited (Hong Kong, with U.S. principal place of business in Massachusetts)
  • Defendant: Meta Platforms, Inc. (Delaware); Meta Platforms Technologies, LLC (Delaware); Oakley, Inc. (Washington); Luxottica of America, Inc. (Ohio); EssilorLuxottica USA, Inc. (Delaware)
  • Plaintiff’s Counsel: Caldwell
• Case Identification: 1:26-cv-10304, D. Mass., 01/23/2026
• Venue Allegations: Plaintiff alleges venue is proper in the District of Massachusetts because Defendants Meta Platforms and Meta Platforms Technologies maintain a regular and established place of business in Cambridge, Massachusetts, where technologies incorporated into the accused products were allegedly researched and developed, and because all Defendants have committed acts of infringement in the District.
• Core Dispute: Plaintiff alleges that smart glasses marketed under Defendants' "Meta Ray-Ban" and "Oakley Meta" brands infringe five U.S. patents related to head-worn acoustic systems, audio beamforming, directional audio projection, and sensor-integrated user assistance.
• Technical Context: The lawsuit concerns core technologies for smart glasses, a product category that integrates sensing, computation, and audio interaction into a hands-free, wearable form factor.
• Key Procedural History: The complaint alleges that Defendants had extensive pre-suit knowledge of Plaintiff's technology and patents through multiple channels, including direct meetings with company personnel, the hiring of an individual who had previously published a detailed study on Plaintiff's technology and patent portfolio, and direct communications with one of the named inventors.

Case Timeline

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

U.S. Patent No. 10,306,389 - Head Wearable Acoustic System with Noise Canceling Microphone Geometry, Apparatuses and Methods

The Invention Explained

• Problem Addressed: The patent's background describes the problem of undesired audio (noise) from stationary and non-stationary sources degrading the quality of a desired audio signal, which negatively impacts speech recognition algorithms and user comprehension in acoustic systems like those in mobile phones or headsets (’389 Patent, col. 1:43-2:4).
• The Patented Solution: The invention proposes a specific microphone geometry for a head-worn device to improve noise cancellation. The system uses at least two microphones: a "main" microphone positioned closer to the user's mouth and a "reference" microphone positioned farther away. This physical arrangement creates a difference in the signal-to-noise ratio (SNR) between the two channels, as the desired voice signal is stronger at the main microphone while ambient noise is roughly equal at both. A noise cancellation unit then uses this SNR difference to distinguish the user's voice from background noise (’389 Patent, Abstract; col. 8:1-12; FIG. 2).
• Technical Importance: This approach enables noise cancellation for voice capture in a compact, head-worn form factor without requiring a traditional boom microphone extending toward the mouth (’389 Patent, Abstract).

Key Claims at a Glance

• The complaint incorporates by reference an external claim chart (Exhibit 7) and does not identify specific asserted claims in its text (Compl. ¶125).

U.S. Patent No. 10,651,866 - Beamforming Using Fractional Time Delay in Digitally Oversampled Sensor Systems, Apparatuses, and Methods

The Invention Explained

• Problem Addressed: The patent addresses the technical challenge of applying precise time delays to signals from digital sensors for applications like beamforming. Applying these delays in the final, lower-sample-rate "baseband" domain can be computationally intensive and may lack the necessary time resolution (’866 Patent, col. 1:29-41).
• The Patented Solution: The invention teaches a method for applying a "fractional time delay" to a signal in the digitally oversampled domain—that is, at the high sampling frequency of the sensor itself, before the signal is filtered and decimated to the lower baseband rate. The time delay is implemented by delaying the signal by an integer number of high-frequency sampling clock cycles, which corresponds to a fraction of a single, lower-frequency baseband sample period. This allows for very fine-grained and computationally efficient time alignment of signals from multiple sensors (’866 Patent, Abstract; col. 3:4-35; FIG. 2A).
• Technical Importance: This technique enables high-resolution digital beamforming in compact sensor arrays (such as those in smart glasses) by performing the critical time-delay operations in the high-frequency oversampled domain, offering greater precision than conventional baseband processing (’866 Patent, col. 3:4-16).

Key Claims at a Glance

• The complaint incorporates by reference an external claim chart (Exhibit 8) and does not identify specific asserted claims in its text (Compl. ¶136).

U.S. Patent No. 11,082,055 - Beamforming Using Fractional Time Delay in Digitally Oversampled Sensor Systems, Apparatuses, and Methods

• Technology Synopsis: As a continuation of the '866 Patent, the '055 Patent is directed to systems and methods for processing signals from multiple sensors. The technology involves applying fine-grained "fractional time delays" to digitally oversampled signals to improve audio capture and beamforming performance in wearable devices (Compl. ¶146; '055 Patent, Abstract).
• Asserted Claims: The complaint incorporates an external claim chart (Exhibit 9) by reference (Compl. ¶147).
• Accused Features: The complaint alleges that the digital signal processing and beamforming architectures in the accused products infringe the '055 Patent (Compl. ¶¶108, 112).

U.S. Patent No. 11,871,174 - Personalized Directional Audio for Head-Worn Audio Projection Systems, Apparatuses, and Methods

• Technology Synopsis: This patent is directed to audio delivery systems for eyewear. The invention involves using speaker modules, acoustic chambers, and temple-embedded audio structures to concentrate and project sound toward a user's ear, creating a personalized, open-ear listening experience (Compl. ¶157; '174 Patent, Abstract).
• Asserted Claims: The complaint incorporates an external claim chart (Exhibit 10) by reference (Compl. ¶158).
• Accused Features: The complaint accuses the "open-ear speakers" and "directional audio ports" integrated into the temples of the infringing products (Compl. ¶¶111, 115).

U.S. Patent No. 12,216,339 - Eyewear Systems, Apparatuses, and Methods for Providing Assistance to a User

• Technology Synopsis: This patent describes inventive sensor-integrated, context-aware, and multimodal smart-eyewear architectures. The technology relates to systems that use data from various sensors embedded in the eyewear to understand the user's state or context and provide assistance accordingly (Compl. ¶168; '339 Patent, Abstract).
• Asserted Claims: The complaint incorporates an external claim chart (Exhibit 11) by reference (Compl. ¶169).
• Accused Features: The complaint alleges infringement by the products' processor-based and sensor-based functions that respond to user and environmental inputs to enable assistance-system features (Compl. ¶¶109, 111).

III. The Accused Instrumentality

Product Identification

• The accused "Infringing Products" include wearable smart glasses marketed under the "Meta Ray-Ban" and "Oakley Meta" brands, such as the Stories, Wayfarer Gen 1, Wayfarer Gen 2, Skyler Gen 2, Headliner Gen 2, Display, and Oakley Meta HSTN models (Compl. ¶14).

Functionality and Market Context

• The complaint alleges these products are a significant collaboration between Meta and EssilorLuxottica that has generated hundreds of millions of dollars in revenue (Compl. ¶15). The products are alleged to incorporate multiple audio, processing, and sensor components, including microphone arrays for directional capture, digital processing for beamforming, and audio-output elements integrated into the eyewear temples for open-ear sound delivery (Compl. ¶109). The complaint provides a visual depiction of a disassembled Meta Ray-Ban Wayfarer Gen 1, identifying components such as microphones, a DSP board, speakers, and acoustic chambers arranged within the eyeglass frame (Compl. ¶111).

IV. Analysis of Infringement Allegations

The complaint references external claim chart exhibits (Exhibits 7-11), which were not provided with the complaint document, to demonstrate how the Infringing Products meet the limitations of the asserted claims (Compl. ¶114). In the absence of these charts, the infringement theory is summarized below in prose based on the complaint's narrative allegations.

• '389 Patent Infringement Allegations: The complaint alleges that the accused products' microphone arrays and noise-reducing capture features practice the '389 Patent (Compl. ¶¶109, 125). The theory suggests that the physical placement of multiple microphones on the eyeglass frames creates the claimed geometric configuration where at least one microphone is acoustically closer to the user's mouth than another, thereby generating the signal-to-noise ratio differential used for noise cancellation.
• '866 Patent Infringement Allegations: The complaint alleges that the accused products' "beamforming architectures" and "digital processing features used for combining and timing signals" practice the '866 Patent (Compl. ¶¶108-109, 136). The theory suggests that the products' digital signal processors implement the patented method of applying fine-grained time delays in the high-frequency, oversampled domain from the digital microphones to perform audio beamforming. The complaint presents an image comparing Figure 22 of the related '174 patent, which illustrates an eyewear temple housing internal electronics and an acoustic projection assembly, with a product photo of the Ray-Ban Wayfarer Gen 1 showing integrated electronics and open-ear acoustic emitters (Compl. ¶115).
• Identified Points of Contention:
  • Technical Questions: A central technical question for the '866 and '055 patents will concern the specific implementation of the accused products' beamforming algorithm. What evidence does the complaint provide that the Defendants' digital signal processing applies time delays in the oversampled domain prior to decimation, as opposed to using alternative, potentially non-infringing techniques in the baseband domain?
  • Scope Questions: For the '389 patent, a key question may be one of functional and quantitative scope. Does the specific physical arrangement of microphones in the accused glasses, as manufactured, reliably create the necessary difference in "acoustic distance" and corresponding signal-to-noise ratio required by the claims, and does the noise cancellation system functionally depend on this specific mechanism?

V. Key Claim Terms for Construction

Because the complaint does not specify the asserted claims, the following analysis is based on terms central to the technology as described in the patents and the complaint's infringement theory.

• Term: "acoustic distance" ('389 Patent)

  • Context and Importance: The invention of the '389 Patent is predicated on a "first acoustic distance" being less than a "second acoustic distance" to create an SNR differential. The definition of this term is critical to determining whether the physical microphone layout of the accused products meets this geometric limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the term represents the "paths that the acoustic wave travels," which "might be linear or they might be curved depending on the particular location of a microphone" ('389 Patent, col. 8:39-44). This language may support an interpretation that includes non-line-of-sight paths around the user's head.
    • Evidence for a Narrower Interpretation: Figures used to illustrate the concept, such as FIG. 2, depict "d₁" and "d₂" as straight lines from the audio source to the microphones (’389 Patent, FIG. 2). This could suggest the term is limited to a more direct, linear path, the difference of which might be argued as negligible in a compact device.

• Term: "fractional time delay" ('866 Patent)

  • Context and Importance: This term is the core of the asserted beamforming invention. Infringement will depend on whether the accused products' method for time-aligning microphone signals falls within the scope of this term.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that "fractional delay" refers to a fraction of a baseband sampling rate cycle (’866 Patent, col. 5:1-4). This may support a broader reading covering any technique that achieves time resolution finer than a single baseband sample period within the oversampled domain.
    • Evidence for a Narrower Interpretation: The patent repeatedly specifies that the time delay "is represented by an integer number of sampling clock cycles" from the oversampling clock (’866 Patent, col. 3:29-31). This may support a narrower construction requiring the delay to be implemented specifically by counting high-frequency clock cycles, potentially excluding other methods of achieving fine-grained delay (e.g., all-pass filters).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendants provide technical documents, marketing materials, and advertising campaigns that encourage and instruct end-users to operate the products in ways that practice the patented technology (e.g., making phone calls) (Compl. ¶¶126, 137, 148, 159, 170). The complaint also alleges inducement of third-party developers through the provision of a platform architecture that relies on the infringing functionalities (Compl. ¶¶ 99-100).
• Willful Infringement: The complaint makes extensive allegations to support a claim of willful infringement based on Defendants' alleged pre-suit knowledge. The basis for willfulness includes allegations of: (1) direct interactions between Plaintiff's inventor and personnel from Oakley and EssilorLuxottica beginning in 2015 (Compl. ¶¶ 65-75); (2) Meta's hiring of a former MIT fellow who had published a technical study on Plaintiff's products and patents (Compl. ¶¶ 78-82); (3) direct communications between Meta personnel and Plaintiff's inventor regarding his work on the patented technologies (Compl. ¶¶ 84-88); and (4) an internal meeting at Meta where Plaintiff's physical products were examined (Compl. ¶93).

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

• A central issue will be one of technical implementation: Can Plaintiff produce evidence demonstrating that the accused smart glasses' audio processing architecture literally practices the claimed methods, specifically by applying time delays in the high-frequency oversampled digital domain ('866, '055 Patents) and by functionally relying on a geometric SNR differential for noise cancellation ('389 Patent), or will Defendants show they employ alternative, non-infringing signal processing techniques?
• A second key question will address willfulness and damages: Given the extensive and specific allegations of pre-suit knowledge—including analysis of Plaintiff's patents, hiring of knowledgeable individuals, and direct inventor contact—will the evidence support a finding that Defendants knowingly and deliberately incorporated the patented technologies, potentially leading to enhanced damages?
• A third question concerns system-level infringement: For the broader system patents ('174, '339), a key point of inquiry will be whether the combination of directional audio speakers and sensor-driven software features in the accused products performs the specific methods for personalized audio projection and user assistance as claimed, raising questions of both functional equivalence and claim scope.