DCT
0:25-cv-04155
Sick AG v. Vision Augmentation Technology LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sick AG (Germany), SICK, Inc. (Minnesota), and SICK Product & Competence Center Americas, LLC (Minnesota)
- Defendant: Vision Augmentation Technology LLC (Texas)
- Plaintiff’s Counsel: Fish & Richardson P.C.
- Case Identification: 0:25-cv-04155, D. Minn., 10/30/2025
- Venue Allegations: Plaintiffs allege venue is proper in the District of Minnesota because the defendant is subject to personal jurisdiction there through its targeted licensing efforts and infringement allegations directed at Minnesota-based entities, and because a substantial part of the events, including product sales and receipt of infringement communications, occurred in the district.
- Core Dispute: Plaintiffs seek a declaratory judgment that their 3D vision sensor products do not infringe Defendant’s patent related to stereoscopic systems that determine an object's location using pre-calibrated angular data for each sensor pixel.
- Technical Context: The technology concerns systems for determining the three-dimensional coordinates of a remote object by using two or more sensors to measure its azimuth and elevation angles, a method with applications in industrial automation, navigation, and defense systems.
- Key Procedural History: The complaint states that this action follows a series of communications initiated by Defendant on July 22, 2025, alleging infringement. Despite Plaintiffs providing a specific non-infringement explanation on September 18, 2025, Defendant allegedly continued to press its infringement claims through at least October 24, 2025, creating the controversy that prompted this declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2004-08-10 | ’021 Patent Priority Date |
| 2008-10-07 | ’021 Patent Issue Date |
| 2025-07-22 | Defendant first alleges infringement in a letter |
| 2025-09-18 | Plaintiffs formally deny infringement |
| 2025-10-24 | Last date of correspondence mentioned in complaint |
| 2025-10-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,433,021 - Stereoscopic targeting, tracking and navigation device, system and method
Issued October 7, 2008 (the “’021 Patent”)
The Invention Explained
- Problem Addressed: The patent’s background section identifies a need for an effective method to determine the origin of small, fast-moving objects like mortar and missile fire, which it states contemporary radar could not track effectively, and a more general need for precise, real-time object location for navigation and surveying (’021 Patent, col. 1:16-30).
- The Patented Solution: The invention proposes a measurement system using at least two sensors separated by a known distance to identify the precise location of a remote object through triangulation (’021 Patent, Abstract). The core of the patented method involves each sensor having a plurality of discrete detection pixels, where each pixel is pre-associated with a specific, "predetermined azimuth angle and a predetermined elevation angle" stored in computerized data (’021 Patent, col. 2:58-65). When a target is detected by a given pixel, the system can "automatically" determine the target's angles relative to that sensor by referencing this pre-calibrated data, enabling a rapid calculation of the target's 3D coordinates (’021 Patent, col. 5:5-14; Fig. 1).
- Technical Importance: The claimed approach purports to enable rapid and accurate tracking by replacing complex, real-time angle calculations with a more direct lookup of pre-calibrated values associated with individual sensor pixels (’021 Patent, col. 1:33-42).
Key Claims at a Glance
- The complaint seeks a declaration of non-infringement of independent claims 1 and 15 (Compl. ¶¶31, 32).
- Independent Claim 1 (System):
- Two sensors, each with a plurality of discrete detection pixels.
- Computerized data that associates each detection pixel with a "predetermined azimuth angle and a predetermined elevation angle."
- A computerized device for "automatically determining" the target's azimuth and elevation angles based on the computerized data.
- Independent Claim 15 (Method):
- Placing two sensors at a known distance and orientation.
- Simultaneously detecting a target with each sensor.
- "Automatically determining" the target's azimuth and elevation angles by using "computerized data associating each said detection pixel... with a predetermined azimuth angle and a predetermined elevation angle."
- The complaint notes Plaintiffs do not infringe these independent claims or "any of its dependent claims" (Compl. ¶¶31, 32).
III. The Accused Instrumentality
Product Identification
The complaint refers generally to "Plaintiffs' products," which are described as "sensor-based solutions, including innovative 3D vision sensors" for the industrial sector (Compl. ¶¶11, 17). No specific product names or models are identified.
Functionality and Market Context
The complaint provides minimal detail regarding the technical operation of the accused products. The central functional allegation is a negative one: that the products do not utilize a system that associates each detection pixel with a "predetermined azimuth angle and a predetermined elevation angle" to determine a target's location (Compl. ¶¶19, 31). The products are described as serving the "industrial sector" (Compl. ¶11).
IV. Analysis of Infringement Allegations
As this is a complaint for declaratory judgment, the following summarizes Plaintiffs' asserted basis for non-infringement.
No probative visual evidence provided in complaint.
’021 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| for each said sensor, computerized data associating each said detection pixel thereof with a predetermined azimuth angle and a predetermined elevation angle | Plaintiffs' products do not practice a sensor system that comprises computerized data associating each detection pixel with a predetermined azimuth and elevation angle. | ¶31 | col. 2:8-11 |
| a computerized device for automatically determining azimuth angles and elevation angles of a target or beacon... based on said computerized data | Plaintiffs' products do not practice a computerized device that automatically determines angles of a target in the manner required by the claim. | ¶31 | col. 2:11-14 |
Identified Points of Contention
- Scope Questions: A central dispute will likely involve the meaning of "predetermined." The complaint's focus on this term suggests a potential argument that Plaintiffs' products calculate angular data dynamically or algorithmically at the time of detection, rather than retrieving pre-stored, static angle values for each pixel as arguably required by the patent's language. The question is whether "predetermined" is limited to a pre-populated lookup table architecture or if it can be construed more broadly to cover any system where the geometric relationship between pixels and angles is known and fixed.
- Technical Questions: The complaint does not explain the alternative method by which Plaintiffs' 3D vision sensors determine a target's angular position. A key factual question will be what evidence is presented to demonstrate that the accused products' method of operation is technically distinct from the "associating" and "automatically determining" limitations of the asserted claims.
V. Key Claim Terms for Construction
"predetermined azimuth angle and a predetermined elevation angle"
- Context and Importance: This phrase appears in both independent claims 1 and 15 and is the explicit basis for Plaintiffs' non-infringement theory (Compl. ¶¶19, 31, 32). The resolution of the case may depend on whether the accused products' method of deriving angular information falls within the scope of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Defendant may argue that "predetermined" simply means the angular value corresponding to a pixel is known and fixed by the sensor's physical construction and calibration prior to target detection. The specification states that "each pixel is assigned a unique azimuth and elevation value," which could support an interpretation that any system with a fixed, known relationship between pixels and angles meets this limitation, regardless of the specific data storage or retrieval method ('021 Patent, col. 3:65-col. 4:1).
- Evidence for a Narrower Interpretation: Plaintiffs may argue that the term, read in light of the specification, requires a specific data structure, such as a "computerized lookup table," that explicitly stores a unique angle pair for each individual pixel before detection occurs ('021 Patent, col. 8:10-14). The patent's emphasis on associating data "with each said detection pixel" could support an argument that systems using more generalized mathematical models or on-the-fly calculations do not meet this limitation ('021 Patent, col. 2:8-11).
"automatically determining"
- Context and Importance: This term is also central to the asserted claims and is part of Plaintiffs' non-infringement argument (Compl. ¶31). Its construction will define the type of process required to derive the angles from the "predetermined" data.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Defendant could argue the term means any computerized process for determining the angles that does not require manual user intervention.
- Evidence for a Narrower Interpretation: Plaintiffs may contend that in the context of the patent, "automatically determining" is functionally linked to the direct retrieval of the "predetermined" data. The specification states that when a pixel detects a target, the angles are "automatically determined from said computerized data," suggesting a direct lookup rather than a multi-step computational process ('021 Patent, col. 8:49-53).
VI. Other Allegations
Indirect Infringement
Plaintiffs seek a declaration of non-infringement under theories of induced and contributory infringement (Compl. ¶30). The complaint does not, however, detail any specific facts underlying Defendant's allegations of indirect infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: Can the phrase "computerized data associating each said detection pixel... with a predetermined azimuth angle and a predetermined elevation angle" be interpreted to cover systems that may calculate angles using algorithms based on a sensor's overall geometry, or is its scope limited to architectures that use a direct, one-to-one lookup of pre-stored angle values for every pixel?
- A key evidentiary question will be one of technical differentiation: How do the accused 3D vision sensors technically operate to find a target's angular position? The case will likely turn on whether discovery reveals a fundamental operational mismatch between the accused products' method and the pre-association and data retrieval process described and claimed in the ’021 Patent.