DCT
2:20-cv-01287
Kamino LLC v. Casio America Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Kamino LLC (Texas)
- Defendant: Casio America, Inc. (New York)
- Plaintiff’s Counsel: STAMOULIS & WEINBLATT LLC; THE MORT LAW FIRM, PLLC
- Case Identification: 2:20-cv-01287, D.N.J., 02/06/2020
- Venue Allegations: Plaintiff alleges venue is proper in the District of New Jersey because Defendant maintains a "regular and established place of business" within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Casio Pro Trek Smart Watch products infringe a patent related to light conducting plates for backlighting display devices.
- Technical Context: The technology concerns the design of components within edge-lit backlights for displays, such as those used in watches and other electronics, to achieve uniform brightness across the screen.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 1999-02-26 | '686 Patent Priority Date |
| 2002-08-20 | '686 Patent Issue Date |
| 2020-02-06 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,435,686 - Light Conducting Plate for a Back Lighting Device and Back Lighting Device
- Issued: August 20, 2002
The Invention Explained
- Problem Addressed: The patent describes a common problem in edge-lit displays where light from a source enters the side of a light-conducting plate. This configuration can lead to non-uniform brightness, specifically "abnormal light-emission" (i.e., overly bright spots) on the part of the screen nearest to the light source. (’686 Patent, col. 2:10-18).
- The Patented Solution: The invention proposes a specially designed reflecting face on the light conducting plate. This face is divided into at least two distinct zones: a primary "light-scattering region" and a "remainder region." By positioning the "remainder region," which has a lower degree of light scattering (e.g., a mirror-like finish), near the light-inlet, the invention aims to suppress the intense, concentrated light in that area and produce a more uniform luminance across the entire display. (’686 Patent, Abstract; col. 3:1-13; Fig. 2).
- Technical Importance: This design sought to improve display quality by providing a structural solution to brightness non-uniformity, potentially reducing the need for costly or bulky corrective components like multiple diffuser sheets. (’686 Patent, col. 1:52-58).
Key Claims at a Glance
- The complaint asserts independent Claim 1. (Compl. ¶12).
- The essential elements of Claim 1 are:
- A light conducting plate for a back lighting device, comprising:
- a light-inlet end face for introducing light from a source;
- a reflecting face to reflect the introduced light;
- a light-outlet face opposite the reflecting face for light to exit;
- wherein the reflecting face includes a "light-scattering region" and a "remainder region," with the "remainder region" located on a side near the light-inlet end face.
- The complaint’s prayer for relief is general as to the patent, which may suggest an intent to reserve the right to assert other claims. (Compl. p. 9).
III. The Accused Instrumentality
Product Identification
- The "Casio Pro Trek Smart Watch products," with model WSD-F20BK identified as an exemplary product. (Compl. ¶13).
Functionality and Market Context
- The complaint alleges that the accused smartwatches contain a display apparatus that utilizes a "light conducting plate" for backlighting. (Compl. ¶14). Teardown photographs provided in the complaint purport to show the internal components of the watch display, including the light conducting plate, light sources, and its various faces. (Compl. pp. 5-9). A product image shows the WSD-F20BK listed for sale at $149.00. (Compl. p. 4).
- A teardown photograph included in the complaint shows the alleged light conducting plate of the accused product removed from the watch assembly. (Compl. p. 5).
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The complaint’s allegations for Claim 1 of the ’686 Patent are presented in a narrative, element-by-element format.
'686 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A light conducting plate for a back lighting device, comprising: | The accused smartwatches allegedly include a light conducting plate within their display apparatus. | ¶14 | col. 6:20-22 |
| a light-inlet end face for introducing light emitted from a light source... | The plate allegedly has a light-inlet end face that receives light from light sources. | ¶14 (p. 5) | col. 6:25-28 |
| a reflecting face for reflecting the light introduced through said light-inlet end face; | The plate allegedly includes a reflecting face to direct light. | ¶14 (p. 6) | col. 6:22-23 |
| a light-outlet face disposed opposite to said reflecting face... | The plate allegedly has a light-outlet face opposite the reflecting face through which light emits. | ¶14 (p. 7) | col. 6:22-23 |
| wherein said reflecting face includes a light-scattering region and a remainder region, and the remainder region is located on a side near to said light-inlet end face. | The reflecting face is alleged to have a "light scattering region" and a "remainder region," with the remainder region located near the light inlet. A labeled photograph purports to identify these two distinct regions on the accused component. | ¶14 (pp. 8-9) | col. 3:4-13 |
Identified Points of Contention
- Technical Question: A central question is whether the two regions identified on the accused product's reflecting face (Compl. p. 9) function as claimed. What evidence demonstrates that the alleged "remainder region" possesses a "smaller degree of light scattering" ('686 Patent, col. 3:7-9) than the "light-scattering region"? The complaint relies on visual evidence from a teardown, which may be challenged as insufficient to prove this functional difference without supporting optical or physical measurement data.
- Scope Questions: The complaint labels a photo showing the "Remainder Region" and "Light Scattering Region" (Compl. p. 9). The defense may question whether the visual distinctions in the photograph correspond to the specific functional definitions and structural relationship required by the claim language and specification.
V. Key Claim Terms for Construction
The Term: "remainder region"
- Context and Importance: This term is at the heart of the patent's purported novelty. The outcome of the infringement analysis will likely depend on whether the designated area on the accused product meets the definition of a "remainder region." Practitioners may focus on this term because its construction will determine whether a mere absence of a scattering treatment is sufficient, or if a specific functional quality (e.g., being "mirror-like") is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines the term as "a region where the light-scattering region is not formed," which could support an argument that any untreated portion of the reflecting face qualifies. (’686 Patent, col. 3:6-7).
- Evidence for a Narrower Interpretation: The patent repeatedly describes the remainder region functionally as having "a smaller degree of light scattering" and being in a "mirror-like surface state." (’686 Patent, col. 3:7-9; col. 6:41-43). This language suggests the term requires a specific optical property, not just a location.
The Term: "light-scattering region"
- Context and Importance: This term defines the primary surface treatment on the reflecting face, and its properties form the baseline against which the "remainder region" is defined. The dispute will concern what type and degree of surface modification constitute a "light-scattering region."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent discloses various methods for creating this surface, such as "dot printing," "satin finish," "chemical etching," and "sand blasting," suggesting the term is not limited to a single manufacturing process. (’686 Patent, col. 5:9-13; col. 7:1-3).
- Evidence for a Narrower Interpretation: The purpose of the region is to "aid the reflection and scattering of the introduced light for improvement in the luminance of the light-outlet face." (’686 Patent, col. 1:35-37). An argument could be made that incidental or unintentional surface variations do not meet the functional requirements of the claimed region.
VI. Other Allegations
Willful Infringement
- The complaint does not explicitly allege willful infringement. However, it requests a declaration that the case is "exceptional under 35 U.S.C. § 285," which could entitle the plaintiff to an award of attorneys' fees. (Compl. p. 10, ¶C). The complaint does not plead facts related to pre- or post-suit knowledge of the patent by the defendant.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of functional proof: Does the "remainder region" identified in the accused product's teardown photographs actually exhibit a "smaller degree of light scattering" than the adjacent "light-scattering region," as required by the patent? The case may turn on whether visual evidence alone is sufficient or if technical data is required to prove this functional distinction.
- A second key question will be one of definitional scope: Can the term "remainder region" be construed broadly to mean any area without an applied scattering texture, or must it be proven to possess the specific "mirror-like" quality described in the patent's preferred embodiments? The answer will significantly impact the evidence needed to prove infringement.