DCT
3:25-cv-15066
Blue 425 LLC v. Trumpf Photonics Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Blue 425 LLC (Delaware)
- Defendant: Trumpf Photonics, Inc. (Delaware), TRUMPF INC (Connecticut), and Trumpf Se & Co. KG (Germany)
- Plaintiff’s Counsel: Hecht Partners LLP
- Case Identification: 3:25-cv-15066, D.N.J., 08/28/2025
- Venue Allegations: Venue is alleged in the District of New Jersey because defendant entities Trumpf Photonics, Inc. and Trumpf, Inc. maintain a place of business in the district, allegedly making them residents for venue purposes, and because the Accused Products are manufactured and sold in the district.
- Core Dispute: Plaintiff alleges that Defendant’s laser-based 3D printing and welding systems infringe four patents related to the use of visible-spectrum lasers for advanced manufacturing of materials, including highly reflective metals.
- Technical Context: The dispute centers on high-power laser systems used in additive manufacturing and welding, a field where precision and efficiency are critical for applications in electronics, automotive, and battery production.
- Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history involving the Asserted Patents.
Case Timeline
| Date | Event |
|---|---|
| 2013-04-29 | Earliest Priority Date for ’536 and ’489 Patents |
| 2016-04-29 | Earliest Priority Date for ’764 Patent |
| 2017-01-31 | Earliest Priority Date for ’562 Patent |
| 2021-03-09 | Issue Date for ’536 Patent |
| 2021-03-09 | Issue Date for ’562 Patent |
| 2023-05-23 | Issue Date for ’489 Patent |
| 2025-02-11 | Issue Date for ’764 Patent |
| 2025-08-28 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,940,536 - "Devices, Systems and Methods for Three-Dimensional Printing"
The Invention Explained
- Problem Addressed: The patent’s background section describes limitations of conventional 3D printing systems that use infrared (IR) lasers, noting they are often slow and produce objects with low feature resolution and high surface roughness, rendering them unsuitable for many applications (’536 Patent, col. 1:35-44).
- The Patented Solution: The invention is a 3D printing system that uses a high-power, high-brightness visible laser to achieve a smaller focused spot size than IR lasers, thereby enabling higher resolution and faster build rates (’536 Patent, col. 1:56-65). The system generates this visible laser light through stimulated Raman scattering (SRS) and uses a scanning module and computer control system to fuse a substrate material, such as a metal powder, on a layer-by-layer basis to form a 3D object (’536 Patent, col. 4:1-15; Fig. 1).
- Technical Importance: The use of visible light significantly increases the energy absorption by many materials compared to IR light, which can lead to dramatic increases in processing speed for materials like metals (’536 Patent, col. 4:51-56, Table 1).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶27).
- Essential elements of claim 1 include:
- A laser light source that generates a coherent beam of visible light by stimulated Raman scattering;
- A solid substrate in optical communication with the laser, where the visible light has a wavelength between 400 nm and 750 nm and is selected to melt or soften the substrate;
- A scanning module that generates a scanning motion of the laser beam corresponding to a predetermined shape; and
- A computer control system programmed to control the scanning motion and the laser power to form the object.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 10,940,562 - "Methods and Systems for Welding Copper Using Blue Laser"
The Invention Explained
- Problem Addressed: The patent describes the significant challenges of welding copper with conventional IR lasers, which stems from copper's high reflectivity at IR wavelengths. This poor energy coupling can lead to process instability, defects, spatter, and "micro-explosions" as the material rapidly transitions from reflecting to absorbing energy (’562 Patent, col. 1:16-51).
- The Patented Solution: The invention proposes a method for welding copper-based materials using a blue laser, operating in a wavelength range where copper is highly absorptive (’562 Patent, col. 2:45-50; Fig. 9). This improved energy absorption enables a stable and efficient "keyhole weld," a deep penetration welding mode, resulting in higher quality welds that are critical for applications like high-performance batteries and electronics (’562 Patent, col. 1:21-28).
- Technical Importance: By enabling a stable, spatter-free welding process for a highly conductive and reflective material like copper, the invention addresses a key manufacturing bottleneck in the electronics and electric vehicle industries (’562 Patent, col. 1:21-28).
Key Claims at a Glance
- The complaint asserts independent claim 70 (Compl. ¶42).
- Essential elements of claim 70 include:
- Placing a workpiece comprising a first and second piece of copper-based material in contact within a laser system; and
- Directing a blue laser beam at the workpiece to form a keyhole mode weld between the pieces, with the resulting weld comprising a heat-affected zone (HAZ) and a resolidification zone.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 11,654,489 - "Devices, Systems and Methods for Three-Dimensional Printing"
- Technology Synopsis: Similar to the ’536 Patent, this patent addresses the shortcomings of IR laser-based 3D printing, such as slow speed and low resolution (’489 Patent, col. 1:35-44). The patented solution is a system for forming a part from a metallic solid substrate using a visible light laser with a power of at least 100 W, which improves processing speed and quality by leveraging the higher absorption of visible light by metals (’489 Patent, col. 10:46-51; Compl. ¶53).
- Asserted Claims: Independent claim 1 and dependent claims 2, 4, and 5 (Compl. ¶52).
- Accused Features: The TruPrint 3000 and TruPrint 5000 Green Edition are accused of infringement. The complaint alleges these products are metal 3D printers that use a visible-spectrum laser and meet the claimed power levels and material processing capabilities (Compl. ¶¶55-56, 63, 65, 67).
U.S. Patent No. 12,220,764 - "Visible Laser Welding of Electronic Packages, Automotive Electrics, Battery and Other Components"
- Technology Synopsis: This patent addresses the challenges of welding highly reflective conductive elements used in batteries and electronics, where conventional lasers can be inefficient and produce inconsistent results (’764 Patent, col. 1:21-34). The invention is a method for joining two metal components using a "blue laser beam" in a process where the laser intensity at the weld site "does not need to be appreciably changed," suggesting a highly stable and controllable welding process enabled by the high absorption of blue light (’764 Patent, claim 17; Compl. ¶72).
- Asserted Claims: Independent claim 17 (Compl. ¶71).
- Accused Features: The TruDisk Series products are accused of performing the patented method. The complaint alleges that the accused products' 515 nm green laser falls within the patent's claimed definition of a "blue laser beam" and performs a stable welding process with constant laser power (Compl. ¶¶75, 76).
III. The Accused Instrumentality
Product Identification
- The Accused Products are laser 3D printing machines and laser sources, including the TruDisk Series (specifically TruDisk 1020, 2021, 3022, Pulse 421), the TruPrint 3000, and the TruPrint 5000 Green Edition (Compl. ¶1, 44, 52). Exhibit 6 of the complaint provides images of the Accused Products (Compl. ¶26).
Functionality and Market Context
- The TruPrint 5000 Green Edition is described as a 3D printing system that uses a green laser light (515 nm wavelength) to process highly reflective materials like copper, which is difficult with traditional infrared lasers (Compl. ¶30). The TruDisk Series is identified as a product portfolio for copper welding, with specific models specialized for deep penetration or spot welding (Compl. ¶45). The complaint alleges these products are sold through distributors and sales representatives across the United States, including via a website that helps customers locate "Smart Factory locations" in North America (Compl. ¶¶6, 25). The complaint includes a screenshot from Defendant's website showing its sales and consulting presence (Compl. Ex. 5).
IV. Analysis of Infringement Allegations
’536 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. a laser light source that generates a coherent beam of visible light by stimulated Raman scattering | The laser light source of the TruPrint 5000 Green Edition allegedly generates a coherent beam of visible light using a "non-linear approach, such as stimulated Raman scattering." | ¶33 | col. 4:3-6 |
| b. a solid substrate in optical communication with said laser light source, the visible light having a wavelength greater than 400 nm and less than 750 nm and selected to melt, soften or both the substrate without chemically reacting the substrate | The TruPrint 5000 Green Edition uses a solid substrate in the form of a powder bed and operates with a visible light wavelength of 515 nm, which is used to melt or soften the substrate. | ¶¶34, 35, 36 | col. 8:63-65 |
| c. a scanning module downstream of said laser light source... adapted to generate a scanning motion of said coherent beam... which scanning motion corresponds to a predetermined shape of said three-dimensional object | The TruPrint 5000 Green Edition has a scanning module that directs the laser beam to create a predetermined 3D object shape. | ¶37 | col. 8:1-11 |
| d. a computer control system operatively coupled to said laser light source and said scanning module, wherein said computer control system is programmed to (i) control said scanning motion... and (ii) a power of said laser light source, to form said object from said substrate | The TruPrint 5000 Green Edition has a computer control system (e.g., TruControl and TruTops Print software) that is programmed to control the scanning motion and laser power to form an object. | ¶38 | col. 4:11-15 |
- Identified Points of Contention:
- Technical Questions: The complaint alleges the accused laser source uses a "non-linear approach, such as stimulated Raman scattering" (Compl. ¶33). A central evidentiary question will be whether the accused product’s laser generation technology actually functions via stimulated Raman scattering, as explicitly required by the claim, or through a different non-linear optical process.
- Scope Questions: The claim requires a "solid substrate." The complaint alleges a "powder bed" meets this limitation (Compl. ¶34). The litigation may raise the question of whether a powder bed, which is a collection of discrete particles, falls within the scope of the term "solid substrate" as used in the patent.
’562 Patent Infringement Allegations
| Claim Element (from Independent Claim 70) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. placing a work piece in a laser system; wherein the work piece comprises placing a first piece of copper based material in contact with a second piece of copper material | The TruDisk Series is used in a laser system to weld a workpiece composed of two pieces of copper-based material. | ¶47 | col. 17:35-41 |
| b. directing a blue laser beam at the work piece, whereby a keyhole mode weld is formed... wherein the weld comprises a HAZ and a resolidification zone. | The TruDisk Series allegedly directs a "blue" laser beam operating at 515 nm to form a keyhole mode weld, a heat-affected zone (HAZ), and a re-solidification zone. | ¶48 | col. 1:30-44 |
- Identified Points of Contention:
- Scope Questions: The most significant point of contention appears to be definitional. The claim requires a "blue laser beam," while the complaint alleges the accused product uses a green laser with a 515 nm wavelength (Compl. ¶48). The case may depend heavily on whether the term "blue laser beam," as defined in the patent, can be construed to encompass the 515 nm wavelength, an issue further analyzed in Section V.
- Technical Questions: The claim requires the formation of a "keyhole mode weld." An evidentiary question will be whether the accused TruDisk Series, when operated as intended for copper welding, necessarily creates this specific type of deep-penetration weld, as opposed to a conduction-mode or other type of weld.
V. Key Claim Terms for Construction
- The Term: "stimulated Raman scattering" (from ’536 Patent, claim 1)
- Context and Importance: This term defines the specific physical process for generating the claimed laser light. Its construction is critical because infringement depends on whether the accused product's laser source operates via this exact mechanism. Practitioners may focus on this term because the complaint's allegation is qualified ("such as stimulated Raman scattering"), suggesting potential ambiguity about the accused product's actual method of operation (Compl. ¶33).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent’s summary describes the invention as providing systems for generating "high power, high brightness visible laser radiation" more generally, with SRS being one described method to achieve that outcome, which may support an argument that the specific mechanism is less central than the overall system configuration (’536 Patent, col. 2:46-49).
- Evidence for a Narrower Interpretation: The claim explicitly recites this technical process. The detailed description explains the SRS process in detail, including how it is used to "combine the outputs of the individual laser diodes into a single mode output," suggesting it is a specific and integral part of the claimed solution (’536 Patent, col. 2:54-58).
- The Term: "blue laser beam" (from ’562 Patent, claim 70)
- Context and Importance: This term is central to the dispute for the ’562 Patent (and the ’764 Patent), as the plaintiff alleges a 515 nm green laser meets this limitation. The outcome of the case may turn on whether the court construes "blue" to include a wavelength commonly understood as "green."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint alleges the patent implies a range of "400 nm to about 500 nm +/- 10%," which would extend up to 550 nm and cover the accused wavelength (Compl. ¶48). The patent specification defines "blue laser beams" as having a wavelength "from about 400 nm to about 500 nm," and a party could argue that the term "about" allows for some flexibility beyond 500 nm (’562 Patent, col. 2:45-50).
- Evidence for a Narrower Interpretation: The patent consistently and repeatedly uses the term "blue laser," not "visible" or "green," to describe the invention. The specification defines distinct wavelength ranges for "visible," "blue," and "green" lasers, suggesting the patentee intended these terms to be distinct (’562 Patent, col. 2:36-55). A defendant may argue that construing "blue" to include 515 nm would render these distinctions meaningless.
VI. Other Allegations
- Indirect Infringement: For all four asserted patents, the complaint alleges induced infringement under 35 U.S.C. § 271(b). The allegations are based on Defendants’ alleged knowledge of the patents as of the filing of the complaint and on accusations that Defendants "actively encourage and instruct their customers and end users to use the Accused Products" in an infringing manner (Compl. ¶¶40, 50, 69, 87).
- Willful Infringement: The complaint does not contain a separate count for willful infringement. However, the prayer for relief requests enhanced damages under 35 U.S.C. § 284 (Compl. p. 16, ¶G), and the inducement allegations are predicated on knowledge of the patents from the date the complaint was served, which may form the basis for a post-suit willfulness claim.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term “blue laser beam,” which the ’562 Patent specification defines as extending to "about 500 nm," be construed to encompass the accused products’ 515 nm green laser? The resolution of this claim construction dispute will be dispositive for at least two of the four asserted patents.
- A key evidentiary question will be one of technical mechanism: for the ’536 Patent, does the accused TruPrint 5000 laser source generate light via the specific process of "stimulated Raman scattering" as required by claim 1, or does it employ a different technology that falls outside the literal scope of the claim?
- The case also raises a question of infringement equivalence: if direct infringement is not found on the term "blue laser beam," the analysis may shift to whether the accused 515 nm green laser performs substantially the same function (welding copper) in substantially the same way (via high absorption) to achieve the same result (a stable, high-quality weld) under the doctrine of equivalents.