Brooks Automation US LLC v. Planar Motor Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Brooks Automation US, LLC (Delaware)
  • Defendant: Planar Motor, Inc. (Canadian)
  • Plaintiff’s Counsel: Brownstein Hyatt Farber Schreck, LLP; DLA Piper LLP (US)
• Case Identification: 3:25-cv-00532, D. Nev., 09/30/2025
• Venue Allegations: Venue is alleged to be proper in the District of Nevada because Defendant is a Canadian corporation that has committed acts of patent infringement in Nevada and regularly solicits and transacts substantial business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s magnetic levitation motor systems infringe patents related to multi-dimensional position sensors for robotic transport.
• Technical Context: The technology at issue involves high-precision position sensing for automated transport systems, which is a critical component in advanced manufacturing environments such as semiconductor fabrication.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of infringement, including detailed claim charts, on April 14, 2025. It further alleges that subsequent communications regarding a potential license were refused by Defendant, which may be relevant to the allegations of willful infringement.

Case Timeline

Date	Event
2007-06-27	Priority Date for ’984 and ’513 Patents
2012-03-06	U.S. Patent No. 8,129,984 Issued
2014-08-12	U.S. Patent No. 8,803,513 Issued
2016-01-01	Defendant Planar Motor, Inc. Founded (approximate, based on "founded in 2016")
2025-04-14	Plaintiff Sent Written Notice of Infringement to Defendant
2025-09-30	Complaint Filed

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

U.S. Patent No. 8,129,984 - "Multiple Dimension Position Sensor" (issued March 6, 2012)

The Invention Explained

• Problem Addressed: The patent addresses the cost, travel range, and degree-of-freedom limitations of conventional high-precision position sensors used in applications like semiconductor manufacturing stages (’984 Patent, col. 1:37-48).
• The Patented Solution: The invention proposes a system where a movable object has an attached "field generating platen" (e.g., a magnet array) that serves for both propulsion and position measurement. Stationary sensor groups are placed along the travel path, with each individual sensor providing only "but one output signal" corresponding to field variances along a single axis. A controller processes these simple, single-axis signals to calculate a complex, "multi-dimensional position" of the movable object, which includes both its planar position and its "gap" (i.e., vertical distance) from the sensor group (’984 Patent, col. 3:36-61; Abstract). Figure 1 illustrates this core concept, showing a controller (190) receiving signals from sensors (130a-n) to determine the position of an object (120) with a magnetic platen.
• Technical Importance: This design allows for the construction of cost-effective, high-resolution, multi-axis positioning systems by using simpler, inexpensive single-axis sensors to achieve a multi-dimensional measurement result (’984 Patent, col. 3:43-49).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2 and 3 (Compl. ¶29).
• Independent Claim 1 recites an apparatus with three main components:
  • A controller;
  • A workpiece transport with a movable portion and a transport path; and
  • A multi-dimensional position measurement device, which itself includes:
    • At least one field generating platen attached to the movable portion, configured for both position measurement and propelling the movable portion; and
    • At least one sensor group positioned along the path.
• The claim further requires that each sensor provides "but one output signal corresponding to variances along a single axis," and the controller is configured to calculate a "multi-dimensional position" (including at least a planar position and a gap) based on that single output signal.

U.S. Patent No. 8,803,513 - "Multiple Dimension Position Sensor" (issued August 12, 2014)

The Invention Explained

• Problem Addressed: As a continuation of the application leading to the ’984 Patent, the ’513 Patent addresses the same technical challenges related to high-precision position sensing in automated systems (’513 Patent, col. 1:11-53; Compl. ¶16).
• The Patented Solution: The patented solution is conceptually identical to that of the ’984 Patent: using a platen for both propulsion and measurement, and processing outputs from single-axis sensors to determine a multi-dimensional position, including planar location and gap (’513 Patent, Abstract; col. 3:36-61). The primary distinction in the asserted claims is terminological, as discussed below.
• Technical Importance: The technical contribution is the same as that of the parent ’984 Patent, focused on enabling cost-effective, high-resolution, multi-axis automated transport systems.

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2 and 3 (Compl. ¶38).
• Independent Claim 1 recites an apparatus that is structurally and functionally very similar to claim 1 of the ’984 Patent, but with key terms changed:
  • It claims a "robotic actuator" instead of a "workpiece transport."
  • It refers to a "path of actuator motion" instead of a "transport path."
• The core limitations regarding the sensor's "but one output signal" and the controller's calculation of a "multi-dimensional position" including a "planar position and a gap" are present in this claim as well.

III. The Accused Instrumentality

Product Identification

The accused instrumentality is the "Planar Motor System," which is composed of "movable and independently controllable robotic XBots magnetically levitated over a stationary surface of modular Flyways under control of a Planar Motor Controller" (Compl. ¶22).

Functionality and Market Context

• The Planar Motor System is a robotic transport system where "XBots" move without contact over a grid of "Flyways" using magnetic levitation and propulsion (Compl. ¶22). The complaint provides visual evidence from a YouTube video of a demonstration at "Pack EXPO in Nevada," which shows the labeled XBots moving over the Flyway surface (Compl. p. 6, ¶24). Further visuals from events like SEMICON West and ATX West are provided to demonstrate the product's use and marketing within the United States, particularly in markets requiring high precision and cleanliness like semiconductor, pharmaceutical, and food manufacturing (Compl. pp. 7, 12; ¶26, fn. 13).
• The complaint alleges that Defendant is a "recent[]" entrant into this market, having been founded in 2016, whereas Plaintiff is a "recognized leader" with over 40 years of investment in the technology (Compl. ¶¶8-9).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products literally infringe the asserted claims but refers to claim charts in Exhibits C and E, which were not included with the filed complaint document (Compl. ¶¶30, 39). The narrative infringement theory is summarized below.

'984 Patent Infringement Allegations

The complaint alleges that the Planar Motor System infringes at least claims 1, 2, and 3 of the ’984 Patent (Compl. ¶¶29-30). The narrative theory suggests that the components of the Accused Product map onto the elements of claim 1 as follows: the "Planar Motor Controller" is the claimed "controller"; the movable "XBots" are the "workpiece transport"; and the system of magnetic "Flyways" and associated sensors constitutes the "multi-dimensional position measurement device" (Compl. ¶22). The complaint alleges this system contains each element of the asserted claims (Compl. ¶30). A screenshot from a LinkedIn post regarding the Automate 2024 exhibition shows the XBots moving on the Flyways, which Plaintiff may use as evidence of the accused system's operation (Compl. p. 8).

'513 Patent Infringement Allegations

The complaint alleges that the same Planar Motor System infringes at least claims 1, 2, and 3 of the ’513 Patent (Compl. ¶¶38-39). The infringement theory is parallel to the theory for the ’984 Patent, with the "XBots" corresponding to the claimed "robotic actuator" (Compl. ¶22). The complaint alleges that the Accused Products contain each element of the asserted claims and again refers to an external, unprovided exhibit for a detailed element-by-element comparison (Compl. ¶39).

Identified Points of Contention

• Scope Questions: The dispute may center on the construction of several claim terms. A primary question may be whether the magnetic components in the Accused Products' "Flyways" and "XBots" meet the limitation of a "field generating platen... configured for both position measurement and propelling the movable portion." Another point of contention could be the definitional scope of "workpiece transport" (’984 Patent) and "robotic actuator" (’513 Patent) and whether they read on the accused "XBots."
• Technical Questions: A core technical question for infringement will be whether the Accused Products operate as claimed. What evidence does the complaint provide that the "Planar Motor Controller" actually "calculate[s] a multi-dimensional position" that includes both "a planar position and a gap," and does so based on "but one output signal" from each individual sensor? Proving the internal software logic and signal processing of the accused system will be a central evidentiary challenge.

V. Key Claim Terms for Construction

The Term: "but one output signal corresponding to variances along a single axis" (from claim 1 of both patents)

• Context and Importance: This limitation defines the nature of the raw data used by the controller and is central to the invention's purported efficiency of using simple sensors for a complex task. The infringement analysis will depend heavily on whether the sensors in the Planar Motor System function this way, or if they provide a more complex, pre-processed, or multi-axis signal.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification refers to these sensors as "linear or single axis sensors" and gives examples such as "Hall effect sensors, inductive sensors and/or capacitive sensors," which are common and varied types (’984 Patent, col. 3:51-54, col. 3:64-66). This may support a construction covering any sensor that primarily measures a field component along a single vector.
  • Evidence for a Narrower Interpretation: The patent’s detailed description and figures illustrate specific arrangements, such as sensor "doublets" used to generate sine/cosine signals from which position is interpolated (’984 Patent, col. 6:28-42). A defendant may argue that the term is implicitly limited to sensors providing a specific type of raw signal suitable for this processing method, not any signal that could be abstractly described as "single axis."

The Term: "[a controller] configured to calculate a multi-dimensional position... [which] includes at least a planar position and a gap" (from claim 1 of both patents)

• Context and Importance: This functional language requires the controller to perform a specific, two-part calculation (planar position + gap). Infringement will require proof that the accused controller performs both functions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is broad, requiring only that the controller be "configured to" perform the calculation. Plaintiff may argue that if the accused system is capable of determining both planar position and gap, it infringes, regardless of the specific algorithm used.
  • Evidence for a Narrower Interpretation: The specification describes specific methods for calculating the gap, such as by measuring "the strength of the magnetic field (e.g. flux density)" or the "amplitude of the signals output by the sensors" (’984 Patent, col. 5:11-14). A defendant might argue that the term should be construed to require one of these disclosed methods, or at least a method where the gap and planar position are derived from the same set of sensor signals in an integrated calculation.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant provides customers with product manuals, training, and other technical information that instruct them on how to set up and use the Accused Products in an infringing manner (Compl. ¶26). It also alleges contributory infringement on the basis that the Accused Products are a material part of the patented apparatus, are not staple articles of commerce, and are especially made for use in an infringing system (Compl. ¶27).

Willful Infringement

The complaint alleges willful infringement based on Defendant's alleged knowledge of the Asserted Patents since at least April 14, 2025, the date of Plaintiff's notice letter. The complaint further alleges that Defendant has continued its infringing activities and has "explicitly stated to Brooks its intention to continue" doing so, suggesting deliberate disregard for Plaintiff's patent rights (Compl. ¶¶25, 35, 44).

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

• A core issue will be one of technical operation: Can Plaintiff produce evidence to demonstrate that the accused Planar Motor System's controller performs the specific function claimed—calculating both a planar position and a gap—by processing "but one output signal" from each of its individual sensors? The case may depend on whether the accused system's internal signal processing architecture maps onto this specific claimed methodology.
• A second key question will be one of definitional scope: Does the magnetic system of the accused XBots and Flyways meet the claim requirement of a single "field generating platen" that is "configured for both position measurement and propelling the movable portion"? The analysis may explore whether these are integrated functions as claimed or are performed by distinct, albeit related, components in the accused system.
• Finally, a central evidentiary question will be one of proof: Given that the infringement allegations appear to be based on publicly available information and product demonstrations, the case will likely turn on the extent to which Plaintiff can use discovery to prove the undisclosed internal workings of the accused system and confirm that its operation aligns with the specific limitations of the asserted claims.