VDPP LLC v. Janam Tech LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: VDPP, LLC (Oregon)
  • Defendant: Janam Technologies LLC (Delaware)
  • Plaintiff’s Counsel: David J. Hoffman
• Case Identification: 1:25-cv-05391, E.D.N.Y., 09/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and has committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s image processing and image capture systems and services infringed two now-expired patents related to electronically controlled spectacles and methods for modifying video images to create 3D visual effects.
• Technical Context: The patents-in-suit describe technology for creating 3D illusions from standard 2D video by using electronically controlled spectacles with variable tint lenses that are synchronized with motion in the video, as well as methods for processing video frames to enhance these effects.
• Key Procedural History: Plaintiff is a non-practicing entity. The complaint notes that both patents-in-suit have expired and that damages are sought for infringement that occurred prior to expiration. Plaintiff also discloses that it and its predecessors have entered into settlement licenses with other entities but asserts that none of these licenses were for the production of a patented article.

Case Timeline

Date	Event
2001-01-23	Earliest Priority Date for ’452 and ’380 Patents
2016-08-23	U.S. Patent No. 9,426,452 Issues
2018-07-10	U.S. Patent No. 10,021,380 Issues
2022-01-22	U.S. Patent No. 9,426,452 Expires
2022-08-15	U.S. Patent No. 10,021,380 Expires
2025-09-25	Complaint Filed

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

U.S. Patent No. 9,426,452 - “Faster State Transitioning for Continuous Adjustable 3Deeps Filter Spectacles Using Multi-Layered Variable Tint Materials” (issued August 23, 2016)

The Invention Explained

• Problem Addressed: The patent’s background section describes the technical challenge of "slow transition time" in electronically controlled variable tint spectacles used for creating 3D effects from 2D movies. This slowness can prevent the lenses from synchronizing properly with on-screen motion, diminishing the visual effect (’452 Patent, col. 2:24-40). The patent also notes that some materials have a limited "cycle life," meaning they can fail after a certain number of transitions (’452 Patent, col. 2:56-58).
• The Patented Solution: The invention proposes fabricating the spectacle lenses using multiple layers of electronically controlled variable tint material (’452 Patent, col. 2:48-55). This multi-layer construction is claimed to enable faster transitions between different levels of darkness, as the required electrical potential can be applied for a shorter period to achieve a target optical density (’452 Patent, col. 2:60-62). The system includes a control unit to independently manage the state of the left and right lenses based on signals corresponding to the video content (’452 Patent, Abstract; Fig. 3).
• Technical Importance: This approach aimed to improve the performance and responsiveness of active eyewear designed to generate 3D illusions, making the effect more robust and commercially viable.

Key Claims at a Glance

The complaint asserts claims 1-4 (Compl. ¶9). Independent claim 1 is an apparatus claim directed to a system.

• A system for presenting a video comprising an apparatus, which includes:
  • a storage adapted to store one or more image frames; and
  • a processor adapted to reshape a portion of at least one of the image frames and cause the frames to be displayed.
• The system further comprises an electrically controlled spectacle, which includes:
  • a spectacle frame with optoelectronic lenses (left and right), each having a plurality of states; and
  • a control unit adapted to control the state of each lens independently.
• Each lens has a dark state and a light state.
• The control unit places both the left and right lens to a dark state when viewing the video.

U.S. Patent No. 10,021,380 - “Faster State Transitioning for Continuous Adjustable 3Deeps Filter Spectacles Using Multi-Layered Variable Tint Materials” (issued July 10, 2018)

The Invention Explained

• Problem Addressed: The patent describes methods for creating visual illusions of continuous motion from a finite number of still pictures (’380 Patent, col. 8:50-57). Conventional motion pictures require a continuous series of unique frames, which can be data-intensive. The patent seeks to create the appearance of seamless movement using a limited set of source images.
• The Patented Solution: The invention is a method for modifying video by acquiring a sequence of image frames and then computationally generating new, modified frames. The method involves steps like "expanding" and "combining" portions of the source frames to generate a "modified combined image frame" that, when displayed, creates a visual illusion of motion (’380 Patent, Abstract; col. 112:50-113:9). This process can involve creating "bridge frames" or "blended frames" to smooth the transition between a small number of source images (’380 Patent, col. 8:50-9:5).
• Technical Importance: This technology provides a method for post-processing standard 2D video to create complex visual and motion effects without requiring specialized cameras or 3D filming techniques.

Key Claims at a Glance

The complaint asserts claims 1-30 (Compl. ¶14). Independent claim 1 is a method claim.

• Acquiring a source video comprising a sequence of image frames.
• Identifying a first and second image frame from the sequence.
• Expanding the first image frame to generate a modified first image frame.
• Expanding the second image frame to generate a modified second image frame.
• Combining the modified first and second image frames to generate a modified combined image frame having specific dimensional properties.
• Displaying the modified combined image frame.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, methods, or services by name. It refers generally to Defendant’s "systems, products, and services in the field of image processing" in relation to the ’452 Patent and "image capture devices" in relation to the ’380 Patent (Compl. ¶9, ¶14).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused instrumentalities.

IV. Analysis of Infringement Allegations

The complaint references preliminary infringement charts as Exhibits B and D but does not attach them (Compl. ¶10, ¶15). No probative visual evidence provided in complaint.

For the ’452 Patent, the complaint alleges that Defendant "maintains, operates, and administers" systems that infringe claims 1-4 by putting the claimed inventions "into service (i.e., used them)" (Compl. ¶9). This suggests a theory of infringement based on the use of a complete system that includes both an image processing apparatus and the claimed electronically controlled spectacles.

For the ’380 Patent, the complaint alleges that Defendant "maintains, operates, and administers" systems and services related to "image capture devices" that infringe claims 1-30 (Compl. ¶14). This suggests a theory based on the performance of the claimed methods for modifying video images.

• Identified Points of Contention:
  • Evidentiary Questions: The central issue will be evidentiary. The complaint lacks any specific facts linking an accused product to the patent claims. A key question will be what evidence Plaintiff provides to demonstrate that Defendant's unspecified products perform the functions recited in the claims, such as reshaping image frames (’452 Patent) or expanding and combining frames to create a "modified combined image frame" (’380 Patent).
  • System Claim Questions (’452 Patent): Claim 1 of the ’452 Patent is a system claim requiring both a processing apparatus and an "electrically controlled spectacle." A potential point of contention may be whether Defendant makes, uses, or sells such a complete system, or whether Plaintiff will need to prove that Defendant's apparatus is used in combination with spectacles provided by a third party.

V. Key Claim Terms for Construction

• For the ’452 Patent:

  • The Term: "reshape a portion of at least one of the one or more image frames" (Claim 1)
  • Context and Importance: This term defines a core function of the processor in the claimed apparatus. The scope of "reshape" will be critical to determining infringement, as it distinguishes the claimed invention from general-purpose video processing. Practitioners may focus on this term because its plain meaning could be very broad.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself is not explicitly defined, which may support an interpretation based on its plain and ordinary meaning, covering any alteration to a part of an image.
    • Evidence for a Narrower Interpretation: The specification repeatedly describes the purpose of modifying frames as creating specific visual illusions, such as "continuous movement" from a limited set of pictures (’452 Patent, col. 3:26-32). This context may support a narrower construction requiring a transformation specifically intended to create such an illusion, rather than any generic image alteration.

• For the ’380 Patent:

  • The Term: "expanding the first image frame to generate a modified first image frame" (Claim 1)
  • Context and Importance: This is a key active step in the claimed method. Whether Defendant's technology performs this "expanding" step will be a central infringement question. The dispute may turn on whether "expanding" simply means enlarging an image or if it requires the more complex processes described in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A defendant could argue the term should be given its plain meaning of making an image larger or increasing its dimensions.
    • Evidence for a Narrower Interpretation: The specification describes a process of generating "blended" or "bridge" frames from source images to create the appearance of motion (’380 Patent, col. 8:50-9:5). A party may argue that "expanding" should be construed as a term of art within the patent, referring to this specific method of frame generation rather than simple scaling.

VI. Other Allegations

• Willful Infringement: The complaint's prayer for relief seeks a declaration of willful infringement and treble damages (Compl. ¶VII.e). However, the body of the complaint does not plead any specific facts to support this claim, such as allegations that Defendant had pre-suit knowledge of the patents-in-suit.

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

• A primary issue will be evidentiary sufficiency: Given the complaint’s lack of factual allegations identifying specific accused products or detailing their operation, a key question is what evidence Plaintiff will produce to connect Defendant's technology to the specific limitations of the asserted claims.
• A central question will be one of technical application and scope: Do Defendant’s accused "image processing" and "image capture" systems perform the highly specific methods of generating modified, blended, and combined video frames for creating 3D illusions as claimed, or do they employ fundamentally different and non-infringing technologies?
• A further question concerns the basis for willfulness: As the complaint seeks enhanced damages but pleads no facts suggesting Defendant's pre-suit knowledge of the now-expired patents, the case may raise the question of what post-complaint conduct or other evidence Plaintiff will rely on to meet the legal standard for willful infringement.