DCT
5:24-cv-00482
LightGuide Inc v. Arkite NV
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: LightGuide, Inc. (Delaware)
- Defendant: Arkite NV (Belgium)
- Plaintiff’s Counsel: Barclay Damon LLP; Gardner, Linn, Burkhart & Ondersma LLP
- Case Identification: 5:24-cv-00482, N.D.N.Y., 04/08/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendant does business in the district, targets New York with marketing, derives substantial revenue from sales in the state, and has made at least one proposal for sale to an entity within the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Arkite Vision" augmented reality operator guidance systems infringe two patents related to using projected light and sensors to guide and error-proof manual assembly tasks.
- Technical Context: The technology at issue falls within the domain of augmented reality for manufacturing, where projected visual cues guide human operators to improve the speed, accuracy, and quality of manual processes.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of the ’981 Patent on or about July 25, 2019, an event that could be significant for allegations of willful infringement and the potential calculation of damages.
Case Timeline
| Date | Event |
|---|---|
| 2005-10-07 | ’981 Patent Priority Date |
| 2009-04-07 | ’981 Patent Issue Date |
| 2011-02-11 | ’614 Patent Priority Date |
| 2017-05-23 | ’614 Patent Issue Date |
| 2019-07-25 | Alleged Written Notice of ’981 Patent to Defendant |
| 2022-02-09 | Alleged Start of U.S. Marketing via Facebook Ads |
| 2023-06-13 | Alleged Start of U.S. Marketing via LinkedIn Ads |
| 2024-04-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,515,981 - "Light Guided Assembly System" (Issued Apr. 7, 2009)
The Invention Explained
- Problem Addressed: The patent’s background section describes the significant costs and production risks associated with human error in manual assembly operations, such as missed steps or incorrect part selection, which can lead to scrapped products or field failures (’981 Patent, col. 1:19-39).
- The Patented Solution: The invention proposes a system to mitigate these errors by actively guiding an operator. It comprises a sensor to detect information about the work environment (e.g., the presence of a workpiece), a controller to process that information, and a directional light device. In response to a signal from the sensor, the controller commands the light device to project a visual cue—an “indicating light”—onto a specific location to direct the operator’s next action, such as selecting a part from a bin or performing an operation on the workpiece (’981 Patent, Abstract; col. 4:6-14).
- Technical Importance: The system provided a flexible and cost-effective method for error-proofing manual tasks, offering an alternative to more expensive and rigid fully-automated inspection stations (’981 Patent, col. 1:63-col. 2:2).
Key Claims at a Glance
- The complaint asserts at least Independent Claim 1 (’981 Patent, Compl. ¶38).
- The essential elements of Claim 1 are:
- An operational guide system.
- At least one sensor apparatus operable to detect operation information and generate an indicative output.
- A controller that receives an input signal based on the operation information and, in response, provides a command signal.
- At least one directional light device operable to project an indicating light in response to the command signal from the controller.
- The complaint does not explicitly reserve the right to assert other claims.
U.S. Patent No. 9,658,614 - "Light Guided Assembly System and Method" (Issued May 23, 2017)
The Invention Explained
- Problem Addressed: As manufacturing became more data-driven, a need arose for guidance systems that could integrate with higher-level enterprise software, such as a Manufacturing Execution System (MES), to execute more complex and dynamic assembly sequences (’614 Patent, col. 13:13-24).
- The Patented Solution: The patent describes a more advanced system where the controller contains a plurality of "programmed selectable addressed display features" (e.g., specific images, text, or instructions, each with a unique ID) and "programmed positional identifiers" (e.g., coordinates on a workpiece). The system is designed to receive input signals from a separate computer system, like an MES, which dynamically triggers the projection of specific display features onto specific physical locations (’614 Patent, Abstract). This architecture allows for the real-time creation of complex, data-driven visual guidance based on enterprise-level production data (’614 Patent, col. 13:57-col. 14:2).
- Technical Importance: This invention represents a step toward more integrated and intelligent manufacturing systems, where shop-floor guidance is directly linked to and controlled by factory-wide production planning software.
Key Claims at a Glance
- The complaint asserts at least Independent Claim 17 (’614 Patent, Compl. ¶39).
- The essential elements of Claim 17 are:
- A guide system with at least one directional light device.
- A guide system controller that includes a plurality of programmed, selectable "addressed display features" and "positional identifiers," where each display feature has a unique address identifier.
- The controller is configured to receive a sequence of input signals from a "separate computer system or controller" to trigger a guided operation.
- The controller selects specific addressed display features based on the input signals and causes the light device to project the corresponding visual indicators onto physical objects at locations defined by the positional identifiers.
- The controller is operative to receive any sequence of input signals to dynamically project a sequence of visual indicators.
- The complaint does not explicitly reserve the right to assert other claims.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is Defendant's "Arkite Vision" system, also marketed as an "AR virtual reality" system or "Digital Work Instructions" platform (Compl. ¶12).
Functionality and Market Context
The Arkite Vision system is an operator guidance platform for manufacturing that uses a projector, a 3D sensor, a vision sensor, and an "Arkite PC" to provide real-time augmented reality guidance (Compl. ¶21-23). A diagram from an Arkite promotional video identifies the system's core components, including a projector, 3D sensor, and Arkite PC (Compl. ¶21). The system projects instructions onto a workspace and can highlight parts for selection or validate an operator's actions using its 3D sensor (Compl. ¶23, ¶24). The complaint alleges the system is sold and marketed in the U.S. and can be integrated with external Manufacturing Execution Systems (MES), such as SAP, to receive operational data and instructions (Compl. ¶14, ¶18, ¶29).
IV. Analysis of Infringement Allegations
’981 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An operational guide system adapted to provide visual indicators to an individual to guide sequential actions | The Arkite Vision system is alleged to be an operation guide system that provides indicators to guide an operator’s sequential actions. | ¶38 | col. 2:4-7 |
| at least one sensor apparatus, said at least one sensor apparatus operable to detect operation information and generate an output indicative of said operation information | The system allegedly includes a 3D sensor, a vision sensor, and a scanning apparatus (e.g., barcode reader) that input information to the system. | ¶38 | col. 5:36-45 |
| a controller, said controller receiving at least a first input signal indicative of said operation information and selectively providing at least one command signal in response to said first input signal | The "Arkite PC" allegedly functions as a controller that receives information from the sensors and, in response, provides command signals for projections. | ¶38 | col. 6:20-24 |
| at least one directional light device...selectively operable to project and target at least one indicating light in response to said at least one command signal from said controller | The system's projector is alleged to be a directional light device that selectively projects indicating lights (e.g., text, highlights) onto the workspace in response to controller commands. A visual from an Arkite video shows text instructions and highlighting projected onto a workspace (Compl. ¶23). | ¶38 | col. 6:60-65 |
- Identified Points of Contention:
- Technical Questions: A technical question is whether the alleged "sensor apparatus" (e.g., the 3D sensor) provides input for guiding a subsequent step, as the patent’s feedback loop structure may suggest, or whether it primarily functions as a post-action validation check. The complaint alleges the 3D sensor "validates all operator actions," which raises the question of its precise role in the command sequence (Compl. p. 11).
- Scope Questions: A potential scope question is whether an initial input, such as a barcode scan to identify a product to be assembled (Compl. ¶22), constitutes "detect[ing] operation information" in the manner required to trigger the claimed sequence of guided steps.
’614 Patent Infringement Allegations
| Claim Element (from Independent Claim 17) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A guide system...comprising: at least one directional light device...; a guide system controller...including a plurality of programmed selectable addressed display features and a plurality of programmed positional identifiers with each...having a unique pre-programmed individual address identifier... | The complaint alleges the Arkite Vision system, when integrated with an MES, includes a controller (the "Human Interface Mate") with these claimed features. A screenshot shows the system highlighting specific parts bins, which Plaintiff may argue corresponds to projecting VDFs based on positional identifiers (Compl. ¶36). | ¶39 | col. 15:23-40 |
| said guide system controller configured to receive a sequence of one or more input signals from a separate computer system or controller to cause said guide system to project visual indicators for a particular guided operation | The system is alleged to integrate with and receive a sequence of input signals from an MES system, such as SAP. A screenshot from a promotional video shows the system waiting for and receiving "approval of ERP" (Compl. ¶33). | ¶39 | col. 19:62-65 |
| said guide system controller is configured to select one or more particular addressed display features...based on the input signals... | The system allegedly selects which visual indicators to project based on the signals it receives from the separate MES. | ¶39 | col. 20:1-4 |
| with said guide system controller causing said directional light device to project visual indicators...onto one or more physical objects at a location corresponding to a positional identifier based on said input signals | The system allegedly projects instructions and highlights onto a workbench or parts bins at specific locations based on the data received from the MES. | ¶39 | col. 20:5-10 |
| wherein said guide system controller is operative to receive any sequence of input signals...to dynamically project any sequence of said visual indicators... | The complaint alleges the integration with an MES results in the "creation of a dynamic, real time projection of visual indicators." | ¶39 | col. 20:11-20 |
- Identified Points of Contention:
- Technical Questions: The infringement theory relies heavily on marketing materials. A central technical question will be what evidence emerges from the accused system's source code and technical documentation to demonstrate that its software architecture actually uses a data structure of "addressed display features" and "positional identifiers" that are selected based on external signals from an MES.
- Scope Questions: A key scope question will be whether the term "addressed display feature" requires the specific pre-programmed, table-like structure disclosed in the patent’s embodiments (e.g., Fig. 3A) or if it can be read more broadly to cover any software object that generates a visual output when called by an external system.
V. Key Claim Terms for Construction
Term: "sensor apparatus" (’981 Patent, Claim 1)
- Context and Importance: The scope of this term is central to the infringement analysis for the ’981 Patent. Practitioners may focus on this term because its construction will determine whether any input device (like a barcode reader initiating a process) meets the limitation, or if it is restricted to devices that sense the state of the assembly operation itself (e.g., part placement).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification lists "a radio frequency identifier device, bar code reader, or the like" as examples of a "sensor apparatus", suggesting the term is not limited to in-process action sensors (’981 Patent, col. 5:42-45).
- Evidence for a Narrower Interpretation: The overall context describes a system for guiding "sequential actions," and embodiments detail sensors that detect the withdrawal of a part from a bin or the completion of a step, which may support an interpretation that the sensor must detect information about the progress of the operation (’981 Patent, col. 9:11-30; col. 10:36-47).
Term: "addressed display feature" (’614 Patent, Claim 17)
- Context and Importance: This term is the core of the asserted claim of the ’614 Patent. Practitioners may focus on this term because infringement will likely depend on whether the Arkite Vision system's software architecture can be shown to use a data structure analogous to the claimed "addressed display features."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language is functional, describing a "selectable" feature with an "address identifier." This could be argued to cover any software system where distinct visual outputs can be called or triggered by an external data signal.
- Evidence for a Narrower Interpretation: The specification discloses a detailed embodiment of a "VDF address table" where specific graphical and textual outputs are explicitly mapped to unique identifiers (e.g., "A1" for "Select 1"). This specific, table-based architecture could be used to argue for a narrower construction limited to such pre-programmed, lookup-style systems (’614 Patent, Fig. 3A; col. 15:23-40).
VI. Other Allegations
Indirect Infringement
The complaint alleges inducement by asserting that Defendant's marketing materials, videos, and user instructions actively encourage and instruct customers on how to use the Arkite Vision system in an infringing manner (Compl. ¶42, ¶52). It further alleges contributory infringement, stating the systems are specially made for infringement and are not staple articles of commerce (Compl. ¶43, ¶53).
Willful Infringement
The complaint pleads willfulness for both patents. It alleges Defendant had pre-suit knowledge of the ’981 Patent via written notice provided on or around July 25, 2019, and post-suit knowledge of both patents from the filing of the action (Compl. ¶10, ¶44, ¶54).
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of "architectural mapping": Does the underlying software architecture of the Arkite Vision system, particularly its interface with MES platforms, actually implement the specific data structure of "addressed display features" with "unique...address identifiers" as required by the ’614 Patent, or is there a fundamental mismatch between the patent's specific disclosure and the accused product's implementation?
- A central claim construction issue will be one of "functional scope": For the ’981 Patent, must the claimed "sensor apparatus" be part of a dynamic feedback loop that detects the completion of one operational step to trigger the next, or is it sufficient for the sensor to provide a single input (like a barcode scan) that initiates a pre-set sequence of guided actions?
- A significant question for damages will be one of "culpability and timing": Given the 2019 pre-suit notice allegation for the ’981 Patent, the court will likely examine Defendant’s conduct after that date to determine whether any infringement was willful, which could expose the defendant to enhanced damages.