DCT
1:25-cv-07387
Artificial Intelligence Industry Association Inc v. Geisel Software Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Artificial Intelligence Industry Association, Inc. (Florida)
- Defendant: Geisel Software, Inc. (Delaware)
- Plaintiff’s Counsel: Michael G. Newell
- Case Identification: 1:25-cv-07387, S.D.N.Y., 09/05/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district, including selling and offering for sale its software products to New York customers, such as the iRobot Corporation. Plaintiff reserves the right to amend its venue contentions pending discovery into Defendant's "regular and established place of business."
- Core Dispute: Plaintiff alleges that Defendant’s synthetic image generation platform, Symage AI, infringes three patents related to stereoscopic 3D video processing and the generation of synthetic image data for training machine learning models.
- Technical Context: The lawsuit concerns the generation of synthetic data, a critical technology for training and validating computer vision and artificial intelligence systems, which requires vast and diverse datasets that can be difficult to capture from the real world.
- Key Procedural History: Prior to filing, Plaintiff sent Defendant a formal demand letter identifying the Asserted Patents and offering a license, which Plaintiff alleges was rejected as Defendant continued its accused activities.
Case Timeline
| Date | Event |
|---|---|
| 2015-04-29 | Earliest Priority Date for U.S. Patent No. 10,075,693 |
| 2015-04-29 | Earliest Priority Date for U.S. Patent No. 9,930,315 |
| 2018-03-27 | U.S. Patent No. 9,930,315 Issued |
| 2018-09-11 | U.S. Patent No. 10,075,693 Issued |
| 2018-10-19 | Earliest Priority Date for U.S. Patent No. 11,257,272 |
| 2022-02-22 | U.S. Patent No. 11,257,272 Issued |
| 2025-09-05 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,930,315 - "Stereoscopic 3D Camera for Virtual Reality Experience"
The Invention Explained
- Problem Addressed: The patent describes the challenge of creating an immersive virtual reality (VR) experience using captured video, which requires not only capturing images from two different perspectives (stereoscopic) but also accounting for user head movement and potential video instability during capture (’315 Patent, col. 2:30-34, col. 8:1-12).
- The Patented Solution: The invention is a stereoscopic device that captures wide-angle 3D images and embeds calibration and sensor data (e.g., from a gyroscope) directly into the video file (’315 Patent, col. 4:3-12). During playback in a VR headset, this embedded data is used to stabilize the video and adjust the viewing perspective in real-time based on the user's head orientation, creating a more seamless and immersive experience (’315 Patent, col. 8:1-26).
- Technical Importance: This approach sought to integrate the capture and playback processes for VR video, enabling dynamic adjustments that could correct for capture-time motion and respond to user-time movement without separate, complex post-processing steps (’315 Patent, col. 7:1-12).
Key Claims at a Glance
- The complaint asserts at least Claim 1 (Compl. ¶46).
- Independent Claim 1 is a method claim with the following essential elements:
- Recording sequences of stereoscopic images using multiple image sensors of a stereoscopic video recording device.
- Combining the recorded sequences into a stereoscopic video sequence.
- Embedding calibration information into the stereoscopic video sequence in real time as the images are being recorded, wherein the embedding includes both a static calibration information component and a time-varying calibration information component.
- The complaint also alleges infringement of dependent claims, including Claim 7 (Compl. ¶26). It reserves the right to assert additional claims.
U.S. Patent No. 10,075,693 - "Embedding Calibration Metadata Into Stereoscopic Video Files"
The Invention Explained
- Problem Addressed: The patent identifies a need for a standardized way to embed camera and sensor parameters (e.g., lens distortion, accelerometer data) directly into a stereoscopic 3D video file so that a playback device can properly decode and render the video, especially when video from different cameras is combined (’693 Patent, col. 1:49-65).
- The Patented Solution: The invention proposes a system where a stereoscopic camera obtains a video feed and contemporaneous metadata feeds (e.g., from an IMU, GPS). It then embeds this metadata into the video file in real-time using specific data channels like the subtitles or closed captioning fields, allowing the timing of the metadata to be synchronized with the video frames (’693 Patent, col. 2:16-34; col. 10:11-20).
- Technical Importance: By using existing data structures within video file formats (like subtitle tracks), this method aimed to create a self-contained video file that carried its own calibration and sensor data, simplifying playback and ensuring synchronization without requiring proprietary file types or sidecar data files (’693 Patent, col. 7:56-65).
Key Claims at a Glance
- The complaint asserts at least Claims 1, 3, and 6 (Compl. ¶32).
- Independent Claim 1 is a system claim with the following essential elements:
- A computer store containing a stereoscopic video feed and a plurality of contemporaneous metadata feeds.
- A computer processor programmed to obtain the video and metadata feeds.
- The processor is further programmed to embed the metadata feeds into the video feed in real-time as it is recorded.
- The embedding is performed by encoding the metadata into the subtitles or closed captioning metadata fields of the video file format, linking the timing of the metadata to the timing of the subtitle/captioning data.
- The complaint reserves the right to assert additional claims.
U.S. Patent No. 11,257,272 - "Systems and Methods for Generating Labeled Image Data for Machine Learning Using a Multi-Stage Image Processing Pipeline"
The Invention Explained
- Technology Synopsis: The patent addresses the need for large, high-quality, and varied datasets to train machine learning models for computer vision tasks (’272 Patent, col. 2:38-51). The invention describes a system for automatically generating synthetic image data by constructing virtual 3D scenes, placing virtual cameras with specific, real-world-simulating parameters, and rendering not only images but also additional data channels like depth maps and segmentation masks (’272 Patent, col. 4:21-44).
Key Claims at a Glance
- Asserted Claims: The complaint asserts at least Claim 1 and recites elements of method Claim 17 (Compl. ¶16, ¶69).
- Accused Features: The complaint alleges that Defendant's "synthetic image generation platform," including its "virtual camera" pipeline, photorealistic labeling engine, and simulation of 3D environments, infringes the ’272 Patent (Compl. ¶30-31).
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant’s “Symage AI” platform and related “Synthetic Data Generation Platforms, APIs, and tools for Dataset Creation” (Compl. ¶1-2).
Functionality and Market Context
- The complaint alleges that Symage AI is a service that generates "AI-generated synthetic images for training machine learning models" (Compl. ¶1). This is described as a "fully automated 3D-to-2D rendering pipeline" that uses synthetic 3D scenes and virtual cameras to generate images and associated labels, such as depth maps and segmentation masks (Compl. ¶21).
- The platform is alleged to provide these services to customers via a commercial SaaS platform and APIs, allowing developers to request batches of training data (Compl. ¶21, ¶23). The complaint asserts that these services directly compete with Plaintiff’s offerings in the AI imaging market (Compl. ¶3, ¶37).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
U.S. Patent No. 9,930,315 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a method for recording stereoscopic 3D video, comprising: recording sequences of stereoscopic images by multiple image sensors of a stereoscopic video recording device; | Defendant's system allegedly performs a method for recording stereoscopic 3D video that includes recording sequences of stereoscopic images using multiple image sensors. | ¶27(a) | col. 13:19-22 |
| combining the recorded sequences of stereoscopic images into a stereoscopic video sequence; and | Defendant's system allegedly captures wide-angle 3D images and videos and provides them for virtual reality applications. | ¶25 | col. 13:23-25 |
| embedding calibration information into the stereoscopic video sequence in a real time as the sequences of stereoscopic images are being recorded... | Defendant's system allegedly includes features for "metadata embedding for camera and sensor parameters." | ¶25 | col. 13:26-30 |
| said embedding comprising: ...a first way comprising embedding a static calibration information once per the stereoscopic video sequence, the static calibration information comprising a lens distortion... | Defendant's system allegedly embeds camera and sensor parameters, such as lens distortion and 3D calibration metadata, into the video file. | ¶27(b) | col. 13:30-39 |
| a second way comprising embedding a time varying calibration information once per frame of the stereoscopic video sequence, the time varying calibration information comprising inertial measurement data... | The complaint alleges Defendant's system supports real-time recalibration during video capture and playback adjustments based on user head orientation in a virtual reality environment. | ¶24 | col. 13:39-44 |
Identified Points of Contention
- Scope Questions: A central question may be whether the claim term "stereoscopic video recording device," which the patent describes as a physical camera with lenses and image sensors, can be construed to read on Defendant’s Symage AI, which is alleged to be a software platform that uses "virtual camera" pipelines (Compl. ¶31). The analysis will likely focus on whether a software-based image generator can be considered a "device" that "records" images using "multiple image sensors" within the meaning of the claims.
- Technical Questions: The complaint alleges Defendant's system performs a "method for recording" video, but the accused product is described as a synthetic data generator. A key factual question will be whether the process of generating synthetic images in software is technically equivalent to the claimed method of "recording sequences of stereoscopic images" and "combining" them, which in the patent's context appears to refer to processing signals from physical hardware (’315 Patent, col. 16:1-12).
U.S. Patent No. 10,075,693 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A computerized system for recording stereoscopic three-dimensional (3D) video on a stereoscopic camera device comprising: (a) a computer store containing data, wherein the data comprises: a stereoscopic video feed... and a plurality of contemporaneous metadata feeds... | Defendant is alleged to offer a platform that generates labeled visual datasets, which includes a multi-stage rendering process based on 3D scenes and annotations, implying the use of stored video and metadata. | ¶21 | col. 9:55-64 |
| b) a computer processor in the stereoscopic video capture device... programmed to: obtain the stereoscopic video feed from the computer store... | Defendant's system allegedly uses a proprietary pipeline with camera simulation and physics-based rendering, which would require a processor to obtain and manipulate stored scene and camera data. | ¶21 | col. 9:65-10:2 |
| embedding, in real-time as the stereoscopic video feed is recorded, the stereoscopic video feed with the plurality of contemporaneous metadata feeds... | Defendant's system is alleged to embed calibration metadata into 3D stereoscopic image and video files for the purpose of training computer vision systems. | ¶32 | col. 10:4-8 |
| wherein the plurality of contemporaneous metadata feeds is embedded into the stereoscopic video feed by encoding the contemporaneous metadata feeds into the subtitles or closed captioning metadata fields of the video file format... | The complaint does not specify how Defendant's system allegedly embeds metadata or whether it uses subtitle or closed captioning fields to do so. | ¶32 | col. 10:14-18 |
Identified Points of Contention
- Scope Questions: The interpretation of "subtitles or closed captioning metadata fields" will be critical. The patent teaches using these specific, standardized fields to carry the metadata (’693 Patent, col. 7:56-65). The infringement analysis will question whether Defendant's proprietary data generation pipeline, which creates modern data files for machine learning, uses anything technically equivalent to these legacy video features.
- Technical Questions: The complaint provides no detail on the specific mechanism Symage AI uses to associate metadata with its synthetic images. A key evidentiary question will be whether Defendant’s method of generating labeled datasets—which may involve creating separate files for images and labels, or embedding metadata in a proprietary format—performs the specific function of "encoding the contemporaneous metadata feeds into the subtitles or closed captioning metadata fields" as required by the claim.
V. Key Claim Terms for Construction
For the ’315 Patent
- The Term: "stereoscopic video recording device"
- Context and Importance: This term appears central to the dispute, as the patent describes a physical hardware device, while the accused instrumentality is a software platform. The viability of the infringement claim may depend on whether this term can be construed broadly enough to cover a software-based "virtual camera" system.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves do not explicitly require the device to be physical hardware, referring generally to "multiple image sensors" and a "recording device" (e.g., ’315 Patent, col. 13:19-22). A party might argue these are functional terms not limited to a specific physical embodiment.
- Evidence for a Narrower Interpretation: The detailed description repeatedly illustrates the invention as a physical camera with "two wide-angle lenses (e.g., fish-eye lenses)," "two digital image sensors," a "head mount device," and an "IMU" (’315 Patent, col. 2:1-31). The abstract and figures also exclusively depict a physical camera device. This may support a narrower construction limited to hardware.
For the ’693 Patent
- The Term: "encoding the contemporaneous metadata feeds into the subtitles or closed captioning metadata fields of the video file format"
- Context and Importance: This term defines the specific technical mechanism for embedding metadata. Practitioners may focus on this term because modern synthetic data formats may not use traditional "subtitle" or "closed captioning" tracks. The infringement question will turn on whether Defendant’s method meets this specific limitation, either literally or under the doctrine of equivalents.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue this term should be interpreted functionally to mean any method of time-syncing metadata within a video file container, asserting that subtitle fields are just one example of such a mechanism. The patent mentions utilizing "metadata channels in the video file format, such as subtitle or closed caption metadata fields," which could be read to imply that these are examples, not exclusive limitations (’693 Patent, col. 7:59-62).
- Evidence for a Narrower Interpretation: Claim 1 explicitly recites "the subtitles or closed captioning metadata fields," not a broader functional equivalent. The specification describes decoding this metadata specifically from "subtitle or closed captioning fields" during playback (’693 Patent, col. 9:9-11). This suggests the invention was directed to this particular technical solution, potentially limiting the claim scope to that implementation.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement under 35 U.S.C. § 271(b) by asserting Defendant provides "tutorials, user guides, and other implementation resources on its website that facilitate the use of the infringing features" (Compl. ¶34). It alleges contributory infringement under § 271(c) by claiming Defendant provides software modules "exclusively designed and marketed for the infringing functionalities, with no substantial non-infringing use" (Compl. ¶36).
- Willful Infringement: Willfulness is alleged based on both pre- and post-suit knowledge. The complaint alleges Defendant had pre-suit knowledge of the patents "at least as of the date it received AIIA's demand letter" and also based on general "industry monitoring" (Compl. ¶34, ¶41). It further alleges that Defendant's "continued promotion and use of the accused features" after receiving notice constitutes deliberate disregard for Plaintiff's patent rights (Compl. ¶41).
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to present several fundamental questions of technology and claim scope for the court's determination.
- A core issue will be one of definitional scope: can the term "stereoscopic video recording device," rooted in the patent's context of a physical camera, be construed to cover the accused "virtual camera" software platform that generates synthetic imagery? The resolution of this question may determine the applicability of the ’315 patent to the accused products.
- A second primary issue will be one of technical implementation: does the accused Symage AI platform, which generates datasets for machine learning, practice the specific method of "embedding" metadata by "encoding" it into "the subtitles or closed captioning metadata fields" as required by claims of the ’693 patent? The case may require a detailed technical comparison between the accused data-packaging methods and the specific mechanism disclosed and claimed in the patent.
- An overarching evidentiary question will be one of mapping allegations to reality: the complaint's infringement theories are based on high-level descriptions of the accused platform from its website. Discovery will be critical to determine how the Symage AI system actually functions and whether its internal architecture and data formats align with the specific limitations recited in the asserted patent claims.