PanoVision LLC v. Maronda Homes LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: PanoVision LLC (New Mexico)
  • Defendant: Maronda Homes, LLC (Pennsylvania)
  • Plaintiff’s Counsel: Golomb Legal, P.C.; Rabicoff Law LLC
• Case Identification: 2:25-cv-07268, E.D. Pa., 12/23/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant having an established place of business in the district and having committed the alleged acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s methods for marketing and selling real property infringe a patent related to systems for facilitating sales through immersive, three-dimensional visualization.
• Technical Context: The technology at issue involves computer-generated, interactive 3D environments that allow prospective buyers to virtually tour and customize properties before they are built or remodeled, a significant feature in the online real estate and construction markets.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2008-10-15	’267 Patent Priority Date
2012-01-31	’267 Patent Issue Date
2025-12-23	Complaint Filing Date

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

U.S. Patent No. 8,108,267 - "Method of facilitating a sale of a product and/or a service,"

• Issued: January 31, 2012

The Invention Explained

• Problem Addressed: The patent’s background section identifies the conventional processes for selling real estate and remodeling as "inefficient and burdensome" for both buyers and sellers (ʼ267 Patent, col. 2:10-12). It notes that buyers must visit numerous properties in person and cannot easily visualize how a finished construction or remodeling project will appear, which can lead to unsatisfactory results (’267 Patent, col. 1:12-28).
• The Patented Solution: The invention is a method that allows a user to view an "immersive three-dimensional image of a scene" that resembles an actual property on a computer display (’267 Patent, Abstract). This system enables the user to view the scene from "any vantage point and at any angle just as if the user were moving around inside or outside the actual property," providing a realistic impression of a property without a physical visit (’267 Patent, col. 2:50-54). The user can select products, such as cabinets or appliances, and see how they would look within the 3D scene, and can also virtually move between different rooms (’267 Patent, col. 10:4-10; Claim 1).
• Technical Importance: The patented method claims to provide a more efficient sales process by giving potential buyers a realistic, interactive preview of a property or renovation, allowing them to make more informed decisions without the time and cost of physical site visits or premature construction (’267 Patent, col. 2:26-35).

Key Claims at a Glance

• The complaint asserts infringement of one or more "Exemplary '267 Patent Claims" without identifying specific claims in the body of the complaint (Compl. ¶11). Independent claim 1 is representative of the patent's scope.
• Independent Claim 1: A method of facilitating a sale of a real property, comprising the steps of:
  • enabling a user of a computing device to select a real property from a plurality of real properties being offered for sale;
  • displaying, on an electronic display, an immersive three-dimensional image of a first one of a plurality of rooms of the real property that has been selected;
  • seamlessly changing a view on the electronic display in order to display an immersive three-dimensional image of a second one of the plurality of rooms of the real property on the display; and
  • enabling the user of the computing device to remove, add, and/or modify a feature shown in an image.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶11). It does not name specific products, services, or websites in the main body of the complaint, instead incorporating by reference claim charts in "Exhibit 2" (Compl. ¶17).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context. The allegations are contained within an exhibit that was not provided with the complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts provided in Exhibit 2, which was not available for this analysis (Compl. ¶¶16-17). The complaint states that the "Exemplary Defendant Products practice the technology claimed by the '267 Patent" and "satisfy all elements of the Exemplary '267 Patent Claims" (Compl. ¶16). No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent's claims and the general nature of the dispute, the infringement analysis may raise several technical and legal questions:
  • Scope Questions: A central question may be whether the Defendant's visualization tools provide an "immersive three-dimensional image" as the patent describes. The patent specification suggests a high degree of realism and freedom of movement, stating the user can view the scene "just as if the user were walking to the left and to the right in the actual property" (’267 Patent, col. 2:55-59). The analysis would need to determine if the accused functionality meets this potentially narrow definition or if a simpler 3D model suffices.
  • Technical Questions: The requirement of "seamlessly changing a view" between rooms will likely be a point of dispute. The analysis will question what evidence demonstrates that the transition between, for example, a virtual kitchen and a virtual living room on Defendant’s platform is "seamless," as opposed to a discrete loading of a new, separate webpage or model.

V. Key Claim Terms for Construction

• The Term: "immersive three-dimensional image"

• Context and Importance: This term is the core of the invention. Its construction will determine whether the accused product, likely a web-based 3D home viewer, falls within the scope of the claims. Practitioners may focus on this term because the patent's description of a user feeling "in effect immersed in the displayed three-dimensional images" suggests a higher standard than a static 3D rendering (’267 Patent, col. 4:42-44).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that axonometric projections (isometric, dimetric, etc.) are one way of displaying 3D images, which could support a construction that includes common, less-realistic 3D modeling techniques (’267 Patent, col. 4:15-19).
  • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes a "realistic impression" and the ability to view a scene "from any vantage point and at any angle just as if the user were moving around inside" (’267 Patent, col. 2:50-54). It also describes the use of stereographic images and virtual cameras, which could support a narrower construction requiring a more advanced, freely navigable virtual reality environment (’267 Patent, col. 4:26-34, 4:49-51).

• The Term: "seamlessly changing a view"

• Context and Importance: This term from claim 1 defines the transition between viewing different rooms. Its definition is critical to determining whether the accused product infringes, as many web platforms transition between views by loading separate pages, which may not be considered "seamless."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not explicitly define "seamlessly." A party could argue it simply means the user can navigate from one room to another within the same application without restarting the process.
  • Evidence for a Narrower Interpretation: The specification describes a user being able to "seamlessly move the location of the virtual camera from one scene to another scene," simulating the view a user would obtain "if the user were walking through one room represented by a scene and into another room" (’267 Patent, col. 6:54-60). This language suggests a continuous, uninterrupted transition, akin to moving through a 3D video game environment, rather than clicking a hyperlink to a new, discretely loaded scene.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that direct end users to use its products in a manner that infringes the ’267 Patent (Compl. ¶14).
• Willful Infringement: The complaint does not use the word "willful" but lays a foundation for it by alleging that the service of the complaint constitutes "actual knowledge of infringement" (Compl. ¶13). It alleges that despite this knowledge, Defendant continues to infringe, which could support a claim for post-suit willful infringement (Compl. ¶14).

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

• A core issue will be one of definitional scope: can the term "immersive three-dimensional image," which the patent describes as creating a realistic experience of "walking around the actual property," be construed to cover the potentially more limited 3D model viewers commonly used on homebuilder websites?
• A second key issue will be both legal and factual: does the transition between different room views in the accused system constitute "seamlessly changing a view" as required by the claims, or is it a series of discrete, separate interactions that fall outside the patent's scope? The interpretation of "seamlessly" will be a legal question for the court, while the technical operation of the accused product will be a factual question.
• A central evidentiary question will be whether the plaintiff can demonstrate that the defendant's system allows users to "remove, add, and/or modify a feature" (such as a wall, as claimed in dependent claims) with the level of interactivity described in the patent, or if the customization is limited to predefined options that do not meet this claim element.