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: 2:26-cv-00036, E.D. Pa., 12/23/2025
• Venue Allegations: Venue is alleged to be proper as Defendant has an established place of business within the Eastern District of Pennsylvania.
• Core Dispute: Plaintiff alleges that Defendant’s methods for marketing and selling homes infringe a patent related to systems that allow users to virtually experience and customize a property using immersive three-dimensional visualizations.
• Technical Context: The technology at issue involves computer-generated, interactive 3D environments that enable customers in the real estate and home remodeling markets to visualize properties and potential changes before committing to a purchase or construction.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

Case Timeline

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"

The Invention Explained

• Problem Addressed: The patent describes the conventional process of selling real estate as "inefficient and burdensome," requiring prospective buyers to physically visit numerous properties, which is time-consuming and often fails to convey how a property might look after remodeling or with different furnishings (’267 Patent, col. 1:28-2:24). For sellers, the process is described as a "gross invasion" of privacy involving numerous strangers visiting their property (’267 Patent, col. 2:21-22).
• The Patented Solution: The invention is a method that allows a user to virtually experience a property by displaying an "immersive three-dimensional image of a scene" on a computer (’267 Patent, col. 2:40-43). This system enables a 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" (’267 Patent, col. 2:50-54). Users can select products (e.g., cabinets, faucets) or real properties and visualize them within this immersive environment, and the view can be "seamlessly" changed from one room to another (’267 Patent, Abstract; col. 15:6-12).
• Technical Importance: The claimed method aims to improve the efficiency of real estate and product sales by replacing physical inspections with realistic virtual simulations, allowing for broader evaluation of options and customization.

Key Claims at a Glance

• The complaint does not identify specific claims but asserts infringement of one or more "Exemplary '267 Patent Claims" (Compl. ¶11, 16). Independent claim 1 is representative of the asserted technology.
• Essential elements of Independent Claim 1 include:
  • 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 room of the selected real property;
  • seamlessly changing a view on the electronic display to display an immersive three-dimensional image of a second room of the real property; and
  • enabling the user of the computing device to remove, add, and/or modify a feature shown in the image of a room.

III. The Accused Instrumentality

Product Identification

The complaint does not identify specific accused products or services by name, referring generally to "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

The complaint alleges that Defendant, Maronda Homes, LLC, makes, uses, offers for sale, and sells products that infringe the ’267 Patent (Compl. ¶11). Given the defendant is a home builder, these instrumentalities are presumably online virtual tours, interactive floor plans, or design center tools that allow prospective buyers to view and customize home models. The complaint alleges these products are used by Defendant's employees and customers (Compl. ¶11-12). The complaint does not provide sufficient detail for further analysis of the accused instrumentality's specific functionality or market positioning.

IV. Analysis of Infringement Allegations

The complaint alleges direct and induced infringement but incorporates by reference claim charts from an "Exhibit 2" that was not provided with the filed complaint (Compl. ¶16-17). In lieu of a claim chart summary, the infringement theory is summarized below.

The complaint alleges that the "Exemplary Defendant Products" practice the technology of the ’267 Patent and satisfy all elements of the asserted claims (Compl. ¶16). It asserts that Defendant directly infringes by making, using, and selling these products, including through internal testing by its own employees (Compl. ¶11-12). The complaint further alleges that Defendant induces infringement by distributing "product literature and website materials" that instruct end users on how to use the products in a manner that infringes the ’267 Patent (Compl. ¶14). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over whether the accused products provide an "immersive three-dimensional image" as required by the claims. The analysis may question if standard website features like clickable photo galleries or 2D interactive floor plans meet the patent's description of a user being able to view a scene "just as if the user were moving around inside" (’267 Patent, col. 2:52-54).
  • Technical Questions: The analysis may focus on whether the accused functionality for moving between different views (e.g., from a living room to a kitchen) constitutes "seamlessly changing a view" as claimed (’267 Patent, col. 15:8). This raises the question of whether loading a new webpage or a distinct image file for a different room meets the "seamless" limitation, which the patent specification analogizes to "walking through one room... and into another" (’267 Patent, col. 6:56-59).

V. Key Claim Terms for Construction

• The Term: "immersive three-dimensional image"

  • Context and Importance: This term is the technological core of the asserted claims. Its construction will likely determine whether the patent reads on a broad range of common web-based virtual tour technologies or is limited to more advanced, virtual-reality-like simulations.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests that representing three-dimensional objects on a two-dimensional screen can be accomplished using conventional techniques like "axonometric projections," which may support an argument that the term does not require stereoscopic or VR-like technology (’267 Patent, col. 4:15-18).
    • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes creating a "realistic impression" that "even more closely resembles a real-life situation" and describes using "stereographic images that trick the brain of the user" (’267 Patent, col. 3:5-10; col. 4:26-30). This language could support a narrower construction requiring a higher degree of realism and interactivity than a simple 3D rendering.

• The Term: "seamlessly changing a view"

  • Context and Importance: This limitation defines the user experience when navigating between different parts of the virtual property (e.g., between rooms). The interpretation of "seamlessly" will be critical in distinguishing between a continuous, fluid virtual environment and a series of discrete, hyperlinked pages or images.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term is not explicitly defined, which may support giving it a plain and ordinary meaning that could encompass any smooth transition effect between two images on a website.
    • Evidence for a Narrower Interpretation: The specification provides context by stating that "the user can seamlessly move from room to room," simulating the "view that the user would obtain if the user were walking through one room... and into another room" (’267 Patent, col. 6:56-59). This could support a construction that requires a continuous transition without the interruption of, for example, a new page load.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "product literature and website materials" that instruct customers to use the accused products in a way that directly infringes the ’267 Patent (Compl. ¶14-15).
• Willful Infringement: The complaint does not contain a specific count for willful infringement, but its inducement allegations are predicated on knowledge acquired upon service of the complaint (Compl. ¶15). It states that service of the complaint "constitutes actual knowledge" and that Defendant’s continued actions thereafter are knowing and intentional (Compl. ¶13, ¶15).

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

1. A core issue will be one of definitional scope: Does the term "immersive three-dimensional image," as defined and used within the ’267 Patent, cover the type of interactive floor plans and virtual tours commonly used in the online real estate marketing industry, or does it require a more sophisticated, virtual-reality-like level of user immersion?
2. A key evidentiary question will be one of technical operation: Does the accused functionality for navigating between virtual rooms operate by "seamlessly changing a view" in a manner consistent with the patent's description of a continuous user experience, or is there a functional mismatch with the accused products' potentially disjointed, page-based navigation?
3. A threshold procedural question may arise regarding pleading sufficiency: Given that the complaint's substantive infringement allegations appear to be contained entirely within an unprovided exhibit, the case may first turn on whether the complaint itself provides sufficient factual detail to state a plausible claim for relief.