DCT

2:17-cv-00249

Corydoras Tech LLC v. Motorola Mobility LLC

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:17-cv-00249, E.D. Tex., 03/31/2017
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has transacted business in the State of Texas and derived financial benefit from residents of the state.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile phones infringe seven patents related to a suite of common smartphone functionalities, including front-facing camera mirror imaging, GPS location display, voice dialing, and caller rejection features.
  • Technical Context: The patents-in-suit address a collection of features that became integral to the modern smartphone user experience during the 2010s.
  • Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit. All asserted patents claim priority to the same 2001 provisional application.

Case Timeline

Date Event
2001-10-18 Earliest Priority Date for all Patents-in-Suit
2010-08-17 U.S. Patent No. 7,778,664 Issues
2011-05-17 U.S. Patent No. 7,945,236 Issues
2011-05-17 U.S. Patent No. 7,945,287 Issues
2011-08-09 U.S. Patent No. 7,996,037 Issues
2011-09-20 U.S. Patent No. 8,024,009 Issues
2014-05-20 U.S. Patent No. 8,731,540 Issues
2015-11-24 U.S. Patent No. 9,197,741 Issues
2017-03-31 Complaint Filed

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

U.S. Patent No. 7,778,664 - “Communication Device”

  • Issued: August 17, 2010

The Invention Explained

  • Problem Addressed: The patent’s background section discusses a prior art mobile device with a display that could function as a pocket mirror by having a reflective surface, but notes this prior art does not disclose a device that uses its camera to create this mirror effect. (’664 Patent, col. 1:20-36).
  • The Patented Solution: The invention is a multi-function communication device that implements a “digital mirror mode,” wherein an image captured by the device’s camera is displayed in an “inverted manner” on the screen, creating an intuitive mirror-like experience for the user. (’664 Patent, col. 1:45-48).
  • Technical Importance: This approach of inverting or "mirroring" the image from a front-facing camera for on-screen previews became a standard feature in smartphones, commonly known as "selfie mode," as it provides a more natural user experience than a non-inverted image. (’664 Patent, col. 1:45-48).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶46).
  • Essential elements of claim 1 include:
    • A communication device comprising a microphone, speaker, display, input device, camera, antenna, and a multiple mode implementor.
    • The implementor provides for a voice communication mode, a digital mirror mode, a video phone mode, and a call blocking mode.
    • In the digital mirror mode, visual data from the camera is converted to “inverted visual data” and output on the display.
    • In the call blocking mode, communication with a caller on a blocking list is not implemented.
  • The complaint reserves the right to assert dependent claims 3, 6-10, and 15-18. (Compl. ¶45).

U.S. Patent No. 7,945,236 - “Communication Device”

  • Issued: May 17, 2011

The Invention Explained

  • Problem Addressed: The patent’s background section, identical to that of the ’664 patent, identifies a need for a communication device that can function as a digital mirror rather than relying on a simple reflective surface. (’236 Patent, col. 1:20-36).
  • The Patented Solution: The invention is a communication device that integrates multiple functionalities, including a digital mirror mode and a “GPS function,” where the device’s “current geographic location ... is indicated on said display when said GPS function is implemented.” (’236 Patent, col. 33:2-4).
  • Technical Importance: The integration of GPS-based location display into a multi-function handheld device was a foundational step for modern mobile mapping and location-aware applications. (’236 Patent, col. 11:15-24).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶59).
  • Essential elements of claim 1 include:
    • A communication device comprising a microphone, speaker, display, 1st camera, 2nd camera, antenna, and a multiple function implementor.
    • The implementor provides for a voice communication function, a digital mirror function, and a GPS function.
    • Visual data from the 1st camera is inverted for the digital mirror function.
    • The device’s current geographic location is indicated on the display when the GPS function is implemented.
  • The complaint reserves the right to assert dependent claims 2-3, 5, 8-11, and 16-18. (Compl. ¶58).

Multi-Patent Capsule: U.S. Patent No. 7,945,287

  • Patent Identification: U.S. Patent No. 7,945,287, “Communication Device,” issued May 17, 2011.
  • Technology Synopsis: This patent claims a communication device with multiple modes, including a "sound caller ID mode." In this mode, a specific sound is output from the speaker corresponding to the caller of an incoming phone call. (’287 Patent, col. 33:1-12).
  • Asserted Claims: Independent claim 1 is asserted. (Compl. ¶72).
  • Accused Features: The complaint alleges that the accused phones infringe by providing the capability to identify an incoming call with a "specifically designated ringtone." (Compl. ¶37, 70).

Multi-Patent Capsule: U.S. Patent No. 7,996,037

  • Patent Identification: U.S. Patent No. 7,996,037, “Communication Device,” issued August 9, 2011.
  • Technology Synopsis: This patent claims a communication device with multiple functions, including a "voice dialing function." This function implements a dialing process by utilizing audio data retrieved via the microphone. (’037 Patent, col. 33:1-11).
  • Asserted Claims: Independent claim 1 is asserted. (Compl. ¶85).
  • Accused Features: The complaint alleges infringement through the "Moto Voice" feature, which provides the capability to initiate a phone call in response to a voice command. (Compl. ¶83).

Multi-Patent Capsule: U.S. Patent No. 8,024,009

  • Patent Identification: U.S. Patent No. 8,024,009, “Communication Device,” issued September 20, 2011.
  • Technology Synopsis: This patent claims a communication device with multiple functions, including an "answer rejecting function." This function rejects a phone call addressed to the device. (’009 Patent, col. 33:10-14).
  • Asserted Claims: Independent claim 1 is asserted. (Compl. ¶98).
  • Accused Features: The complaint alleges infringement via the "All calls to voicemail" feature, which rejects an incoming call and prevents a voice communication from being established. (Compl. ¶96).

Multi-Patent Capsule: U.S. Patent No. 8,731,540

  • Patent Identification: U.S. Patent No. 8,731,540, “Communication Device,” issued May 20, 2014.
  • Technology Synopsis: This patent claims a communication device implementing multiple functions, including a digital mirror function and an "email function." The email function is for authoring and sending email in a wireless fashion. (’540 Patent, col. 33:1-13).
  • Asserted Claims: Independent claim 1 is asserted. (Compl. ¶111).
  • Accused Features: The complaint alleges infringement based on the capability of the accused phones to author and wirelessly transmit email. (Compl. ¶109).

Multi-Patent Capsule: U.S. Patent No. 9,197,741

  • Patent Identification: U.S. Patent No. 9,197,741, “Communication Device,” issued November 24, 2015.
  • Technology Synopsis: This patent claims a system comprising a communication device with multiple implementers, including a voice communication implementer, a digital mirror implementer, and an "incoming communication ID implementer." The ID implementer provides a specific performance corresponding to the ID of an incoming communication. (’741 Patent, col. 33:9-16).
  • Asserted Claims: Independent claim 1 is asserted. (Compl. ¶126).
  • Accused Features: The complaint alleges infringement based on the capability of associating a specific ringtone with a specific incoming phone number. (Compl. ¶124).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Motorola's mobile phones, collectively referred to as the "Accused Phones." (Compl. ¶17). Specific examples cited include Motorola’s Z, G, E, and X series phones, as well as the Droid Maxx 2 and Droid Turbo 2. (Compl. ¶17).

Functionality and Market Context

  • The complaint alleges the Accused Phones are wireless mobile communication devices that incorporate a range of features corresponding to the asserted patents. (Compl. ¶17, 38). These features include a "front camera" on the same side as the display capable of showing a "mirror image" of a user, a second camera on the opposite side, GPS capability for displaying the phone's location, voice dialing capability such as "Moto Voice," caller rejection identified as "All calls to voicemail," and the ability to author and send email. (Compl. ¶14, 17, 26, 31, 33, 35, 57, 83, 96, 109). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

7,778,664 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A communication device comprising a microphone, a speaker, a display... a camera, an antenna, and a multiple mode implementor The Accused Phones are wireless communication devices with microphones, speakers, displays, front and rear cameras, and antennas. ¶17, 24, 25, 30, 38, 43 col. 5:35-50
wherein said multiple mode implementor implements a voice communication mode, a digital mirror mode, a video phone mode, and a call blocking mode The Accused Phones are capable of voice calls, audiovisual communication, displaying a mirror image via the front camera, and rejecting callers via "All calls to voicemail." ¶17, 22, 23, 31, 44 col. 1:45-48
visual data is input via said camera, said visual data is converted to an inverted visual data... and said inverted visual data is output from said display when said digital mirror mode is implemented The Accused Phones' front camera is allegedly capable of displaying a "mirror image" of an object in its view. ¶14, 16, 28, 44 col. 1:47-48
when said communication device receives an incoming call... communication between the caller and said communication device is not implemented when said call blocking mode is implemented The "All calls to voicemail" feature, when activated, allegedly prevents an incoming caller from conducting a voice communication. ¶31, 32 col. 7:45-50
  • Identified Points of Contention:
    • Scope Questions: The claim requires the device to implement a combination of four specific "modes" (voice communication, digital mirror, video phone, call blocking). A central question may be whether Plaintiff must prove every Accused Phone model implements all four distinct modes as claimed. For example, what evidence does the complaint provide that the "All calls to voicemail" feature constitutes the claimed "call blocking mode"?
    • Technical Questions: Does the "mirror image" displayed by the Accused Phones (Compl. ¶44) result from a process that meets the claim limitation of converting visual data to "inverted visual data"? The analysis may hinge on the specific software and hardware implementation of the "selfie photo mirror" feature. (Compl. ¶16).

7,945,236 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A communication device comprising a... 1st camera, a 2nd camera... and a multiple function implementor The Accused Phones are alleged to have a "front camera" and a second camera on the opposite side of the device. ¶24, 26, 27 col. 5:35-50
wherein said multiple function implementor implements a voice communication function, a digital mirror function, and a GPS function The Accused Phones are alleged to be capable of voice communication, displaying a mirror image, and displaying their geographic location based on GPS data. ¶17, 55, 56, 57 col. 11:15-24
and the current geographic location of said communication device is indicated on said display when said GPS function is implemented The Accused Phones are alleged to be capable of displaying their geographic location on their display, based at least in part on GPS data. ¶33, 57 col. 11:21-24
  • Identified Points of Contention:
    • Scope Questions: The claim requires a "GPS function" where the "current geographic location... is indicated on said display." Does any application that uses GPS to show location on a map (e.g., a third-party mapping app) satisfy this limitation, or must the functionality be a specific, integrated "mode" of the core operating system as contemplated by the patent?
    • Technical Questions: The complaint states the phones are "capable" of displaying their location. (Compl. ¶57). An issue may be whether this capability alone is sufficient for infringement of the apparatus claim, or if specific software must be installed and configured to perform the claimed function.

V. Key Claim Terms for Construction

The Term: "digital mirror mode" (’664 Patent, Claim 1)

  • Context and Importance: This term is the central novel feature of the ’664 Patent. Its construction will determine whether simply providing a "selfie" preview on a smartphone screen is infringing, or if a more specific technical implementation is required. Practitioners may focus on this term because the infringement allegation rests on equating the common "selfie photo mirror" feature with this claimed mode. (Compl. ¶16).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself requires that "visual data is converted to an inverted visual data," which could arguably read on any software process that horizontally flips a camera feed for display. (’664 Patent, col. 33:8-12).
    • Evidence for a Narrower Interpretation: The patent’s Summary of the Invention states the device "implements the digital mirror mode, wherein the image retrieved from the camera is displayed in an inverted manner." (’664 Patent, col. 1:45-48). The specification also distinguishes the invention from prior art that used a physical "reflecting" surface, suggesting the "mode" is an active software function, not a passive property. (’664 Patent, col. 1:20-36).

The Term: "GPS function" (’236 Patent, Claim 1)

  • Context and Importance: The definition of this term is critical for determining the scope of the ’236 Patent. The dispute may turn on whether having a GPS receiver and the general capability to display location is sufficient, or if the claim requires a specific, integrated "function" that operates alongside the other claimed functions (voice, digital mirror).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim requires that the "current geographic location... is indicated on said display when said GPS function is implemented." This could be interpreted broadly to cover any standard use of a smartphone's GPS to show location on a map application. (’236 Patent, col. 33:2-4).
    • Evidence for a Narrower Interpretation: The claim recites a "multiple function implementor" that implements a discrete set of functions. This suggests "GPS function" is not just a hardware capability but a specific software mode that is part of the claimed combination, potentially requiring a particular integration with the voice and digital mirror functions. (’236 Patent, col. 32:46-48).

VI. Other Allegations

  • Indirect Infringement: For each asserted patent, the complaint alleges induced infringement under 35 U.S.C. § 271(b). The basis for these allegations is that Motorola provides "User guides, that instruct consumers on how to use the Accused Phones in such infringing manner, specifically intending such consumers will operate" the devices as claimed. (Compl. ¶48, 61, 74, 87, 100, 113, 128).
  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or plead facts supporting pre-suit knowledge of the patents. It alleges that Motorola has engaged in inducement "knowingly and, at least from the time of receipt of the Complaint," which may support a claim for post-filing inducement or willfulness. (Compl. ¶50, 63, 76, 89, 102, 115, 130).

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

  • A core issue will be one of claim scope for system claims: The asserted independent claims each require a single device to implement a specific combination of multiple, distinct "modes" or "functions." A central question for the court will be whether infringement requires proving that every accused device practices every single claimed function (e.g., voice communication, digital mirror, video phone, and call blocking for the ’664 patent), or if the capability to perform these functions is sufficient.
  • A key evidentiary question will be one of functional mapping: The complaint alleges infringement by mapping common, commercially-named smartphone features (e.g., "selfie photo mirror," "Moto Voice") to the technical "modes" recited in the claims. The case may turn on what evidence is presented to demonstrate that these features perform the specific technical operations required by the patent claims, particularly for terms like "inverted visual data" and "call blocking mode."