DCT

2:18-cv-00288

Corydoras Technologies, LLC v Sony Mobile Communications Inc

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:18-cv-00288, E.D. Tex., 07/13/2018
  • Venue Allegations: Venue is alleged to be proper as Defendant is a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s Xperia line of smartphones infringes seven patents related to various communication device features, including front-facing camera modes, call management, and location-based services.
  • Technical Context: The dispute involves foundational smartphone functionalities that emerged in the late 2000s and early 2010s, combining digital imaging with mobile communication.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2001-10-18 Priority Date for ’664, ’236, ’287, ’037, ’009, ’540, ’741 Patents
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
2018-07-13 Complaint Filed

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

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

The Invention Explained

  • Problem Addressed: The patent’s background section discusses prior art mobile devices with reflective displays that could function as a physical pocket mirror. It notes, however, that this prior art fails to disclose a "digital mirror mode, wherein the image retrieved from the camera is displayed in an inverted manner" (’664 Patent, col. 1:33-36).
  • The Patented Solution: The invention claims to solve this by implementing a "digital mirror mode" on a communication device. In this mode, the device uses a camera to capture an image and then displays that image "in an inverted manner" on the screen, thereby digitally simulating the reflection of a physical mirror (’664 Patent, col. 2:45-48; Abstract).
  • Technical Importance: This feature allowed early smartphones to replicate the function of a physical mirror using a front-facing camera, a common hardware component, which enhanced user convenience for personal grooming or self-viewing.

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 15 (Compl. ¶43).
  • Independent Claim 1 includes these essential elements:
    • A wireless communication device comprising a microphone, speaker, display, input device, a 1st camera, a 2nd camera, an antenna, and a multiple mode implementor.
    • The multiple mode implementor implements a voice communication mode, a digital mirror mode, a non-digital mirror mode, a video phone mode, and a call blocking mode.
    • A 1st visual data from the 1st camera is inverted and output on the display when the digital mirror mode is implemented.
    • A 2nd visual data from the 2nd camera is output from the display without being inverted when the non-digital mirror mode is implemented.
  • Independent Claim 15 includes these essential elements:
    • A communication device comprising a microphone, a speaker, a display, an input device, a 1st camera, a 2nd camera, an antenna, and a multiple mode implementor.
    • The multiple mode implementor implements a voice communication mode, a digital mirror mode, and a non-digital mirror mode.
    • Visual data from the 1st camera is inverted and displayed in the digital mirror mode.
    • Visual data from the 2nd camera is displayed without being inverted in the non-digital mirror mode.
  • The complaint reserves the right to assert dependent claims 3, 6-10, and 16-18 (Compl. ¶43).

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

The Invention Explained

  • Problem Addressed: The patent addresses the same problem as the ’664 Patent: the lack of a true digital mirror function in prior art devices that used physically reflective screens (’236 Patent, col. 1:35-38).
  • The Patented Solution: The invention described in the ’236 Patent combines the "digital mirror mode" with a "GPS function." The solution is a multi-function device that can both display an inverted, mirror-like image from its camera and also indicate the device's current geographic location on its display (’236 Patent, Abstract; col. 33:10-15).
  • Technical Importance: This patent claims an invention that integrates digital imaging features with then-emerging location-based services (GPS), reflecting a key trend in the development of multi-purpose smartphones.

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 16 (Compl. ¶56).
  • Independent Claim 1 includes these essential elements:
    • A communication device comprising a microphone, speaker, display, input device, a 1st camera, a 2nd camera, an antenna, and a multiple function implementor.
    • The multiple function implementor implements a voice communication mode, a digital mirror mode, a non-digital mirror mode, and a GPS function.
    • A 1st visual data from the 1st camera is inverted and displayed when in the digital mirror mode.
    • The current geographic location of the device is indicated on the display when the GPS function is implemented.
  • Independent Claim 16 includes these essential elements:
    • A method for a communication device comprising a microphone, a speaker, display, input device, a 1st camera, a 2nd camera, and an antenna.
    • A method comprising a digital mirror implementing step and a GPS implementing step.
    • In the digital mirror step, 1st visual data from the 1st camera is inverted and displayed.
    • In the GPS implementing step, the current geographic location is indicated on the display.
  • The complaint reserves the right to assert dependent claims 2-3, 5, 8-11, and 17-18 (Compl. ¶56).

U.S. Patent No. 7,945,287 - "Communication Device"

  • Technology Synopsis: The technology relates to a communication device that can associate a specific, preloaded ringtone with an incoming call based on user input. This allows a user to audibly identify a caller without viewing the device's display (Compl. ¶68).
  • Asserted Claims: Independent claims 1 and 16 (Compl. ¶69).
  • Accused Features: The accused functionality is the capability of Sony’s phones to allow a user to designate a specific, preloaded ringtone for an incoming call (Compl. ¶68).

U.S. Patent No. 7,996,037 - "Communication Device"

  • Technology Synopsis: This patent describes a communication device capable of initiating a phone call in response to a voice command. This allows for hands-free operation of the device's dialing function (Compl. ¶81).
  • Asserted Claims: Independent claims 1 and 16 (Compl. ¶82).
  • Accused Features: The accused feature is the voice dialing capability of Sony's smartphones, which allows users to initiate a call by speaking a command (Compl. ¶81).

U.S. Patent No. 8,024,009 - "Communication Device"

  • Technology Synopsis: The patent pertains to a communication device with the capability to reject an unwanted incoming call. Upon activation of a "Route to voicemail" or "Block" feature for a designated caller, the device prevents the call from connecting for voice communication (Compl. ¶94).
  • Asserted Claims: Independent claims 1 and 16 (Compl. ¶95).
  • Accused Features: The accused functionalities are the "Route to voicemail" and "Block" features in Sony's phones that reject incoming calls from designated numbers (Compl. ¶94).

U.S. Patent No. 8,731,540 - "Communication Device"

  • Technology Synopsis: This patent relates to a communication device's ability to author and wirelessly transmit an email. The device is described as capable of composing an email based on user input and sending it to a recipient (Compl. ¶107).
  • Asserted Claims: Independent claims 1 and 18 (Compl. ¶108).
  • Accused Features: The accused feature is the capability of Sony's phones to send and receive email, including authoring an email and transmitting it wirelessly (Compl. ¶107).

U.S. Patent No. 9,197,741 - "Communication Device"

  • Technology Synopsis: The technology described involves a device's functionality during an audiovisual call. The patent claims a device that displays a mirror image to the local user from the front camera while being capable of wirelessly transmitting a video of that same object (the user) during the call (Compl. ¶120).
  • Asserted Claims: Independent claims 1 and 9 (Compl. ¶123).
  • Accused Features: The accused functionality is the ability of Sony's phones to conduct an audiovisual (video) call where a mirror image is shown on the user's display while video is transmitted to the other party (Compl. ¶120).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Sony-branded mobile phones, collectively referred to as the "Accused Phones" (Compl. ¶18). Specific examples include "Sony's Xperia line of smartphones, more specifically including the Xperia XA2 Ultra, XA2, XZ2 and XZ2 Compact, and all reasonably similar phones of Sony" (Compl. ¶18).

Functionality and Market Context

The complaint alleges the Accused Phones include a set of core smartphone features. These include a front-facing camera capable of displaying a "mirror image" of an object in its view (Compl. ¶¶16, 29, 42). The devices are alleged to be capable of voice and audiovisual communication (Compl. ¶¶23, 24), have two or more cameras (Compl. ¶25), display the phone’s geographic location (Compl. ¶34), send and receive email (Compl. ¶35), initiate calls via voice command (Compl. ¶36), assign specific ringtones to callers (Compl. ¶37), and block incoming calls via features like "Route to voicemail" or "Block" (Compl. ¶32). The complaint does not contain specific allegations regarding the products' market positioning beyond their general sale in the United States (Compl. ¶3).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,778,664 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A wireless communication device comprising a microphone, a speaker, a display...a 1st camera, a 2nd camera, an antenna, and a multiple mode implementor... The Accused Phones are wireless communication devices that include a microphone, speaker, display, front camera, a second camera, and an antenna. ¶25, 26, 27, 31, 38 col. 5:28-59; Fig. 1
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 and audiovisual communication, displaying a mirror image, and blocking incoming calls. ¶16, 23, 24, 30, 32 col. 1:33-36
a 1st visual data is input via said 1st camera, said 1st visual data is inverted, and said 1st visual data which is inverted is output from said display when said digital mirror mode is implemented... The Accused Phones include a front camera that is used to display a mirror image of an object in its view. ¶16, 29, 42 col. 19:8-12
a 2nd visual data is input via said 2nd camera, said 2nd visual data is output from said display without being inverted when said non-digital mirror mode is implemented... The Accused Phones have a second camera with a lens located on the side of the phone that is opposite of the display. ¶27 col. 33:53-60

Identified Points of Contention

  • Scope Questions: A central question may be whether the various alleged functionalities (e.g., call blocking, video calling, mirror display) are implemented by a single, integrated "multiple mode implementor" as required by the claim, or if they operate as distinct software applications. The complaint alleges the existence of the features, but their integration into a single "implementor" may be a point of dispute.
  • Technical Questions: The complaint alleges the Accused Phones have a second camera on the opposite side of the display (Compl. ¶27), but it does not provide facts alleging that this second camera outputs an image "without being inverted." The analysis will question what evidence supports this specific limitation of the "non-digital mirror mode."

U.S. Patent No. 7,945,236 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 1st camera, a 2nd camera, an antenna, and a multiple function implementor... The Accused Phones are communication devices that include a microphone, speaker, display, a front camera, and a second camera. ¶25, 26, 27, 31 col. 5:43-65; Fig. 1
wherein said multiple function implementor implements a voice communication mode, a digital mirror mode...and a GPS function... The Accused Phones are capable of voice communication, displaying a mirror image, and displaying their geographic location. ¶16, 23, 29, 34, 55 col. 11:1-4
a 1st visual data is input via said 1st camera, said 1st visual data is inverted, and said 1st visual data which is inverted is output from said display when said digital mirror mode is implemented... The Accused Phones' front camera is capable of displaying a mirror image of an object in its view. ¶16, 29, 54 col. 19:8-12
the current geographic location of said communication device is indicated on said display when said GPS function is implemented. Each of the Accused Phones is capable of displaying its geographic location on its display based, at least in part, on GPS data. ¶34, 55 col. 11:23-26

Identified Points of Contention

  • Scope Questions: Similar to the ’664 Patent, a dispute may arise over whether the accused device contains a singular "multiple function implementor" that integrates the recited digital mirror and GPS functions, or if these are provided by separate, non-integrated applications.
  • Technical Questions: The infringement analysis raises the question of whether a standard mapping application displaying a location pin based on GPS data meets the claim limitation that "the current geographic location of said communication device is indicated on said display when said GPS function is implemented." This language could be construed to require a specific operational mode rather than a general capability.

V. Key Claim Terms for Construction

U.S. Patent No. 7,778,664

  • The Term: "digital mirror mode"
  • Context and Importance: This term is central to the patent’s novelty. Its construction will determine whether simply displaying a horizontally-flipped image from a front-facing camera, a now-standard feature for "selfies" and video calls, falls within the scope of the claims. Practitioners may focus on this term because its definition is key to distinguishing the invention from both prior art and the accused functionality.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification repeatedly describes the mode's function as displaying an image "in an inverted manner" (’664 Patent, col. 1:36), a general description that could encompass any form of image inversion, including the horizontal flipping common in modern phones.
    • Evidence for a Narrower Interpretation: The detailed description of an embodiment explains the process as reading video data stored in an area "from right to left" to produce the mirror image (’664 Patent, col. 19:8-12; Fig. 44e). A defendant may argue this specific implementation limits the scope of the term to devices that process image data in this particular way.

U.S. Patent No. 7,945,236

  • The Term: "GPS function is implemented"
  • Context and Importance: The infringement allegation for this element rests on the general capability of the Accused Phones to display their location using GPS (Compl. ¶55). The construction of this term will determine whether that general capability is sufficient, or if the claim requires a specific, integrated "GPS function" that is actively "implemented" as part of the claimed multi-function system.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad, only requiring that the "geographic location...is indicated on said display when said GPS function is implemented" (’236 Patent, Claim 1). This could be read to cover any standard use of a phone's GPS to show location on a map.
    • Evidence for a Narrower Interpretation: The specification describes a detailed "Positioning System" that uses a network of relays to pinpoint a device's location (’236 Patent, col. 11:15-26; Figs. 20a-26). A defendant may argue that "GPS function" should be construed in light of these specific embodiments, suggesting a more complex, integrated system than a standalone mapping application.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all asserted patents. The basis for inducement is the allegation that Sony provides "User Guides, and instructions" that instruct consumers on how to use the Accused Phones in a manner that directly infringes the patent claims (Compl. ¶¶ 48, 61, 74, 87, 100, 113, 128).
  • Willful Infringement: The complaint does not contain an explicit count for willful infringement. However, for each count of inducement, it alleges that Sony acted "knowingly and, at least from the time of receipt of the Complaint" (Compl. ¶¶ 48, 61, 74, 87, 100, 113, 128). This allegation may form a basis for seeking enhanced damages for any post-filing infringement but does not allege pre-suit knowledge required for pre-suit willfulness.

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

  • A central issue for many of the asserted patents will be one of claim scope: can the term "multiple mode implementor" be construed to cover a modern smartphone operating system where features like call blocking, video chat, and GPS navigation exist as distinct applications, or does the claim require a more unified software architecture where these functions are integrated into a single, cohesive "implementor"?
  • A key technical question will be one of definitional interpretation: does the standard "selfie view" on a smartphone, which horizontally flips a camera image for user orientation, constitute the claimed "digital mirror mode" that requires an image to be displayed in an "inverted manner"? The construction of "inverted" will be pivotal to the infringement analysis for a core feature of the asserted patents.
  • An evidentiary question will be one of factual support: what evidence does the complaint provide to satisfy claim limitations that are not directly addressed by its factual allegations, such as the requirement in the ’664 Patent that the second (rear) camera outputs an image "without being inverted"? The focus of the allegations on front-camera features may create proof challenges for limitations concerning other components.