DCT

2:19-cv-00326

Clear Imaging Research LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:19-cv-00326, E.D. Tex., 10/01/2019
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. maintains regular and established places of business in Plano and Richardson, Texas, and has committed acts of infringement in the district. Venue for the foreign parent, Samsung Electronics Co. Ltd., is alleged to be proper in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphone and tablet products, including the Galaxy and Note series, infringe six patents related to computational photography techniques for correcting image blur and creating artificial depth-of-field effects.
  • Technical Context: The patents address software-based methods for improving digital image quality, a critical area of technological competition and a key marketing feature in the modern smartphone industry.
  • Key Procedural History: The complaint alleges a history of communications regarding the patent portfolio, beginning with discussions between the inventor and Samsung executives in 2014. It further alleges that after Samsung ceased communications, Plaintiff sent letters in June 2017, November 2017, and May 2018 identifying the patents and relevant Samsung products, which Plaintiff asserts provided pre-suit notice of infringement.

Case Timeline

Date Event
2004-03-25 Earliest Priority Date for all Patents-in-Suit ('484, '699, '175, '450, '740, '944)
2014-01-14 U.S. Patent No. 8,630,484 Issues
2014-06-15 Alleged notice of '484 Patent to Samsung via written and verbal correspondence
2015-10-06 U.S. Patent No. 9,154,699 Issues
2016-07-12 U.S. Patent No. 9,392,175 Issues
2017-06-20 Plaintiff allegedly informs Samsung that its products infringe the '484, '175, and '699 Patents
2017-11-06 Plaintiff again allegedly informs Samsung that its products infringe the '484, '175, and '699 Patents
2018-01-02 U.S. Patent No. 9,860,450 Issues
2018-05-XX Plaintiff allegedly sends email correspondence to Samsung executives regarding the patent portfolio
2019-01-01 U.S. Patent No. 10,171,740 Issues
2019-08-20 U.S. Patent No. 10,389,944 Issues
2019-10-01 Complaint Filed

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

U.S. Patent No. 8,630,484 - "Method and Apparatus to Correct Digital Image Blur Due to Motion of Subject or Imaging Device"

  • Issued: January 14, 2014

The Invention Explained

  • Problem Addressed: The patent’s background section identifies the problem of image blur resulting from camera movement or subject motion, particularly in low-light conditions requiring slow shutter speeds (Compl. ¶29; '484 Patent, col. 1:42-51). It critiques prior art solutions, noting that electro-mechanical image stabilization systems are expensive and bulky, while post-processing sharpness filters result in data loss and do not truly "correct" the blur (Compl. ¶29; '484 Patent, col. 2:5-17).
  • The Patented Solution: The invention proposes a computational method to overcome blur. The system captures multiple images in quick succession using a fast shutter speed, ensuring each individual frame is not blurred by motion ('484 Patent, Abstract; col. 10:5-11). These individual sharp images are then computationally shifted to align them with one another and combined to produce a single, clear final image that has the light-gathering benefits of a long exposure without the associated motion blur ('484 Patent, Fig. 11).
  • Technical Importance: This software-based approach to image stabilization provided a path to achieving clear low-light photos in compact, less expensive devices like smartphones, without requiring complex and costly mechanical lens components (Compl. ¶29).

Key Claims at a Glance

  • The complaint asserts independent claim 28 (Compl. ¶40).
  • The essential elements of apparatus claim 28 are:
    • A viewfinder configured to display an image.
    • A processor configured to receive user input data that designates a subject in the image.
    • A recording medium configured to capture a plurality of two-dimensional photographic images that include the designated subject.
    • The processor is further configured to: shift each of the plurality of images vertically and horizontally such that the designated subject is aligned at a same location in each of the shifted images.
    • The processor is further configured to: combine the shifted images to obtain a corrected, two-dimensional photographic image.
  • The complaint states that these products are covered by "one or more claims... including but not limited to claim 28" (Compl. ¶40).

U.S. Patent No. 9,154,699 - "Method and Apparatus to Correct Blur in All or Part of a Digital Image by Combining Plurality of Images"

  • Issued: October 6, 2015

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of correcting unwanted image blur in lightweight and inexpensive devices ('699 Patent, col. 2:21-27). It also identifies a separate artistic goal: the desirability of creating an image where a "designated subject in a field of view [is] clear and sharp whereas other parts of the image may be blurred" (Compl. ¶31; '699 Patent, col. 10:52-55).
  • The Patented Solution: The invention describes a method where a device captures multiple photographic images. A processor then combines these images to create a final, combined image where a user-designated "main subject" is "substantially blur free" while other areas of the image are "blurred" ('699 Patent, Abstract; col. 10:52-11:2). This technique computationally mimics the shallow depth-of-field effect typically associated with larger, more expensive camera lenses.
  • Technical Importance: This technology allows compact consumer devices to create "portrait mode" style images with artistic background blur, a feature that has become a significant differentiator in the smartphone market (Compl. ¶35).

Key Claims at a Glance

  • The complaint asserts independent claim 9 (Compl. ¶51).
  • The essential elements of apparatus claim 9 are:
    • A viewfinder configured to display an image.
    • A processor configured to receive user input that designates a main subject in the image in the viewfinder.
    • A recording medium configured to capture a plurality of photographic images, which includes the designated main subject.
    • The processor is further configured to combine the plurality of photographic images to create a combined photographic image such that the main subject is substantially blur free and areas other than the main subject are blurred.
    • A memory configured to record the combined photographic image.
  • The complaint states that these products are covered by "one or more claims... including but not limited to, Claim 9" (Compl. ¶51).

Multi-Patent Capsule: U.S. Patent No. 9,392,175

  • Patent Identification: U.S. Patent No. 9,392,175, "Method and Apparatus for Using Motion Information and Image Data to Correct Blurred Images", issued July 12, 2016.
  • Technology Synopsis: This patent addresses problems of image blur caused by camera or subject motion (Compl. ¶29). The invention discloses selectively combining different sets of images from a captured plurality to generate different parts of a final corrected image, allowing for more complex corrections than a simple overlay ('175 Patent, Abstract; col. 9:43-52).
  • Asserted Claims: Independent claim 23 is asserted (Compl. ¶62).
  • Accused Features: The complaint alleges that Samsung's "multi-frame image processing" and "multi-frame noise reduction" features, which allegedly capture and combine multiple images to form a final picture, practice the invention (Compl. ¶65-67).

Multi-Patent Capsule: U.S. Patent No. 9,860,450

  • Patent Identification: U.S. Patent No. 9,860,450, "Method and Apparatus to Correct Digital Video to Counteract Effect of Camera Shake", issued January 2, 2018.
  • Technology Synopsis: This patent resolves technological problems related to reducing motion blur in video by using motion sensor data (Compl. ¶33). The invention discloses using motion sensors (e.g., gyroscopes) to detect device motion during video capture and then computationally determining and applying vertical and horizontal shifts to the image sequence to modify the frames and create a stabilized final video ('450 Patent, Abstract).
  • Asserted Claims: Independent claim 14 is asserted (Compl. ¶74).
  • Accused Features: The complaint alleges that Samsung's devices equipped with "video stabilization," "video digital image stabilization (vDIS)," "gyro-based electronic image stabilization," and "hyperlapse" technology infringe this patent (Compl. ¶76-77).

Multi-Patent Capsule: U.S. Patent No. 10,171,740

  • Patent Identification: U.S. Patent No. 10,171,740, "Method and Apparatus to Correct Blur in All or Part of a Digital Image By Combining Plurality of Images", issued January 1, 2019.
  • Technology Synopsis: This patent is directed to technology for creating an artificial depth-of-field effect where one subject is in focus and another is blurred (Compl. ¶31). The invention discloses a user interface for displaying a preview image with first and second subjects, receiving user input to designate the first subject to be kept blur-free, and then capturing and combining a plurality of images to create a final image where the first subject is blur-free and the second subject is blurred in comparison ('740 Patent, Abstract; Claim 20).
  • Asserted Claims: Independent claim 20 is asserted (Compl. ¶84).
  • Accused Features: The complaint alleges that Samsung's "selective focus" and "live focus" features, which allow a user to select a subject to keep in focus while blurring the background, infringe this patent (Compl. ¶85, 87).

Multi-Patent Capsule: U.S. Patent No. 10,389,944

  • Patent Identification: U.S. Patent No. 10,389,944, "Method and Apparatus to Correct Blur in All or Part of an Image", issued August 20, 2019.
  • Technology Synopsis: This patent addresses creating a combined image with a blurred background by taking into account camera lens properties (Compl. ¶100). The invention discloses capturing a plurality of images containing a first and second subject and processing them, taking into account the focal length or zoom level of the lens, to create a combined image where the first subject is blur-free and the second subject is blurred ('944 Patent, Abstract).
  • Asserted Claims: Independent claim 6 is asserted (Compl. ¶95).
  • Accused Features: The complaint alleges that Samsung's "live focus" mode, particularly on dual-camera devices that use lenses with different focal lengths to create the effect, infringes this patent (Compl. ¶100-101).

III. The Accused Instrumentality

Product Identification

  • The accused products include a wide range of Samsung mobile phones and tablets, including Galaxy S-series (S5 through S10), Galaxy Note series (Note 4 through Note 10), Galaxy Fold/X, Galaxy A-series, and Galaxy Tab S-series devices (Compl. ¶38).

Functionality and Market Context

  • The complaint targets camera functionalities that Samsung markets under names such as "multi-frame image processing," "multi-frame noise reduction," "selective focus," and "live focus" (Compl. ¶43, 54). Samsung allegedly promoted these features as being "at the forefront of camera development," taking "mobile photography to a new level," and allowing for "fast and accurate image capture" to create "pin-sharp productions" (Compl. ¶35). For example, the complaint cites a Samsung website explaining that its "Selective focus mode works by taking multiple photos of your subject at varying focus levels then allowing you to change the focus of your photo after it's been saved to your gallery" (Compl. p. 22). This screenshot from a Samsung website describes a multi-photo process for creating adjustable focus (Compl. p. 22).

IV. Analysis of Infringement Allegations

U.S. Patent No. 8,630,484 Infringement Allegations

Claim Element (from Independent Claim 28) Alleged Infringing Functionality Complaint Citation Patent Citation
a viewfinder configured to display an image. The display screen of the accused products is used as a viewfinder for the camera. ¶41 col. 11:4-6
a processor configured to receive user input data that designates a subject in the image. The processor receives user input via the touchscreen, such as a tap on the screen, to focus on and designate a subject. ¶42 col. 11:4-6
a recording medium configured to capture a plurality of images, wherein the images are two-dimensional photographic images and include the designated subject. The accused products' "multi-frame image processing," "selective focus," and "live focus" features capture multiple two-dimensional photos upon a single shutter press. ¶43 col. 10:5-11
wherein the processor is further configured to: shift each of the plurality of images vertically and horizontally such that the designated subject is aligned at a same location in each of the shifted images. The processor allegedly combines multiple images, including by "impos[ing]" them "on top of one another," which the complaint alleges performs the claimed shifting and alignment. ¶44 col. 10:12-21
combine the shifted images to obtain a corrected image... The processor combines the captured images to obtain a single corrected image, which Samsung describes as a "high-quality photo" where "every image looks crystal clear." ¶45 col. 10:22-24

Identified Points of Contention

  • Scope Questions: A central question may be whether the accused products' method of "imposing" images on top of one another or selecting the "clearest image and us[ing] the other two to reduce the blur" (Compl. p. 21) meets the claim limitation of "shift[ing] each of the plurality of images...such that the designated subject is aligned." The defense may argue that "blending" or "selecting" is technically distinct from the explicit "shifting" and "aligning" of each captured image as required by the claim. The complaint provides a marketing graphic stating that "the Galaxy S8 takes multiple shots and combines them into a single photo," which supports the allegation of combination but is less specific on the alignment mechanism (Compl. p. 21).
  • Technical Questions: What evidence does the complaint provide that the processor performs the specific two-step process of first shifting all captured images for alignment and then combining them? The complaint relies on marketing descriptions of the final output rather than detailing the specific intermediate software steps performed by the accused devices.

U.S. Patent No. 9,154,699 Infringement Allegations

Claim Element (from Independent Claim 9) Alleged Infringing Functionality Complaint Citation Patent Citation
a viewfinder configured to display an image. The accused products' display screen functions as a camera viewfinder. ¶52 col. 10:52-55
a processor configured to receive user input that designates a main subject in the image in the viewfinder. The processor receives user input when a user taps the screen to select a subject for focus in modes like "Selective Focus" or "Live Focus." ¶53 col. 10:52-55
a recording medium configured to capture a plurality of photographic images, wherein the plurality of photographic images includes the designated main subject. The "selective focus" and "live focus" features capture multiple photos of the designated subject. ¶54 col. 10:56-62
the processor further configured to combine the plurality of photographic images to create a combined photographic image such that the main subject... is substantially blur free and areas... other than the main subject are blurred. The processor combines the captured images to create a final image with an artificially blurred background, as described for the "selective focus" and "live focus" features. ¶55 col. 10:63-11:2
a memory configured to record the combined photographic image. The accused products provide an option to save the final combined image with the blur effect to the device's memory. ¶56 col. 11:3-4

Identified Points of Contention

  • Scope Questions: The term "substantially blur free" is a term of degree and may be a central point of claim construction. The defense could argue that the output of the accused modes does not meet this standard, particularly in light of evidence cited in the complaint itself that the accused Note 8 "often does, get the exact edges of your subjects wrong leading to blurred hands, hair or clothes" (Compl. p. 37). The complaint provides a screenshot of the "Selective Focus" interface, which shows options for "Near Focus," "Far Focus," and "Pan Focus," illustrating the intended functionality of creating differential blur (Compl. p. 36).
  • Technical Questions: Does the accused functionality intentionally "blur" the background as a primary step, or is the blur a byproduct of combining images focused at different depths? The claim requires an outcome where non-subject areas "are blurred," which raises the question of whether this blurring is an affirmatively applied effect or an artifact of the combination process. A screenshot from a user guide shows the user can tap the screen to select a focus location, supporting the allegation that a subject is designated to be kept sharp (Compl. p. 32).

V. Key Claim Terms for Construction

Term from '484 Patent, Claim 28: "shift each of the plurality of images...such that the designated subject is aligned"

  • Context and Importance: The infringement analysis for the '484 patent may depend on whether Samsung's "multi-frame image processing," described as "imposing" or "blending" images, constitutes the specific alignment process recited in the claim. Practitioners may focus on this term because it appears to describe a specific technical mechanism, not just a desired outcome.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the goal as "aligning" and "combining" images to reduce blur, which could be read to encompass various computational techniques that achieve that end result ('484 Patent, col. 10:12-24).
    • Evidence for a Narrower Interpretation: The patent's Figure 11 explicitly depicts a process of taking multiple, slightly displaced images and applying a compensatory shift to each frame to bring them into alignment before combining. This figure may support a narrower construction requiring a specific, discrete shifting step for each image ('484 Patent, Fig. 11).

Term from '699 Patent, Claim 9: "substantially blur free"

  • Context and Importance: This term is qualitative and establishes the required performance standard for the final image. The dispute may turn on how much, if any, residual blur is permissible for an image to be considered "substantially blur free." Practitioners may focus on this term because its indefiniteness makes it a likely candidate for construction and a focal point for expert testimony on technical performance.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's summary describes the invention as preventing image distortion to create a "substantially undistorted image," using the term in a general, descriptive sense ('699 Patent, col. 2:38-41). This could suggest the term does not imply perfect, pixel-level sharpness.
    • Evidence for a Narrower Interpretation: The patent contrasts its solution with prior art that produces a "less accurate image than the original" ('699 Patent, col. 2:1-2). This contrast could support an interpretation requiring a high degree of clarity and accuracy in the final "blur free" subject, potentially higher than what the accused products achieve.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges Samsung induces infringement by "actively encouraging" users to use the accused features. It points to marketing materials, technical specifications, user manuals, and the company website as evidence of instructions that lead users to infringe the patents (Compl. ¶47, 58, 70, 80, 91, 104).

Willful Infringement

  • The complaint alleges willful infringement based on Samsung's purported knowledge of the patents prior to the lawsuit. This knowledge is alleged to stem from direct business communications with the inventor regarding the '484 patent as early as June 2014, and from a series of letters sent by Plaintiff to Samsung's general counsel in 2017 identifying the '484, '699, and '175 patents and the allegedly infringing products (Compl. ¶21, 46, 57). The complaint asserts that Samsung continued its allegedly infringing activities despite this notice.

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

  • A core issue will be one of mechanistic scope: can the claim language describing a specific process of "shifting each" image to achieve "alignment" (as in the '484 patent) be construed to cover the accused products' more general computational methods of "blending," "imposing," or "selecting" from multiple images to enhance sharpness? The case may depend on whether the court views the claims as protecting a specific algorithm or a broader concept.
  • A key evidentiary question will be one of technical performance and equivalence: do the accused "Selective Focus" and "Live Focus" features, which the complaint itself acknowledges can produce edge-detection errors, achieve the claimed outcome of a "substantially blur free" subject and intentionally "blurred" surroundings (as in the '699 and '740 patents)? The analysis will likely require a technical deep-dive into how the accused software operates and whether its results are functionally equivalent to the claimed invention, or if its inherent artifacts create a fundamental mismatch.