DCT
2:22-cv-00239
Lonestar Biometrics LLC v. Shenzhen OnePlus Science Technology Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lonestar Biometrics LLC (Texas)
- Defendant: Shenzhen OnePlus Science & Technology Co., Ltd. (China)
- Plaintiff’s Counsel: Rubino Law LLC; Truelove Law Firm, PLLC
- Case Identification: 2:22-cv-00239, E.D. Tex., 06/28/2022
- Venue Allegations: Plaintiff alleges venue is proper in any U.S. judicial district because Defendant is not a resident of the United States.
- Core Dispute: Plaintiff alleges that Defendant’s smartphones equipped with under-display optical fingerprint scanners infringe three patents related to capturing images through a display screen.
- Technical Context: The technology enables a device's display to perform a dual function: visual output and optical input, a key innovation for integrating biometric security features like fingerprint scanning directly into the screen.
- Key Procedural History: The complaint does not allege any pre-suit notice, prior litigation, or administrative proceedings involving the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2011-08-20 | Earliest Priority Date for ’088, ’082, ’293 Patents |
| 2016-01-05 | U.S. Patent No. 9,232,088 Issues |
| 2016-01-19 | U.S. Patent No. 9,241,082 Issues |
| 2017-01-31 | U.S. Patent No. 9,560,293 Issues |
| 2022-06-28 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,232,088 - "Scanning in a Defined Region on a Display Screen," issued January 5, 2016
The Invention Explained
- Problem Addressed: The patent's background notes that while many mobile devices have cameras, using them to capture high-quality images of documents is difficult, creating a need for a more integrated scanning solution. (’088 Patent, col. 2:7-16)
- The Patented Solution: The invention proposes embedding an "image sensing module" behind a device's Liquid Crystal Display (LCD) panel. By controlling the liquid crystals to become transparent ("fully open"), the device can allow reflected light from an object placed on the screen to pass through to the underlying sensors. The system activates this function within a "scanning region" that is visibly designated to the user and smaller than the full display area. (’088 Patent, col. 2:26-34; Fig. 5B)
- Technical Importance: This approach enabled the dual use of screen real estate for both displaying content and capturing images, representing a technological step toward seamlessly integrating biometric scanners and other sensors into consumer devices. (’088 Patent, col. 2:13-16)
Key Claims at a Glance
- The complaint asserts at least independent claim 1. (Compl. ¶17)
- Independent Claim 1 requires:
- A computing device with a display device that has a viewing area.
- The display device is caused to show a "scanning region" that is visible to the user and smaller than the total viewing area.
- A portion of a scanning object placed in this region is scanned by an "array of sensors embedded in the display device."
- A "circuit module" reads out sensing signals from the sensors to produce an image of the scanned portion of the object.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 9,241,082 - "Method and Apparatus for Scanning Through a Display Screen," issued January 19, 2016
The Invention Explained
- Problem Addressed: The patent identifies a need for technology that can scan large objects on portable devices, capture multiple fingerprints simultaneously for enhanced security, and detect marks that are not visible under normal lighting, such as security features on currency. (’082 Patent, col. 2:11-25)
- The Patented Solution: This invention describes a display device capable of a "moment of see-through." It incorporates a sensing module that includes its own set of lighting sources (e.g., at least three primary colored lights and optionally a "special light" like infrared or ultraviolet) to illuminate an object placed on the screen. The device's display unit is driven to become transparent, allowing the dedicated light source to illuminate the object and the reflected light to be captured by the sensor. (’082 Patent, Abstract; col. 3:1-9)
- Technical Importance: The invention advanced the concept of on-screen scanning by adding dedicated, multi-wavelength illumination, expanding its potential use from basic image capture to more sophisticated applications like counterfeit detection and advanced biometrics. (’082 Patent, col. 2:18-25)
Key Claims at a Glance
- The complaint asserts at least independent claim 20. (Compl. ¶28)
- Independent Claim 20 requires:
- A display device with a display unit driven to display a scanning region.
- A sensing module integrated with the display unit.
- At least one light source to illuminate a portion of an object placed in the scanning region.
- The display unit is "driven to have a moment of see-through," and the light source is turned on to cause the sensing module to generate an image.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
Multi-Patent Capsule
- Patent Identification: U.S. Patent No. 9,560,293, "Method and Apparatus for Image Capture Through a Display Screen," issued January 31, 2017.
- Technology Synopsis: This patent, from the same family as the others, focuses on a specific optical architecture for the image sensing module. The claimed invention uses an "optical assembly" that includes a "first light guide" with a second end shaped in a "parabolic curvature" that acts as an "edge-type micro-optical light guide reflector" to collect and focus light onto an image sensor disposed at the center of the first end. (’293 Patent, Abstract; col. 3:13-24)
- Asserted Claims: The complaint asserts at least independent claim 1. (Compl. ¶40)
- Accused Features: The complaint alleges the OnePlus 10 Pro contains an image sensing module with an optical assembly, a light guide with parabolic curvature acting as a reflector, and an image sensor, which are alleged to map to the elements of claim 1. (Compl. ¶41)
III. The Accused Instrumentality
- Product Identification: The complaint names mobile and/or handheld devices with optical fingerprint scanners, specifically identifying the "OnePlus 10 Pro" as an exemplary accused product. (Compl. ¶16)
- Functionality and Market Context: The accused devices are alleged to incorporate an "optical fingerprint scanner embedded beneath the display screen." (Compl. ¶16). The complaint provides a screenshot of the OnePlus 10 Pro's specifications listing "Fingerprint (under display, optical)" as a feature. (Compl. ¶17). A photograph included in the complaint shows the device in use, with a user's thumb placed over an illuminated icon on the screen, described as the "scanning region." (Compl. ¶18). Plaintiff alleges that Defendant is a "leading manufacturer and seller of smart phones in the world and in the United States." (Compl. ¶2)
IV. Analysis of Infringement Allegations
’088 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a display device having a viewing area for displaying content, the display device caused to display a scanning region for a user to place a scanning object onto the display device... | The OnePlus 10 Pro is a computing device with a display that presents a scanning region for a user to place an object (a finger) for scanning. | ¶18 | col. 10:57-60 |
| wherein the scanning region is defined visibly to the user and smaller than the viewing area in size... | A photo shows the scanning region is visibly defined by an icon on the screen and is smaller than the full display. | ¶18 | col. 10:60-62 |
| a portion of the scanning object falling into the scanning region is scanned by an array of sensors embedded in the display device... | The OnePlus 10 Pro includes an "optical fingerprint scanner embedded beneath the display screen" that scans the portion of the user's finger placed in the scanning region. | ¶17 | col. 10:62-65 |
| a circuit module, coupled to the sensors, reading out sensing signals from the sensors to produce an image of the portion of the scanning object, wherein the image captures details on the portion... | The device contains a circuit module that processes signals from the sensors to produce a fingerprint image. | ¶19 | col. 10:65-68 |
’082 Patent Infringement Allegations
| Claim Element (from Independent Claim 20) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a display unit driven to display thereon at least a scanning region | The OnePlus 10 Pro display is driven to show a scanning region. A provided photo depicts this scanning region on the device's screen. | ¶29 | col. 16:37-38 |
| a sensing module integrated with the display unit | The device's "under display, optical" fingerprint scanner constitutes a sensing module integrated with the display. | ¶30 | col. 16:39-40 |
| at least a light source to illuminate a portion of an object being placed in the scanning region and against the display unit... | The complaint cites a diagram explaining that optical scanners "incorporate arrays of LEDs or even your phone's display as a flash to light up the picture." | ¶31 | col. 16:41-43 |
| wherein the display unit is driven to have a moment of see-through, and at least a source is turned on to cause the sensing module to generate an image of the portion of the object. | The complaint alleges that the display unit is driven to have a "moment of see-through" and a light source is turned on to allow the sensor to generate an image. | ¶31 | col. 16:43-46 |
- Identified Points of Contention:
- Technical Questions: A primary question will concern the evidence for the "moment of see-through" functionality. The complaint relies on third-party articles explaining the general operation of optical scanners (Compl. ¶31) rather than specific technical evidence about the OnePlus 10 Pro's internal operation. The ability of the Plaintiff to prove this specific claimed mechanism will be central to its infringement case for the ’082 and ’293 Patents.
- Scope Questions: For the '088 Patent, a potential issue is the scope of "embedded in the display device." The patent describes placing a scanning module behind the LCD layers (’088 Patent, col. 4:41-44), and the court may need to determine if the "under display" configuration of the accused product meets this limitation as construed. For the ’293 Patent, infringement will turn on whether the accused device's optical assembly contains the specific "edge-type micro-optical light guide reflector" with "parabolic curvature" as claimed.
V. Key Claim Terms for Construction
The Term: "moment of see-through" (’082 Patent, Claim 20)
- Context and Importance: This term describes the core operational principle of the invention. Its construction will be critical because it defines the specific technical action that Plaintiff must prove the accused devices perform. Practitioners may focus on this term because it is functional, not structural, and its meaning will dictate the type of technical evidence required for infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The abstract describes the display being "controlled to have a moment of see-through either entirely or on a specified portion," suggesting flexibility in how this state is achieved. (’082 Patent, Abstract)
- Evidence for a Narrower Interpretation: The detailed description explains that when "liquid crystals are all fully opened, a full amount of the light from the backlighting section... goes through the LCD panel," linking the "see-through" state to the specific action of opening liquid crystals. (’082 Patent, col. 5:40-45)
The Term: "an array of sensors embedded in the display device" (’088 Patent, Claim 1)
- Context and Importance: The location and integration of the sensors are fundamental to the claim. The dispute may center on whether an "under display" scanner, which is physically located beneath the display stack, qualifies as "embedded in" the device as a whole.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent summary describes "scanners built in LCD devices" and an "image sensing module disposed in the liquid crystal display (LCD) device," which could be read to encompass any configuration where the scanner is part of the overall display assembly. (’088 Patent, col. 2:28, col. 2:47-49)
- Evidence for a Narrower Interpretation: The description and Figure 2A show a "space 204" between the "LCD panel 202 and the backlighting unit 208" where the scanning mechanism is located, which could support a narrower construction requiring placement within specific layers of the display stack. (’088 Patent, col. 4:41-44)
VI. Other Allegations
- Indirect Infringement: The complaint alleges that OnePlus induces infringement by "providing these products to end users for use in an infringing manner." (Compl. ¶¶21, 33, 44). It further alleges that Defendant acts with the intent to cause infringement or, alternatively, with willful blindness. (Compl. ¶¶22, 34, 45).
- Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of infringement "at least as of the date of this Complaint." (Compl. ¶¶21, 33, 44). The complaint does not plead any facts suggesting pre-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central evidentiary question will be one of operational proof: can Plaintiff produce specific, non-public evidence demonstrating that the accused OnePlus devices function with the claimed "moment of see-through," or will it have to rely on inference from general industry knowledge, which Defendant may argue is insufficient to prove infringement?
- A core issue will be one of structural and terminological scope: can the specific optical structures claimed in the ’293 Patent, such as the "edge-type micro-optical light guide reflector," be read to cover the components within the OnePlus scanner? Similarly, the case may turn on whether the term "embedded in the display device" from the '088 Patent is construed broadly enough to encompass the "under display" configuration of the accused product.