Lonestar Biometrics LLC v. ZTE

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lonestar Biometrics LLC. (Texas)
  • Defendant: ZTE Corporation (China)
  • Plaintiff’s Counsel: Rubino IP; Truelove Law Firm, PLLC
• Case Identification: 2:22-cv-00242, E.D. Tex., 06/28/2022
• Venue Allegations: Venue is alleged to be proper because Defendant is not a resident of the United States and may therefore be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s ZTE Axon 30 Ultra smartphone infringes three patents related to methods and apparatuses for scanning or capturing images through a device's display screen.
• Technical Context: The technology at issue involves integrating optical sensors beneath a mobile device's display to enable biometric authentication, such as fingerprint scanning, directly on the screen.
• Key Procedural History: The asserted patents are part of a continuing patent application family, but the complaint does not mention any prior litigation, inter partes review proceedings, or specific licensing history concerning the patents-in-suit.

Case Timeline

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 Jan. 5, 2016)

The Invention Explained

• Problem Addressed: The patent describes the need for a better way to capture images of documents or other objects using electronic devices, noting that built-in webcams are "not ideal" for this purpose and that a dedicated scanning capability within the display itself would be desirable (’088 Patent, col. 2:6-16).
• The Patented Solution: The invention proposes a computing device with a display that can present a visually defined "scanning region" to the user. An array of sensors embedded within the display assembly is configured to scan only the portion of an object placed within this specific, smaller-than-screen region, with a circuit module processing the sensor signals to create an image (’088 Patent, Abstract; col. 8:12-24). This allows for targeted scanning without capturing useless data from the surrounding display area (’088 Patent, col. 8:25-39).
• Technical Importance: This technology allows for the integration of scanning functions directly into a display, which can save space and improve user experience on portable devices by eliminating the need for a separate scanner (’088 Patent, col. 2:10-16).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶17).
• The essential elements of claim 1 include:
  • A computing device comprising a display device with a viewing area.
  • The display device is caused to display a "scanning region" for a user to place a scanning object.
  • The scanning region is "defined visibly to the user and smaller than the viewing area in size."
  • A portion of the object falling into the scanning region is scanned by an "array of sensors embedded in the display device."
  • A "circuit module" is coupled to the sensors and reads out signals to produce an image of the scanned portion.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,241,082 - "Method and Apparatus for Scanning Through a Display Screen" (Issued Jan. 19, 2016)

The Invention Explained

• Problem Addressed: The patent identifies a need for technology that can scan objects on a portable device, including for multi-fingerprint authentication or for identifying marks on an object (like a currency bill) that are not visible under normal lighting (’082 Patent, col. 2:11-24).
• The Patented Solution: The invention describes a display device, such as an LCD, that is engineered to have a "moment of see-through." This is achieved by controlling the display's liquid crystals to become fully transparent. During this moment, an image sensing module located behind the display, equipped with its own light source, can illuminate and capture an image of an object placed on the screen (’082 Patent, Abstract; col. 2:35-49).
• Technical Importance: By enabling the display to become temporarily transparent in a controlled manner, this invention allows for the integration of sophisticated scanning capabilities, including those using specialized light sources, directly into a standard display stack (’082 Patent, col. 2:11-14).

Key Claims at a Glance

• The complaint asserts at least independent claim 20 (Compl. ¶28).
• The essential elements of claim 20 include:
  • A display device comprising 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."
  • At least one source is turned on to cause the sensing module to generate an image of the object portion.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,560,293 - "Method and Apparatus for Image Capture Through a Display Screen" (Issued Jan. 31, 2017)

• Technology Synopsis: This patent discloses an image capture apparatus integrated into a display screen. The technology centers on an optical assembly that uses a first light guide with a "parabolic curvature" on its second end, which acts as an "edge-type micro-optical light guide reflector." This specific geometry is designed to collect and focus reflected light from an object on the screen onto an image sensor located at the first end of the light guide, enabling image capture through the display during a "moment of see-through" (’293 Patent, Abstract; col. 3:12-25).
• Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶40).
• Accused Features: The complaint alleges that the ZTE Axon 30 Ultra's image sensing module contains an optical assembly with a first light guide whose second end is "shaped in parabolic curvature" and acts as a reflector, and an image sensor disposed at the first end, thereby infringing the ’293 patent (Compl. ¶41).

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is the ZTE Axon 30 Ultra smartphone and other similar products (Compl. ¶13).

Functionality and Market Context

• The complaint focuses on the product's "Ultra-thin optical fingerprint under the screen" feature (Compl. ¶17, ¶30). The allegations describe a system where the user is prompted to place their finger on a designated icon (a "scanning region") on the display (Compl. ¶18, ¶29). The complaint provides an image from a third-party review showing the illuminated fingerprint icon on the device's lock screen (Compl. ¶18). The complaint further alleges, citing an external article, that the device uses the phone's display as a "flash to light up the picture" for an embedded optical sensor to capture the fingerprint image (Compl. ¶31). The complaint characterizes ZTE as a "leading manufacturer and seller of smart phones" (Compl. ¶2).

IV. Analysis of Infringement Allegations

’088 Patent Infringement Allegations

’082 Patent Infringement Allegations

Identified Points of Contention

• Technical Questions: The patents-in-suit extensively describe the "see-through" capability in the context of controlling Liquid Crystal Displays (LCDs). The ZTE Axon 30 Ultra uses an AMOLED display, which operates on a different principle. A central technical question will be whether the mechanism by which an AMOLED display allows a sensor to capture an image from beneath is the same as or equivalent to the "fully open" liquid crystals described in the patents.
• Scope Questions: The ’088 Patent requires sensors "embedded in the display device." The complaint alleges the scanner is "embedded beneath the display screen" (Compl. ¶17). This raises the question of whether a sensor module placed under the display stack, but not necessarily integrated within its layers, falls within the scope of the term "embedded." The construction of this term may be a focal point of the dispute.
• Evidentiary Questions: The complaint relies on marketing materials and third-party articles to allege the internal workings of the accused device. A key question is what technical evidence, such as from device teardowns or internal ZTE documents, will be presented to prove that the actual operation and structure of the scanner match the specific limitations of the claims.

V. Key Claim Terms for Construction

The Term: "array of sensors embedded in the display device" (’088 Patent, Claim 1)

• Context and Importance: The location and integration level of the sensor array are core to the invention. The definition of "embedded" will be critical for determining infringement. Practitioners may focus on this term because the physical placement of the accused sensor—whether it is laminated into the display stack or is a discrete component placed under the stack—will directly impact the infringement analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes placing a "scanning mechanism" in a "space" between the LCD panel and the backlighting unit, which could support a construction where "embedded" means housed within the overall device assembly, not necessarily integrated into the display panel itself (’088 Patent, col. 4:41-47).
  • Evidence for a Narrower Interpretation: An embodiment is described where photosensors are on a transparent sheet "disposed behind the array of colored filters and corresponding liquid crystals," suggesting a more tightly integrated configuration within the display layers, which could support a narrower definition (’088 Patent, col. 9:16-19).

The Term: "moment of see-through" (’082 Patent, Claim 20)

• Context and Importance: This term describes the fundamental mechanism that enables the under-display scanning. Its construction is vital because the accused device uses AMOLED technology, whereas the patent's examples focus on LCDs. Practitioners may focus on this term because the defense could argue that the term is limited to the specific LCD mechanism described in the patent, creating a potential non-infringement argument.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The abstract broadly describes scanners in display devices that can be "controlled to have a moment of see-through," which could be read as a functional description applicable to any display technology that can be made temporarily transparent (’082 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The detailed description repeatedly explains the concept by referencing the control of "liquid crystals" to be "fully opened," allowing light to pass. This explicit linkage to LCD mechanics could be used to argue for a narrower construction limited to that specific implementation (’082 Patent, col. 5:40-44; col. 6:1-3).

VI. Other Allegations

Indirect Infringement

• The complaint alleges that ZTE induced infringement by "providing these products to end users for use in an infringing manner" (Compl. ¶21, ¶33, ¶44). The allegations of knowledge and intent are based on ZTE's awareness of its own product's functionality and its role in putting the infringing devices into the hands of consumers.

Willful Infringement

• Willfulness is alleged based on ZTE’s knowledge of infringement "at least as of the date of this Complaint" (Compl. ¶21, ¶33, ¶44). The complaint does not allege any facts supporting pre-suit knowledge of the patents or the alleged infringement.

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

• A core issue will be one of technological scope: can the claims, which are explained in the context of Liquid Crystal Display (LCD) technology and "fully open" liquid crystals, be construed to read on the accused ZTE Axon 30 Ultra, which uses a fundamentally different AMOLED display technology to achieve its under-display scanning?
• A second central issue will be one of definitional interpretation: does the term "embedded in the display device" as claimed in the ’088 patent require the sensor to be an integral part of the display's laminated layers, or is it broad enough to cover a discrete sensor module located "beneath the display screen," as alleged in the complaint?
• A key evidentiary question will be one of operational proof: can the plaintiff move beyond the marketing claims and third-party articles cited in the complaint to provide concrete technical evidence that the internal architecture and specific method of operation of the accused scanner meet every limitation of the asserted claims?