DCT

2:22-cv-00433

LightGuide Inc v. Amazon.com Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: LightGuide, Inc. v. Amazon.com, Inc., 2:22-cv-00433, E.D. Tex., 11/07/2022
  • Venue Allegations: Venue is alleged to be proper based on Amazon operating regular and established physical places of business in the district, including the Amazon Robotics Fulfillment Center FTW3/FTW4 in Fort Worth, Texas, where acts of infringement are alleged to have occurred.
  • Core Dispute: Plaintiff alleges that Defendants’ operational guidance systems used in fulfillment centers, such as the Nike Intent Detection System, infringe three patents related to augmented reality systems that use projected light to guide and monitor manual tasks.
  • Technical Context: The technology at issue involves augmented reality projection systems that overlay digital instructions onto physical workspaces to guide workers in industrial processes like assembly, kitting, and logistics.
  • Key Procedural History: The complaint alleges an extensive pre-suit history, including that Amazon first became aware of LightGuide's technology in September 2016, subsequently purchased several of LightGuide’s patented systems for its "Innovation Lab," and engaged in discussions about a potential business relationship. LightGuide alleges it provided Amazon with a formal notice of infringement on October 11, 2021, over a year before filing the complaint.

Case Timeline

Date Event
2005-10-07 ’981 Patent Priority Date
2009-04-07 ’981 Patent Issue Date
2011-02-11 ’614 and ’036 Patents Priority Date
2016-09 Amazon allegedly becomes aware of LightGuide’s technology
2017-03-26 Amazon purchases first LightGuide system
2017-05-23 ’614 Patent Issue Date
2017-09-20 Amazon purchases second LightGuide system
2018-02 Amazon executives allegedly visit LightGuide's lab
2018-03-09 Amazon purchases third LightGuide system
2020-01-07 ’036 Patent Issue Date
2021-10-11 LightGuide provides Amazon with actual notice of infringement
2022-11-07 Complaint Filing Date

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

U.S. Patent No. 7,515,981 - "Light Guided Assembly System" (Issued April 7, 2009)

The Invention Explained

  • Problem Addressed: The patent’s background section describes the technical problem of human error in performing pre-designated operational steps, such as in a manufacturing environment, which can lead to workmanship issues, failure to meet standard time allowances, costly bottlenecks, and excess inventory (US 7,515,981 B2, col. 1:20-41).
  • The Patented Solution: The invention solves this problem with an operational guide system comprising a sensor, a controller, and a directional light device. The system detects a workpiece, and the controller directs the light device to project visual indicators (e.g., lights, shapes, text) to guide an operator through a sequence of physical tasks, such as selecting a specific part from a bin and installing it in the correct location on the workpiece, while also monitoring the process (US7515981B2, Abstract; col. 4:5-43).
  • Technical Importance: The technology provided a flexible and cost-effective method for error-proofing manual industrial processes, offering an alternative to more rigid and expensive automated machine vision systems or less reliable human inspection (US7515981B2, col. 1:42-56).

Key Claims at a Glance

  • The complaint asserts at least independent claim 12 (Compl. ¶39).
  • The essential elements of independent claim 12 are:
    • An operational guide system adapted to provide visual indicators to an individual to guide sequential actions;
    • At least one sensor apparatus operable to detect operation information and generate an output;
    • A controller that receives an input signal based on the sensor output and provides a command signal in response;
    • At least one directional light device that projects an indicating light in response to the command signal;
    • Wherein the controller is configured to monitor operational information associated with the sequential actions, with the information including at least one of: a cycle time, an incorrectly performed action, a time between sequential actions, or an operator identification.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,658,614 - "Light Guided Assembly System and Method" (Issued May 23, 2017)

The Invention Explained

  • Problem Addressed: The patent addresses the need for improvements in systems that guide individuals through operational steps to ensure proper and timely completion of tasks (US 9,658,614 B2, col. 1:15-23).
  • The Patented Solution: The invention is a method that uses a guide system with a controller and a projector. The controller contains a "plurality of selectable addressed display features," each with a "unique pre-programmed individual address identifier." The system receives input signals from a separate computer system, which causes the controller to select specific display features based on their address identifiers and project corresponding visual indicators onto physical objects. This allows for the dynamic, real-time projection of a sequence of visual instructions to guide an operator (US9658614B2, Abstract; col. 2:40-62).
  • Technical Importance: This technology enabled more complex and flexible guidance by creating an addressable system that could be dynamically controlled by higher-level software, such as a Manufacturing Execution System (MES), to adapt to complex and non-linear workflows in real time (US9658614B2, col. 1:57-65).

Key Claims at a Glance

  • The complaint asserts at least dependent claim 11, which depends on independent claim 1 (Compl. ¶55).
  • The essential elements of independent claim 1 are:
    • A method of projecting visual indicators to guide an individual's actions;
    • Providing a guide system with a controller and projector, where the controller includes a plurality of selectable addressed display features, each having a unique pre-programmed individual address identifier;
    • Receiving a sequence of input signals at the controller from a separate computer system or controller;
    • Selecting one or more particular addressed display features based on the input signals, which control selection based on the address identifier;
    • Projecting visual indicators corresponding to the selected features onto physical objects;
    • Wherein the guide system controller can receive any sequence of input signals to dynamically control the projection of visual indicators, creating a dynamic, real-time projection.
  • The complaint does not explicitly reserve the right to assert other dependent claims.

U.S. Patent No. 10,528,036 - "Light Guided Assembly System and Method" (Issued January 7, 2020)

  • Technology Synopsis: This patent, a continuation of the '614 Patent, adds a camera and a remote monitor to the light-guided system. The camera is located proximate to the projector and is configured to capture an image of the individual, the physical object, and the projected visual indicator simultaneously. This captured image is then displayed on a monitor remote from the operator's station, enabling remote verification, recording, and analysis of the guided task (US 10,528,036 B2, Abstract; col. 2:19-29).
  • Asserted Claims: The complaint asserts at least independent claim 7 (Compl. ¶75).
  • Accused Features: The complaint alleges that Amazon’s NIKE IDS system infringes by using a projector, a controller, cameras (RGB and ODS cameras), and a remote monitor viewed by "TRON or AVOC associates" to classify and verify stowing activities (Compl. ¶¶77, 83-85).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Amazon’s "Nike Intent Detection System (Nike IDS)" and "Bin Vision System" used for "guided stow/pick activities" in its fulfillment centers (Compl. ¶32).

Functionality and Market Context

  • The complaint alleges the accused systems use projectors to project light indicators (e.g., purple or magenta lights) onto storage pods to guide fulfillment center associates on where, or where not, to stow items (Compl. ¶¶47-48). The system uses barcode scanners (e.g., Cognex) to identify items and "programmable logic controllers" to process information and direct the system's components (Compl. ¶¶44, 46). Figure 15 of the complaint provides a labeled diagram of the "IDS Equipment," including a projector, cameras, and a scanner at a stowing station (Compl. ¶32, Fig. 15). The system is also alleged to use cameras to monitor the associate's actions and verify task completion, sometimes involving remote human review via monitors (Compl. ¶¶49, 83-85).
  • The complaint frames these systems as integral to Amazon's logistics operations, enabling the company to manage and track millions of items and fulfill customer orders at a massive scale (Compl. ¶¶35-36).

IV. Analysis of Infringement Allegations

'981 Patent Infringement Allegations

Claim Element (from Independent Claim 12) Alleged Infringing Functionality Complaint Citation Patent Citation
an operational guide system...comprising: at least one sensor apparatus, said at least one sensor apparatus operable to detect operation information and generate an output indicative of said operation information; The NIKE IDS system includes a Cognex camera or handheld barcode scanner that detects the Amazon Standard Identification Number (ASIN) on an item to be stowed. ¶44 col. 6:40-54
a controller, said controller receiving at least a first input signal indicative of said operation information and selectively providing at least one command signal in response to said first input signal; The NIKE IDS system uses programmable logic controllers that receive the scan information (input signal) and in response generate command signals to control other system components, such as the projector. ¶46 col. 4:10-25
and at least one directional light device...selectively operable to project and target at least one indicating light in response to said at least one command signal from said controller, The system includes a projector that, in response to a command signal, projects purple or magenta lights onto specific bins of a storage pod to guide the associate. Figure 23 shows an associate at a work station where a storage pod is illuminated by projected lights. ¶¶47-48, Fig. 23 col. 7:6-24
wherein said controller is configured to monitor operational information associated with sequential actions, said operational information including at least one selected from the group consistent of a cycle time, an incorrectly performed action, a time between sequential actions, and an operator identification. The NIKE IDS system is configured to monitor the associate’s stow rate (cycle time), time elapsed between scans, and incorrect actions, such as stowing an item in a bin marked with a magenta light. Figure 24 shows a user interface displaying a 15-second timer for a "Stow Item" task. ¶49, Fig. 24 col. 2:27-33
  • Identified Points of Contention:
    • Scope Question: A potential point of contention is whether a system that guides an operator by indicating where not to place an item (a negative instruction) meets the limitation of a system that "guide[s] sequential actions" in the affirmative manner described in the patent's embodiments.
    • Technical Question: The infringement analysis may focus on whether the alleged monitoring of "stow rate" and "multiple events" by Amazon's system constitutes the specific types of "operational information" (cycle time, incorrectly performed action, etc.) as enumerated in the Markush group of claim 12.

'614 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method of projecting visual indicators...comprising: providing a guide system having a guide system controller and a projector, said guide system controller including a plurality of selectable addressed display features with each said addressed display feature having a unique pre-programmed individual address identifier within said guide system controller; Amazon provides the NIKE IDS method, which uses a controller and projector. The controller manages various light displays (e.g., different colors, shapes, flashing), which are alleged to be "selectable addressed display features" with "pre-programmed individual address identifiers." ¶¶60-61 col. 15:20-37
receiving a sequence of one or more input signals at said guide system controller, with the input signals being provided to said guide system controller by a separate computer system or controller... The guide system controller receives input signals when an associate scans an item. This action is allegedly directed by "artificial intelligence driven logic," suggesting that a separate, higher-level system provides the operative signals to the guide controller. ¶¶63-64 col. 1:40-44
selecting one or more particular addressed display features...based on said input signals, wherein said input signals control selection of said addressed display features based on the address identifier for the said addressed display feature; Based on the scanned item and the AI logic, the system selects a particular light display (e.g., magenta lights of a certain shape) to project onto specific bins, allegedly corresponding to selecting a feature based on its address identifier. ¶64 col. 1:45-54
and projecting one or more visual indicators corresponding to said selected particular addressed display features onto one or more physical objects... The projector projects the selected visual indicator (magenta lights) onto the physical bins of the storage pod. Figure 33 shows an associate viewing lights projected onto a pod. ¶64, Fig. 33 col. 1:55-62
wherein said guide system controller is operative to receive any sequence of input signals from the separate computer system or controller to dynamically control projection of any sequence of said visual indicators...resulting in a creation of a dynamic, real time projection of visual indicators; The system is alleged to dynamically control the projector in real time based on the specific item scanned, bin fullness, weight distribution, and other factors, thereby creating a dynamic, real-time projection of instructions for the associate. ¶¶65-66 col. 2:10-14
  • Identified Points of Contention:
    • Scope Question: A central dispute will likely be whether Amazon’s "artificial intelligence driven logic" uses a structure that meets the "unique pre-programmed individual address identifier" limitation. The defense may argue that an AI model does not use discrete, pre-programmed identifiers in the manner disclosed in the patent's specification (e.g., the VDF address table in Fig. 3A).
    • Technical Question: What evidence does the complaint provide that the control logic resides in a "separate computer system or controller" that provides signals to the guide system controller, as opposed to being an integrated function of a single controller?

V. Key Claim Terms for Construction

For the ’981 Patent

  • The Term: "monitor operational information"
  • Context and Importance: This term is critical because it defines a key function of the claimed controller. The infringement case for claim 12 hinges on whether the accused NIKE IDS system's alleged monitoring of "stow rate" and "multiple events" falls within the scope of the specific types of information listed in the claim's Markush group.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification broadly discusses using the control module to "monitor cycle times of the individual operational steps" and for "system productivity reporting" (US7515981B2, col. 5:50-56), which could support a more general reading of the term.
    • Evidence for a Narrower Interpretation: Claim 12 itself explicitly lists what this information includes: "at least one selected from the group consist[ing] of a cycle time, an incorrectly performed action, a time between sequential actions, and an operator identification." A defendant may argue this list is exhaustive and that any monitoring outside these specific categories does not meet the limitation.

For the ’614 Patent

  • The Term: "unique pre-programmed individual address identifier"
  • Context and Importance: This term is the core of the asserted inventive concept in the '614 patent family, distinguishing it from more basic light-guidance systems. Practitioners may focus on this term because the viability of the infringement claim depends on mapping Amazon's AI-driven system onto this claim element.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the identifier as the mechanism for selecting a "visual display feature" (VDF) from a plurality of options (US9658614B2, col. 1:45-54). Plaintiff may argue that any programmatic method for selecting a specific light pattern (e.g., magenta, blinking, specific location) in response to a specific input functionally uses an "address identifier," even without a literal address table.
    • Evidence for a Narrower Interpretation: The specification provides a very concrete embodiment in Figure 3A, which depicts a "VDF address table" with unique alphanumeric identifiers (e.g., A1, F6) corresponding to specific instructions and graphics (US9658614B2, Fig. 3A, col. 15:20-41). A defendant could argue this disclosure limits the term to a discrete, pre-programmed tabular structure, which an AI-based system may not possess.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Amazon induces infringement by providing the accused systems to its fulfillment centers and instructing its employees and agents on how to perform the allegedly infringing methods of stowing and picking items (Compl. ¶¶53, 73, 89). It further alleges contributory infringement by providing components that are a material part of the invention and not a staple article of commerce (Compl. ¶53).
  • Willful Infringement: The complaint makes detailed allegations to support willfulness. It claims Amazon had pre-suit knowledge of the patents and technology dating back to September 2016 through inquiries, multiple purchases of LightGuide's own patented products, and visits to LightGuide's lab (Compl. ¶¶21-28, 51). The complaint further alleges that LightGuide sent a formal notice letter on October 11, 2021, and that Amazon's in-house counsel requested that patent references be removed from a presentation, stating that "Amazon engineers need to develop as if there were no patents" (Compl. ¶¶31, 34).

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

  • A core issue will be one of definitional scope: can the term "unique pre-programmed individual address identifier," which is exemplified in the '614 patent with a discrete address table, be construed to read on the "artificial intelligence driven logic" alleged to be used by Amazon’s fulfillment center systems?
  • A key evidentiary question will be one of technical operation: does the evidence show that Amazon's system, which primarily provides negative guidance (where not to place an item), performs the affirmative "guid[ing of] sequential actions" as required by claim 12 of the '981 Patent, and does it "monitor" the specific categories of information enumerated in that claim?
  • A third central question, pertinent to damages, will be one of intent: given the extensive allegations of pre-suit interactions and an explicit notice of infringement, did Amazon's continued use of the accused systems constitute objective recklessness sufficient to support a finding of willful infringement?