DCT

2:24-cv-00372

C47 Tech LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00372, U.S. District Court for the Eastern District of Texas (E.D. Tex.), 11/13/2024
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants maintain regular and established places of business in the district, including through a network of Authorized Service Providers over which Lenovo allegedly exerts control and ratifies as its own locations. Alternatively, venue is alleged to be proper for foreign defendant Lenovo Group Ltd. in any judicial district.
  • Core Dispute: Plaintiff alleges that certain Lenovo and Motorola smartphones, which feature multi-camera systems to create "Portrait Mode" and other depth-of-field effects, infringe a patent directed to methods of combining image data from multiple cameras captured using different parameters.
  • Technical Context: The technology at issue relates to computational photography, specifically the use of multiple camera sensors and processing to produce a single, enhanced image, a key competitive feature in the modern smartphone market.
  • Key Procedural History: The complaint notes prior litigation in Texas courts where jurisdiction over Lenovo was established, which Plaintiff cites to support personal jurisdiction in this matter. The complaint does not mention any prior licensing or inter partes review proceedings concerning the patent-in-suit.

Case Timeline

Date Event
2001-10-12 ’605 Patent Priority Date
2021-04-20 ’605 Patent Issue Date
2021 Representative launch year for an Accused Product line (Motorola Edge 2021)
2022 Representative launch year for an Accused Product line (Motorola Edge 2022)
2024-11-13 First Amended Complaint Filing Date

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

U.S. Patent No. 10,984,605 - "Camera Arrangements with Backlighting Detection and Methods of Using Same," issued April 20, 2021

The Invention Explained

  • Problem Addressed: The patent describes a technical challenge in early multi-image systems where combining images—such as a virtual object on a real background, or two separate real images—could result in an unnatural appearance ('605 Patent, col. 2:30-44). This mismatch often arose because the illumination (e.g., brightness, color, direction of light) on the separate image elements was inconsistent (Compl. ¶49; ’605 Patent, col. 2:30-40).
  • The Patented Solution: The invention proposes a camera system that captures not only pixel data for an image but also corresponding illumination data ('605 Patent, col. 3:1-6). By using data from multiple cameras or sensors, each potentially capturing the scene with different parameters, the system can merge the data to create a single, more realistic composite image where lighting and other characteristics are properly blended ('605 Patent, col. 3:10-25, 4:45-55; Compl. ¶50).
  • Technical Importance: The technology aimed to improve the realism of merged images in applications like augmented reality, telepresence, and computational photography by actively accounting for and correcting illumination differences between source images (Compl. ¶¶53, 56).

Key Claims at a Glance

  • The complaint asserts infringement of claims 1-3, 5-7, 10-12, 20, 24, 62, and 63 (Compl. ¶64). The independent claims in this set are 1 and 62.
  • Independent Claim 1: The core elements include:
    • A first camera configured to transmit a set of first camera data.
    • A second camera configured to transmit a set of second camera data.
    • Data communication circuitry coupling the cameras.
    • At least one processing chip configured to merge the data from the first and second cameras into a set of merged camera data.
    • The data from the first and second cameras are "representative of images taken with different camera parameters."
    • The merged data is "capable of being displayed as a single image."
  • Independent Claim 62: This claim is structurally similar to claim 1 but recites "a series of" camera data rather than "a set of" camera data, which may be relevant to continuous video capture versus a single photograph.
  • The complaint’s use of "at least" suggests the right to assert additional claims, including dependent claims, may be reserved (Compl. ¶64).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are "one or more cellular phones and other mobile devices," specifically including products from the "Motorola Edge Series," "Motorola G Series," and "Motorola One Series" (Compl. ¶¶57, 62).

Functionality and Market Context

  • The complaint targets camera features such as "Portrait Mode," "blur, depth and focus features" (Compl. ¶62). These features are alleged to use a multi-camera system, comprising, for example, a "50 MP Main" camera and a "Depth sensor," to capture and process information (Compl. ¶63). This allows the devices to generate photographs with artistic effects like a "soft, natural-looking background blur," which are created by combining data from the different sensors (Compl. ¶63). A screenshot from a Motorola support website shows instructions for users to adjust background "Blur" and foreground "Depth," illustrating the functionality that allegedly relies on merging data captured with different parameters (Compl. p. 23). This screenshot provides instructions for editing photos on a Motorola Edge device, thereby linking the accused functionality to a specific product line (Compl. p. 23).

IV. Analysis of Infringement Allegations

'605 Patent Infringement Allegations (Representative Claim 1)

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first camera configured to transmit a set of first camera data... The accused devices contain a primary camera, such as a "50 MP Main" camera, which captures image data. ¶63 col. 5:51-53
a second camera configured to transmit a set of second camera data... The accused devices contain a second camera-like sensor, identified as a "Depth sensor," which captures depth information. ¶63 col. 5:51-53
data communication circuitry... The accused devices contain the necessary internal circuitry to connect the multiple cameras to at least one processor. ¶62 col. 6:16-18
at least one processing chip... configured to merge said set of first camera data and said set of second camera data... A processor in the devices is alleged to combine the image data from the main camera and the depth data from the depth sensor to create the final "Portrait Mode" effect. ¶¶52, 62, 63 col. 3:26-29
wherein said set of first camera data and said set of second camera data are representative of images taken with different camera parameters The main camera captures a color image, while the depth sensor captures depth information. The complaint's theory is that capturing these different types of data constitutes capturing images with "different camera parameters." ¶¶52, 57, 63 col. 15:41-42
wherein said set of merged camera data is capable of being displayed as a single image The final photograph with the software-applied background blur is presented to the user as a single, "improved image." A screenshot of a fire hydrant in Portrait Mode is provided as an example. ¶¶52, 63, p. 23 col. 4:52-55
  • Identified Points of Contention:
    • Scope Questions: The central infringement question appears to be one of scope: does a "Depth sensor" that captures a depth map qualify as a "camera" that takes an "image" as those terms are used in the patent? The dispute may focus on whether the claim requires two cameras that both capture conventional visual images, or if it is broad enough to cover one camera capturing a visual image and a second sensor capturing non-visual data like depth.
    • Technical Questions: A related question is what constitutes "different camera parameters." The patent provides "different exposure settings" as one example (claim 12). The court will need to determine if capturing fundamentally different data types (color image vs. depth map) falls within the scope of this limitation, or if the term is restricted to adjustable settings (e.g., exposure, ISO, aperture) on otherwise similar cameras.

V. Key Claim Terms for Construction

  • The Term: "camera"

    • Context and Importance: This term's construction is critical, as infringement of claim 1 requires two distinct "cameras." Whether the accused "Depth sensor" meets the patent's definition of a "camera" will likely be a primary point of dispute.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification explicitly defines "camera" broadly as "any sensor device capable of sensing waves of energy varying in wavelength," including those that detect "infrared or ultraviolet energy" ('605 Patent, col. 13:27-32). This language may support an argument that a depth sensor, which often uses infrared light, qualifies.
      • Evidence for a Narrower Interpretation: The patent’s embodiments primarily describe "solid state imaging chip[s]" like "a CMOS imaging chip, a CCD imaging chip" used to capture visual "images" ('605 Patent, col. 5:56-65). A party could argue that in the context of the overall disclosure, a "camera" is an apparatus that produces a pictorial image, not a spatial data map.

  • The Term: "different camera parameters"

    • Context and Importance: This limitation defines the inventive concept of combining differently-captured data. The case may turn on whether the accused method of combining a color image with a depth map meets this requirement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not provide an exhaustive list of "parameters." The claims and specification discuss combining images from different sources (e.g., real and virtual) to solve lighting mismatches, suggesting "parameters" could broadly refer to the fundamental nature and source of the data, not just minor setting adjustments.
      • Evidence for a Narrower Interpretation: A defendant may argue that the term should be limited by its examples, such as "different exposure settings" (claim 12). This could support a narrower construction where "parameters" refer to adjustable settings on conventional cameras (e.g., exposure, aperture, focus), rather than the capture of entirely different data types like a depth map.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement to infringe, stating that Lenovo provides "promotional materials, manuals, guides, [and] terms of use" that instruct customers on how to use the accused camera features (Compl. ¶27). The screenshot from a Motorola support website, which provides step-by-step instructions for using the "Blur" and "Depth" adjustment features, is presented as direct evidence of these instructions (Compl. p. 23).
  • Willful Infringement: The complaint does not contain a separate count for willful infringement or allege any facts indicating that Defendants had knowledge of the '605 patent prior to the lawsuit. Therefore, the complaint does not provide sufficient detail for analysis of this element.

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

This case appears to center on questions of claim scope and technical interpretation. The key issues for the court will likely be:

  • A core issue will be one of definitional scope: can the term "camera", as used in the patent, be construed to cover the "Depth sensor" in the accused smartphones, or is it limited to devices that capture a conventional pictorial image? The patent's own broad definition will be weighed against the context provided by its specific embodiments.
  • A second key issue will be the interpretation of technical requirements: does the combination of a standard color image from one sensor and a depth map from another constitute merging "images taken with different camera parameters" as required by the claims? The outcome may depend on whether "parameters" is interpreted broadly to include the type of data captured, or narrowly to mean only adjustable settings of a traditional camera.
  • Finally, an evidentiary question may arise regarding the actual operation of the accused devices: what specific data does the "Depth sensor" provide, and how is that data "merged" with the data from the main camera by the processor? Discovery will likely focus on the underlying software and hardware implementation to determine if it aligns with the functional steps recited in the patent's claims.