DCT

2:24-cv-00624

Ai Core Tech LLC v. Omron Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00624, E.D. Tex., 02/06/2025
  • 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 machine vision systems, industrial cameras, and barcode readers infringe seven patents related to configurable image processing drivers, image sensor manufacturing, dynamic data tag reader adjustment, graphical user interfaces, and networked computing.
  • Technical Context: The technologies at issue are foundational to industrial automation and machine vision, a market sector focused on automated inspection, process control, and data capture in manufacturing and logistics.
  • Key Procedural History: The complaint notes that Plaintiff served its Preliminary Infringement Contentions on Defendant on January 30, 2025, prior to filing the amended complaint.

Case Timeline

Date Event
1996-02-16 Earliest Priority Date for U.S. Patent No. 9,338,217
2002-06-07 Earliest Priority Date for U.S. Patent No. 7,215,834
2002-08-23 Earliest Priority Date for U.S. Patent No. 7,746,516
2003-07-16 Earliest Priority Date for U.S. Patent No. 8,130,241
2003-07-16 Earliest Priority Date for U.S. Patent No. 8,610,742
2003-09-29 Earliest Priority Date for U.S. Patent No. 7,365,298
2004-10-29 Earliest Priority Date for U.S. Patent No. 7,623,036
2007-05-08 U.S. Patent No. 7215834 Issues
2008-04-29 U.S. Patent No. 7365298 Issues
2009-11-24 U.S. Patent No. 7623036 Issues
2010-06-29 U.S. Patent No. 7746516 Issues
2012-03-06 U.S. Patent No. 8130241 Issues
2013-12-17 U.S. Patent No. 8610742 Issues
2016-05-10 U.S. Patent No. 9338217 Issues
2025-01-30 Plaintiff Serves Preliminary Infringement Contentions
2025-02-06 First Amended Complaint Filed

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

U.S. Patent No. 7,215,834 - "Configurable Image Processing Driver", Issued May 8, 2007

The Invention Explained

  • Problem Addressed: The patent’s background section describes the technical problem that conventional image capturing device drivers are not designed to adapt to variations in the hardware characteristics (e.g., CPU architecture, coupling bandwidth) or real-time operating conditions of the image capturing device and its host machine (Compl. ¶¶27-28; ’834 Patent, col. 1:33-54). This rigidity leads to a cumbersome design process and can result in degraded image quality when conditions change (Compl. ¶28; ’834 Patent, col. 1:62-2:2).
  • The Patented Solution: The invention is a device driver that runs on a host machine and processes images by first detecting static and dynamic characteristics of the device and host system (Compl. ¶31; ’834 Patent, col. 1:7-11). Based on these detected characteristics, the driver coordinates image processing by selecting and configuring appropriate versions of various "functional modules" (e.g., decompression, color correction) on-the-fly to optimize performance (Compl. ¶¶40-41; ’834 Patent, col. 3:50-56). Figure 1 of the patent illustrates the overall architecture, separating the image capturing device (105) from the host machine (145), where the device driver (150) orchestrates the processing modules (Compl. ¶32).
  • Technical Importance: This approach allows for a more flexible and robust image processing system that can dynamically adapt to different hardware configurations and changing operating environments without requiring a custom-designed driver for each specific setup (Compl. ¶30; ’834 Patent, col. 3:2-6).

Key Claims at a Glance

  • The complaint asserts at least independent claim 10 (Compl. ¶54).
  • Independent Claim 10 requires:
    • An image capturing device comprising a sensor and a transceiver.
    • The transceiver is adapted to transfer captured image data to a host machine.
    • The host machine supports a device driver for the image capturing device.
    • The driver is adapted to detect characteristics of the image capturing device and the host machine.
    • The driver is further adapted to coordinate image processing by configuring a plurality of image processing functional modules in response to the detected characteristics.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,365,298 - "Image Sensor And Method For Manufacturing The Same", Issued April 29, 2008

The Invention Explained

  • Problem Addressed: The patent addresses the problem of reduced light-collection efficiency in conventional CMOS image sensors. When light passes through the multiple insulating layers above a photodiode, it can be refracted and deviate from its intended path, causing noise and reducing photosensitivity (’298 Patent, col. 1:53-2:20).
  • The Patented Solution: The patent describes an image sensor with multi-layer interlayer insulating films where the density of the upper layers is progressively lower than that of the lower layers (’298 Patent, col. 2:38-43). This density gradient decreases the angle of refraction as light passes through the layers, ensuring more light is focused vertically onto the photodiode and increasing its light-collection efficiency (’298 Patent, col. 4:21-34).
  • Technical Importance: This manufacturing technique provides a method to improve the signal quality and sensitivity of CMOS image sensors, a critical component in digital cameras and machine vision systems, without fundamentally altering the photodiode itself (Compl. ¶67).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶71).
  • Independent Claim 1 requires:
    • An image sensor.
    • At least one photodiode formed on a semiconductor substrate.
    • Multi-layer interlayer insulating films on the photodiode, stacked in at least two layers of oxide film with different densities and refractive indexes.
    • The density and refractive index of the upper interlayer insulating film is lower than that of the lower interlayer insulating film.
    • A light shield layer and an element-protecting film sequentially stacked on the multi-layer films.
    • Color filter arrays and a flattening layer stacked on the element-protecting film.
    • Microlenses arranged corresponding to the color filters.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,623,036 - "Adjusting Data Tag Readers With Feed-Forward Data", Issued November 24, 2009

  • Technology Synopsis: This patent addresses the challenge of reliably reading RFID and other data tags, where the reader's power level may be too low for a successful read or too high, causing interference (Compl. ¶90). The invention is a "feed-forward" system where a sensor determines characteristics of an article approaching a data tag reader, and that information is used to proactively adjust a configurable parameter of the reader (e.g., power level, antenna position) to improve the reading of the tag on the moving article (Compl. ¶¶91, 93).
  • Asserted Claims: At least independent claim 21 is asserted (Compl. ¶115).
  • Accused Features: The Omron MicroHAWK V430-F series Barcode Reader is accused of infringing. It is alleged to be an image-based scanner with an imaging engine that processes captured images and improves the readability of captured data tags (Compl. ¶114).

U.S. Patent No. 7,746,516 - "Image Scanning", Issued June 29, 2010

  • Technology Synopsis: The patent addresses inefficiencies in conventional document scanning, where parameter settings (e.g., brightness, contrast) must be re-adjusted for each new document, which is time-consuming and error-prone (Compl. ¶135). The invention is a method where a scanner can store multiple sets of parameters from a first pre-scanned document and then apply those stored sets to a second pre-scanned document to generate multiple scanned images without repeated manual adjustments (Compl. ¶¶136-137).
  • Asserted Claims: At least independent claim 10 is asserted (Compl. ¶150).
  • Accused Features: The Omron MicroHAWK V430-F series Barcode Reader and its associated WebLink software are accused. The products allegedly provide an image-based scanner with advanced algorithms and a software interface to configure and set up the reader (Compl. ¶149).

U.S. Patent No. 8,130,241 - "Graphics Items That Extend Outside A Background Perimeter", Issued March 6, 2012

  • Technology Synopsis: This patent addresses limitations in conventional graphical user interfaces (GUIs) where graphical items like windows are strictly confined within a fixed background perimeter (Compl. ¶169). The invention allows a user to customize the background (e.g., resize it to be smaller than the maximum display area) and to move or size graphics items so that they reside at least partially outside the customized background's perimeter, which is particularly useful for projectors navigating physical obstacles in a room (Compl. ¶¶173-174).
  • Asserted Claims: At least independent claim 24 is asserted (Compl. ¶193).
  • Accused Features: The Omron FH Series Vision System is accused. It allegedly utilizes sensor controllers that are accessed via a network and have their own configurations that can be saved and loaded by a computer (Compl. ¶192).

U.S. Patent No. 8,610,742 - "Graphics Controls For Permitting Background Size Changes", Issued December 17, 2013

  • Technology Synopsis: This patent, related to the ’241 Patent, is directed to GUIs where conventional backgrounds fixedly fill the entire display area (Compl. ¶205). The invention provides systems and methods, including a "display background control tool," that allow a user to change the size of the background, which in turn re-defines the usable area for the display of other graphical components like windows and icons (Compl. ¶¶207-208).
  • Asserted Claims: At least independent claim 20 is asserted (Compl. ¶225).
  • Accused Features: The Omron WebLink software is accused of providing a system for the configuration and setup of barcode readers (Compl. ¶224).

U.S. Patent No. 9,338,217 - "Method And Apparatus For Computing Within A Wide Area Network", Issued May 10, 2016

  • Technology Synopsis: The patent addresses the limitations of the early World Wide Web as a passive information provider by proposing a system for distributing computational power across a network (Compl. ¶¶244, 247). The invention permits a computer system to be run as a "virtual machine" through a web page, allowing a client computer to view and/or control a remote host computer, and includes a "cluster administration computer" to manage a "stored personal state" that can be loaded onto a network computer to replicate a user's prior workspace (Compl. ¶¶248, 251).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶263).
  • Accused Features: The Omron FH Series Vision System is accused. The complaint alleges these systems use sensor controllers accessed by a computer over a network, with each controller having its own configuration settings that can be saved and loaded (Compl. ¶262).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities include the Omron FH and FZ Series Vision Systems, the Omron STC-MBA503POE PoE camera, the Omron MicroHAWK V430-F series Barcode Reader, and the Omron WebLink software application (Compl. ¶17).

Functionality and Market Context

  • The complaint alleges the accused products are used for industrial machine vision and data capture. The Omron FH and FZ Series Vision Systems and associated cameras are alleged to perform machine vision tasks using image sensors to capture data for automatic information extraction (Compl. ¶53). The Omron MicroHAWK V430-F is identified as an image-based barcode scanner that uses processing algorithms to decode barcodes and improve readability (Compl. ¶114). The Omron WebLink software is described as an application used to configure and set up the barcode readers (Compl. ¶149). The complaint's Figure 1 from the '036 patent, depicting a system where a sensor provides data to adjust a data tag reader, is used to illustrate the functionality of the accused barcode readers (Compl. ¶94).

IV. Analysis of Infringement Allegations

The complaint incorporates by reference "First Preliminary Infringement Contentions" served on the Defendant but does not attach them as an exhibit (Compl. ¶¶52, 71). The complaint itself provides only high-level, conclusory allegations of infringement for each patent, which do not contain sufficient technical detail to construct element-by-element claim charts. The narrative infringement theories for the lead patents are summarized below.

’834 Patent Infringement Allegations

  • The complaint alleges that the Omron FH and FZ Series Vision Systems directly infringe at least claim 10 of the ’834 patent (Compl. ¶¶53-54). The asserted basis for infringement is that these systems perform machine vision tasks and utilize an image capturing device (e.g., FH/FZ series cameras) comprising a sensor (e.g., CMOS or CCD) adapted to capture image data (Compl. ¶53). The complaint does not provide specific factual allegations detailing how the accused systems meet the "device driver," "detect characteristics," or "configuring... functional modules" limitations of claim 10.

Identified Points of Contention

  • Architectural Questions: A central question will be whether the software architecture of the accused Omron Vision Systems maps onto the specific "device driver" and "plurality of image processing functional modules" structure required by claim 10. The court may need to determine if the accused software performs functions equivalent to a "driver" as that term is used in the patent.
  • Functional Questions: The infringement analysis will likely focus on whether the accused systems perform the dynamic functions of "detect[ing] characteristics" of the device and host machine and "configuring" the processing modules "in response to" those characteristics, as the claim requires. The complaint does not allege facts showing that the accused systems perform such on-the-fly adaptation.

’298 Patent Infringement Allegations

  • The complaint alleges that the Omron STC-MBA503POE PoE camera directly infringes at least claim 1 of the ’298 patent because it provides "CMOS imaging and a CMOS active pixel digital image sensor" (Compl. ¶¶70-71). The complaint does not provide further factual allegations explaining how the physical structure of the accused camera's sensor meets the specific limitations of claim 1, particularly the requirement for multi-layer insulating films with a specific density and refractive index gradient.

Identified Points of Contention

  • Evidentiary Questions: The dispute will likely turn on physical evidence. The analysis will require a technical examination of the accused camera's image sensor to determine if it is constructed with the multi-layer interlayer insulating films having the specific decreasing density gradient required by claim 1.

V. Key Claim Terms for Construction

For the ’834 Patent

  • The Term: "device driver" (from claim 10)
  • Context and Importance: This term is foundational to claim 10. The infringement case depends on whether the software controlling the accused Omron systems constitutes a "device driver" that performs the functions recited in the claim. Practitioners may focus on this term because Defendant may argue that its system software has a different architecture or function than the specific "driver" contemplated by the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification describes the invention as "using a driver run on a host machine to processing the captured images" (’834 Patent, col. 1:7-9). This general functional description could support an interpretation covering any software component that manages the image processing pipeline between the camera and host.
    • Evidence for a Narrower Interpretation: The detailed description explains that the driver "orchestrates and coordinates" various "functional modules" by selecting different "versions" of those modules on-the-fly (’834 Patent, col. 2:53-56, 3:57-4:2). This could support a narrower construction requiring software that specifically manages and dynamically reconfigures a library of distinct, versioned processing modules.

For the ’298 Patent

  • The complaint does not provide sufficient detail for analysis of key claim terms.

VI. Other Allegations

  • Indirect Infringement: For each asserted patent, the complaint alleges induced infringement, stating that Defendant provides instructions, advertising, and technical support that guide customers to use the Accused Products in an infringing manner (e.g., Compl. ¶¶55, 72, 116). The complaint also alleges contributory infringement, asserting the Accused Products have special features that are material to the invention and not suitable for substantial non-infringing use (e.g., Compl. ¶¶56, 73, 117).
  • Willful Infringement: For each asserted patent, willfulness is alleged based on Defendant’s knowledge of the patents "at least as of the date when it was notified of the filing of this action" (e.g., Compl. ¶¶57, 74, 118). The complaint further alleges that Defendant has a "policy or practice of not reviewing the patents of others" and has thus been "willfully blind" of Plaintiff's rights (e.g., Compl. ¶¶58, 75, 119).

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

This litigation presents a broad assertion of seven patents with disparate technologies against several of Defendant's product lines. The case will likely turn on the resolution of the following central questions:

  • A primary issue will be one of evidentiary sufficiency: The complaint makes infringement allegations across a wide range of technologies—from the physical construction of a semiconductor ('298 Patent) to the architecture of networked computing (’217 Patent)—with minimal specific factual support. A key question for the case will be whether facts developed during discovery can substantiate these varied and highly technical infringement theories against the accused products.
  • A second core issue will be one of architectural mapping: For patents like the '834, '241, and '217, the claims recite specific software and system architectures (e.g., a "device driver" that "configures functional modules"; a system for managing a "stored personal state"). The court will need to determine whether the functional software and network operations of the accused Omron products can be mapped onto these specific claimed structures or if there is a fundamental mismatch.
  • Finally, the case raises a question of temporal and technological scope: The asserted patents claim priority to dates spanning a critical period of technological evolution (from 1996 to 2004). The interpretation of claim terms and the ultimate questions of infringement and validity will depend heavily on establishing the state of the art and the understanding of a person of ordinary skill at each of these distinct time periods.