2:24-cv-00645
Stratasys Inc v. Shenzhen Tuozhu Technology Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Stratasys, Inc. (Delaware)
- Defendant: Shenzhen Tuozhu Technology Co., Ltd., et al. (collectively "Bambu Lab") (People's Republic of China and Hong Kong SAR, China)
- Plaintiff’s Counsel: McDermott Will & Emery LLP; The Dacus Firm, P.C.; Ward, Smith & Hill, PLLC
- Case Identification: 2:24-cv-00645, E.D. Tex., 08/08/2024
- Venue Allegations: Venue is alleged to be proper because the Defendants are foreign entities that have committed acts of infringement in the district, including by selling products through their online store accessible to customers in the district.
- Core Dispute: Plaintiff alleges that Defendant’s 3D printers, associated accessories, and software infringe five U.S. patents related to tagged build materials, networked printer monitoring and control, and automated printer configuration.
- Technical Context: The technology domain is additive manufacturing, commonly known as 3D printing, a field with significant applications in rapid prototyping, custom manufacturing, and consumer products.
- Key Procedural History: The complaint alleges that Defendants were notified of the infringement via a notice letter sent on August 5, 2024, three days prior to the filing of the complaint, which forms the basis for the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2011-01-12 | ’324 Patent Priority Date |
| 2011-07-25 | ’097 Patent Priority Date |
| 2012-10-29 | ’466 and ’464 Patents Priority Date |
| 2013-10-22 | ’324 Patent Issue Date |
| 2013-12-31 | ’774 Patent Priority Date |
| 2014-06-10 | ’097 Patent Issue Date |
| 2020-02-25 | ’466 Patent Issue Date |
| 2021-11-09 | ’464 Patent Issue Date |
| 2022-01-01 | Accused Bambu Lab Printers First Sold (approx. "by 2022") |
| 2024-01-30 | ’774 Patent Issue Date |
| 2024-08-05 | Plaintiff Sends Notice Letter to Defendants |
| 2024-08-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,569,466 - "Tagged Build Material For Three-Dimensional Printing"
The Invention Explained
- Problem Addressed: The patent’s background section notes that for a 3D printer to properly fabricate an object, its controller needs to know the characteristics of the build material being used (Compl. ¶25; ’466 Patent, col. 1:16-24).
- The Patented Solution: The invention proposes instrumenting a supply of build material (e.g., a filament spool) with a data tag, such as an RFID tag. A 3D printer equipped with a tag sensor reads information from the tag, provides that data over a network to a remote client (e.g., a software application), receives operational parameters back from the client, and then fabricates the object according to those parameters (’466 Patent, Abstract; col. 14:26-35). This automates the configuration process and enables remote management.
- Technical Importance: This approach reduces user error in printer setup and facilitates a more integrated, networked ecosystem where material information can be seamlessly communicated between the physical material, the printer, and remote control software.
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶27).
- Essential elements of Claim 1 include:
- providing a 3D printer with a tag sensor;
- receiving a request from a client over a network to fabricate an object, with the printer coupled to a build material supply that has a tag storing at least one property;
- reading data from the tag with the sensor;
- providing the tag data to the client over the network;
- receiving one or more operational parameters from the client selected for use in controlling the printer; and
- fabricating the object according to those operational parameters.
U.S. Patent No. 11,167,464 - "Tagged Build Material For Three-Dimensional Printing"
The Invention Explained
- Problem Addressed: Similar to the ’466 Patent, the technology addresses the need for a 3D printer to automatically acquire and use build material characteristics to determine its operational settings (’464 Patent, col. 1:19-25).
- The Patented Solution: The patent describes a system where a printer reads data from a material tag and a processor uses that data to determine an operational parameter (e.g., build platform temperature, support structure requirement). Crucially, the processor then performs a "diagnostic test" to determine if that parameter is suitable for the printer before fabrication begins (’464 Patent, Abstract; col. 15:52-64). This internal verification step ensures compatibility between the material, the selected settings, and the printer's capabilities.
- Technical Importance: The invention adds an automated pre-flight check to the printing process, intended to prevent print failures caused by incompatible materials or settings.
Key Claims at a Glance
- The complaint asserts at least independent Claim 12 (Compl. ¶43).
- Essential elements of Claim 12 include:
- a 3D printer system with a coupling for build material and a tag sensor;
- a processor configured to determine an operational parameter based on data read from the tag;
- the processor is also configured to perform a diagnostic test to determine if the operational parameter is suitable for the printer; and
- a controller configured to control the printer to fabricate an object according to the operational parameter when the diagnostic test indicates it is suitable.
U.S. Patent No. 8,747,097 - "Networked Three-Dimensional Printer With Three-Dimensional Scanner"
Technology Synopsis
The patent describes providing networking capabilities to improve 3D printing fabrication resources (Compl. ¶57). The claimed invention is a 3D printer that includes a 3D scanner to capture information from an object during a print job, a machine vision system to analyze that information and provide a job status, and a web server to transmit that status for display at a remote client (Compl. ¶59).
Asserted Claims
At least Claim 1 is asserted (Compl. ¶59).
Accused Features
The complaint accuses Bambu Lab's X1C and X1E printers, alleging they contain a lidar scanner, use artificial intelligence to inspect the print's first layer, and transmit the status of the print job via a network interface and web server (Compl. ¶60).
U.S. Patent No. 11,886,774 - "Detection And Use Of Printer Configuration Information"
Technology Synopsis
The patent relates to methods for detecting the hardware and software properties of a 3D printer to enable the selection of suitable print models (Compl. ¶73). The claimed method involves software querying a target printer for its configuration information, receiving a "dictionary" of properties that affect its capabilities, creating a fabrication profile based on those properties, and then generating a machine-ready representation of a 3D model for that specific printer (Compl. ¶75).
Asserted Claims
At least Claim 1 is asserted (Compl. ¶75).
Accused Features
The complaint accuses the Bambu Studio software, specifically its "Synchronize filament list from AMS" feature, which allegedly queries the printer for the types of filament currently loaded and uses that information to configure the slicing parameters for the model (Compl. ¶76).
U.S. Patent No. 8,562,324 - "Networked Three-Dimensional Printing"
Technology Synopsis
The patent describes providing networking capabilities to 3D printers to improve fabrication resources (Compl. ¶89). The claimed device is a networked 3D printer with a video camera positioned to capture video of the build volume. A processor is configured to provide a user interface to a remote user that presents both an image from the video camera and a two-dimensional projection of the 3D model being printed, from the same point of view as the camera (Compl. ¶91).
Asserted Claims
At least Claim 1 is asserted (Compl. ¶91).
Accused Features
The complaint accuses Bambu Lab printers that include a network interface and a chamber camera. The associated Bambu Studio and/or Handy apps allegedly provide remote users with an interface showing both the camera feed and a 2D projection of the print job (Compl. ¶92).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are the Bambu Lab A1, A1 mini, P1P, X1-Carbon (X1C), P1S, and X1E 3D printers, along with the Bambu Studio and Bambu Handy software applications (Compl. ¶19).
Functionality and Market Context
The complaint alleges that the accused printers use an Automatic Material System (AMS) that includes RFID readers to identify data from RFID tags on filament spools (Compl. ¶28). These printers are network-enabled and are controlled by the Bambu Studio or Handy apps, which receive data from the printer and send fabrication instructions to it (Compl. ¶28, ¶44). Certain models, like the X1C and X1E, are alleged to include lidar scanners and machine vision systems for in-process print inspection (Compl. ¶60). The software is alleged to query the printers for configuration data to create print profiles (Compl. ¶76) and to provide a remote user interface displaying both a live camera feed and a 2D projection of the model being printed (Compl. ¶92). Defendants are alleged to have begun selling these printers in the U.S. by 2022 through direct online sales and resellers (Compl. ¶18). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
'466 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing a three-dimensional printer that includes a tag sensor; | Bambu Lab's printers include an Automatic Material System (AMS) with RFID tag readers. | ¶28 | col. 14:31-35 |
| receiving a request from a client over a network to fabricate an object...the printer coupled to a supply of a build material including a tag that stores at least one property of the build material; | A print request is received from the Bambu Studio/Handy apps; the printer is coupled to filament spools with RFID tags storing material properties like type and color. | ¶28 | col. 14:1-4 |
| reading data from the tag with the tag sensor; | The AMS's RFID tag readers read data from the RFID tag on each filament spool. | ¶28 | col. 15:8-14 |
| providing the data from the tag to the client over the network...; | Data from the RFID tag is provided to the Bambu Studio/Handy apps, which are connected to the printers via a network. | ¶28 | col. 15:35-40 |
| receiving one or more operational parameters from the client selected for use in controlling operation of the three-dimensional printer...; | The Bambu Studio/Handy app sends fabrication instructions to the printer based on the tag data. | ¶28 | col. 16:45-54 |
| fabricating the object with the build material according to the one or more operational parameters. | The Bambu Lab printers fabricate the object according to the instructions received from the apps. | ¶28 | col. 15:15-24 |
- Identified Points of Contention:
- Scope Questions: The claim requires "receiving one or more operational parameters from the client selected for use in controlling operation." The complaint alleges the app "sends fabrication instructions." This raises the question of whether these instructions are "selected" by a human user at the client, or if they are automatically generated by the client software. The degree of user input versus app automation in defining these parameters may be a central point of dispute.
'464 Patent Infringement Allegations
| Claim Element (from Independent Claim 12) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a system, comprising: a three-dimensional printer; a coupling adapted to receive a supply of a build material; a tag sensor...configured to read data from a data tag...; | Bambu Lab printers have an AMS that serves as a coupling for filament spools, and RFID readers (tag sensors) that read data from RFID tags on the spools. | ¶44 | col. 13:58-67 |
| a processor configured to determine an operational parameter of a fabrication process...based upon the data...; | The printer's processor determines operational parameters, such as a support structure requirement, based on the material type read from the RFID tag. | ¶44 | col. 15:15-24 |
| and to perform a diagnostic test to determine whether the operational parameter is suitable for the three-dimensional printer...; | The printer allegedly performs a diagnostic test, such as determining if the support structure filament in the printer is compatible with the build material filament. | ¶44 | col. 15:52-56 |
| a controller for the three-dimensional printer, the controller configured to, when the operational parameter is suitable...according to the diagnostic test, control operation of the three-dimensional printer...; | The printer's controller proceeds with fabrication according to the instructions from the Bambu Studio/Handy apps after the suitability is determined. | ¶44 | col. 15:25-34 |
- Identified Points of Contention:
- Technical Questions: The claim requires the processor to "perform a diagnostic test." The complaint alleges this is met by the printer determining if the loaded support and build filaments are compatible. A key technical question for the court will be what level of analysis or verification constitutes a "diagnostic test" under the patent's teachings, and whether the accused compatibility check rises to that level or is merely a data lookup.
V. Key Claim Terms for Construction
"diagnostic test" ('464 Patent, Claim 12)
- Context and Importance: This term appears to be a key differentiator of the invention. Its construction will be critical to determining whether the accused functionality—allegedly checking for filament compatibility—infringes. Practitioners may focus on this term because if it is construed narrowly to require an active, physical test or complex simulation, the accused compatibility check might not infringe; if construed broadly to include a software-based data comparison or lookup, the infringement case may be stronger.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides an example of a "preliminary diagnostic test" as checking "whether the diameter of the build material... is appropriate for the three-dimensional printer," which suggests a data-based suitability check could qualify ('464 Patent, col. 15:52-56).
- Evidence for a Narrower Interpretation: The complaint does not provide sufficient detail for analysis of intrinsic evidence supporting a narrower interpretation. Defendants may argue that the ordinary meaning of "test" implies more than a simple data comparison, potentially requiring an active process of verification beyond a lookup in a compatibility table.
"operational parameters from the client selected for use" ('466 Patent, Claim 1)
- Context and Importance: The infringement analysis for this claim element depends on where and by whom the "operational parameters" are "selected." Practitioners may focus on this term because the locus of control—whether the user at the client device makes an active selection, or whether the client software automatically generates instructions—is central to the infringement question.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that a "remote client device 206 may select which of the one or more supplies 302 to use in fabricating the object," suggesting an active user selection at the client is contemplated (’466 Patent, col. 16:50-52).
- Evidence for a Narrower Interpretation: The specification also notes that the "controller may calculate a suitable extruder temperature based on the type" of material identified from the tag, which could support an argument that some parameters are determined automatically rather than being "selected" by the client (’466 Patent, col. 15:30-32).
VI. Other Allegations
Indirect Infringement
For all asserted patents, the complaint alleges induced infringement based on Defendants providing the accused printers and software along with "supporting materials, maintenance guides, troubleshooting guides... instructions, product manuals, and technical information" that allegedly instruct and encourage customers to use the products in an infringing manner (e.g., Compl. ¶30, ¶46). Contributory infringement is also alleged on the basis that the accused products are specially designed to operate in an infringing manner and are not staple articles of commerce suitable for substantial non-infringing use (e.g., Compl. ¶32, ¶48).
Willful Infringement
The complaint alleges willful infringement of all asserted patents. The basis for this allegation is Defendants' alleged knowledge of the patents and their infringement as of August 5, 2024, the date a notice letter was allegedly sent (e.g., Compl. ¶34, ¶50).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "diagnostic test" in the ’464 patent be construed to cover the accused system’s alleged software-based check for filament compatibility, or does the term require a more active or physical verification process that is not performed?
- A second key issue will be one of locus of control: for the ’466 patent, does the accused system’s workflow, where an app "sends fabrication instructions," satisfy the claim requirement for receiving "operational parameters from the client selected for use"? The case may turn on evidence showing the extent of user-driven selection versus software automation in the Bambu Studio and Handy applications.
- A central evidentiary question across the networked printer patents ('097, '774, '324) will be one of functional correspondence: does the interaction between the Bambu Lab printers and the Bambu Studio software perform the specific, multi-step data-querying, processing, and display functions required by the respective claims, or are there fundamental mismatches in technical operation that place the accused system outside the claims' scope?