Cedar Lane Tech Inc v. Bixolon Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Bixolon Co., Ltd. (Republic of Korea)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00897, E.D. Tex., 11/03/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains an established place of business in the District and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s remote printing products infringe seven U.S. patents related to network communication protocols between a printer and a server, as well as methods for high-speed image printing.
• Technical Context: The patents address methods for enabling remote printers to communicate directly with servers to download and print data, which is significant for mobile and internet-connected printing applications that operate without a dedicated host computer.
• Key Procedural History: The complaint does not specify any prior litigation or administrative proceedings involving the patents-in-suit. However, the patents largely stem from a single original application filed in 2002, creating a large family of related patents through a series of continuation applications. U.S. Patent No. 10,346,105, one of the asserted patents, is subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier patent in the family.

Case Timeline

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

U.S. Patent No. 10,346,105 - “Method and system for communicating between a remote printer and a server,” Issued July 9, 2019

The Invention Explained

• Problem Addressed: The patent’s background describes the conventional process of printing digital images from the internet as "cumbersome," "tedious, time-consuming, and error-prone" (’105 Patent, col. 2:65-67). This process typically requires a user to manually locate an image on the web, download it to a host computer, and then issue a print command from that computer, a process that limits user mobility and introduces multiple points of potential failure (’105 Patent, col. 1:53-2:52).
• The Patented Solution: The invention proposes a direct communication protocol between a remote printer and a server, eliminating the need for a host computer (’105 Patent, Abstract). The method involves the printer establishing a network connection end point (a "socket") with the server, sending an authentication request, receiving print data in portions, and sending a notification back to the server after each portion is printed, allowing for robust and resumable printing sessions (’105 Patent, col. 5:8-6:5).
• Technical Importance: This protocol was designed to enable reliable printing from mobile or standalone network-connected devices, a key technical hurdle for expanding printing capabilities beyond the traditional PC-centric model (’105 Patent, col. 3:4-15).

Key Claims at a Glance

• The complaint asserts infringement of one or more "exemplary method claims" but does not specify them (Compl. ¶17). Independent claim 1 is representative.
• Essential Elements of Claim 1 (Method):
  • Receiving, by a computing device from a remote printer, data identifying one or more characteristics of the remote printer.
  • Verifying that the remote printer has been registered with the computing device.
  • Sending, from the computing device to the remote printer, an indication of a number of data items to be printed.
  • Sending an indication of a number of print data items to be downloaded, where the printer is configured to download the print data items.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to "one or more claims" (Compl. ¶17).

U.S. Patent No. 7,383,321 - “Method and system for communicating between a remote printer and a server,” Issued June 3, 2008

The Invention Explained

• Problem Addressed: The patent, which is the original patent in a large family, addresses the same technical problem as the ’105 Patent: the complexity and unreliability of printing images from the internet using a host computer (’321 Patent, col. 2:1-49).
• The Patented Solution: The invention provides a protocol for direct communication between a printer and a server. Key steps include establishing an "interprocess communication mechanism" (e.g., a socket), requesting authentication, requesting and receiving print data, and notifying the server of print completion (’321 Patent, Abstract; Fig. 2). The protocol is designed to handle unreliable connections by allowing transmission to restart at the point of interruption (’321 Patent, col. 3:40-44).
• Technical Importance: This direct communication architecture was a foundational step for enabling network-aware printers that could function independently of a companion computer, supporting emerging mobile and internet-based services (’321 Patent, col. 4:46-53).

Key Claims at a Glance

• The complaint asserts infringement of one or more "exemplary claims" without identifying them (Compl. ¶23). Independent claim 1 is representative.
• Essential Elements of Claim 1 (Method):
  • Establishing an interprocess communication mechanism comprising a connection end point and a network address identifying a server.
  • Communicating with the server, which includes sending an authentication request and receiving a response.
  • Requesting print data portions to be downloaded if authentication is successful.
  • Attempting to receive the print data portions, including security indicator verification.
  • Notifying the server after print completion.
  • Terminating the connection when a session ends or an error occurs.
• The complaint refers broadly to "one or more claims" of the patent (Compl. ¶23).

Multi-Patent Capsule: U.S. Patent No. 7,958,205

• Patent Identification: U.S. Patent No. 7,958,205, “Method and system for communicating between a remote printer and a server,” Issued June 7, 2011.
• Technology Synopsis: This patent is part of the same family as the ’105 and ’321 Patents. It describes a client-server communication protocol that enables a remote printer to connect directly to a server, authenticate, and download print jobs in a manner robust to network interruptions (Compl. ¶11; ’205 Patent, Abstract).
• Asserted Claims: The complaint asserts unspecified "exemplary method claims" (Compl. ¶32).
• Accused Features: The complaint alleges infringement by Defendant's products that implement a method for communicating between a remote printer and a server (Compl. ¶32, ¶34).

Multi-Patent Capsule: U.S. Patent No. 8,645,500

• Patent Identification: U.S. Patent No. 8,645,500, “Method and system for communicating between a remote printer and a server,” Issued February 4, 2014.
• Technology Synopsis: As a continuation in the same patent family, this patent discloses the same core printer-server communication protocol. The claims focus on the server-side method, including receiving a challenge phrase from a printer for authentication and receiving print data based on a wireless connection (Compl. ¶12; ’500 Patent, Abstract, Claim 1).
• Asserted Claims: The complaint asserts unspecified "exemplary method claims" (Compl. ¶38).
• Accused Features: The complaint accuses Defendant's products that utilize a method for communicating between a remote printer and a server (Compl. ¶38, ¶40).

Multi-Patent Capsule: U.S. Patent No. 8,773,685

• Patent Identification: U.S. Patent No. 8,773,685, “High-speed digital image printing system,” Issued July 8, 2014.
• Technology Synopsis: Unlike the other patents-in-suit, this patent addresses methods for increasing the efficiency of a printing system itself, rather than the communication protocol. The invention describes techniques for decreasing the total time to print a plurality of images by, for example, transferring images to a high-speed RAMdisk at the print server before printing and processing images in a specific order (e.g., based on estimated processing time) to ensure the print engine does not stop and restart (Compl. ¶13; ’685 Patent, Abstract).
• Asserted Claims: The complaint asserts unspecified "exemplary claims" (Compl. ¶44).
• Accused Features: The complaint alleges infringement by Defendant's products that practice methods for high-speed printing, separate from the communication protocol allegations (Compl. ¶44, ¶49).

Multi-Patent Capsule: U.S. Patent No. 9,448,750

• Patent Identification: U.S. Patent No. 9,448,750, “Method and system for communicating between a remote printer and a server,” Issued September 20, 2016.
• Technology Synopsis: This patent, another member of the primary patent family, claims methods for printer-server communication. The claims are directed to the server-side actions of receiving printer characteristics, verifying registration in a database, and sending back indications of data items to be printed and downloaded (Compl. ¶14; ’750 Patent, Abstract, Claim 1).
• Asserted Claims: The complaint asserts unspecified "exemplary method claims" (Compl. ¶53).
• Accused Features: The complaint alleges infringement by Defendant's products that perform communication between a remote printer and a server (Compl. ¶53, ¶55).

Multi-Patent Capsule: U.S. Patent No. 9,983,836

• Patent Identification: U.S. Patent No. 9,983,836, “Method and system for communicating between a remote printer and a server,” Issued May 29, 2018.
• Technology Synopsis: Also from the same family, this patent describes the core printer-server communication protocol. The claims focus on the server's role in the method, including receiving printer characteristics, verifying registration, and sending indications of data items to be printed (Compl. ¶15; ’836 Patent, Abstract, Claim 1).
• Asserted Claims: The complaint asserts unspecified "exemplary method claims" (Compl. ¶59).
• Accused Features: The complaint accuses Defendant's remote printing products of practicing the claimed communication methods (Compl. ¶59, ¶61).

III. The Accused Instrumentality

• Product Identification: The complaint does not name any specific accused products. It refers generally to "Exemplary Defendant Products" that are identified in claim chart exhibits (Compl. ¶17, ¶19). These exhibits were not filed with the complaint.
• Functionality and Market Context: The complaint alleges that the accused products are devices that communicate with a server to receive and print data (Compl. ¶17, ¶23). The infringement allegations suggest these products implement a network protocol for authenticating with a server and downloading print jobs. The complaint does not provide sufficient detail for analysis of the products' specific functionality or market context.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim chart Exhibits 8 through 14, which allegedly compare the asserted claims to the "Exemplary Defendant Products" (Compl. ¶19, ¶28, ¶34, ¶40, ¶49, ¶55, ¶61). As these exhibits are not provided, the following analysis is based on the narrative infringement theory presented in the complaint.

No probative visual evidence provided in complaint.

• Infringement Theory for the ’105, ’321, ’205, ’500, ’750, and ’836 Patents: The core infringement theory is that Defendant makes, uses, sells, and imports products that practice the patented methods for communicating between a remote printer and a server (Compl. ¶17, ¶23, ¶32, ¶38, ¶53, ¶59). The complaint alleges that these products establish a network connection, authenticate with a server, and download print data using a protocol that meets the specific steps recited in the asserted claims (Compl. ¶19).
• Infringement Theory for the ’685 Patent: The infringement theory for this patent is distinct, focusing on the internal operation of the accused products to achieve high-speed printing (Compl. ¶44). The allegations suggest the products use methods such as intelligent print queue management or high-speed memory to minimize print engine downtime, thereby practicing the methods claimed in the ’685 patent (Compl. ¶49).
• Identified Points of Contention:
  • Scope Questions: A central question will be whether the specific protocols used by Defendant's products fall within the scope of the claims. For example, does the accused protocol "establish... communication connection end points ('sockets')" as that term is understood in the patent, or does it use a fundamentally different mechanism for network communication? (’321 Patent, col. 19:30-34).
  • Technical Questions: The analysis will likely focus on whether the accused products perform the specific sequence of steps claimed. For instance, what evidence does the complaint provide that the accused products "notify[] the server after each print data portion has been printed," as required by the claims, versus providing a single notification after an entire job is complete? (’105 Patent, Abstract).

V. Key Claim Terms for Construction

• The Term: "establishing an interprocess communication mechanism comprising a connection end point and a network address" (’321 Patent, Claim 1) / "establishing communication connection end points ('sockets')" (’105 Patent, Abstract).

• Context and Importance: This term is foundational to the claimed invention. The patents describe this step as creating a "socket" akin to a telephone connection for communication (’105 Patent, col. 5:14-24). Practitioners may focus on this term because the infringement analysis will depend on whether the accused products’ method for initiating a network session is structurally and functionally equivalent to the "socket" mechanism described and claimed.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes "sockets" as the "most common mechanism" but not necessarily the only one, referring more generally to an "interprocess communication mechanism" (’105 Patent, col. 5:14-21). This may support an argument that the term covers any protocol that establishes a dedicated communication channel.
  • Evidence for a Narrower Interpretation: The patent provides a detailed description of a "typical socket API" with specific functions like "bind", "listen", "accept", and "connect" (’105 Patent, col. 5:25-38). This specific embodiment could be used to argue that the term is limited to protocols that operate in a similar, stateful manner.

• The Term: "notifying the server after print completion" (’321 Patent, Claim 1).

• Context and Importance: This step creates a feedback loop that the patent leverages for robust, resumable downloads and tracking print status. The dispute may turn on the timing and content of this notification. An accused product that sends a single notification at the end of a multi-part job might be argued not to infringe a claim requiring notification after each "print data portion" is completed (’105 Patent, Abstract).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The general purpose of the notification is to ensure reliable communication and manage print queues (’321 Patent, col. 3:40-44). An argument could be made that any server notification that achieves this purpose meets the limitation.
  • Evidence for a Narrower Interpretation: The flowcharts and detailed description repeatedly show the notification step occurring immediately after a single "print data portion" is printed and before the next portion is requested (e.g., ’105 Patent, Fig. 3, steps 150, 160). This could support a narrower construction requiring a specific, iterative notification sequence.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for U.S. Patent Nos. 7,383,321 and 8,773,685. The basis for inducement is Defendant’s alleged distribution of "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" the patents (Compl. ¶26, ¶47).
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. It does allege "Actual Knowledge of Infringement" for the ’321 and ’685 patents, but this knowledge is predicated on the service of the complaint and its attached claim charts (Compl. ¶25, ¶46). This may support a claim for enhanced damages for any post-filing infringement but does not allege pre-suit knowledge.

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

• A core issue will be one of technical mapping: Lacking specific details on the accused products' operation, the case will depend on evidence demonstrating whether Defendant's communication protocol performs the precise, ordered steps of the asserted protocol claims—specifically, the establishment of a "socket"-like connection, the prescribed authentication sequence, the portion-by-portion data request, and the iterative post-print server notification.
• A second key question involves the scope of distinct technologies: The case asserts patents covering both a communication protocol (the ’321 family) and an internal printing process for speed (the ’685 patent). A central issue for the court will be to separately analyze these distinct allegations and determine whether the accused products infringe one, both, or neither of these patented technologies.
• A final strategic question will be one of patent family overlap: With six highly similar patents from the same family asserted against the same accused functionality, the case may raise questions regarding claim differentiation and the cumulative scope of the patent portfolio. The defendant may argue that many of the claims are duplicative, which could impact claim construction and potential damages calculations.