DCT
2:24-cv-00924
Baker Laser Technology LLC v. Seiko Epson Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Baker Laser Technology, LLC (Massachusetts)
- Defendant: Seiko Epson Corporation (Japan)
- Plaintiff’s Counsel: KENT & RISLEY LLC
- Case Identification: 2:24-cv-00924, E.D. Tex., 11/13/2024
- Venue Allegations: Plaintiff alleges venue is proper in the district because the defendant is a foreign corporation.
- Core Dispute: Plaintiff alleges that Defendant’s laser projectors infringe a patent related to a laser projection system that uses a synchronized, rotating disk to form an image.
- Technical Context: The technology at issue addresses methods for creating compact and portable laser-based projection systems as alternatives to larger, traditional projectors.
- Key Procedural History: The complaint notes that the asserted patent is part of a family of applications, claiming priority back to 2006 through a series of continuation and continuation-in-part applications. No prior litigation or post-grant proceedings are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2006-08-19 | '373 Patent Priority Date |
| 2015-11-10 | '373 Patent Issue Date |
| 2024-11-13 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,185,373 - Laser Projection System
- Patent Identification: U.S. Patent No. 9,185,373 ("the ’373 Patent"), "Laser Projection System," issued November 10, 2015.
The Invention Explained
- Problem Addressed: The patent identifies a need for a projection system that is more portable than prior art devices, which are described as "heavy and bulky" ('373 Patent, col. 1:65-66). It states that "a lighter and more portable solution is needed" ('373 Patent, col. 2:1-2).
- The Patented Solution: The invention is a system that uses two or more semiconductor lasers to generate colored pulses of light. These pulses are directed through a "rotating disk" containing a multitude of lenses ('373 Patent, Abstract; Fig. 5). The system synchronizes the firing of the laser pulses with the rotation of the disk, causing the lenses to direct each pulse to a specific location on a screen, thereby "painting" a complete image ('373 Patent, col. 2:28-36).
- Technical Importance: The described approach of using lasers and a compact rotating disk mechanism sought to enable the creation of small, lightweight projectors, potentially the size of a pen, that could be easily carried ('373 Patent, col. 2:37-43).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 8 ('373 Patent, Compl. ¶16-17). The primary allegation for direct infringement is against claim 8 (Compl. ¶13).
- Independent Claim 8 (Method):
- generating a beam of light using two or more semiconductor lasers,
- the beam of light consisting of a stream of pulses of light to display on a surface,
- transmitting the pulses of light through a rotating disk, and
- synchronizing the rotating disk with the lasers such that the pulses are modified to form an image on the surface.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant’s laser projectors, including at least the Epson EpiqVision Mini series, the Epson EpiqVision Ultra LS800, and the Epson Pro Cinema LS12000 (Compl. ¶13).
Functionality and Market Context
- The complaint identifies the accused instrumentalities as laser projectors but provides no specific technical details regarding their internal operation (Compl. ¶13). Instead, it alleges that the products operate in a manner that meets the limitations of the asserted claims as detailed in preliminary claim charts attached as exhibits, which were not available for this analysis (Compl. ¶13-14). The complaint does not contain specific allegations regarding the products' market share or commercial positioning. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges infringement of at least claim 8 of the '373 Patent, incorporating by reference preliminary claim charts that were not filed with the public complaint (Compl. ¶13). The following table summarizes the infringement theory based on the claim language and the complaint's narrative allegations.
'373 Patent Infringement Allegations
| Claim Element (from Independent Claim 8) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of delivering a beam of light across a surface comprising generating a beam of light using two or more semiconductor lasers, | The complaint alleges that the accused projectors generate a beam of light using at least two semiconductor lasers. | ¶13, ¶14 | col. 4:62-65 |
| said beam of light consisting of a stream of pulses of light to display on the surface, | The accused projectors allegedly produce a stream of light pulses to create a display on a surface. | ¶13, ¶14 | col. 2:30-32 |
| transmitting said pulses of light through a rotating disk; and | The accused projectors are alleged to transmit the pulses of light through a rotating disk. | ¶13, ¶14 | col. 2:32-33 |
| synchronizing said rotating disk with the lasers such that the pulses of light are modified such that an image is formed on the surface. | The complaint alleges that the accused projectors synchronize a rotating disk with lasers to form an image on a surface. | ¶13, ¶14 | col. 4:45-49 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the definition of a "rotating disk." The complaint does not specify the type of beam-steering mechanism used in the accused projectors. The question will be whether the mechanism in the accused products, which could be based on technologies like DLP or LCoS, falls within the scope of the term "rotating disk" as used in the patent.
- Technical Questions: A key evidentiary question will be whether the complaint provides sufficient factual basis to support the allegation that the accused projectors utilize a "rotating disk" that is "synchronized" with laser pulses as claimed. The complaint's reliance on unincorporated exhibits for technical detail raises the question of what evidence Plaintiff will present to prove this functionality.
V. Key Claim Terms for Construction
- The Term: "rotating disk"
- Context and Importance: This term appears to be the central mechanical element of the claimed invention. The outcome of the infringement analysis will likely depend heavily on how this term is construed, as it defines the specific mechanism for steering the laser light. Practitioners may focus on this term because modern laser projectors employ various beam-steering technologies, and the applicability of this patent will turn on whether the accused technology is captured by this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the term is not limited to a disk with physical lenses, stating that "the rotating disk 502 could have a series of fins or mirrors that bend the light as the rotating disk spins, bending or reflecting the light across each row. These fins or mirrors would act as lenses 504" ('373 Patent, col. 5:46-50). This language may support an argument that any rotating structure that directs light can be a "rotating disk."
- Evidence for a Narrower Interpretation: The patent’s abstract, summary, and primary embodiment consistently refer to a "rotating disk containing numerous lenses" or a "rotating disk of a multitude of lenses" ('373 Patent, Abstract; col. 2:32-33). Figure 5 depicts a "Disk" (502) with discrete "Lenses" (504). This could support a narrower construction where the "disk" must be a plate-like structure containing distinct optical lenses.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by marketing, advertising, and distributing the accused projectors with knowledge of the '373 patent, at least from the date of service of the complaint (Compl. ¶15-16). It is also alleged that Defendant contributes to infringement by providing products whose infringing features do not constitute a staple article and have no substantial non-infringing use (Compl. ¶17).
- Willful Infringement: The complaint alleges that since receiving notice of its infringement, Defendant has acted with "specific intent to cause infringement or with willful blindness," which provides a basis for alleging willfulness for post-suit conduct (Compl. ¶16).
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to center on fundamental questions of claim scope and evidentiary proof, stemming from a complaint that is light on technical specifics of the accused products. The key questions for the court will likely be:
A core issue will be one of definitional scope: How will the court construe the term "rotating disk"? The case may turn on whether this term is limited to the patent's specific embodiment of a disk with embedded lenses, or if it can be interpreted more broadly to cover other types of rotating, beam-steering mechanisms that may be used in modern projectors.
A key evidentiary question will be one of technical proof: What is the actual internal architecture of the accused Epson projectors? As the complaint provides no technical details, the case will hinge on whether discovery reveals a mechanism that practices the "synchronizing" and "transmitting said pulses of light through a rotating disk" limitations of the asserted claims.