DCT

2:25-cv-00240

Clear Imaging Research LLC v. Lenovo Group Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00240, E.D. Tex., 02/26/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Lenovo, a foreign corporation, has transacted business and committed acts of infringement within the Eastern District of Texas. As a foreign entity, it may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones, tablets, and laptops infringe seven patents related to digital image processing, including techniques for correcting image blur and stabilizing video.
  • Technical Context: The technology involves computational photography methods to improve image quality in digital cameras, a critical feature set in the competitive smartphone and consumer electronics market.
  • Key Procedural History: The complaint alleges an extensive history of pre-suit communications beginning on May 20, 2021, including notice letters identifying infringed patents and accused products, multiple video conferences, and the provision of claim charts to Lenovo. Plaintiff alleges that after a final conference on November 22, 2022, Lenovo ceased substantive communication. The complaint also notes that Plaintiff has licensed its patent portfolio to 13 other companies, including Samsung.

Case Timeline

Date Event
2004-03-25 Earliest Priority Date for Asserted Patents
2005-03-24 Initial Utility Application Filing
2014-01-01 U.S. Patent No. 8,630,484 Issues
2014-XX-XX Lenovo acquires Motorola Mobility
2015-04-21 U.S. Patent No. 9,013,587 Issues
2017-10-24 U.S. Patent No. 9,800,788 Issues
2018-01-02 U.S. Patent No. 9,860,450 Issues
2019-01-01 U.S. Patent No. 10,171,740 Issues
2021-05-20 Plaintiff sends initial notice letter to Defendant
2021-11-02 U.S. Patent No. 11,165,961 Issues
2022-09-27 U.S. Patent No. 11,457,149 Issues
2022-11-22 Final alleged video conference between parties
2023-08-24 Plaintiff sends updated notice letter including '961 and '149 Patents
2025-02-26 Complaint Filed

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

U.S. Patent No. 9,013,587 - "Method and apparatus to correct digital image blur by combining multiple images"

  • Issued: April 21, 2015

The Invention Explained

  • Problem Addressed: The patent’s background section identifies image blur caused by camera movement ("shaking"), particularly when using slow shutter speeds in low-light conditions, as a significant problem that degrades photograph quality ('587 Patent, col. 1:40-52). It notes that conventional digital sharpening techniques do not truly correct the blur and can result in data loss ('587 Patent, col. 1:53-59).
  • The Patented Solution: The invention discloses a method to prevent or correct blur by capturing a plurality of images at a fast shutter speed and then computationally combining them to produce a single, blur-free image equivalent to one taken at a slower shutter speed ('587 Patent, col. 2:50-58). The process can involve aligning the images based on a designated subject to keep that subject sharp while allowing the background to remain blurred, as illustrated in the patent's description of aligning images based on a moving car ('587 Patent, Abstract; col. 9:58-67).
  • Technical Importance: This computational photography approach allows for improved low-light performance and motion capture in consumer-grade digital cameras without requiring expensive and bulky optical image stabilization hardware ('587 Patent, col. 1:18-26).

Key Claims at a Glance

  • The complaint asserts independent claim 15 of the '587 Patent (Compl. ¶54).
  • Essential elements of claim 15 (a method) include:
    • capturing a plurality of photographic images in a recording medium;
    • combining the plurality of photographic images to generate a corrected image;
    • wherein the combining includes determining, for each image point in the main subject of the corrected image, a pixel value based on pixel values in the plurality of photographic images at the image point.

U.S. Patent No. 8,630,484 - "Method and apparatus to correct digital image blur due to motion of subject or imaging device"

  • Issued: January 1, 2014

The Invention Explained

  • Problem Addressed: The patent addresses image blur resulting from relative motion between an imaging device and the subject being photographed, which is described as a common problem that significantly degrades image quality ('484 Patent, col. 1:36-40).
  • The Patented Solution: The invention describes a system and method where a computing device processes a sequence of captured images by first detecting a "main subject" within them. It then computationally shifts the images so that the main subject is aligned across the frames before combining them to create a final "corrected image" ('484 Patent, Abstract; col. 11:6-14). This process is designed to render the main subject sharp and blur-free, potentially at the expense of blurring the background.
  • Technical Importance: This technology enables motion-tracking and subject-isolating features in digital photography, allowing a user to capture a clear image of a moving subject without motion blur, a valuable function for consumer and sports photography ('484 Patent, col. 11:6-14).

Key Claims at a Glance

  • The complaint asserts independent claim 15 of the '484 Patent (Compl. ¶65).
  • Essential elements of claim 15 (a computing device) include:
    • a memory configured to store a plurality of sequential images;
    • a processor configured to:
      • detect a main subject for each of the images;
      • shift each of the images vertically and horizontally such that the main subject is aligned at a same location in each of the shifted images; and
      • combine the shifted images to obtain a corrected image.

U.S. Patent No. 10,171,740 - "Method and apparatus to correct blur in all or part of a digital image by combining plurality of images"

  • Issued: January 1, 2019 (Compl. ¶74)

Technology Synopsis

This patent describes correcting image blur by combining a plurality of images. The technology allows for a "main subject" to be made blur-free, potentially leaving the rest of the image blurred, or for the entire image to be made blur-free, with the resulting corrected image stored in memory ('740 Patent, Abstract).

Asserted Claims

Independent claim 20 is asserted (Compl. ¶76).

Accused Features

The complaint alleges that the "Portrait Mode" digital camera functionality in Defendant's smartphones and tablets infringes this patent (Compl. ¶¶78-79).

U.S. Patent No. 11,165,961 - "Method and apparatus for capturing digital video"

  • Issued: November 2, 2021 (Compl. ¶85)

Technology Synopsis

This patent relates to capturing digital video where a main subject is computationally separated from the background. By capturing a sequence of images and combining them, the system generates modified images where the main subject is blur-free and the background is blurred. These modified images are then combined to create a final video with a depth-of-field effect ('961 Patent, Abstract).

Asserted Claims

Independent claim 8 is asserted (Compl. ¶87).

Accused Features

The complaint alleges that the "Portrait Mode" digital video functionality in Defendant's smartphones infringes this patent (Compl. ¶¶89-90).

U.S. Patent No. 11,457,149 - "Method and apparatus for capturing digital video"

  • Issued: September 27, 2022 (Compl. ¶96)

Technology Synopsis

Similar to the '961 Patent, this patent describes a method for capturing digital video that involves identifying a main subject and a background from a sequence of images. It then obtains a sequence of modified images by combining frames to render the main subject blur-free and the background blurred, ultimately producing a final video with this effect ('149 Patent, Abstract).

Asserted Claims

Independent claim 21 is asserted (Compl. ¶98).

Accused Features

The complaint alleges that the "Portrait Mode" digital camera functionality in Defendant's smartphones and tablets infringes this patent (Compl. ¶¶100-101).

III. The Accused Instrumentality

Product Identification

The complaint names a wide range of Lenovo and Motorola-branded smartphones, tablets, and laptops as the "Accused Products" (Compl. ¶¶31, 42, 53, 64, 75, 86, 97).

Functionality and Market Context

The infringement allegations target specific computational photography features within the Accused Products' camera software. These include "video stabilization," "HDR" (High Dynamic Range), "Night Vision," and "Portrait Mode" for both still photos and video (Compl. ¶¶34, 56, 67, 78, 89). The complaint alleges that Lenovo has sold millions of these devices in the United States and has derived substantial revenue from them (Compl. ¶¶15, 23). The complaint uses a screenshot of the Motorola website's navigation menu, which includes a direct link to "Lenovo," to support its allegation that the companies operate as an integrated entity in the market (Compl. p. 8).

IV. Analysis of Infringement Allegations

As the complaint references claim-chart exhibits that are not provided, the following summarizes the narrative infringement theories in prose.

'587 Patent Infringement Allegations

The complaint alleges that features such as "HDR" and "Night Vision" on products like the Moto Razr+ infringe claim 15 of the '587 Patent (Compl. ¶¶54, 56). The asserted theory is that these modes function by capturing multiple images and computationally combining them to generate a single improved photograph. This process of capturing and combining a "plurality of photographic images" to create a "corrected image" is alleged to meet the limitations of the claim (Compl. ¶54). The complaint cites Lenovo's user instructions for these features as evidence of inducement (Compl. ¶56).

Identified Points of Contention

  • Scope Questions: A potential point of contention is whether features designed for High Dynamic Range (exposure blending) or Night Vision (light gathering) perform the claimed method of "correct[ing] digital image blur." The court may need to determine if the primary purpose of the accused features aligns with the problem solved by the patent.
  • Technical Questions: The analysis may turn on the specific algorithms the Accused Products use to "combine" images. The question is whether the evidence will show these algorithms are technically equivalent to the blur-correction methods described in the '587 Patent’s specification, or if they are fundamentally different processes for different purposes.

'484 Patent Infringement Allegations

The complaint alleges that the same "HDR" and "Night Vision" functionalities infringe claim 15 of the '484 Patent (Compl. ¶¶65, 67). The general theory is that these features infringe by capturing and processing multiple frames to create a final image (Compl. ¶65). However, the complaint’s narrative does not specify how these accused features meet the more particular limitations of claim 15, such as "detect[ing] a main subject" and "shift[ing] each of the images" to align that subject before combining them.

Identified Points of Contention

  • Scope Questions: A central dispute may be whether a general image-stacking feature like HDR or Night Vision inherently includes the specific, claimed step of "detect[ing] a main subject." Defendant may argue that these modes operate on entire frames without identifying or tracking a particular subject.
  • Technical Questions: A key evidentiary question will be whether the complaint can show that the accused HDR and Night Vision modes actually perform subject detection and image shifting for the purpose of subject-specific alignment, as required by the claim, rather than a more general full-frame alignment or blending.

V. Key Claim Terms for Construction

  • The Term: "correct digital image blur" ('587 Patent, claim 15)

    • Context and Importance: This term is central to the dispute, as the accused "HDR" and "Night Vision" features are marketed for improving exposure and low-light performance, not explicitly for correcting motion blur. The definition of this term will determine whether these features fall within the scope of the claim.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the problem as blur from "camera movement (i.e. shaking)," a common occurrence in low-light conditions where Night Vision mode would be used ('587 Patent, col. 1:42-44). Plaintiff may argue that any computational combination of frames that mitigates the effects of motion inherent in such conditions "corrects ... blur."
      • Evidence for a Narrower Interpretation: The patent describes its solution as combining multiple images taken at a "fast shutter speed to avoid blur" ('587 Patent, col. 2:53-54). Defendant may argue this language limits the claim to methods with the specific purpose of counteracting motion blur, as distinct from the exposure-blending purpose of HDR.

  • The Term: "main subject" ('484 Patent, claim 15)

    • Context and Importance: Infringement of claim 15 requires the accused device to affirmatively "detect a main subject" and align images based on that subject. If the accused features operate without identifying such a subject, they may not infringe. Practitioners may focus on this term because it links the infringement analysis to a specific, required technical step.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification allows for the subject to be designated by a user or automatically ('484 Patent, col. 11:12-21). This could support an argument that an object selected by a device's autofocus system qualifies as the "main subject" for the claim's purpose.
      • Evidence for a Narrower Interpretation: The claim requires detecting the subject and then shifting the images based on that detection. The abstract further clarifies the goal is to make "the main subject ... blur free and the background ... blurred." Defendant may argue this requires a specific subject-tracking and differential-processing algorithm, not merely a general autofocus lock or a full-frame stacking process.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement for all asserted patents. The factual basis is Defendant's alleged advertising of the accused features and its publication of user manuals and online instructions that guide customers to use the features in a manner that allegedly practices the claimed methods (Compl. ¶¶34, 56, 67, 78, 89, 100).

Willful Infringement

Willfulness is alleged based on pre-suit knowledge. The complaint details communications beginning May 20, 2021, which allegedly included notice letters and claim charts for the '788, '450, '587, '484, and '740 patents (Compl. ¶24). Knowledge for the '961 and '149 patents is alleged from an updated notice letter dated August 24, 2023 (Compl. ¶27). The complaint alleges that Defendant continued its infringing activities despite this knowledge.

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

  • A central issue will be one of functional mismatch: do the accused "HDR" and "Night Vision" features, which are primarily designed for exposure management, perform the specific methods of motion blur correction and main-subject alignment as claimed in the '587 and '484 patents, or is there a fundamental difference in their technical operation and purpose?
  • The case will likely involve a key question of claim scope: can terms like "correct digital image blur" and "detect a main subject," which are described in the patents in the context of specific anti-blur and subject-tracking solutions, be construed broadly enough to cover general-purpose computational photography features that may achieve a similar result through different means?
  • Given the detailed allegations of extensive pre-suit notice dating back nearly four years, a significant focus will be the question of willfulness: the court will likely examine the substance of the parties' communications and whether Defendant's conduct following the alleged notice rises to the level of egregious behavior that could warrant enhanced damages.