Baker Laser Technology LLC v. Samsung Electronics America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Baker Laser Technology, LLC (Massachusetts)
  • Defendant: Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: KENT & RISLEY LLC
• Case Identification: 2:25-cv-00436, E.D. Tex., 04/25/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has a regular and established place of business in the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s Premiere line of ultra-short-throw laser projectors infringes a patent related to compact laser projection systems.
• Technical Context: The technology concerns methods for creating compact, portable video projectors that use lasers and a rotating optical element to scan an image onto a surface.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement via a letter dated April 16, 2025, which was delivered on April 21, 2025, four days before the complaint was filed. This notice may form the basis for allegations of willful infringement.

Case Timeline

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

U.S. Patent No. 9,185,373 - "Laser Projection System", issued November 10, 2015

The Invention Explained

• Problem Addressed: The patent’s background section identifies a need to overcome the drawbacks of conventional projectors, which it describes as being "heavy and bulky" ('373 Patent, col. 1:63-64). The stated goal was to develop "a lighter and more portable solution" that could be "easily carried in a pocket or a briefcase" ('373 Patent, col. 1:68; col. 2:1-2).
• The Patented Solution: The invention is a system that projects an image by sending pulses of light from semiconductor lasers through a "rotating disk" that contains a "multitude of lenses" ('373 Patent, Abstract; col. 2:21-23). The system synchronizes the firing of the laser pulses with the rotation of the disk, so that each lens on the spinning disk directs a light pulse to a specific location on the projection surface, thereby "painting" a complete image ('373 Patent, col. 2:30-35). Figure 5 illustrates a key embodiment, showing a motor (501) spinning a disk (502) populated with lenses (504) to direct the light.
• Technical Importance: The described approach sought to replace the complex and bulky lamp-and-prism assemblies of traditional LCD projectors with a more compact, solid-state laser and mechanical scanning system ('373 Patent, col. 1:53-62).

Key Claims at a Glance

• The complaint asserts independent claims 1 (an apparatus claim) and 8 (a method claim) (Compl. ¶13).
• Independent Claim 1: A light projecting device comprising:
  • an interface for connecting to a video generating device;
  • the interface receiving instructions that specify a video image;
  • the instructions being "reformatted by the light projecting device" into instructions for activating semiconductor lasers to form "pulses of light";
  • the pulses of light being sent through a "rotating disk";
  • such that the video image is projected onto a surface.
• Independent Claim 8: A method of delivering a beam of light across a surface, comprising:
  • generating a beam of light using two or more semiconductor lasers, with the beam consisting of a stream of "pulses of light";
  • transmitting the pulses of light through a "rotating disk";
  • "synchronizing" the rotating disk with the lasers so that an image is formed on the surface.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are at least the "Samsung Premiere LSP7T and the Premiere 7 SP-LPU7D" projectors (Compl. ¶13).

Functionality and Market Context

• The complaint characterizes these products as laser-based projection systems but provides no specific technical details about their internal operation (Compl. ¶13). The infringement allegations are detailed in a preliminary claim chart (Exhibit B) which is incorporated by reference but was not filed with the complaint (Compl. ¶13). The complaint alleges that Defendant makes, uses, sells, and imports these products, which suggests they are commercial consumer electronics devices (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint alleges that the accused Samsung projectors directly infringe at least claims 1 and 8 of the ’373 patent, but it relies entirely on an external claim chart (Exhibit B) to provide the substance of this allegation (Compl. ¶13). Because this exhibit was not provided with the filed complaint, the pleading itself contains no specific mapping of claim elements to the features of the accused projectors. The complaint asserts narratively that for a user to utilize the accused projectors, "the steps of claim 8 of the '373 patent had to be performed in the manner described in Exhibit B" (Compl. ¶14).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central dispute may concern the definition of a "rotating disk" containing "lenses" as recited in the claims ('373 Patent, cl. 1, 5, 8). The case may turn on whether the light-scanning mechanism in the accused projectors, which may use different technology such as a Digital Micromirror Device (DMD) or other scanning mirror systems, can be considered equivalent to the patent's described embodiment of a spinning physical disk with numerous lenses arranged in a circle.
• Technical Questions: Claim 1 requires that the "light projecting device" itself "reformats" instructions received from a video source ('373 Patent, cl. 1). A key question will be what processing the accused projectors perform on an incoming video signal (e.g., from an HDMI source) and whether this activity constitutes "reformatting" as contemplated by the patent, or if the projectors merely act as displays for a pre-formatted signal.

V. Key Claim Terms for Construction

• The Term: "rotating disk"
• Context and Importance: This term is the central structural element of the asserted claims. The infringement analysis will depend heavily on whether the architecture of the accused projectors includes a component that meets the definition of a "rotating disk." Practitioners may focus on this term because modern laser projectors often use non-disk-based scanning technologies.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests alternatives, stating the system could use "a series of fins or mirrors that bend the light as the rotating disk spins," and that these "fins or mirrors would act as lenses" ('373 Patent, col. 5:46-50). This language may support an argument that the term is not limited to a disk with traditional transmissive lenses but could encompass other rotating structures with reflective or refractive elements.
  • Evidence for a Narrower Interpretation: The primary embodiment described and depicted is highly specific: a "disk 502 that has 1200 different lenses 504... placed in a single rotation of a spiral) placed in a circle near the outer edge" ('373 Patent, col. 5:28-32, Fig. 5). A defendant may argue that this specific disclosure limits the term to a physical, spinning disk with a plurality of distinct lenses mounted upon it.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement.
  • Inducement: The complaint alleges inducement based on Defendant's continued marketing, advertising, and distribution of the accused projectors after receiving actual notice of the ’373 patent on April 21, 2025. These acts are alleged to have been done with "specific intent to cause infringement or with willful blindness" (Compl. ¶15-16).
  • Contributory Infringement: The complaint alleges that Defendant contributes to infringement by providing accused products with features that are "understood and intended to infringe," do not constitute a staple article of commerce, and "have no substantial non-infringing use" (Compl. ¶17).
• Willful Infringement: The allegation of willfulness is predicated on Defendant’s alleged continuation of infringing activities after receiving the notice letter on April 21, 2025, which allegedly gave Defendant "actual knowledge of the '373 patent" (Compl. ¶16).

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

The resolution of this case will likely depend on the answers to two central questions:

1. A core issue will be one of definitional scope: can the term "rotating disk," which the patent primarily describes as a physical disk carrying numerous lenses, be construed to cover the potentially different light-scanning technology (such as a DMD chip or scanning mirror) used in the accused modern laser projectors?
2. A key infringement question will be one of locus of function: does the accused projector itself perform the claimed step of "reformatting" video instructions into laser control signals, as required by claim 1, or does it primarily function as a display for an externally processed video stream, potentially placing that claimed function outside the accused device?