Ai Core Tech LLC v. Omron Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ai-Core Technologies, LLC (Texas)
  • Defendant: Omron Corp (Japan)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:25-cv-00607, E.D. Tex., 06/06/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation not resident in the United States and may therefore be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s Omron WebLink software infringes patents related to the customization of graphical user interface (GUI) backgrounds and the placement of graphical items relative to those backgrounds.
• Technical Context: The technology addresses methods for resizing GUI backgrounds to be smaller than the maximum display area and for positioning other GUI elements, such as windows, partially outside the boundary of that resized background.
• Key Procedural History: U.S. Patent No. 7,928,994 is a continuation-in-part of the application that led to U.S. Patent No. 7,274,382, indicating a shared technological lineage. The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history for the asserted patents.

Case Timeline

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

U.S. Patent No. 7,274,382 - "Customizable background sizes and controls for changing background size," issued September 25, 2007

The Invention Explained

• Problem Addressed: The patent describes that conventional GUI backgrounds are rigidly fixed to the maximum size of a display screen (e.g., an LCD monitor or a projected image) (Compl. ¶20; ’382 Patent, col. 1:28-33). This is particularly problematic for projectors, where physical obstacles in the projection path or on the receiving surface can obstruct portions of the image, limiting placement and utility (’382 Patent, col. 1:35-49).
• The Patented Solution: The invention provides a method and system that allow a user to change the size of a GUI background to be less than the maximum available display area. This allows the background to be tailored to fit an unobstructed portion of a wall or to a user's preference (’382 Patent, Abstract). A key aspect is that changing the background size also re-defines the "usable area" for the GUI, thereby setting new boundaries for pointers, windows, and other graphical elements (’382 Patent, col. 2:6-17).
• Technical Importance: This technology provided a way to increase the usability of GUIs in non-ideal display environments, particularly those involving projectors, by decoupling the background size from the maximum physical display size (’382 Patent, col. 4:11-28).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶23).
• The essential elements of claim 1 include:
  • Displaying an arrow that operates as a background control tool at a border portion of the background.
  • The tool allows a user to manually control the dimensions of the background to a size less than the maximum allowed by a projector.
  • The background defines a "usable area" for the GUI's visual and user input limits.
  • Receiving user input that moves the arrow.
  • In response, changing the background's dimensions in the direction the arrow is moved.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,928,994 - "Graphics items that extend outside a background perimeter," issued April 19, 2011

The Invention Explained

• Problem Addressed: Building on the idea of a resizable background, this patent addresses the limitation that graphical items (like application windows) are conventionally confined within the background's perimeter. This restricts the utility of the screen space left empty when the background is made smaller than the full display area (’994 Patent, col. 2:36-41).
• The Patented Solution: The invention discloses methods that allow a user to reposition or resize a graphical item so that a portion of it extends outside the background perimeter, into the otherwise unused screen area (’994 Patent, col. 2:42-48). To maintain spatial continuity, the invention introduces an "anchor" that is not permitted to be positioned outside the background perimeter, effectively tethering the graphical item to the background and preventing it from being moved completely away (’994 Patent, cl. 1).
• Technical Importance: This approach allows for more flexible and efficient use of the entire display area by enabling a user to customize not just the background, but the placement of functional windows relative to it, effectively creating a larger, multi-zoned workspace (’994 Patent, col. 2:56-62).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶32).
• The essential elements of claim 1 include:
  • Displaying a background and a graphics item within it.
  • Displaying a graphics tool that permits repositioning or resizing the graphics item such that a portion resides outside the background.
  • Receiving user input indicating such a change.
  • Displaying the graphics item with a portion outside the background.
  • The graphics item includes an "anchor" that is not permitted to be positioned outside the background's perimeter, with the anchor's location defined relative to the graphic item's geometric center.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• Omron WebLink software, along with "other substantially similar products and services offered in the past or the future and all of the prior models, iterations, releases, versions, generations, and prototypes" (collectively, the "Accused Products") (Compl. ¶15).

Functionality and Market Context

• The complaint alleges that the Accused Products are provided to U.S. customers via download from Defendant's website (Compl. ¶16). It asserts that the products contain "inventive components that improve upon the function and operation of backgrounds used with graphics-based user interfaces" (Compl. ¶20, ¶29). However, the complaint does not provide specific technical details regarding how the Omron WebLink software operates, its user interface, or its features related to background and window management. The complaint alleges Defendant derives substantial revenue from its products sold in the district but offers no specific market context for the Accused Products (Compl. ¶7, ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint makes general allegations of direct infringement for the ’382 Patent and direct, induced, and contributory infringement for the ’994 Patent but does not provide claim charts or detailed mapping of the Accused Products' features to the elements of any asserted claim (Compl. ¶22, ¶31-34). The complaint states that the written description of each patent "describes in technical detail each limitation of the claims" but does not perform this mapping for the accused functionality (Compl. ¶21, ¶30). As such, a detailed claim chart cannot be constructed based on the provided pleading. The analysis below summarizes the infringement theory at the level of detail provided.

’382 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Question: A foundational question for the court will be whether the Omron WebLink software includes any functionality for creating and resizing a GUI background to a size less than the maximum display area, particularly in a manner involving a projector.
  • Evidentiary Question: What evidence does Plaintiff possess that the accused software uses a control tool that meets the specific description of "an arrow...at a border portion of the background" which, when moved, "chang[es] the dimensions of the background"? The complaint does not present such evidence.

’994 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Question: Does the accused software allow application windows or other "graphics items" to be moved such that they are partially inside and partially outside of a defined background area?
  • Scope Question: The infringement analysis for the ’994 Patent will almost certainly focus on the term "anchor." A key question will be whether the Omron WebLink software contains any underlying mechanism that tethers a graphical item to a background, preventing its complete separation, and whether that mechanism meets the claim’s specific locational and definitional requirements.

V. Key Claim Terms for Construction

For the ’382 Patent:

• The Term: "background control tool"
• Context and Importance: Claim 1 specifically recites "an arrow that operates as a background control tool." The viability of the infringement claim may depend on whether the accused product's resizing mechanism, if one exists, can be fairly characterized as such a tool. Practitioners may focus on this term to determine if the claim is limited to the specific "arrow" embodiment or can cover other UI controls.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discloses multiple types of controls for changing background size, including a "background size control tool" with increase/decrease buttons (Fig. 2, 45), a text input window for percentages (Fig. 2, 51a), and a scroll tool (Fig. 2, 51b). This may support an argument that "background control tool" is a generic term and the "arrow" is merely an exemplary embodiment.
  • Evidence for a Narrower Interpretation: The language of claim 1 is specific: "displaying an arrow that operates as a background control tool." A defendant may argue that by explicitly claiming "an arrow," the patentee distinguished this claim from other possible embodiments and deliberately narrowed its scope to that specific UI element.

For the ’994 Patent:

• The Term: "anchor"
• Context and Importance: The "anchor" is the central novel feature of claim 1 of the ’994 Patent, providing the "spatial continuity" between a background and a partially external graphics item. Infringement will hinge on whether any feature in the accused software can be shown to perform this specific function as claimed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's overview section suggests the anchor's purpose is to provide "spatial continuity between the background and graphics item" (’994 Patent, col. 2:62-64). A plaintiff could argue that any software feature that prevents a graphical item from being completely separated from the background meets the functional requirement of an "anchor."
  • Evidence for a Narrower Interpretation: Claim 1 defines the anchor with structural and functional precision: it is "not permitted to be positioned outside a perimeter of the background" and includes a "point location...defined relative to a geometric center" (’994 Patent, cl. 1). The specification illustrates this with specific examples, such as an overlapping pixel (anchor 60c) or a point on a line connecting the centers of the two items (anchor 60b) (’994 Patent, Fig. 2A, col. 9:1-21). This language may support a narrow construction requiring a demonstrable, defined point of connection.

VI. Other Allegations

• Indirect Infringement: For the ’994 Patent only, the complaint alleges induced infringement based on Defendant "advising or directing customers," "distributing instructions," and providing "technical support" that allegedly guide users to infringe (Compl. ¶33). It further alleges contributory infringement, asserting the Accused Products have "special features" with no substantial non-infringing use (Compl. ¶34). The complaint does not provide specific factual examples for these allegations.
• Willful Infringement: For the ’994 Patent only, willfulness is alleged based on Defendant's knowledge of the patent "at least as of the date when it was notified of the filing of this action" (post-suit knowledge) (Compl. ¶35). The complaint also alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others" (Compl. ¶36).

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

1. The Evidentiary Question of Functionality: The complaint provides no specific facts about how the accused Omron WebLink software operates. A primary and immediate question for the litigation is whether discovery will uncover evidence that the accused software performs the core functions recited in the patents—namely, resizing a GUI background and allowing graphical items to be positioned partially outside of it. Without such evidence, the infringement claims may not be viable.

2. The Definitional Scope of "Anchor": For the ’994 Patent, the case will likely turn on claim construction. The central issue will be whether the term "anchor," which is defined with significant specificity in the claim language, can be construed to read on a feature of the accused product. The outcome will depend on whether the court adopts a broader functional definition or a narrower one tied to the specific structural embodiments described in the patent.

3. The Specificity of the "Control Tool": For the ’382 Patent, a key issue will be whether the claim term "an arrow that operates as a background control tool" is a hard-and-fast limitation. The case may depend on whether the accused product has this exact UI feature or if Plaintiff can successfully argue that another type of UI control is legally equivalent.