DCT

2:25-cv-00846

Imod Systems LLC v. Hisense Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:

  • Case Identification: 2:25-cv-00846, E.D. Tex., 08/22/2025

  • Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign corporation.

  • Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to a flexible connector module for a digital micromirror device (DMD), a core component in digital light processing (DLP) projectors.

  • Technical Context: The technology concerns the internal architecture of digital projectors, specifically how the main processing board connects to the DMD chip that creates the image, aiming to improve manufacturability and enable more compact designs.

  • Key Procedural History: The complaint does not reference any prior litigation, licensing history, or inter partes review proceedings concerning the patent-in-suit.

Case Timeline

Date Event
2010-05-21 U.S. Patent No. 8,562,149 Priority Date
2011-05-13 U.S. Patent No. 8,562,149 Application Filing Date
2013-10-22 U.S. Patent No. 8,562,149 Issue Date
2025-08-22 Complaint Filing Date

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

U.S. Patent No. 8,562,149 - Flexibly connectable digital micromirror device module and projecting apparatus employing same

  • Patent Identification: U.S. Patent No. 8,562,149, “Flexibly connectable digital micromirror device module and projecting apparatus employing same,” issued October 22, 2013 (’149 Patent).

The Invention Explained

  • Problem Addressed: The patent's background describes prior art methods for connecting a projector's main board to its Digital Micromirror Device (DMD) board as suffering from several drawbacks. These methods, using rigid board-to-board or card-edge connectors, are said to be expensive, complicated to manufacture, and difficult to assemble, particularly because the downward connection manner makes it hard for an operator to visually confirm a secure connection. These rigid configurations are also described as hampering the trend toward miniaturization in projector design (’149 Patent, col. 1:45 - col. 2:50).
  • The Patented Solution: The invention proposes a module where the DMD unit is mounted directly onto a flexible connection device, such as a flexible flat cable (’149 Patent, col. 4:26-28). This cable has a connecting interface at its other end that can be inserted into the projector's main board. This design is intended to increase "assembling convenience and reliability," provide "a better assembling tolerance," and meet "a downsizing requirement" by replacing rigid, multi-part connectors with a single, pliable component (’149 Patent, col. 2:54-61; Fig. 3).
  • Technical Importance: This approach seeks to simplify the internal mechanical and electrical assembly of DLP projectors, potentially lowering manufacturing costs and enabling more compact and varied product designs (’149 Patent, col. 2:54-61).

Key Claims at a Glance

  • The complaint alleges infringement of "Exemplary '149 Patent Claims" but does not identify specific claims in the body of the complaint, instead incorporating them by reference from an unattached exhibit (Compl. ¶¶11, 16). The patent's independent claims are 1 (directed to a device module) and 11 (directed to a projecting apparatus).
  • Independent Claim 1 of the ’149 Patent includes the following essential elements:
    • A flexible connection device comprising a plurality of conducting wires and an external insulation layer.
    • A digital micromirror device unit disposed on the external insulation layer of the flexible connection device and electrically connected with the conducting wires.
    • A supporting plate for supporting the digital micromirror device unit and fixing an edge part of the flexible connection device.
    • A connecting interface at a lateral end of the flexible connection device, connected with the conducting wires.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers to "Exemplary Defendant Products" that are allegedly identified in charts incorporated by reference as Exhibit 2, but this exhibit was not filed with the complaint (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It alleges only that Defendant makes, uses, sells, and imports infringing products in the United States (Compl. ¶¶11-12).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s "Exemplary Defendant Products" infringe the ’149 Patent, stating that these products "practice the technology claimed" and "satisfy all elements of the Exemplary '149 Patent Claims" (Compl. ¶16). All specific infringement allegations are incorporated by reference from an exhibit that is not attached to the public complaint, precluding a detailed element-by-element analysis at this stage (Compl. ¶17).

No probative visual evidence provided in complaint.

  • Identified Points of Contention: Based on the patent's claims and the general nature of the technology, the infringement analysis may raise several technical and legal questions once the accused products are identified:
    • Structural Questions: A primary question will be whether the accused products contain the specific structural combination recited in the claims. For example, does the accused product possess a distinct "supporting plate" that performs the dual functions of "supporting said digital micromirror device unit and fixing an edge part of said flexible connection device," as required by claim 1?
    • Scope Questions: The analysis may turn on the scope of key terms. For instance, what constitutes being "disposed on said external insulation layer"? Does this require a specific manufacturing method, such as the "surface mount technology" mentioned in the specification, or can it read on other forms of attachment (’149 Patent, col. 4:40-43)?

V. Key Claim Terms for Construction

  • The Term: "a supporting plate for supporting said digital micromirror device unit and fixing an edge part of said flexible connection device" (from Claim 1)

  • Context and Importance: This term appears to define a key structural element of the claimed module. The infringement analysis will depend on whether an element in the accused product meets both the structural identity ("plate") and the dual functional requirements ("supporting" the DMD unit and "fixing" the flexible connection device). Practitioners may focus on this term because a defendant could argue its product either lacks a "plate" altogether or uses a structure that performs only one of the two claimed functions.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent states that the supporting plate can be a "printed circuit board or a flat plate," suggesting some flexibility in its form (’149 Patent, col. 4:62-63).
    • Evidence for a Narrower Interpretation: The figures depict a distinct, separate component (element 34) that is attached to the flexible connection device (32) and upon which the DMD unit (31) rests (’149 Patent, Figs. 4A, 4B). Language describing the DMD unit and supporting plate as being on "opposite sides" of the flexible connection device could be used to argue for a multi-layered structure that requires a separate plate element (’149 Patent, col. 4:52-55).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to use the products in an infringing manner (Compl. ¶14). However, the complaint provides no specific examples of such materials or instructions.

  • Willful Infringement: The complaint does not use the term "willful." It alleges Defendant has had "actual knowledge" of its infringement at least since the service of the complaint and has continued its allegedly infringing activities thereafter (Compl. ¶¶13-14). This allegation could form the basis for a claim of post-filing willful infringement and enhanced damages.

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

  • A central issue will be one of structural correspondence: Do the yet-unidentified accused products contain the specific three-part assembly claimed in the patent—a DMD unit, a flexible cable, and a distinct "supporting plate" that performs the claimed dual functions of supporting the unit and fixing the cable?
  • A key evidentiary question will arise from the complaint's lack of specificity: As the complaint defers all technical details of infringement to a missing exhibit, a threshold issue will be whether the plaintiff can produce sufficient evidence to demonstrate that Defendant's products practice each limitation of the asserted claims.