DCT
2:25-cv-00887
Baker Laser Technology LLC v. BenQ Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Baker Laser Technology, LLC (Massachusetts)
- Defendant: BenQ Corporation (Taiwan)
- Plaintiff’s Counsel: KENT & RISLEY LLC
- Case Identification: 2:25-cv-00887, E.D. Tex., 08/27/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because the Defendant is a foreign corporation.
- Core Dispute: Plaintiff alleges that Defendant’s laser projectors infringe a patent related to a compact laser projection system that uses a rotating disk of lenses to form an image.
- Technical Context: The technology at issue addresses the miniaturization of video projectors, aiming to replace bulky, conventional systems with portable devices that use synchronized lasers and rotating optics.
- Key Procedural History: The complaint notes that the asserted patent claims priority back to a 2006 application, potentially insulating it from prior art post-dating that filing. No prior litigation or administrative proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2006-08-19 | ’373 Patent earliest priority date |
| 2015-11-10 | ’373 Patent issues |
| 2025-08-27 | Complaint filed |
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, "Laser Projection System," issued November 10, 2015 (’373 Patent).
The Invention Explained
- Problem Addressed: The patent describes conventional video projectors as "heavy and bulky," noting a need for a "lighter and more portable solution" that can be easily carried in a pocket or briefcase (’373 Patent, col. 1:64-68).
- The Patented Solution: The invention proposes a system where an electronic image representation is transformed into synchronized pulses of light from semiconductor lasers (’373 Patent, col. 2:28-36). These light pulses are directed through a "rotating disk" containing a multitude of lenses, with each lens directing the pulses to a specific location on a screen to form a visible image (’373 Patent, Abstract; Fig. 5). The synchronization of the laser pulses with the disk's rotation is what allows the system to "paint" the image onto a surface (’373 Patent, col. 6:16-22).
- Technical Importance: This design provides a technical pathway for creating highly miniaturized projection devices, moving beyond the traditional lamp-and-panel architecture of larger projectors (’373 Patent, col. 2:1-4).
Key Claims at a Glance
- The complaint asserts independent claim 8 of the ’373 Patent (Compl. ¶12).
- The essential elements of independent claim 8 are:
- generating a beam of light using two or more semiconductor lasers,
- said beam of light consisting of a stream of pulses of light to display on the surface,
- transmitting said pulses of light through a rotating disk; and
- 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 does not explicitly reserve the right to assert other claims.
III. The Accused Instrumentality
Product Identification
- Defendant’s laser projectors, "including at least the BenQ LU710 laser projector" (Compl. ¶12).
Functionality and Market Context
- The complaint alleges that the accused projectors are used to project images and directly infringe by performing all steps of the claimed method (Compl. ¶13).
- The complaint does not provide specific technical details about the internal operation of the accused projectors, instead incorporating by reference a "preliminary claim chart attached hereto as Exhibit B" (Compl. ¶12). This exhibit was not included with the public filing.
- No probative visual evidence provided in complaint.
- The complaint does not provide sufficient detail for analysis of the accused product's commercial importance or market positioning.
IV. Analysis of Infringement Allegations
The complaint alleges infringement via a claim chart in Exhibit B, which was not provided with the complaint. The following chart summarizes the infringement theory based on the complaint's narrative allegations, which assert that the accused products perform all steps of claim 8 (Compl. ¶13).
’373 Patent Infringement Allegations
| Claim Element (from Independent Claim 8) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| generating a beam of light using two or more semiconductor lasers, | The accused products are identified as "laser projectors" that allegedly generate a beam of light as part of their operation. | ¶12 | col. 8:23-25 |
| said beam of light consisting of a stream of pulses of light to display on the surface, | The complaint alleges the accused products perform the steps of claim 8, which includes generating a stream of light pulses. | ¶13 | col. 8:26-27 |
| transmitting said pulses of light through a rotating disk; | The complaint alleges the accused products transmit light pulses through a rotating disk to form an image. | ¶13 | col. 8:28-29 |
| and 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 the accused products synchronize a rotating disk with lasers to form a projected image. | ¶13 | col. 8:30-32 |
- Identified Points of Contention:
- Structural Questions: The central factual dispute will likely be whether the accused BenQ projectors contain a "rotating disk" that transmits light pulses as claimed. The complaint does not provide any public-facing evidence, such as product teardowns or technical schematics, to support this structural allegation.
- Technical Questions: A key technical question is whether the accused products’ method of image formation relies on "synchronizing" laser pulses with a rotating component to scan an image onto a surface. The complaint's allegations raise the question of whether this specific claimed mechanism is present, or if the accused products use an alternative technology (e.g., a Digital Micromirror Device or LCD panel) for image formation.
V. Key Claim Terms for Construction
The Term: "rotating disk"
- Context and Importance: This term appears to be the central structural element of the invention, distinguishing it from other projection technologies. The outcome of the infringement analysis may depend heavily on whether the components inside the accused projectors can be characterized as a "rotating disk" that transmits light.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification mentions an alternative where the disk could have "a series of fins or mirrors that bend the light as the rotating disk spins," which could suggest the term is not limited to a disk with transmissive lenses (’373 Patent, col. 6:46-49).
- Evidence for a Narrower Interpretation: The primary embodiment describes a "disk 502 that has 1200 different lenses 504... placed in a circle near the outer edge," and Figure 5 visually depicts this specific structure, potentially limiting the term to a disk with embedded lenses (’373 Patent, col. 6:28-32; Fig. 5).
The Term: "synchronizing"
- Context and Importance: This term defines the critical functional relationship between the light source and the rotating component. Practitioners may focus on this term because the specific method of synchronization is key to how the claimed invention forms a coherent image.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is functional, requiring synchronization "such that the pulses of light are modified such that an image is formed on the surface," which may support a construction covering any timing mechanism that achieves this result (’373 Patent, col. 8:30-32).
- Evidence for a Narrower Interpretation: The specification describes a specific implementation where the system uses a "sensor 407 that synchronizes the location of the rotating lens disk 502," which receives input that allows the CPU to coordinate the firing of the lasers (’373 Patent, col. 6:16-22). This could support a narrower definition requiring a sensor-based feedback loop.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced infringement and contributory infringement (Compl. ¶¶14-16). The inducement allegation is based on Defendant’s alleged marketing, advertising, and distribution of the accused products, which allegedly encourages end-users to infringe (Compl. ¶14). The contributory infringement allegation asserts that Defendant provides products with features intended to infringe that are not staple articles of commerce and have no substantial non-infringing use (Compl. ¶16).
- Willful Infringement: The complaint bases its willfulness allegation on post-suit conduct, stating that Defendant has "continued to induce third-parties... to directly infringe" after receiving notice of the ’373 patent via service of the complaint (Compl. ¶14). It also alleges "willful blindness" to the infringement (Compl. ¶15).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural presence: does the accused BenQ LU710 projector contain a "rotating disk" with optical properties that transmits light pulses, as required by claim 8? The complaint makes this allegation but provides no specific public evidence, making this a central factual question for discovery.
- A key evidentiary question will be one of operational equivalence: how does the accused projector form an image at a technical level? The case will likely turn on whether BenQ's products employ the claimed method of "synchronizing" laser pulses with a rotating component, or if they utilize a different, non-infringing image modulation technology.