Baker Laser Technology LLC v. Delta Electronics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Baker Laser Technology, LLC (Massachusetts)
  • Defendant: Delta Electronics, Inc. (Taiwan)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:25-cv-00890, E.D. Tex., 08/27/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and does business in the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s laser projectors infringe a patent related to a laser projection system that uses a rotating disk of lenses to form an image.
• Technical Context: The patent addresses technology for compact, portable laser-based video projectors, a market segment that seeks to overcome the size and weight limitations of traditional bulb-based projectors.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement via a letter dated March 10, 2025, a fact which may form the basis for its willfulness allegations.

Case Timeline

Date	Event
2006-08-19	’373 Patent Priority Date
2015-11-10	’373 Patent Issue Date
2025-03-10	Plaintiff allegedly provides Defendant with notice of infringement
2025-08-27	Complaint Filing Date

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

• Patent Identification: 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 the problem that conventional projectors, such as LCD projectors, are "heavy and bulky," creating a need for a "lighter and more portable solution" that can be easily carried in a pocket or briefcase (’373 Patent, col. 1:63-68, col. 2:1-4).
• The Patented Solution: The invention proposes a compact projection system that uses semiconductor lasers (e.g., red, green, and blue) to generate colored pulses of light (’373 Patent, col. 5:7-10). These light pulses are combined and then transmitted through a "rotating disk" containing a multitude of lenses (’373 Patent, Abstract). As the disk spins, each lens directs the light pulses to a specific location, effectively "painting" or scanning the image line-by-line onto a surface (’373 Patent, col. 6:31-40; Fig. 5). The system synchronizes the firing of the lasers with the rotation of the disk to ensure the image is formed correctly (’373 Patent, col. 6:16-21).
• Technical Importance: This scanning-based laser projection architecture enabled the development of projection devices small enough to fit into a pen-sized form factor, a significant reduction in size compared to prior art projectors (’373 Patent, col. 2:37-43).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claims 1 and 8 (Compl. ¶¶15-16).
• Independent Claim 1 (An Apparatus):
  • An interface for connecting to a video generating device
  • The interface receiving instructions specifying a video image
  • The instructions being reformatted into instructions for activating two or more semiconductor lasers to form pulses of light
  • The pulses of light being sent through a rotating disk
  • Projecting the video image in a visible format on a surface
• Independent Claim 8 (A Method):
  • Generating a beam of light using two or more semiconductor lasers
  • 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 the pulses of light are modified to form an image on a surface

III. The Accused Instrumentality

Product Identification

The complaint names "laser projectors, including at least the Vivitek DU9900Z laser projector" (Compl. ¶12).

Functionality and Market Context

The complaint identifies the accused instrumentality as a "laser projector" but does not provide specific details regarding its internal architecture or method of operation (Compl. ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of at least claims 1 and 8 of the ’373 Patent and incorporates by reference a "preliminary claim chart attached hereto as Exhibit B" (Compl. ¶12). This exhibit was not included with the complaint as filed. The narrative allegations state that Defendant’s laser projectors, including the Vivitek DU9900Z, infringe the ’373 Patent (Compl. ¶¶12-13). The complaint does not contain sufficient detail for a tabular analysis of the infringement allegations.

• Identified Points of Contention:
  • Technical Questions: A central evidentiary question will be whether the accused Vivitek DU9900Z projector, or any other accused product, actually employs a "rotating disk" with optical elements to direct light pulses as required by the asserted claims. The complaint does not provide any evidence regarding the internal mechanics of the accused products, leaving open the possibility that they operate using an alternative, non-infringing technology (e.g., digital light processing (DLP) chips or MEMS-based mirror systems).
  • Scope Questions: The dispute may turn on the definition of "rotating disk." The patent specification describes embodiments with lenses and also suggests alternative structures like "a series of fins or mirrors that bend the light" (’373 Patent, col. 6:46-49). A key legal question will be whether the scope of this term can be construed to read on the specific light modulation and deflection technology used in Defendant's projectors.

V. Key Claim Terms for Construction

• The Term: "rotating disk"

• Context and Importance: This term is the central structural element of the asserted claims and appears to be the primary point of novelty. The outcome of the infringement analysis will likely depend on whether the mechanism inside Defendant's projectors meets the court's construction of this term.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification mentions that in an alternative to lenses, "the rotating disk 502 could have a series of fins or mirrors that bend the light as the rotating disk spins, bending or reflecting the light across each row," and that these "fins or mirrors would act as lenses 504" (’373 Patent, col. 6:46-50). This language could support an argument that the term is not limited to a disk with transmissive lenses but covers other rotating structures that perform the same scanning function.
  • Evidence for a Narrower Interpretation: The primary embodiment described in detail and depicted in figures focuses on a disk containing "a multitude of lenses" (’373 Patent, col. 2:22-24, Fig. 5). The abstract similarly specifies a "rotating disk containing numerous lenses" (’373 Patent, Abstract). This focus could support a narrower construction limited to disks with lens elements.

• The Term: "instructions reformatted by the light projecting device"

• Context and Importance: This limitation in claim 1 requires a specific data processing step to occur within the projector itself. Practitioners may focus on this term because the location of this processing—whether inside the accused projector or in an external source device—could be dispositive of infringement for this claim.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term itself does not specify the degree or type of reformatting, which could support a construction that covers any data conversion necessary to drive the lasers, regardless of complexity.
  • Evidence for a Narrower Interpretation: The specification describes a CPU assembly (302) within the projector that incorporates "logic cells to incorporate the decoding of the USB protocol and converting the information received into signals to energize or deenergize each of the three lasers" (’373 Patent, col. 4:35-42). This passage links the "reformatting" to a specific hardware component within the device, potentially limiting the claim's scope to devices that perform this specific type of internal conversion.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant encourages infringement by "marketing, advertising, and distributing" its projectors for use in their "customary and intended manner" (Compl. ¶14). It also pleads contributory infringement, alleging the accused products contain features intended to infringe and have "no substantial non-infringing use" (Compl. ¶16).
• Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after receiving a notice letter from Plaintiff on March 10, 2025, which allegedly gave Defendant "actual knowledge of the '373 patent" (Compl. ¶¶14, 18).

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

1. A central issue will be one of technical implementation: what is the actual architecture of the accused Delta Electronics laser projectors? The case will depend heavily on discovery into whether these products in fact utilize a "rotating disk" mechanism as claimed, or if they employ an alternative projection technology that falls outside the patent's scope.

2. A related question will be one of definitional scope: how will the court construe the term "rotating disk"? Whether this term is limited to the patent's primary embodiment (a disk with lenses) or is broad enough to cover other rotating optical scanning systems will be a critical determinant of infringement.