Baker Laser Technology LLC v. LG Electronics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Baker Laser Technology, LLC (Massachusetts)
  • Defendant: LG Electronics Inc. (Korea)
  • Plaintiff’s Counsel: KENT & RISLEY LLC
• Case Identification: 2:25-cv-00891, E.D. Tex., 08/27/2025
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s laser projectors infringe a patent related to a system for projecting images using semiconductor lasers and a rotating disk of lenses.
• Technical Context: The technology at issue relates to methods for creating compact and portable laser-based video projection systems, a domain significant for both consumer and professional electronics.
• Key Procedural History: The asserted patent is a continuation of an application filed in 2007, which itself is a continuation-in-part of an application filed in 2006. The complaint alleges that Plaintiff provided Defendant with notice of infringement via a letter four months prior to filing the suit.

Case Timeline

Date	Event
2006-08-19	Earliest Patent Priority Date (’373 Patent)
2015-11-10	U.S. Patent No. 9,185,373 Issued
2025-04-18	Plaintiff allegedly sent Defendant a notice of infringement letter
2025-08-27	Complaint Filed

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

• 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’s background section identifies the problem of prior art video projectors (such as LCD projectors) being heavy, bulky, and inconvenient to transport (Compl. ¶6; ’373 Patent, col. 1:53-66). It states a need for a "lighter and more portable solution" that could fit in a pocket or briefcase (’373 Patent, 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 pulses of light (’373 Patent, col. 5:8-10). These light pulses are transmitted through a "rotating disk" containing a multitude of lenses, which directs each pulse to a specific location on a screen to form an image (’373 Patent, Abstract; col. 2:28-36). The system synchronizes the firing of the lasers with the rotation of the disk to build the image pixel by pixel and line by line (’373 Patent, col. 6:16-21, Fig. 5).
• Technical Importance: This approach aimed to replace the bulky high-wattage bulbs and complex optics of conventional projectors with smaller, solid-state laser components and a novel mechanical scanning system, enabling significant miniaturization (’373 Patent, col. 1:53-66).

Key Claims at a Glance

• The complaint asserts independent claim 8 (Compl. ¶12).
• Essential elements of claim 8 include:
  • 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: The complaint identifies the LG AU/HU810P laser projector as an exemplary accused product (Compl. ¶12).
• Functionality and Market Context: The complaint alleges that the accused product is a laser projector that Defendant has made, used, sold, and imported (Compl. ¶13). The complaint does not provide specific technical details regarding the internal operation of the accused projector, instead incorporating by reference a preliminary claim chart (Exhibit B) that was not attached to the publicly filed document (Compl. ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a preliminary claim chart in Exhibit B to detail its infringement allegations but does not include the exhibit in the filing (Compl. ¶12). The complaint’s narrative allegations state that Defendant’s laser projectors, including the LG AU/HU810P, infringe at least claim 8 by incorporating the claimed inventions (Compl. ¶12-13). Without the claim chart, a detailed mapping of accused functionality to claim elements is not possible based on the complaint alone.

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the mechanism used in the LG projector constitutes a "rotating disk" as contemplated by the patent. The dispute could turn on whether this term is limited to the patent's described embodiment of a disk with numerous lenses arranged in a circle or spiral, or if it can read on other rotating optical components used in modern projectors, such as phosphor wheels.
  • Technical Questions: The complaint lacks factual allegations explaining how the accused LG projector generates and transmits light pulses or synchronizes its components. A key evidentiary question will be whether the accused product's internal architecture performs the specific function of "transmitting said pulses of light through a rotating disk" to form an image, as required by the claim.

V. Key Claim Terms for Construction

• The Term: "rotating disk"

• Context and Importance: This term is the central structural element of the asserted method claim. The infringement case will depend heavily on whether the optical scanning component within the LG projector falls within the scope of this term. Practitioners may focus on this term because many modern laser projectors use rotating phosphor wheels or other mechanisms that are functionally related but may be structurally distinct from the lens-based disk described in the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not specify what must be on the disk (e.g., lenses, mirrors, or other elements). An argument could be made that any rotating, disk-shaped component that modifies light pulses for image formation meets the limitation.
  • Evidence for a Narrower Interpretation: The specification repeatedly and consistently describes the disk as containing a "multitude of lenses" (’373 Patent, col. 2:31-32). Figure 5 depicts a disk (502) with lenses (504) around its periphery. An argument for a narrower construction may assert that the term "rotating disk" is implicitly limited to this disclosed lens-based structure.

• The Term: "synchronizing said rotating disk with the lasers such that the pulses of light are modified"

• Context and Importance: This limitation defines the functional relationship between the lasers and the rotating disk. The infringement analysis will require determining what type and degree of "synchronizing" and "modification" are required.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language is functional, suggesting that any method of timing the laser pulses relative to the disk's rotation to form an image could suffice.
  • Evidence for a Narrower Interpretation: The specification discloses a specific synchronization mechanism involving a sensor (407) that detects a mirror (503) on the disk to establish a timing reference for the CPU to fire the lasers (’373 Patent, col. 4:45-53; col. 6:16-21). A defendant may argue that the term should be limited to such a feedback-based synchronization system.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant encourages infringement through marketing, advertising, and distributing the accused 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 dated April 18, 2025 (Compl. ¶14, ¶18).

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

• A primary issue will be one of evidentiary sufficiency: Given the complaint’s lack of technical detail on the accused product's operation, a key question is what facts Plaintiff will produce to demonstrate that the LG projector contains a "rotating disk" that "modifies" laser pulses in the manner required by claim 8.
• The case may also turn on a question of claim scope and technological evolution: Can the term "rotating disk," described in the 2006-priority patent in the context of a disk filled with lenses, be construed to encompass potentially different rotating components, such as the phosphor wheels common in later-developed laser-phosphor projectors? The court's construction of this term will likely be dispositive.