DCT
2:25-cv-00892
Baker Laser Technology LLC v. Optoma Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Baker Laser Technology, LLC (Massachusetts)
- Defendant: Optoma Corporation (Taiwan)
- Plaintiff’s Counsel: KENT & RISLEY LLC
- Case Identification: 2:25-cv-00892, 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 synchronized rotating disk.
- Technical Context: The technology relates to compact and portable laser projection systems, an area of the market where miniaturization and efficiency are significant commercial drivers.
- Key Procedural History: The patent-in-suit claims priority back to an application filed in 2006. Plaintiff alleges it provided Defendant with notice of infringement via a letter five months prior to filing the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2006-08-19 | ’373 Patent Priority Date |
| 2014-12-05 | ’373 Patent Application Filing Date |
| 2015-11-10 | ’373 Patent Issue Date |
| 2025-03-10 | Plaintiff sends notice of infringement letter to Defendant |
| 2025-08-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,185,373 - "Laser Projection System,"
- Issued: November 10, 2015
- Identifier: (’373 Patent)
The Invention Explained
- Problem Addressed: The patent’s background section identifies a need for a projection solution that is lighter and more portable than existing LCD projectors, which are described as "heavy and bulky" (ʼ373 Patent, col. 2:4-7).
- The Patented Solution: The invention proposes a system that generates an image using pulses of light from semiconductor lasers. These light pulses are directed through a "rotating disk" containing a multitude of lenses, which steers each pulse to a specific location on a screen. The rotation of the disk is synchronized with the firing of the lasers to "paint" a visible image line by line. (’373 Patent, Abstract; col. 2:20-36). Figure 5 illustrates the core rotating disk assembly, showing a motor (501) spinning a disk (502) that contains numerous lenses (504).
- Technical Importance: The described approach sought to replace the complex and bulky optics and high-powered bulbs of conventional projectors with a more compact, solid-state laser and mechanical scanning system. (’373 Patent, col. 2:4-7).
Key Claims at a Glance
- The complaint asserts independent method claim 8 (Compl. ¶12). It also references independent claim 1 in the context of indirect infringement (Compl. ¶¶15-16).
- Essential elements of independent 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.
III. The Accused Instrumentality
Product Identification
- The Optoma UHZ68LV and the Optoma ZW300UST laser projectors (the "Accused Instrumentalities") (Compl. ¶12).
Functionality and Market Context
- The complaint identifies the Accused Instrumentalities as "laser projectors" (Compl. ¶12). The complaint alleges that these products are made, used, sold, or imported by the Defendant and that they incorporate the inventions claimed in the ’373 patent (Compl. ¶13).
- The complaint does not provide further technical detail regarding the specific internal operation of the Accused Instrumentalities, instead incorporating by reference preliminary claim charts attached as Exhibits B and C, which were not publicly filed with the complaint (Compl. ¶12).
IV. Analysis of Infringement Allegations
The complaint alleges that the Defendant has directly infringed at least independent claim 8 of the ’373 Patent through its activities related to the Accused Instrumentalities (Compl. ¶¶12-13). The complaint states that a detailed breakdown of this infringement is provided in preliminary claim charts (Exhibits B and C), which are incorporated by reference but were not filed on the public docket (Compl. ¶12). The complaint asserts that for a user to utilize the accused projectors, the steps of claim 8 must be performed (Compl. ¶13). No probative visual evidence provided in complaint.
Identified Points of Contention
- Scope Questions: A potential point of contention may be whether the image-forming components within the accused projectors meet the "rotating disk" limitation of claim 8. The prosecution history and specification's description of a disk with "a multitude of lenses" or "a series of fins or mirrors" may be contrasted with the technology used in the accused products.
- Technical Questions: The complaint’s infringement theory rests on the allegation that the accused projectors perform the claimed method. A central technical question will be whether the accused projectors, in operation, perform the step of "synchronizing said rotating disk with the lasers" to form an image, as specified in the claim and described in the patent (ʼ373 Patent, col. 8:28-32).
V. Key Claim Terms for Construction
The Term: "rotating disk"
- Context and Importance: This term appears in the core functional limitations of claim 8 and defines the mechanism for directing light pulses. The definition of "rotating disk" will be critical to determining whether the accused projectors, which may use different light modulation or scanning technologies (e.g., digital micromirror devices or MEMS mirrors), fall within the scope of the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the "lenses" could be implemented differently, stating the disk "could have a series of fins or mirrors that bend the light" and that these "would act as lenses 504" (’373 Patent, col. 5:46-49). This may support an argument that the term should not be limited to a disk with traditional refractive lenses.
- Evidence for a Narrower Interpretation: The patent’s detailed description and figures consistently depict a physical, circular disk containing numerous lenses arranged in a circle or spiral. Figure 5, for example, shows a "disk 502" with "1200 different lenses 504" mounted on it. (’373 Patent, Fig. 5; col. 6:27-40). An argument for a narrower construction may rely on these specific embodiments as defining the invention's scope.
The Term: "synchronizing"
- Context and Importance: This active step links the laser operation to the mechanical rotation of the disk, and is essential to forming a coherent image rather than a blur of light. The dispute may turn on whether the control systems in the accused projectors perform synchronization in the manner required by the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is functional, requiring only that the synchronization results in an image being "formed on the surface" (’373 Patent, col. 8:31-32). This could support a reading that covers any method of timing the lasers relative to the scanning mechanism to produce an image.
- Evidence for a Narrower Interpretation: The specification describes a specific method for achieving synchronization, wherein a "sensor 407" monitors the rotating disk's position, "so that the firing of the lasers...can be synchronized to the location where the lens will direct the light" (’373 Patent, col. 4:45-53). A defendant may argue that this disclosed method limits the scope of the more general term "synchronizing."
VI. Other Allegations
Indirect Infringement
- The complaint alleges inducement to infringe by Defendant marketing, advertising, and distributing the accused projectors and "encouraging others to...use them in a way known to infringe" (Compl. ¶14). It also alleges contributory infringement, asserting that the accused projectors contain features "understood and intended to infringe," are not staple articles of commerce, and have no substantial non-infringing use (Compl. ¶16).
Willful Infringement
- The complaint alleges Defendant had actual knowledge of the ’373 Patent and its infringement at least as of March 10, 2025, due to a notice letter from Plaintiff. Willfulness is alleged based on Defendant’s continued infringing conduct after receiving this notice. (Compl. ¶¶14, 18).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute may depend on the court's interpretation of several key technical and legal issues. Based on the complaint, the case appears to present two central questions:
- A core issue will be one of technological scope: can the term "rotating disk," which the patent describes as a physical wheel with lenses or mirrors, be construed broadly enough to read on the specific image-forming and light-scanning mechanisms employed in the accused modern laser projectors?
- A second issue will be one of infringement evidence: as the complaint's technical infringement details are contained in non-public exhibits, a key question will be what evidence Plaintiff produces in discovery to demonstrate that the accused products actually perform each step of the claimed method, particularly the specific functional requirement of "synchronizing" the light source with a mechanical scanner to form an image.