Baker Laser Technology LLC v. Panasonic Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Baker Laser Technology, LLC (Massachusetts)
  • Defendant: Panasonic Corporation (Japan)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:25-cv-00893, E.D. Tex., 08/27/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has placed its products into the stream of commerce with the expectation that they will be purchased and used by customers in the district.
• Core Dispute: Plaintiff alleges that Defendant’s laser projectors infringe a patent related to systems for projecting images using semiconductor lasers and a rotating disk of lenses.
• Technical Context: The technology concerns compact and portable laser projection systems, aiming to replace heavier, bulkier prior art projectors with miniaturized components.
• Key Procedural History: The asserted patent is a continuation of an application filed in 2007, which itself was a continuation-in-part of an application filed in 2006, suggesting a lengthy prosecution history that may be relevant to claim scope.

Case Timeline

Date	Event
2006-08-19	Earliest Priority Date for ’373 Patent
2015-11-10	’373 Patent Issued
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’s background section identifies a need for a more portable and lightweight image projection solution than the "heavy and bulky" LCD projectors prevalent at the time, which could weigh 4-8 pounds and occupy significant volume ( Compl. ¶6; ’373 Patent, col. 1:63-67).
• The Patented Solution: The invention proposes a compact system that uses semiconductor lasers to generate pulses of colored light. These pulses are transmitted through a "rotating disk" containing a multitude of lenses. The system synchronizes the firing of the laser pulses with the rotation of the disk, using each lens on the disk to direct the light pulses to a specific location on a screen, thereby building a complete image line-by-line (’373 Patent, Abstract; col. 2:28-36). The specification describes how each lens on the disk is slightly offset from the previous one, allowing it to project the next line of the image as the disk spins (’373 Patent, col. 6:34-40).
• Technical Importance: This approach sought to enable the miniaturization of projectors, envisioning a device "the size of a pen" that could be easily carried in a pocket or briefcase (’373 Patent, col. 2:38-43).

Key Claims at a Glance

• The complaint asserts independent claim 8 (Compl. ¶12).
• The essential elements of claim 8, a method claim, are:
  • Generating a beam of light using two or more semiconductor lasers.
  • The beam of light consisting of a stream of pulses of light to display on a surface.
  • Transmitting the pulses of light through a rotating disk.
  • Synchronizing the rotating disk with the lasers so the pulses are modified to form an image on the surface.
• The complaint does not explicitly reserve the right to assert other claims.

III. The Accused Instrumentality

Product Identification

• The complaint identifies Defendant’s laser projectors, including "at least the PT-VMZ51 laser projector" (Compl. ¶12).

Functionality and Market Context

• The complaint describes the accused instrumentalities as "laser projectors" but does not provide specific details on their internal operation or optical architecture (Compl. ¶12). The complaint alleges Defendant has made, used, sold, and imported these products (Compl. ¶13). The complaint does not provide sufficient detail for analysis of the product's specific market positioning.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement details are provided in a preliminary claim chart attached as Exhibit B; however, this exhibit was not included with the filed complaint (Compl. ¶12). The narrative allegations state that Defendant's laser projectors, such as the PT-VMZ51, perform all steps of claim 8 of the ’373 Patent (Compl. ¶13). This includes allegations that to the extent a user performs any step, the Defendant has conditioned the user's use on the performance of that step (Compl. ¶13). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Technical Questions: Given the lack of a claim chart or detailed technical allegations, a primary question will be evidentiary. What evidence will the Plaintiff provide to demonstrate that the accused Panasonic projectors utilize a "rotating disk" to transmit and modify light pulses in the manner required by the claim? Does the PT-VMZ51 projector contain an internal component that meets the structural and functional requirements of the claimed "rotating disk"?
  • Scope Questions: The analysis may turn on whether the optical system in the accused projectors, which may use different components such as digital micromirror devices (DMDs) or liquid crystal on silicon (LCoS) panels, can be interpreted as reading on the claim language "transmitting said pulses of light through a rotating disk."

V. Key Claim Terms for Construction

• The Term: "rotating disk"

• Context and Importance: This term is the central mechanical component of the claimed invention. Its definition will be critical, as the infringement dispute may hinge on whether the component used in Panasonic’s projectors qualifies as a "rotating disk."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim itself does not specify the material of the disk or the exact arrangement of components on it, which may support an argument that the term covers any rotating, disk-shaped optical element that transmits light pulses.
  • Evidence for a Narrower Interpretation: The specification and figures consistently describe a specific structure: a disk containing "a multitude of lenses" arranged in a circle near the outer edge, where each lens is "offset slightly from its predecessor" to create successive lines of an image (’373 Patent, col. 2:31-32; col. 6:28-40; Fig. 5). This detailed description of a preferred embodiment may be used to argue for a narrower construction limited to this lens-based architecture.

• The Term: "pulses of light are modified"

• Context and Importance: This phrase describes the function performed by the "rotating disk." The nature of this "modification" is key to distinguishing the invention from other light projection methods.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party might argue that "modified" simply means the light's direction is changed in any way by the rotating disk, a common function of optical components.
  • Evidence for a Narrower Interpretation: The specification explains the modification with high specificity: the rotating lenses on the disk "bend the light to the precise location on the screen for that particular pixel," sweeping across a line and then moving to the next line as the disk rotates (’373 Patent, col. 5:33-36; col. 7:13-43). This suggests "modified" requires a specific, systematic bending of light pulses to "form a visible representation of the image on the surface" (’373 Patent, col. 2:32-35).

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced infringement and contributory infringement. Inducement is alleged based on Defendant's marketing, advertising, and distributing the accused projectors, thereby encouraging infringement by end-users (Compl. ¶14-15). Contributory infringement is alleged on the basis that Defendant provides products with features "understood and intended to infringe" which "do not constitute a staple article, and which have no substantial non-infringing use" (Compl. ¶16).
• Willful Infringement: Willfulness is alleged based on Defendant's continued infringement after having "actual knowledge of the ’373 patent" upon service of the complaint (Compl. ¶14-15). This frames the allegation as one of post-suit willfulness.

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

• A core issue will be one of definitional scope: can the term "rotating disk," which the patent specification describes as a disk populated with numerous discrete lenses, be construed to cover the potentially different optical scanning or modulation technology used in a modern commercial laser projector like the accused Panasonic PT-VMZ51?
• A second key issue will be one of evidentiary proof: in the absence of detailed technical allegations in the complaint, the case will depend on whether discovery reveals that the accused projectors in fact perform the claimed method, specifically the step of "synchronizing" laser pulses with a "rotating disk" to have those pulses "modified" in a way that forms an image on a surface.