DCT

2:25-cv-00894

Baker Laser Technology LLC v. Sharp Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00894, 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 systems for projecting images using semiconductor lasers and a rotating disk.
  • Technical Context: The technology concerns compact and portable laser projection systems designed to display images from devices such as computers or television receivers.
  • Key Procedural History: The patent-in-suit is a continuation of an application filed in 2007, which was a continuation-in-part of an application filed in 2006. The complaint alleges that Plaintiff provided Defendant with notice of infringement via a letter dated March 10, 2025, approximately five months prior to filing suit.

Case Timeline

Date Event
2006-08-19 ’373 Patent Earliest Priority Date
2015-11-10 ’373 Patent Issue Date
2025-03-10 Plaintiff allegedly sent notice 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 Nov. 10, 2015)

The Invention Explained

  • Problem Addressed: The patent’s background section describes conventional projectors, such as those using LCD technology, as being "heavy and bulky," making them difficult to transport for presentations. The patent notes a need for a "lighter and more portable solution." (’373 Patent, col. 1:62-67).
  • The Patented Solution: The invention proposes a compact projection system that uses semiconductor lasers to generate pulses of light. These light 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, causing each lens to direct the light to a specific location on a surface, thereby "painting" a visible image pixel by pixel and line by line. (’373 Patent, Abstract; col. 2:27-35; Fig. 5).
  • Technical Importance: This technical approach is intended to enable the creation of a projection device small enough to be easily carried in a pocket or briefcase, addressing the portability problem of prior art projectors. (’373 Patent, col. 2:1-4).

Key Claims at a Glance

  • The complaint asserts independent claim 8. (Compl. ¶12).
  • Essential elements of independent claim 8 include:
    • A method of delivering a beam of light across a surface comprising
    • 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 Sharp/NEC XP-X141Q-B-W Laser Projector. (Compl. ¶12).

Functionality and Market Context

  • The complaint identifies the accused instrumentality as a "laser projector" but provides no specific details about its internal components or method of operation. (Compl. ¶12). The infringement allegations are detailed in a "preliminary claim chart attached hereto as Exhibit B," which is incorporated by reference but was not provided with the complaint. (Compl. ¶12). Therefore, the complaint itself does not describe the specific functionality of the accused product alleged to meet the claim limitations.

IV. Analysis of Infringement Allegations

The complaint references a claim chart (Exhibit B) to detail its infringement allegations; however, this exhibit was not provided. (Compl. ¶12). The narrative allegations state that the Defendant has made, used, and sold products, including the Sharp/NEC XP-X141Q-B-W Laser Projector, that practice the method of claim 8. (Compl. ¶13). The complaint further alleges 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:
    • Structural Questions: A central question will be whether the accused Sharp laser projector contains a "rotating disk" used for transmitting light pulses, as required by the claim. Modern commercial laser projectors frequently use alternative scanning technologies, such as arrays of micromirrors (DLP) or liquid crystal on silicon (LCoS) systems, which may not correspond to the claimed structure.
    • Functional Questions: What evidence does the complaint provide that the accused product "synchroniz[es]" its lasers with a rotating component in the specific manner claimed? The claim requires this synchronization to "modify" the pulses of light to form an image on a surface. The analysis will depend on the precise mechanism used in the accused projector to direct laser light and build an image.

V. Key Claim Terms for Construction

  • The Term: "rotating disk"

    • Context and Importance: This term appears to be the central structural element of the claimed method. The infringement analysis will likely depend entirely on whether the scanning mechanism in the accused projector can be characterized as a "rotating disk."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests alternatives to a disk with physical lenses, stating that the "rotating disk 502 could have a series of fins or mirrors that bend the light as the rotating disk spins... These fins or mirrors would act as lenses 504." (’373 Patent, col. 5:46-50). This language may support a construction that is not strictly limited to a disk with transmissive lenses.
      • Evidence for a Narrower Interpretation: The primary embodiment described and illustrated focuses on a physical "disk 502 that has 1200 different lenses 504... placed in a circle near the outer edge." (’373 Patent, col. 5:28-32; Fig. 5). Language tying the invention to this specific structure could be used to argue for a narrower definition that excludes other types of rotating optical scanners.

  • The Term: "synchronizing said rotating disk with the lasers such that the pulses of light are modified such that an image is formed on the surface"

    • Context and Importance: This limitation defines the control relationship between the mechanical scanner and the light sources. The scope of "synchronizing" and how the pulses are "modified" will be critical to determining infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party could argue this language covers any system where the timing of laser emissions is controlled relative to the angular position of a rotating scanner to place pixels correctly on a screen.
      • Evidence for a Narrower Interpretation: The specification discloses a specific implementation where a "sensor 407" on the rotating disk provides positional feedback to the "CPU assembly 302," which in turn directs the lasers. (’373 Patent, col. 4:45-53, col. 6:16-22). A defendant may argue that the term should be limited to a system employing this type of explicit feedback mechanism.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement, asserting that since receiving notice, Defendant has continued to market, advertise, and distribute the accused projectors while encouraging their use in an infringing manner. (Compl. ¶14). It also pleads contributory infringement, alleging the accused products are not staple articles of commerce and have no substantial non-infringing use. (Compl. ¶16).
  • Willful Infringement: The willfulness allegation is based on alleged pre-suit knowledge of the ’373 Patent, stemming from a notice letter Plaintiff claims to have sent on March 10, 2025. (Compl. ¶¶14, 18).

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

  • A core issue will be one of structural correspondence: Does the accused Sharp projector employ the specific "rotating disk" mechanism for scanning laser light as described and claimed in the ’373 patent, or does it utilize a technologically distinct and non-infringing alternative, such as a micromirror-based system? The outcome may hinge on the construction of this central claim term.
  • A key evidentiary question will be one of operational proof: The complaint’s infringement theory is contained entirely within an unprovided claim chart exhibit. A central question for discovery will be whether Plaintiff can produce evidence demonstrating that the accused projector’s internal components and software actually perform the claimed steps of "generating a stream of pulses" and "synchronizing" them with a rotating element to form an image.