Baker Laser Technology LLC v. Sony Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Baker Laser Technology, LLC (Massachusetts)
  • Defendant: Sony Corporation (Japan)
  • Plaintiff’s Counsel: KENT & RISLEY LLC
• Case Identification: 2:25-cv-00895, E.D. Tex., 08/27/2025
• Venue Allegations: Venue is asserted as proper on the basis that the defendant is a foreign corporation.
• 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 dispute concerns the field of digital projection systems, specifically those using laser light sources and mechanical scanning methods to create images.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement via a letter dated January 13, 2022, nearly three years and eight months before filing the suit. The patent-in-suit is part of a family with priority dating back to 2006.

Case Timeline

Date	Event
2006-08-19	’373 Patent Earliest Priority Date
2015-11-10	’373 Patent Issue Date
2022-01-13	Plaintiff allegedly sent notice of infringement 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"

• 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 describes prior art projectors, such as LCD-based systems, as being disadvantageously "heavy and bulky" and notes that a "lighter and more portable solution is needed" (’373 Patent, col. 1:62-66). The goal was to create a projection device small and light enough to be easily carried in a pocket or briefcase (’373 Patent, col. 2:1-4).
• The Patented Solution: The invention proposes a system where beams from multiple semiconductor lasers (e.g., red, green, and blue) are combined into a single pulsed beam of light (’373 Patent, Abstract). This combined beam is then directed through a "rotating disk" containing a "multitude of lenses," which directs each light pulse to a specific location on a screen to form a visible image (’373 Patent, Abstract; col. 2:21-26). The system synchronizes the firing of the laser pulses with the rotation of the disk to "paint" the image line-by-line (’373 Patent, col. 2:31-35; Fig. 5).
• Technical Importance: The described approach seeks to miniaturize projector technology significantly, envisioning a device potentially "the size of a pen" (’373 Patent, col. 2:37-38).

Key Claims at a Glance

• The complaint asserts at least independent claim 8 of the ’373 Patent (Compl. ¶12).
• The essential elements of independent claim 8 are:
  • 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.

III. The Accused Instrumentality

Product Identification

• Defendant’s laser projectors, including at least the Sony VPL-GTZ380/P laser projector (Compl. ¶12).

Functionality and Market Context

• The complaint does not describe the specific technical operation of the accused Sony VPL-GTZ380/P projector. It alleges generally that the product infringes the ’373 Patent and that its functionality requires performance of the steps of claim 8 (Compl. ¶13). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint’s substantive infringement allegations are contained within a "preliminary claim chart attached hereto as Exhibit B," which is incorporated by reference but was not provided with the complaint (Compl. ¶12). Without this exhibit, the complaint itself offers only conclusory allegations that the accused projectors perform the steps of the asserted claims (Compl. ¶13).

Identified Points of Contention

• Technical Questions: A central factual question will be whether the accused Sony projectors employ a "rotating disk" mechanism to direct laser pulses, as required by claim 8. The complaint provides no evidence on this point, making it a primary area for discovery and potential dispute. Further, questions may arise as to how the accused products perform the claimed step of "synchronizing" the disk and lasers to "modify" the light pulses.
• Scope Questions: The case may turn on whether the accused projector’s internal architecture, which is not described in the complaint, falls within the scope of the claim term "rotating disk." The interpretation of this term in light of the patent's specification will be critical.

V. Key Claim Terms for Construction

"rotating disk"

Context and Importance

This term describes the core mechanical scanning component of the claimed method. The infringement analysis will likely depend on whether the component used in the accused Sony projectors, if any, for scanning the laser beam constitutes a "rotating disk" as contemplated by the patent.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The claim language itself does not explicitly require the "rotating disk" to have any specific features, such as lenses. An argument could be made that any rotating optical component used for scanning could meet this limitation.
• Evidence for a Narrower Interpretation: The specification repeatedly and consistently describes the invention as using a "rotating disk of lenses" (’373 Patent, col. 1:22-23) or a disk that "contains a multitude of lenses" (’373 Patent, col. 2:22-23). Figure 5 depicts a disk (502) populated with lenses (504). This consistent description in the specification may be used to argue that the term "rotating disk" should be construed to require the presence of lenses.

"synchronizing said rotating disk with the lasers such that the pulses of light are modified"

Context and Importance

This functional limitation defines how the system creates an image. Practitioners may focus on this term because the nature of the "modification" will be a key point of dispute. The question is whether this requires a specific type of optical alteration or merely temporal coordination.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: A defendant could argue that any system that times laser pulses to the position of a rotating scanner "modifies" the pulses by placing them in the correct sequence, thus meeting the claim language.
• Evidence for a Narrower Interpretation: The patent's detailed description explains that as the disk rotates, successive lenses bend the light pulses to form distinct lines of the image on the screen (’373 Patent, col. 7:13-33). A plaintiff may argue that "modified" requires this specific act of optical redirection by the physical structures on the rotating disk, not just timing the laser pulses.

VI. Other Allegations

Indirect Infringement

• The complaint alleges both induced and contributory infringement (Compl. ¶¶14-16). Inducement is alleged based on Defendant’s marketing, advertising, and distributing the accused projectors with knowledge of the ’373 patent after receiving a notice letter (Compl. ¶¶14-15). Contributory infringement is alleged on the basis that the accused projectors contain features intended to infringe, are not staple articles of commerce, and have no substantial non-infringing use (Compl. ¶16).

Willful Infringement

• The complaint alleges willful infringement based on Defendant's continued infringing conduct after receiving actual notice of the ’373 patent via a letter dated January 13, 2022 (Compl. ¶¶14, 18).

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

The resolution of this case will likely depend on the answers to a few central questions for the court:

• A primary issue will be one of technical architecture: Does the accused Sony VPL-GTZ380/P projector, a commercial-grade product, utilize the specific "rotating disk" with lenses mechanism described in the ’373 patent, or does it employ a different, non-infringing laser scanning technology?
• A related issue will be one of claim scope: Can the term "rotating disk," as used in claim 8, be construed broadly enough to cover the scanning mechanism in the accused product, even if it differs from the lens-based embodiments detailed in the patent’s specification?
• A key evidentiary question will be whether the complaint’s sparse allegations, which rely entirely on an unattached exhibit for technical substance, are sufficient to plausibly state a claim for patent infringement.