DCT
2:25-cv-01130
Ar Design Innovations LLC v. Kohler Co
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: AR Design Innovations LLC (Texas)
- Defendant: Kohler Co. (Wisconsin)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-01130, E.D. Tex., 11/17/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains established and regular places of business in the district, including at least one retail store and facility, and has committed alleged acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s augmented reality tools for visualizing home products infringe a patent related to three-dimensional interior design systems.
- Technical Context: The lawsuit concerns augmented reality (AR) and 3D visualization technology, which allows consumers to preview how products like furniture and fixtures will look in their own physical space before purchasing.
- Key Procedural History: The asserted patent was the subject of a Certificate of Correction issued on May 18, 2010, which corrected the assignee information on the patent's title page.
Case Timeline
| Date | Event |
|---|---|
| 2003-10-10 | U.S. Patent No. 7,277,572 Priority Date |
| 2007-10-02 | U.S. Patent No. 7,277,572 Issue Date |
| 2010-05-18 | Certificate of Correction Issued for U.S. Patent No. 7,277,572 |
| 2025-11-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,277,572 - “Three-Dimensional Interior Design System”
- Patent Identification: U.S. Patent No. 7,277,572, “Three-Dimensional Interior Design System,” issued October 2, 2007 (’572 Patent).
The Invention Explained
- Problem Addressed: At the time of the invention, computer-based interior design systems were limited. They either generated only 2D images, or if they used 3D models, they could not render them for manipulation within a 3D representation of a room on a client computer, limiting real-time, user-friendly visualization (’572 Patent, col. 2:19-22, 2:64-3:4; Compl. ¶¶ 24-25).
- The Patented Solution: The invention provides a client-server system where a user on a client computer can generate or import a 3D scene (e.g., a room), retrieve 3D objects (e.g., furniture) from a server, and manipulate those objects within the scene in real-time. The system is capable of rendering a photorealistic 3D view of the combined scene and object, including applying specific luminosity characteristics to simulate realistic lighting (’572 Patent, Abstract; col. 4:26-49; Compl. ¶¶ 26-27).
- Technical Importance: The technology aimed to provide an improved, easy-to-use visualization system that allowed users to generate, manipulate, and render photorealistic 3D interior design scenes on a local client computer in real-time (Compl. ¶ 26; ’572 Patent, col. 4:18-25).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶ 51).
- Claim 1 of the ’572 Patent recites a method with the following essential elements:
- Communicably accessing a server with a client.
- Operating a client application with a GUI for scene editing and rendering.
- Displaying a 3D scene with the GUI.
- Configuring the 3D scene for display in a plurality of views.
- Retrieving at least one 3D object from the server.
- Importing the 3D object into the 3D scene to generate a composite.
- Manipulating the 3D object within the composite for placement and orientation.
- Rendering a 3D image of the composite at the client.
- Selectively reconfiguring the 3D image in real time.
- Applying luminosity characteristics to the 3D image.
- Rendering a photorealistic 3D view of the composite image, including the luminosity characteristics.
- The complaint alleges infringement of "one or more claims" of the patent, focusing its narrative allegations on claim 1 (Compl. ¶ 48, 51-52).
III. The Accused Instrumentality
Product Identification
- The "Augmented Reality ('AR') tool" and the "View in Your Space" tool available on Defendant’s website (kohler.com) and within its "Kohler View" mobile application (collectively, the "Accused Products") (Compl. ¶ 37).
Functionality and Market Context
- The Accused Products are augmented reality tools that allow a user to employ a device's camera to visualize Kohler products, such as a bathroom vanity, within the user's actual physical space (Compl. ¶¶ 19, 37). Figure 2 of the complaint depicts the "View in Your Space" feature superimposing a 3D model of a vanity onto a live camera feed of a room (Compl. p. 10, Fig. 2). Figure 4 shows interface elements for manipulating the 3D model's position and orientation within the augmented reality view (Compl. p. 10, Fig. 4).
- Plaintiff alleges that the use of such patented technology has become "widespread" and "advantageous" for consumers in the process of purchasing home furnishings (Compl. ¶ 30).
IV. Analysis of Infringement Allegations
The complaint does not contain a claim chart exhibit, but it narrates the infringement theory for claim 1.
’572 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method...comprising: (a) communicably accessing a server with a client; | The Accused Products communicably access a server with a client device. | ¶52 | col. 4:30-31 |
| (b) operating with the client, a client application configured for scene editing and rendering, including a graphical user interface (GUI); | The Accused Products operate on the client device and include a GUI for scene editing and rendering. | ¶52 | col. 4:32-35 |
| (c) displaying a 3D scene with the GUI; | The Accused Products display a 3D scene (the user's space via camera) with the GUI. | ¶52 | col. 4:36-37 |
| (d) configuring the 3D scene for being selectively displayed in a plurality of views; | The Accused Products configure the 3D scene to be displayed in multiple views. | ¶52 | col. 4:37-38 |
| (e) retrieving at least one 3D object from the server; | The Accused Products retrieve 3D objects (e.g., Kohler products) from a server. | ¶52 | col. 4:39 |
| (f) importing the 3D object into the 3D scene to generate a composite; | The Accused Products import the 3D object into the scene to create a composite view. | ¶52 | col. 4:40-41 |
| (g) manipulating the 3D object within the composite for placement and orientation; | The Accused Products allow manipulation of the 3D object for placement and orientation. | ¶52 | col. 4:41-43 |
| (h) rendering a 3D image of the composite at the client; | The Accused Products render a 3D image of the composite on the client device. | ¶52 | col. 4:43-44 |
| (i) selectively reconfiguring the 3D image in real time; | The Accused Products selectively reconfigure the 3D image in real time as it is manipulated. | ¶52 | col. 4:44-45 |
| (j) applying luminosity characteristics to the 3D image; and | The Accused Products apply luminosity characteristics to the 3D image. | ¶52 | col. 4:45-47 |
| (k) rendering, with the client application, a photorealistic 3D view of the composite image, including the luminosity characteristics. | The Accused Products render a photorealistic 3D view of the composite, including luminosity characteristics. | ¶52 | col. 4:47-49 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the term "3D scene" as used in the patent, which is described and depicted as a user-generated virtual room built with drawing tools, can be construed to read on the live camera feed of a physical environment used by the accused AR products.
- Technical Questions: The complaint alleges that the Accused Products apply "luminosity characteristics" and render a "photorealistic" view. A point of contention may be whether the standard rendering of a 3D model in an AR overlay meets the specific technical requirements for "luminosity characteristics" and "photorealistic" rendering as described in the ’572 Patent, which details features like simulating light based on geographic location, season, and time of day (’572 Patent, col. 7:12-17).
V. Key Claim Terms for Construction
The Term: "3D scene"
- Context and Importance: The definition of this term is critical because the patent’s embodiments exclusively depict the creation of a virtual room from scratch using design tools (’572 Patent, Figs. 12-14), whereas the accused functionality involves overlaying an object onto a live view of a real-world environment. Practitioners may focus on whether "3D scene" is limited to a wholly computer-generated environment or is broad enough to encompass an augmented reality environment.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims and summary use broad language, referring to a "user-selected or user-generated interior design scene" without explicitly limiting it to a purely virtual construct (’572 Patent, Abstract; col. 4:26-29).
- Evidence for a Narrower Interpretation: The detailed description and figures consistently illustrate the "3D scene" as a room that the user builds by drawing walls, floors, and other architectural elements within the software application, suggesting the term contemplates a modeled virtual space (’572 Patent, col. 12:12-19; col. 13:4-12).
The Term: "applying luminosity characteristics"
- Context and Importance: This term is a key technical limitation requiring a specific action beyond simple rendering. The dispute may center on what level of lighting simulation is required. The accused AR tools inherently place a lit 3D model into a real-world lighting context, but the patent describes more complex simulations.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is general and does not specify the type of luminosity characteristics, potentially allowing it to cover basic lighting and shadow effects applied to a 3D model.
- Evidence for a Narrower Interpretation: The specification provides specific examples of "luminosity effects," such as simulating "natural light at a particular geographic location, orientation... time of year, and time of day" (’572 Patent, col. 13:31-35). This language may support an argument that the term requires sophisticated, configurable lighting simulation rather than default model illumination.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement on the basis that Defendant provides the Accused Products and distributes instructions that guide end-users to use them in an infringing manner (Compl. ¶ 54). It also alleges contributory infringement, asserting the Accused Products have special features for performing the claimed method that lack substantial non-infringing uses (Compl. ¶ 55).
- Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’572 Patent since at least the filing of the complaint (post-suit knowledge) and on an alleged "policy or practice of not reviewing the patents of others," which Plaintiff characterizes as willful blindness (Compl. ¶¶ 56-57).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "3D scene," which the patent illustrates as a virtually constructed environment, be construed to cover the live, real-world camera view used as the background in the accused augmented reality systems?
- A second key question will be one of technical functionality: does the rendering performed by the accused AR tools, which places a 3D model into a real-world view, meet the specific claim requirements of "applying luminosity characteristics" and creating a "photorealistic" view as those terms are described and enabled by the patent specification?