DCT

2:26-cv-00035

Ipg Photonics Corp v. Trumpf Se + Co KG

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00035, E.D. Tex., 01/15/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas based on Defendants' purposeful and sustained contacts within the state, including long-standing customer relationships, sales and servicing of equipment to Texas businesses, and current job advertisements for Texas-based positions.
  • Core Dispute: Plaintiff alleges that Defendant’s industrial laser systems infringe a patent related to a high-power fiber laser safety control system.
  • Technical Context: The technology concerns safety mechanisms for high-power industrial fiber lasers, which are critical components in advanced manufacturing for applications such as cutting, welding, and marking materials.
  • Key Procedural History: The complaint alleges that Defendants gained actual knowledge of the patent-in-suit no later than November 18, 2022, when an International Search Report for one of Defendants' own patent applications cited the asserted patent’s publication as an anticipatory reference, a fact central to the willfulness allegations.

Case Timeline

Date Event
2014-03-04 ’415 Patent Priority Date
2016-05-31 ’415 Patent Issue Date
2022-11-18 Alleged Date of Defendant's Actual Knowledge of the ’415 Patent
2026-01-15 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,356,415 - *"High Power Fiber Laser Safety Control System"*

The Invention Explained

  • Problem Addressed: The patent’s background section identifies drawbacks in prior art safety systems for high-power lasers. Systems using mechanical contactors to cut power suffer from wear, slow restart times, and inefficiency. Alternative systems using optical shutters are expensive and can degrade the quality of the laser beam. (’415 Patent, col. 1:51 - col. 2:13).
  • The Patented Solution: The invention is an electronic safety control system integrated into the laser’s power source. It employs a redundant, two-channel safety mechanism to switch the power source from a high-voltage "normal operating regime" to a low-voltage "safe regime" where the laser cannot generate hazardous radiation. This is achieved by electronically shutting down the power source's DC/DC converter and actively discharging output capacitors, thereby eliminating the need for mechanical parts. (’415 Patent, Abstract; col. 2:16-32; Fig. 4).
  • Technical Importance: This electronic approach is designed to increase system reliability, improve electrical efficiency, and reduce the downtime associated with restarting a laser system after a safety event, which is a significant factor in high-volume manufacturing environments. (Compl. ¶18).

Key Claims at a Glance

  • The complaint asserts infringement of independent claim 4. (Compl. ¶¶19, 26).
  • The essential elements of Claim 4 include:
    • A power source module coupled to an AC source, which includes a galvanically isolated DC/DC converter.
    • A safety mechanism with first and second safety channels that operate independently.
    • Each channel has a shutdown circuit to switch the power source from a high-voltage normal regime to a low-voltage safe regime.
    • Each channel has a discharging circuit to discharge an output capacitor to the low voltage, with the discharging circuits operating subsequently to or simultaneously with the shutdown circuit.
    • A laser module (including a fiber laser and pump system) that receives the DC output, where the low voltage is below the pump system's emission threshold.
  • The complaint notes infringement of "one or more claims... including but not limited to claim 4," reserving the right to assert additional claims. (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused products as "at least the TruFiber and TruDiode lines of laser equipment, as well as any other laser products that include a voltage-reducing safety circuit" manufactured, sold, or imported by Defendants. (Compl. ¶26).

Functionality and Market Context

  • The complaint alleges the accused products are industrial laser systems used for applications such as marking, cutting, and welding. (Compl. ¶20). These systems are alleged to incorporate a laser safety control system that disables the laser output in response to a trigger condition, such as an interlock switch trip. (Compl. ¶27). The complaint alleges these systems contain a "Diode Power Supply (DPS) module" that functions as the claimed power source module and an "ASV module" that functions as the claimed two-channel safety mechanism. (Compl. ¶¶28-30). To support its venue allegations, the complaint provides a visual from Defendant's website highlighting a long-standing customer relationship in Texas, which suggests the market presence of the accused technology. (Compl. ¶10, p. 3).

IV. Analysis of Infringement Allegations

’415 Patent Infringement Allegations

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint Citation Patent Citation
a power source module coupled to an AC source and including a galvanically isolated DC/DC converter, and Defendant's laser systems include a Diode Power Supply (DPS) module configured to couple to an AC source and which includes a galvanically isolated DC/DC converter for each laser channel. ¶¶28, 29 col. 2:36-39
a safety mechanism which is configured with first and second safety channels operating independently from one another Defendant’s laser systems include an ASV module configured with two safety channels that, on information and belief, operate independently as required by industry safety standards. ¶30 col. 2:41-42; col. 2:66-67
and each provided with: a shutdown circuit for switching the power source module from a normal operating regime...to a safe regime On information and belief, the ASV module signals the DPS to reduce its output voltage from a high-voltage normal state to a low-voltage safe state upon a fault condition. ¶31 col. 8:7-12
a discharging circuit operative to discharge an output capacitor...to the low voltage in the safe regime; wherein the discharging circuits of respective safety channels each operate subsequently to or simultaneously with the shutdown circuit On information and belief, the DPS contains circuitry that, in response to a fault signal, discharges output capacitors to a level too low to operate the laser pump diodes, and does so subsequent to or simultaneously with the shutdown. ¶32 col. 8:13-20
a laser module including a high power fiber laser system and a laser pump system which receives the DC output, wherein the low voltage is lower than an emission threshold of the laser pump system. Defendant’s laser systems include a high-power fiber laser module and a laser pump system that receives DC output from the DPS, and the safe-state voltage is too low to operate the laser pump diodes. ¶33 col. 8:21-25

Identified Points of Contention

  • Scope Questions: The infringement allegations rely on mapping functional blocks from the accused systems (e.g., "ASV module," "DPS") to claim terms ("safety mechanism," "power source module"). A potential dispute may arise over whether these accused components are structurally and functionally equivalent to the structures disclosed and claimed in the patent.
  • Technical Questions: The complaint makes several allegations "on information and belief," particularly regarding the independent operation of the two safety channels and the existence and timing of the "discharging circuit." (Compl. ¶¶30, 32). A primary technical question will be what evidence confirms that the accused systems possess these specific, independent, and sequentially-operated circuits, as opposed to a more integrated or functionally different safety architecture.

V. Key Claim Terms for Construction

  • The Term: "safety mechanism"
    • Context and Importance: This term is central to the claimed invention, as it recites the core redundant safety architecture. Whether Defendant's alleged "ASV module" meets the definition of this term will be a critical issue for infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification functionally describes the mechanism as being "operative to discharge the output capacitor and switch the power source module between normal and safe regimes." (’415 Patent, col. 2:41-44). This functional language could support an interpretation that covers any set of components performing these roles, regardless of specific implementation.
      • Evidence for a Narrower Interpretation: The patent discloses a specific embodiment of the safety mechanism in Figure 6, which includes distinct shutdown and discharge command paths with specific components like optocouplers (40, 41), logic elements (48, 49), and monitoring units (44, 47). An argument could be made that the term should be construed as limited to structures possessing these or equivalent discrete features.
  • The Term: "operating independently from one another"
    • Context and Importance: This limitation defines the required level of redundancy between the two safety channels. The dispute will likely focus on how much, if any, hardware or logic can be shared between the channels while still satisfying the "independently" requirement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party could argue that "independently" merely requires that a single fault in one channel does not cause the other to fail, which may permit some shared resources (e.g., a common input from a safety controller) so long as the core logic paths are distinct.
      • Evidence for a Narrower Interpretation: The specification states that the channels "work independently of each other and are capable of bringing the laser to a safe state even in case of any single fault in the scheme." (’415 Patent, col. 6:32-34). This language, along with the distinct parallel circuits shown in Figure 6, may support a stricter interpretation requiring significant electrical and logical separation.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant induces infringement by "directing, encouraging, promoting, and instructing others" to use the accused products in the United States. (Compl. ¶36).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant having had actual knowledge of the ’415 Patent since at least November 18, 2022. This knowledge is alleged to stem from an International Search Report for Defendant’s own patent application, which cited the ’415 Patent’s publication as an anticipatory ("X") reference against all claims. (Compl. ¶¶22, 35). The complaint alleges that Defendant’s continued infringement despite this notice constitutes willful and exceptional conduct. (Compl. ¶¶24, 38).

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

  • A core issue will be one of evidentiary proof: The complaint’s technical infringement theory relies heavily on "information and belief" regarding the internal architecture and operation of the accused laser systems. A key question for the case will be whether discovery reveals that Defendant's "ASV" and "DPS" modules in fact contain two distinct and "independently operating" safety channels with the specific shutdown and discharge functionalities required by Claim 4.
  • A second central issue will be one of culpability and intent: The willfulness claim is predicated on knowledge derived from a patent examiner’s rejection of Defendant’s own patent application. This raises the question of whether a prior art citation in a patent prosecution, on its own, is sufficient to establish the deliberate or egregious conduct necessary for a finding of willful infringement and enhanced damages, or if Defendant can demonstrate a good-faith belief of non-infringement or invalidity that negates such intent.