2:26-cv-00087
Ar Design Innovations LLC v. Techo Bloc Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: AR Design Innovations LLC (Texas)
- Defendant: Techo-Bloc Inc. (Canada)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:26-cv-00087, E.D. Tex., 02/02/2026
- Venue Allegations: Plaintiff alleges that because Defendant is not a resident of the United States, venue is proper in any judicial district pursuant to 28 U.S.C. § 1391(c)(3).
- Core Dispute: Plaintiff alleges that Defendant’s "View in Space" augmented reality feature infringes a patent related to a three-dimensional design and visualization system.
- Technical Context: The technology at issue involves client-server systems that allow users to retrieve three-dimensional models of objects and visualize them within a real or virtual scene, a functionality now common in e-commerce and augmented reality applications.
- Key Procedural History: The asserted patent was subject to a Certificate of Correction on May 18, 2010, which corrected the name of the assignee on the patent's front page. The complaint does not mention any prior litigation or post-grant proceedings involving the patent.
Case Timeline
| Date | Event |
|---|---|
| 2003-10-10 | ’572 Patent Priority Date (Filing Date) |
| 2007-10-02 | ’572 Patent Issue Date |
| 2010-05-18 | ’572 Patent Certificate of Correction Issue Date |
| 2025-11-17 | Date of website visit cited in complaint |
| 2026-02-02 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- 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: The patent’s background section describes the limitations of prior art 3D modeling systems from the early 2000s. These systems either generated only 2D images, were unable to place 3D objects into the context of a background scene (like a room), or lacked the ability for real-time manipulation of 3D objects on a client computer. ’572 Patent, col. 2:17-24, col. 3:20-27
- The Patented Solution: The patent discloses a client-server method and system for generating a photorealistic 3D view of an object within a 3D scene. A user on a client computer can access a server to retrieve 3D objects, import them into a 3D scene (e.g., a virtual room), manipulate the objects for placement and orientation, and apply lighting effects ("luminosity characteristics"), with the client application then rendering a photorealistic composite image in real time. ’572 Patent, Abstract; col. 4:26-49
- Technical Importance: The invention aimed to provide a more dynamic and user-friendly visualization tool for interior design, enabling users to interactively design and render customized spaces on their own computers without the lag associated with server-side rendering. Compl. ¶¶20-22
- Key Claims at a Glance:
- The complaint asserts infringement of at least Claim 1. Compl. ¶42
- The essential elements of independent method Claim 1 include:
- 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, configured 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; and
- rendering a photorealistic 3D view of the composite image that includes the luminosity characteristics.
- The complaint seeks a judgment that "one or more claims" have been infringed. Compl. ¶55
III. The Accused Instrumentality
- Product Identification: The accused instrumentality is the Techo-Bloc “View in Space” augmented reality (“AR”) feature available on Defendant's website. Compl. ¶¶6, 31
- Functionality and Market Context: The "View in Space" feature allows a customer to use a device like a smartphone to visualize Defendant's products (e.g., outdoor firepits, pavers) in a real-world environment. Compl. ¶31 The process involves selecting a product on the website and scanning a QR code, which launches an AR experience that overlays a 3D model of the product onto the live view from the phone's camera. Compl. ¶6, Fig. 1 A screenshot in the complaint shows a 3D model of a firepit rendered on a user's floor as seen through a phone. Compl. Fig. 7 The complaint alleges this feature is used to advertise and sell Defendant's products by allowing customers to “[s]ee [Defendant’s] product in your space.” Compl. ¶¶30-31
IV. Analysis of Infringement Allegations
The complaint alleges that the "View in Space" feature performs all steps of Claim 1 of the ’572 patent. Compl. ¶¶42-43 The complaint references an "Evidence of Use Chart" in its Exhibit B, which was not included with the public filing. The following summary is based on the narrative allegations.
’572 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| communicably accessing a server with a client; | A user's device (client) accesses Defendant's website (server) to use the "View in Space" feature. | ¶43 | col. 4:27-28 |
| operating with the client, a client application configured for scene editing and rendering, including a GUI; | The user operates the "View in Space" AR tool, which functions as the client application with a GUI on their device. | ¶43 | col. 4:32-36 |
| displaying a 3D scene with the GUI; | The live camera feed of the user's real-world environment (e.g., a backyard) is displayed as the 3D scene. | ¶43 | col. 4:36-37 |
| retrieving at least one 3D object from the server; | The 3D model of the selected Techo-Bloc product is retrieved from Defendant's server. | ¶43 | col. 4:38-39 |
| importing the 3D object into the 3D scene to generate a composite; | The 3D product model is imported and overlaid onto the live camera view, creating a composite AR image. | ¶43 | col. 4:39-41 |
| manipulating the 3D object within the composite for placement and orientation; | The user can move and rotate the 3D model within the AR view to position it as desired. | ¶43 | col. 4:41-43 |
| selectively reconfiguring the 3D image in real time; | As the user moves their phone or manipulates the model, the composite view is updated in real time. | ¶43 | col. 4:44-45 |
| applying luminosity characteristics to the 3D image; | The complaint alleges the AR tool applies lighting and shadow effects to the 3D model. | ¶43 | col. 4:45-46 |
| rendering, with the client application, a photorealistic 3D view of the composite image, including the luminosity characteristics. | The user's device renders and displays the final AR view, which allegedly includes the applied luminosity effects. | ¶43 | col. 4:46-49 |
- Identified Points of Contention:
- Scope Questions: The infringement theory raises the question of whether the term "3D scene" can be construed to cover a live camera feed. The patent's specification consistently describes the "3D scene" as a computer-generated model of a room, created using tools like drawing wizards and floor plans ’572 Patent, col. 11:17-21, Fig. 5, which differs from the accused product's use of a real-world camera view.
- Technical Questions: The complaint alleges the accused product performs the steps of "applying luminosity characteristics" and rendering a "photorealistic" view. Compl. ¶43 This raises the question of what evidence Plaintiff will offer to prove the AR tool performs active, dynamic lighting and shadowing calculations, as described in the patent specification ’572 Patent, col. 7:12-17, rather than simply displaying a pre-lit 3D model.
V. Key Claim Terms for Construction
The Term: "3D scene"
Context and Importance: This term is critical because the accused product's use of a live camera feed as the "scene" is a central point of divergence from the patent's described embodiments. The construction of this term may determine whether the accused functionality falls within the scope of the claims at all.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not restrict how the "3D scene" is created, simply requiring it to be "display[ed]." Compl. ¶43 ’572 Patent, col. 36:26-27 This could support an argument that any 3D environment, including one captured by a camera, meets the limitation.
- Evidence for a Narrower Interpretation: The patent's title ("Three-Dimensional Interior Design System"), abstract, and detailed description are focused on creating a virtual model of a room using drawing tools, templates, and wizards. ’572 Patent, Abstract; col. 6:55-67 Fig. 5 A party could argue these embodiments define the term as a computer-generated model of an environment, not a live video stream of a real one.
The Term: "applying luminosity characteristics"
Context and Importance: This term recites a specific technical function beyond simply placing an object in a scene. Practitioners may focus on this term because proving that a real-time AR application performs sophisticated lighting calculations, rather than using pre-rendered lighting on a model, can be an evidentiary challenge.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language is not highly specific, which might allow for an interpretation that includes any application of light or shadow, even if basic or pre-set.
- Evidence for a Narrower Interpretation: The specification describes "luminosity effects" as including "ray tracing, radiosity, shadow effects" and simulating natural light based on "a particular geographic location, orientation..., time of year, and time of day." ’572 Patent, col. 11:29-34 This detailed description could support a narrower construction requiring a computationally intensive and environmentally aware lighting simulation.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on Defendant allegedly providing instructions and encouraging customers to use the "View in Space" feature in an infringing manner. Compl. ¶45 Contributory infringement is based on the allegation that the feature has special components designed for infringement with no substantial non-infringing use. Compl. ¶46
- Willful Infringement: The complaint alleges willfulness based on Defendant's knowledge of the patent since at least the filing of the lawsuit. Compl. ¶47 It further alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others." Compl. ¶48
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "3D scene," rooted in the patent’s context of building a virtual room model, be construed to cover the live, camera-captured real-world environment used by the accused augmented reality system?
- A key evidentiary question will be one of technical proof: does the accused "View in Space" feature perform the specific function of "applying luminosity characteristics" by dynamically calculating light and shadow, or does it simply overlay a pre-lit 3D model, and would the latter meet the claim limitation as construed by the court?