Optimum Imaging Tech LLC v. Nikon Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Optimum Imaging Technologies LLC (Texas)
  • Defendant: Nikon Corporation (Japan)
  • Plaintiff’s Counsel: Carter Arnett PLLC; Cherian LLP
• Case Identification: 4:23-cv-00923, E.D. Tex., 10/18/2023
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign entity and conducts business in the Eastern District of Texas through sales, distribution channels, and commercial websites accessible to residents.
• Core Dispute: Plaintiff alleges that Defendant’s digital cameras, which feature in-camera image processing, infringe four patents related to the automated correction of optical aberrations and wireless image transfer.
• Technical Context: The technology concerns in-camera systems that use software and hardware to automatically correct image distortions, a key feature in modern digital photography that aims to improve image quality without requiring expensive lenses or complex post-production software.
• Key Procedural History: The complaint alleges that Defendant had actual notice of the asserted patent family as early as 2012, when the earliest issued patent was cited as prior art during the prosecution of one of Nikon’s own Chinese patent applications, a fact that may be central to Plaintiff's allegations of willful infringement.

Case Timeline

Date	Event
2006-07-11	Priority Date for all Asserted Patents (’805, ’339, ’685, ’266)
2009-11-03	U.S. Patent No. 7,612,805 Issued
2012-01-01	Alleged earliest date of Nikon's pre-suit knowledge of '805 Patent
2013-05-28	U.S. Patent No. 8,451,339 Issued
2020-12-22	U.S. Patent No. 10,873,685 Issued
2020-12-29	U.S. Patent No. 10,877,266 Issued
2023-10-18	Complaint Filed

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

U.S. Patent No. 7,612,805 - "Digital imaging system and methods for selective image filtration"

• Issued: November 3, 2009

The Invention Explained

• Problem Addressed: The patent addresses optical and digital problems in photography, such as lens aberrations (e.g., distortion, vignetting) and digital artifacts (e.g., aliasing), which traditionally required complex optical filters or time-consuming post-production software to correct (’685 Patent, col. 6:35-43).
• The Patented Solution: The invention is an automated in-camera system that corrects these aberrations. It comprises a combination of hardware components—including a microprocessor, a digital signal processor (DSP), and an application-specific integrated circuit (ASIC)—and software that accesses a database of lens-specific correction data to apply digital filtration to the captured image before it is stored (’805 Patent, Abstract; ’685 Patent, col. 8:10-16). Figure 1 illustrates the relationship between the optical components, the digital sensor, and the various processing circuits (’805 Patent, Fig. 1).
• Technical Importance: This approach sought to improve image quality and simplify the photographic process by automating corrections inside the camera, reducing the need for expensive, specialized lenses or extensive user skill in post-processing software (’685 Patent, col. 7:18-24).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 9 (Compl. ¶23).
• Claim 1 recites a digital imaging system for a fixed focal length lens comprising:
  • A digital camera mechanism, optical lens mechanism, digital sensor, microprocessor, digital signal processor, application specific integrated circuit, system software, a database management system, and a memory storage sub-system.
  • Aberrations from the lens are corrected by applying digital filtration using the ASIC and the DSP.
  • The microprocessor provides digital and optical data to the DSP.
  • The system software is organized to identify aberrations and access the database for specific corrections.
  • The system software forwards data from the sensor to the digital processor.
  • The DSP selects a procedure to optimize the image and corrects the aberrations.
  • A modified data file is stored in memory.
• Claim 9 recites a similar system adapted for a zoom lens.

U.S. Patent No. 8,451,339 - "Digital imaging system for correcting image aberrations"

• Issued: May 28, 2013

The Invention Explained

• Problem Addressed: As with the related '805 Patent, this patent addresses the technical challenge of correcting optical aberrations that degrade image quality in digital cameras (’685 Patent, col. 1:40-43).
• The Patented Solution: The patent describes a digital imaging system where a microprocessor uses system software to access a database, not only to identify an optical aberration but also to identify a specific "algorithm" to correct it. This algorithm is then used by a digital signal processor to apply digital filtration to the captured image file, which is then stored in memory (’339 Patent, Abstract; Claim 1). The system is designed to automate corrections for various lens types and aberrations by matching them to pre-programmed solutions stored in the database (’685 Patent, col. 10:5-10).
• Technical Importance: By specifying the use of distinct correction algorithms stored in a database, the invention provides a structured and extensible method for handling a wide variety of lens-specific imperfections automatically within the camera (’685 Patent, col. 7:45-51).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 14 (Compl. ¶53).
• Claim 1 recites a digital imaging system for a fixed focal length lens comprising:
  • A digital camera mechanism, optical lens mechanism, digital sensor, microprocessor, DSP, system software, database management system, and memory storage sub-system.
  • A microprocessor uses system software to identify an optical aberration by accessing the database.
  • The microprocessor uses the database to identify at least one algorithm to correct the aberration.
  • The captured image file is forwarded to the DSP.
  • The image file is corrected by the DSP applying digital filtration using the identified algorithm.
  • The modified digital file is stored in memory.
• Claim 14 recites a similar system adapted for a zoom lens.

Multi-Patent Capsule: U.S. Patent No. 10,873,685

• Patent Identification: U.S. Patent No. 10,873,685, titled "Digital imaging system for correcting video image aberrations", issued December 22, 2020.
• Technology Synopsis: This patent extends the core technology of in-camera aberration correction to the domain of digital video. It claims a system that uses in-camera software and an integrated circuit to identify and correct an optical aberration in at least one frame of a captured digital video, using correction data from a database (’685 Patent, Abstract; Compl. ¶84).
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶84).
• Accused Features: The complaint alleges that the video recording functions of Nikon cameras, such as the Nikon Z9, infringe by applying "auto distortion control" to video frames during capture (Compl. ¶85, ¶92-93).

Multi-Patent Capsule: U.S. Patent No. 10,877,266

• Patent Identification: U.S. Patent No. 10,877,266, titled "Digital camera with wireless image transfer", issued December 29, 2020.
• Technology Synopsis: This patent claims a method of processing images in a digital camera that combines in-camera image correction with wireless data transmission. The method involves using upgradable in-camera hardware and software to perform correction algorithms, storing the corrected image in memory, and then wirelessly transmitting the corrected image (’266 Patent, Abstract; Compl. ¶105).
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶105).
• Accused Features: Accused features include Nikon cameras with built-in Wi-Fi, such as the Z 9 and D6, which perform the patented in-camera corrections and can wirelessly transfer images using utilities like the Nikon SnapBridge app (Compl. ¶108, ¶117-118).

III. The Accused Instrumentality

Product Identification

• The accused products are a wide range of Nikon's digital cameras, including its DSLR and mirrorless camera lines (Compl. ¶18). Specific examples cited throughout the complaint include the Nikon D6, D610, and Z 9 cameras (Compl. ¶16, ¶17, ¶85).

Functionality and Market Context

• The complaint focuses on the cameras' internal image processing capabilities, marketed under names like "Auto Distortion Control," "Vignette control," and "chromatic aberration reduction" (Compl. ¶16-17). These features are powered by Nikon’s proprietary "Expeed" image-processing engines, which the complaint alleges contain the microprocessor, DSP, and ASIC components recited in the patents (Compl. ¶32-33). The correction process allegedly relies on "Distortion Control Data," which are firmware files available for download from Nikon's website and which function as the claimed database of lens-specific aberration corrections (Compl. ¶31, ¶64). Certain accused cameras also possess video recording and wireless image transfer capabilities, which are accused of infringing the '685 and '266 patents, respectively (Compl. ¶85, ¶117). A screenshot from the D6 reference manual shows "Auto distortion control" as a selectable option in the camera's shooting menu (Compl. ¶16, p. 6).

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,612,805 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A digital imaging system for image filtration comprising: a digital camera mechanism, an optical lens mechanism, a digital sensor, a microprocessor, a digital signal processor, an application specific integrated circuit, system software, a database management system and a memory storage sub-system	The accused Nikon digital cameras allegedly contain all of these hardware and software components (Compl. ¶26).	¶26	col. 5:26-40
wherein the optical lens mechanism is a fixed focal length	The accused cameras are compatible with and are used with fixed focal length NIKKOR lenses (Compl. ¶28).	¶28	col. 9:56-61
wherein the aberrations from the optical lens mechanism are corrected by applying digital filtration by using the application specific integrated circuit and the digital signal processor	Nikon's "Expeed" image-processing engine, which performs "distortion control," is alleged to be an ASIC that includes DSP functionality (Compl. ¶32-33).	¶32, ¶33	col. 10:55-61
wherein the system software is organized to identify specific optical aberrations and to access the database to identify specific corrections to the aberrations	The camera firmware's "Auto Distortion Control" feature uses downloadable "Distortion Control Data" files (the alleged database) to correct for lens-specific aberrations like barrel and pincushion distortion (Compl. ¶31).	¶31, ¶34	col. 10:40-44
wherein the modified data file ... is stored in memory	The complaint alleges that corrected images are stored in the cameras' memory, pointing to user manual descriptions of a "Storage folder" for processed images (Compl. ¶38). A provided visual shows the menu for selecting this storage folder (Compl. ¶38, p. 18).	¶38	col. 8:6-9

• Identified Points of Contention:
  • Scope Questions: A central question may be whether Nikon's integrated "Expeed" image-processing engine, which the complaint alleges is a system-on-a-chip, can satisfy the claim limitations for a discrete "microprocessor," "digital signal processor," and "application specific integrated circuit." The defense may argue that the claim requires structurally separate components as depicted in the patent's figures.
  • Technical Questions: Claim 1 requires the DSP to apply a "fast Fourier transform" to a data file to satisfy a "special effects function." The complaint makes this allegation without providing specific evidence from Nikon's technical documentation showing the use of an FFT for this purpose, raising an evidentiary question for the Plaintiff to address (Compl. ¶37).

U.S. Patent No. 8,451,339 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A digital imaging system for correcting image aberrations comprising: a digital camera mechanism, an optical lens mechanism, a digital sensor, a microprocessor, a digital signal processor, system software, a database management system and a memory storage sub-system	The accused Nikon digital cameras are alleged to comprise all of these components (Compl. ¶56).	¶56	col. 5:26-40
wherein a microprocessor uses system software to identify at least one optical aberration by accessing the database	The "Auto Distortion Control" feature allegedly uses system software to access the "Distortion Control Data" files (the alleged database) to identify aberrations for a given lens (Compl. ¶64, ¶67). A visual of this menu option is provided (Compl. ¶68, p. 31).	¶67	col. 10:5-10
wherein the microprocessor uses the database to identify at least one algorithm to use to correct the at least one optical aberration	The complaint alleges that the system software must necessarily use the database of lens data to identify the appropriate correction algorithm to apply for the identified aberration (Compl. ¶67).	¶67	col. 10:5-10
wherein the image file with at least one optical aberration is corrected by applying digital filtration by using at least one algorithm in the digital signal processor	The Expeed engine, containing the DSP, is alleged to apply the identified algorithm to the image file to perform the correction (Compl. ¶61, ¶67).	¶61, ¶67	col. 6:35-43

• Identified Points of Contention:
  • Scope Questions: As with the '805 Patent, the mapping of the integrated Expeed engine to the separately recited processor components will likely be a point of dispute.
  • Technical Questions: The claim requires the microprocessor to use the database to identify both an "aberration" and an "algorithm." The defense may argue that the accused system does not perform two separate identification steps but rather applies a pre-packaged correction profile associated with a lens ID, and that this single operation does not meet the multi-step claim limitation.

V. Key Claim Terms for Construction

• The Term: "application specific integrated circuit," "digital signal processor," and "microprocessor"

• Context and Importance: These terms are central to the dispute because they are recited as distinct elements in the claims, while the accused products utilize a single, integrated "Expeed" image-processing engine. The viability of the infringement case may depend on whether a single hardware component can be construed to meet the limitations for three separately named components.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader (Functional) Interpretation: The specification describes the functions performed by these components in cooperation. The patent states the system "may be implemented with a single microprocessor or with multiple microprocessors," which may suggest architectural flexibility beyond the specific block diagram in Figure 1 (’685 Patent, col. 6:52-54).
  • Evidence for a Narrower (Structural) Interpretation: Figure 1 of the patents depicts the Microprocessor, DSP, and Multifunctional Analysis Engine (ASIC) as distinct, labeled boxes, which could support an argument that the inventor contemplated them as structurally separate components (’805 Patent, Fig. 1). The use of three different names for the components in the same claim implies they are presumptively distinct entities.

• The Term: "database management system" / "database"

• Context and Importance: Plaintiff's infringement theory hinges on Nikon's downloadable "Distortion Control Data" files being construed as the claimed "database" or "database management system." The outcome of this construction could determine whether a core element of the claims is met by the accused products.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the function of the database as matching a specific lens type with its corresponding optical aberrations and correction data, a function that appears to align with the alleged purpose of Nikon's data files (’685 Patent, col. 10:40-44; Fig. 5).
  • Evidence for a Narrower Interpretation: The claim charts in the patents use the acronym "DBMS" for "database management system," a term of art that practitioners may argue implies a more complex system with capabilities like querying and data management, potentially beyond that of a simple firmware data file (’805 Patent, Fig. 1).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement based on Defendant’s marketing materials, user manuals, and online support articles that allegedly instruct customers on how to use the accused features, such as "Auto Distortion Control" and "Vignette control" (Compl. ¶44, ¶75, ¶96, ¶122).
• Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge. Critically, the complaint alleges that Nikon has had actual notice of the asserted patent family since at least 2012, when the '805 Patent was cited as prior art during the patent prosecution of one of Nikon’s own applications in China (Compl. ¶48, ¶79, ¶100, ¶126).

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

• A core issue will be one of architectural scope: can Nikon’s single, integrated “Expeed” image-processing engine be construed to meet the claims’ requirements for a distinct microprocessor, digital signal processor, and application-specific integrated circuit, or is there a fundamental mismatch between the claimed architecture and the accused design?
• A second key issue will be one of definitional scope: does Nikon's use of downloadable firmware files containing lens correction data meet the claim requirement for a “database management system,” or does that term require a more complex and functionally distinct software system than what is used in the accused products?
• A central question for damages will be one of willfulness: what evidentiary weight will the court give to the allegation that Nikon knew of the foundational patent in this family since 2012—years before the two most recent patents issued—due to its citation in Nikon's own patent prosecution, and can this establish the "egregious" conduct often required for enhanced damages?