DCT
4:23-cv-00927
Optimum Imaging Tech LLC v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Optimum Imaging Technologies LLC (Texas)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea) and Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Cherian LLP
- Case Identification: 4:23-cv-00927, E.D. Tex., 10/24/2024
- Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics Co., Ltd., a foreign entity, in any judicial district. Venue for Samsung Electronics America, Inc. is alleged to be proper based on its regular and established place of business in Plano, Texas, within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Galaxy line of smartphones infringes patents related to in-camera systems and methods for the automated correction of optical and digital image aberrations.
- Technical Context: The technology involves using integrated hardware and software within a digital camera to automatically correct image distortions caused by the optical lens system, thereby improving image quality without manual post-processing.
- Key Procedural History: The complaint alleges that all asserted patents share a common specification and priority date. To support its claims for willful infringement, Plaintiff alleges that Defendant had pre-suit knowledge of the patent family as early as 2008 through citations made by patent examiners during the prosecution of Defendant’s own Korean and U.S. patent applications.
Case Timeline
| Date | Event |
|---|---|
| 2006-07-11 | Priority Date for ’805, ’339, and ’266 Patents |
| 2008-07-24 | ’805 Patent application published |
| 2008-11-03 | Alleged notice to Samsung via Korean patent prosecution citing the ’805 patent family |
| 2009-11-03 | ’805 Patent issued |
| 2010-07-23 | Alleged notice to Samsung via U.S. patent prosecution citing the ’805 patent application |
| 2013-05-28 | ’339 Patent issued |
| 2020-12-29 | ’266 Patent issued |
| 2024-10-24 | Complaint Filing Date |
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 Nov. 3, 2009)
The Invention Explained
- Problem Addressed: The patent describes the challenge of correcting for both optical problems (e.g., spherical aberration, distortion, vignetting) and digital artifacts (e.g., moiré effects, dust on the sensor) that degrade image quality in digital photography (Compl., Ex. A, ’805 Patent, col. 4:32-5:51). These issues were traditionally addressed with physical filters or time-consuming post-production software.
- The Patented Solution: The invention proposes an automated, in-camera digital imaging system that identifies a specific lens type, refers to a database that matches the lens with its known optical aberrations, and applies pre-programmed digital corrections using dedicated processors (e.g., a Digital Signal Processor and an Application Specific Integrated Circuit) to optimize the final image before it is stored (’805 Patent, Abstract; col. 9:51-10:14). Figure 1 illustrates the system architecture, showing data flow from the lens and sensor through processors that access a database management system (DBMS) to correct the image (’805 Patent, Fig. 1).
- Technical Importance: This automated approach aimed to improve image quality and reduce user effort by integrating complex image correction, once the domain of professional editing software, directly into the camera’s hardware and software systems (Compl., Ex. A, ’805 Patent, col. 7:25-30).
Key Claims at a Glance
- The complaint asserts representative Claim 1, an independent system claim (Compl. ¶27).
- Claim 1 requires, in part:
- A digital imaging system comprising a digital camera mechanism, optical lens mechanism, digital sensor, microprocessor, digital signal processor (DSP), application specific integrated circuit (ASIC), system software, a database management system, and a memory storage sub-system.
- The optical lens mechanism is a fixed focal length.
- Aberrations are corrected by digital filtration using the ASIC and DSP.
- The system software is organized to identify specific optical aberrations and access the database for corresponding corrections.
- The DSP applies a fast Fourier transform for a user-specified special effects function.
- The corrected and optimized data file is stored in memory.
U.S. Patent No. 8,451,339 - “Digital imaging system for correcting image aberrations” (Issued May 28, 2013)
The Invention Explained
- Problem Addressed: As a continuation of the ’805 Patent, the ’339 Patent addresses the same technical problems of optical and digital aberrations that compromise image quality in digital cameras (Compl., Ex. B, ’339 Patent, col. 4:32-5:51).
- The Patented Solution: The invention claims a digital imaging system where a microprocessor uses system software to access a database to first identify an optical aberration and then identify a corresponding algorithm to correct it. An image file captured by the sensor is then forwarded to a digital signal processor, which applies digital filtration using the identified algorithm to correct the image before storing it in memory (’339 Patent, Abstract; col. 10:41-53).
- Technical Importance: This system provides a structured, software-driven method for automating lens-specific corrections within the camera itself, aiming to deliver higher-quality images directly from the device (’339 Patent, col. 7:25-30).
Key Claims at a Glance
- The complaint asserts representative Claim 1, an independent system claim (Compl. ¶51).
- Claim 1 requires, in part:
- A digital imaging system comprising a digital camera mechanism, optical lens mechanism, digital sensor, microprocessor, DSP, system software, a database management system, and a memory storage sub-system.
- The optical lens mechanism is a fixed focal length lens.
- A microprocessor uses system software to identify at least one optical aberration by accessing the database.
- The microprocessor uses the database to identify at least one algorithm to correct the aberration.
- The image file is corrected by the DSP applying digital filtration using the identified algorithm.
- The modified digital file is stored in memory.
Multi-Patent Capsule
- U.S. Patent No. 10,877,266: “Digital camera with wireless image transfer” (Issued Dec. 29, 2020)
- Technology Synopsis: The ’266 Patent claims a method of processing images in a digital camera. The method involves using in-camera hardware and software to perform image correction algorithms and process correction data from a database system. A key aspect is that the in-camera software and database are upgradable to provide improved algorithms, and the corrected images can be wirelessly transmitted from the camera (Compl. ¶¶74, 77; Compl., Ex. C, ’266 Patent, Abstract).
- Asserted Claims: Claim 1 (Compl. ¶74).
- Accused Features: Plaintiff alleges that the accused smartphones perform image correction using updatable in-camera software and databases and are configured to wirelessly transmit the resulting corrected images (Compl. ¶¶76-77, 80, 82).
III. The Accused Instrumentality
Product Identification
- The complaint identifies numerous Samsung Galaxy smartphones as the "Infringing Products," including the Galaxy S10, S20, S21, S22, and S23 series, as well as the Z Fold and Z Flip series, using the Galaxy S10 as a specific, exemplary device (Compl. ¶22).
Functionality and Market Context
- The accused products are smartphones equipped with multi-lens digital cameras, including fixed focal length "ultra wide angle" lenses (Compl. ¶30). The complaint includes a screenshot from Samsung's website detailing the triple rear camera setup of the Galaxy S10 (Compl. p. 10).
- The complaint alleges these phones contain integrated processors, such as the Qualcomm Snapdragon 855, which includes a CPU (central processing unit) and an ISP (image signal processor) that perform the functions of the claimed microprocessor and digital signal processor, respectively (Compl. ¶¶32, 56).
- Central to the allegations is the "Ultra wide shape correction" software feature, which the complaint alleges performs the claimed digital filtration to correct optical aberrations (Compl. ¶36). A screenshot from a Samsung support article shows a user interface toggle for this feature, describing its function as automatically correcting distortion from the ultra-wide lens (Compl. p. 13).
- The complaint further alleges the phones contain an updatable database of camera software and data, store the corrected images to internal or external memory, and are capable of wirelessly transmitting the images (Compl. ¶¶34, 39, 82).
IV. Analysis of Infringement Allegations
’805 Patent 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 smartphones contain these components; the Qualcomm Snapdragon 855 processor is alleged to comprise the microprocessor, digital signal processor, and ASIC. | ¶28, ¶32, ¶34, ¶35 | col. 29:39-44 |
| wherein the optical lens mechanism is a fixed focal length | The accused products include an ultra wide angle lens with a fixed focal length. | ¶30 | col. 9:62-63 |
| 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 | The "Ultra wide shape correction" feature allegedly uses the Snapdragon's processing components (ISP and others) to perform digital filtration and correct optical distortion. | ¶29, ¶36 | col. 10:43-48 |
| wherein the system software is organized to identify specific optical aberrations and to access the database to identify specific corrections to the aberrations | The "Ultra wide shape correction" software allegedly identifies aberrations and accesses a database of camera software and data to determine corrections. | ¶29, ¶34 | col. 10:2-6 |
| wherein the digital signal processor selects a specific procedure to optimize the image and corrects the aberrations | The ISP is alleged to execute the "ultra wide shape correction" procedure to correct aberrations and optimize the final image. | ¶29, ¶36 | col. 9:11-14 |
| wherein the digital signal processor applies a fast Fourier transform to a data file in order to satisfy a user specified special effects function | The complaint alleges on information and belief that the products apply a fast Fourier transform for special effects functions. | ¶38 | col. 31:49-54 |
| wherein the modified data file...is stored in memory | Corrected photos are automatically saved to the phone's internal memory or an installed memory card. | ¶39 | col. 9:18-20 |
’339 Patent 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 smartphones contain these components, with the Snapdragon 855 processor alleged to comprise the microprocessor and digital signal processor. | ¶52, ¶56, ¶58, ¶59 | col. 29:39-44 |
| wherein the optical lens mechanism is a fixed focal length lens | The accused products include an ultra wide angle lens with a fixed focal length. | ¶54 | col. 9:62-63 |
| wherein a microprocessor uses system software to identify at least one optical aberration by accessing the database | The "Ultra wide shape correction" software, running on the CPU, allegedly identifies optical distortion by accessing a database of camera data. | ¶53, ¶60 | col. 10:2-6 |
| wherein the microprocessor uses the database to identify at least one algorithm to use to correct the at least one optical aberration | The software allegedly uses the database to identify the correction algorithm required for the "Ultra wide shape correction" function. | ¶53, ¶60 | col. 10:7-9 |
| 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 ISP allegedly applies the identified "ultra wide shape correction" algorithm to correct the distortion in the image file. A screenshot shows this functionality (Compl. p. 22). | ¶53, ¶60 | col. 10:43-48 |
| wherein the modified digital file...is stored in memory | Corrected photos are automatically saved to the phone's memory. | ¶62 | col. 9:18-20 |
- Identified Points of Contention:
- Scope Questions: A primary question may be one of claim construction and mapping for the hardware elements in Claim 1 of the ’805 Patent. It raises the question of whether the integrated processing cores within the accused Snapdragon System-on-a-Chip (e.g., CPU, ISP) correspond to the discretely listed "microprocessor", "digital signal processor", and "application specific integrated circuit", or if the patent requires physically separate components.
- Technical Questions: The infringement theory for the ’339 Patent rests on the accused system using a database to "identify at least one algorithm" for correction. This raises the evidentiary question of how the "Ultra wide shape correction" feature technically operates: does it select a specific algorithm from a database based on the lens in use, or does it apply a universal correction process based on real-time image analysis, which may not meet the claim's two-step "identify-then-correct" process? The complaint's bare allegation regarding the use of a "fast Fourier transform" for "special effects" in the ’805 Patent also suggests a potential evidentiary gap (Compl. ¶38).
V. Key Claim Terms for Construction
The Term: "application specific integrated circuit" (’805 Patent, Claim 1)
- Context and Importance: This term is critical because the accused products utilize a highly integrated System-on-a-Chip (SoC) rather than discrete, single-purpose chips. The infringement analysis for the ’805 Patent may turn on whether a specialized, but programmable, processing core within the SoC (like an ISP) meets the definition of an ASIC. Practitioners may focus on this term because Defendant could argue its general-purpose, programmable hardware does not meet the structural requirements of a circuit designed for a "specific" application.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification depicts the ASIC as a "Multifunctional Analysis Engine," suggesting it can perform more than a single, narrow task, which may support an argument that a specialized core within a larger processor qualifies (’805 Patent, Fig. 1).
- Evidence for a Narrower Interpretation: The claim and Figure 1 both list the "microprocessor", "digital signal processor", and "application specific integrated circuit" as separate elements. This structure suggests the patentee viewed them as structurally distinct components, which may support an argument that an integrated processor that performs all three functions does not meet the limitation.
The Term: "algorithm" (’339 Patent, Claim 1)
- Context and Importance: The claim requires the system to use a database to "identify at least one algorithm to use to correct" an aberration. The definition of "algorithm" and the meaning of "identify" will be central to the dispute. The case may depend on whether activating a single, pre-programmed function (like "Ultra wide shape correction") satisfies this limitation, or if it requires a selection from a plurality of distinct corrective routines stored in the database.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the corrective process in general terms, such as using "pre-set calculations" to compensate for optical distortion, which could support interpreting any set of corrective software instructions as the claimed "algorithm" (’339 Patent, col. 10:20-25).
- Evidence for a Narrower Interpretation: The claim recites a two-step process: first identifying an aberration, and then using the database to identify an algorithm. This sequence may suggest a more complex process than a simple on/off switch for a single function, potentially requiring a choice among multiple algorithms based on the specific aberration found.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement of infringement under 35 U.S.C. § 271(b). The basis for this allegation is Defendant’s affirmative acts of providing marketing materials, user manuals, and online support articles that allegedly instruct and encourage customers to use the accused "Ultra wide shape correction" feature (Compl. ¶¶42, 65, 85).
- Willful Infringement: The complaint alleges willful infringement based on both pre-suit and post-suit knowledge of the asserted patents. It alleges pre-suit knowledge dating back to at least November 3, 2008, based on citations to the ’805 patent family made by patent examiners during the prosecution of Defendant's own patent applications in Korea and the United States (Compl. ¶¶46, 69, 89).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural equivalence: can the discretely claimed hardware components of the ’805 patent—specifically the "microprocessor", "digital signal processor", and "application specific integrated circuit"—be mapped onto the multifunctional, integrated processing cores of the accused smartphones' System-on-a-Chip architecture?
- A key evidentiary question will be one of operational fidelity: does the accused "Ultra wide shape correction" feature function by accessing a database to "identify at least one algorithm" for use, as required by the ’339 patent, or does it employ a more generic, real-time image analysis that may not map to the specific process recited in the claim?
- The allegations of willfulness will likely focus on pre-suit knowledge: given the complaint's specific evidence of prior art citations in Defendant's own patent prosecution dating back over a decade, a central question for the case will be what, if any, investigation or opinion of counsel Defendant secured regarding these patents before implementing the accused features.