DCT
4:23-cv-00928
Optimum Imaging Tech LLC v. Sony Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Optimum Imaging Technologies LLC (Texas)
- Defendant: Sony Corporation (Japan)
- Plaintiff’s Counsel: Carter Arnett PLLC; Cherian LLP
- Case Identification: 4:23-cv-00928, E.D. Tex., 10/18/2023
- Venue Allegations: Plaintiff asserts venue is proper because Defendant is a foreign entity and because it conducts substantial business in the district, including selling the accused products through authorized dealers, commercial websites, and online retailers accessible to residents of the district.
- Core Dispute: Plaintiff alleges that Defendant’s digital cameras with "Lens Compensation" functionality infringe four patents related to in-camera systems and methods for correcting optical and digital image aberrations.
- Technical Context: The technology involves using on-board processors and software to computationally correct image flaws—such as distortion, vignetting, and chromatic aberration—that arise from optical lenses, thereby improving image quality without expensive hardware or post-production editing.
- Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the patent family as early as July 23, 2010, when the earliest patent-in-suit was cited as prior art during the prosecution of at least one of Defendant’s own U.S. patent applications.
Case Timeline
| Date | Event |
|---|---|
| 2006-07-11 | Priority Date for all Asserted Patents |
| 2009-11-03 | U.S. Patent No. 7,612,805 Issued |
| 2010-07-23 | Alleged first notice to Sony of ’805 Patent via citation |
| 2012-07-18 | Alleged notice to Sony of ’339 Patent application |
| 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"
The Invention Explained
- Problem Addressed: The patent family addresses optical and digital problems in photography, including lens aberrations (e.g., distortion, vignetting) and digital artifacts (e.g., moiré, noise) that can degrade image quality, particularly as digital sensor capabilities advance. (’685 Patent, col. 1:40-2:62).
- The Patented Solution: The invention is a digital imaging system that automates the correction of these aberrations inside the camera. It uses a combination of hardware components—including a microprocessor, a digital signal processor (DSP), and an application-specific integrated circuit (ASIC)—and system software that accesses a database of known lens flaws and corrections to apply digital filtration to the captured image data. (’685 Patent, col. 7:8-14; ’685 Patent, Fig. 1).
- Technical Importance: This in-camera approach aimed to improve final image quality while reducing the need for more complex, expensive optical lens designs or for time-consuming post-production software editing. (’685 Patent, col. 7:20-29).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 9. (Compl. ¶22).
- Claim 1 recites a digital imaging system for a fixed focal length lens, comprising:
- A set of hardware including a digital camera mechanism, optical lens mechanism, digital sensor, microprocessor, DSP, and an application specific integrated circuit (ASIC).
- System software organized to identify specific optical aberrations and access a database to identify corresponding corrections.
- An ASIC and DSP that correct aberrations by applying digital filtration.
- A DSP that applies a fast Fourier transform to satisfy a user-specified special effects function.
- A memory for storing the modified data file.
- Claim 9 recites a digital imaging system for a zoom lens, comprising:
- A similar set of hardware components as claim 1.
- System software for identifying aberrations and accessing a database for corrections.
- Correction of optical aberrations with digital filtration to modify multiple images from different focal lengths.
- A memory for storing the modified data file consisting of the optimized and corrected digital data.
U.S. Patent No. 8,451,339 - "Digital imaging system for correcting image aberrations"
The Invention Explained
- Problem Addressed: The patent, sharing a specification with the ’805 Patent, addresses the same optical and digital aberrations inherent in digital photography. (’685 Patent, col. 1:40-2:62).
- The Patented Solution: This invention refines the correction system by explicitly claiming the use of a microprocessor and software to access a database to identify not just a general correction, but a specific "algorithm" to correct an identified optical aberration. The selected algorithm is then used by the DSP to apply the digital filtration. (’339 Patent, col. 39:46-56).
- Technical Importance: This approach provides a more structured and targeted method for correction, where specific, pre-defined algorithms are matched to specific, identified aberrations for a given lens type. (’685 Patent, col. 9:38-43).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 14. (Compl. ¶46).
- Claim 1 recites a digital imaging system for a fixed focal length lens, comprising:
- A set of hardware including a digital camera mechanism, optical lens mechanism, sensor, microprocessor, DSP, system software, and a database.
- A microprocessor that uses system software to access the database to identify at least one optical aberration.
- The microprocessor then uses the database to identify at least one algorithm to correct that aberration.
- The image file is corrected by the DSP applying digital filtration using that algorithm.
- A memory for storing the modified file.
- Claim 14 recites a digital imaging system for a zoom lens, comprising:
- A similar set of hardware components.
- A microprocessor that uses the database to identify an optical aberration at any focal length of the zoom lens.
- The microprocessor accesses the database to obtain a filtration correction algorithm and forwards it to the DSP.
- The image file is corrected at the specific focal length using the identified algorithm.
Multi-Patent Capsule: U.S. Patent No. 10,873,685
- Patent Identification: U.S. Patent No. 10,873,685, "Digital imaging system for correcting video image aberrations," issued December 22, 2020.
- Technology Synopsis: This patent extends the core aberration correction technology specifically to the context of digital video. The invention describes a digital video camera where an integrated circuit uses in-camera software to access a database of aberration corrections and applies a correction to at least one frame of the captured video. (Compl. ¶72).
- Asserted Claims: Independent claim 1 is asserted. (Compl. ¶72).
- Accused Features: The complaint accuses the video recording capabilities of Sony cameras, alleging that the "Lens Compensation" feature is applied to video files during or after capture. (Compl. ¶¶ 74, 81).
Multi-Patent Capsule: U.S. Patent No. 10,877,266
- Patent Identification: U.S. Patent No. 10,877,266, "Digital camera with wireless image transfer," issued December 29, 2020.
- Technology Synopsis: This patent claims a method for processing images within a digital camera. The claimed method includes digitally processing a captured image using in-camera hardware and upgradable software to perform correction algorithms, storing the corrected image, and wirelessly transmitting the corrected image. (Compl. ¶93).
- Asserted Claims: Independent claim 1 is asserted. (Compl. ¶93).
- Accused Features: The complaint points to the ability of accused Sony cameras to be updated via firmware downloads and to wirelessly transmit images to other devices using applications like Sony’s PlayMemories Mobile. (Compl. ¶¶ 99, 101).
III. The Accused Instrumentality
Product Identification
- Sony digital cameras that include digital lens aberration correction functionality, with the Sony α9 Interchangeable Lens Digital Camera and its successors cited as exemplary products. (Compl. ¶¶ 16, 17).
Functionality and Market Context
- The accused products are interchangeable lens cameras compatible with a wide range of both fixed focal length and zoom lenses. (Compl. ¶¶ 27, 51). A product brochure image shows a variety of compatible lenses for the Sony α9. (Compl. p. 10).
- The core accused functionality is a feature marketed as "Lens Compensation," which the complaint alleges automatically corrects for "shading in the corners of the screen" (vignetting), "color deviation at the corners of the screen" (chromatic aberration), and "distortion of the screen." (Compl. ¶¶ 16, 31). A screenshot from a Sony help guide illustrates the menu for this feature. (Compl. p. 11).
- This correction is allegedly performed by an on-board "BIONZ X image processing engine," which includes a "processor and a front-end LSI," the latter of which Plaintiff identifies as an application-specific integrated circuit (ASIC). (Compl. ¶¶ 30, 53).
- The complaint alleges that the software and correction data underlying this feature are upgradable via firmware updates available for download from Sony's website, and that the cameras can wirelessly transmit the resulting corrected images. (Compl. ¶¶ 99, 101).
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 | Each accused camera is alleged to be a digital imaging system containing these hardware and software components, embodied in the camera body, lens, sensor, BIONZ X processing engine, firmware, and memory slots. | ¶25 | ’685 Patent, Fig. 1 |
| wherein the optical lens mechanism is a fixed focal length | The accused cameras are compatible with and operate with fixed focal length lenses. | ¶27 | ’685 Patent, col. 9:57-58 |
| 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 BIONZ X engine, which contains an alleged ASIC ("front-end LSI") and a processor, performs the "Lens Compensation" feature to automatically correct aberrations like distortion and vignetting. | ¶¶26, 30, 31 | ’685 Patent, col. 8:10-14 |
| wherein the system software is organized to identify specific optical aberrations and to access the database to identify specific corrections to the aberrations | The "Lens Compensation" software automatically corrects aberrations based on the specific lens being used, which allegedly requires accessing a database of lens correction data stored in the camera. | ¶¶26, 29 | ’685 Patent, col. 9:38-43 |
| wherein the data are forwarded from the digital sensor to the digital signal processor by an application specific integrated circuit | Image data from the sensor's pixel area is allegedly forwarded through a signal processing circuit and on to the image processing engine for correction. | ¶32 | ’685 Patent, col. 31:40-44 |
| 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 to apply user-specified special effects functions. | ¶33 | ’685 Patent, col. 31:55-60 |
| wherein the modified data file ... is stored in memory | The accused cameras automatically create storage folders in memory, where the corrected images are recorded. | ¶34 | ’685 Patent, col. 32:1-3 |
Identified Points of Contention
- Functional Questions: A primary question may be whether the accused "Lens Compensation" feature, which is described as correcting optical flaws, performs the function recited in Claim 1 of applying a "fast Fourier transform... to satisfy a user specified special effects function." The complaint provides only a conclusory allegation for this element, which may indicate a functional mismatch between the claim and the accused product's operation. (Compl. ¶33).
- Scope Questions: It may be disputed whether the "front-end LSI" component of Sony's BIONZ X processing engine constitutes an "application specific integrated circuit" as that term is used in the patent, or if it is a more general-purpose component outside the claim's scope. (Compl. ¶30).
’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 | Each accused camera is alleged to be a digital imaging system containing these hardware and software components, embodied in the camera body, lens, sensor, BIONZ X processing engine, and memory. | ¶49 | ’685 Patent, Fig. 1 |
| wherein the optical lens mechanism is a fixed focal length lens | The accused cameras are compatible with and operate with fixed focal length lenses. | ¶51 | ’685 Patent, col. 9:57-58 |
| wherein a microprocessor uses system software to identify at least one optical aberration by accessing the database | To perform automatic "Lens Compensation," the camera's microprocessor allegedly uses system software to access an on-board database to identify aberrations associated with the attached lens. | ¶57 | ’685 Patent, col. 10:55-62 |
| 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 microprocessor further uses the database to identify a specific correction algorithm for the identified aberration. | ¶57 | ’685 Patent, col. 12:40-42 |
| 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 BIONZ X engine allegedly applies the identified algorithm via its DSP to correct the image file. The "Lens Compensation" feature is the embodiment of this functionality. | ¶57 | ’685 Patent, col. 7:10-14 |
| wherein the modified digital file ... is stored in memory | Corrected images are automatically recorded to a storage folder created in the camera's memory. | ¶59 | ’685 Patent, col. 32:1-3 |
Identified Points of Contention
- Technical Questions: The infringement theory hinges on the camera's microprocessor not only identifying an aberration but also actively identifying an algorithm from a database to correct it. The central technical question will be what evidence demonstrates this specific two-step selection process, as opposed to a system that simply applies a pre-set, non-selected correction profile for a given lens.
V. Key Claim Terms for Construction
"application specific integrated circuit" (from ’805 Patent, Claim 1)
- Context and Importance: This term is critical because the complaint maps it directly to the "front-end LSI" within Sony's BIONZ X image processing engine. (Compl. ¶30). The viability of the infringement allegation may depend on whether a "front-end LSI," which works in concert with a main processor, can be construed as a distinct "application specific integrated circuit."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide a specific definition for the term. Practitioners may argue that any integrated circuit within the camera that is configured and used to perform the specialized image correction functions recited in the claims, such as the "front-end LSI," falls within the term's ordinary meaning, regardless of its name or its integration with other processors.
- Evidence for a Narrower Interpretation: The patent's Figure 1 depicts the "Multifunctional Analysis Engine (ASIC)" as a structurally separate component from the "Microprocessor" and "DSP." (’685 Patent, Fig. 1). A party could argue that this figure defines the term as requiring a physically or architecturally distinct chip, not merely a component of a larger, integrated processing engine.
"algorithm" (from ’339 Patent, Claim 1)
- Context and Importance: Claim 1 of the ’339 Patent requires the microprocessor to use a database to "identify at least one algorithm" for correction. The dispute may turn on whether the lens correction profiles allegedly stored in the accused cameras qualify as "algorithms" and whether the microprocessor "identifies" them in the manner claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification refers to developing "mathematical algorithms for automatic correction" and implementing them in software. (’685 Patent, col. 12:40-42). A party may argue that any set of pre-programmed rules or correction values stored in the database for a specific lens constitutes an "algorithm" in this context.
- Evidence for a Narrower Interpretation: The claim language recites a sequence where the microprocessor first identifies an aberration, and then "uses the database to identify at least one algorithm to use to correct" it. This language suggests an active selection process. A party could argue that this requires more than simply applying a default correction profile associated with a lens, but rather a dynamic choice of a specific computational procedure from a library of potential procedures.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement of infringement for all four patents. The basis for this allegation is that Defendant provides user manuals, help guides, and other materials that allegedly instruct customers and end-users in the United States to use the infringing "Lens Compensation" functionality. (Compl. ¶¶ 38, 63, 84, 104).
- Willful Infringement: Willfulness is alleged for all four patents based on Defendant’s alleged pre-suit knowledge. The complaint asserts that Defendant was on notice of the patent family at least as early as July 23, 2010, when the ’805 Patent was cited as prior art during the prosecution of Defendant's own U.S. Patent application. (Compl. ¶¶ 41, 67, 88, 108).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the hardware term "application specific integrated circuit," depicted in the patent as a distinct component, be construed to cover the "front-end LSI" that is part of Sony's integrated BIONZ X image processing engine?
- A key evidentiary question will be one of functional mismatch: does the accused "Lens Compensation" feature, which corrects inherent optical flaws, perform the specific function of applying a "fast Fourier transform...to satisfy a user specified special effects function," as required by Claim 1 of the ’805 patent, or are these technologically distinct operations?
- The dispute over the ’339 patent will likely turn on algorithmic selection: what evidence will show that the accused cameras perform the claimed step of a microprocessor using a database to actively "identify" a corrective "algorithm," as opposed to simply applying a single, pre-determined set of correction values associated with a detected lens?