DCT

4:24-cv-00847

Panasonic Entertainment & Communication Co Ltd v. Optimum Imaging Tech LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:24-cv-00847, N.D. Cal., 04/25/2024
  • Venue Allegations: Plaintiff Panasonic alleges that venue is proper in the Northern District of California because Defendant OIT’s sole managing member and the sole named inventor of the patents-in-suit, Neal Solomon, is a resident of and has conducted OIT's business from this district for over 20 years.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its LUMIX digital cameras and lenses do not infringe four of Defendant's patents related to in-camera digital systems for correcting optical and digital image aberrations.
  • Technical Context: The technology concerns automated, in-camera software and hardware systems that identify and correct optical imperfections, such as distortion and vignetting, which is a significant feature in the digital photography market.
  • Key Procedural History: This declaratory judgment action follows a patent infringement complaint filed by Optimum Imaging Technologies (OIT) against Panasonic Corporation on October 18, 2023, in the Eastern District of Texas. Panasonic asserts that OIT sued the wrong corporate entity. The complaint also notes that OIT previously litigated two of the patents-in-suit (’805 and '339) against Canon Inc. in the Eastern District of Texas, beginning in July 2019.

Case Timeline

Date Event
2006-07-11 Earliest Priority Date for all Patents-in-Suit
2009-11-03 U.S. Patent No. 7,612,805 Issues
2013-05-28 U.S. Patent No. 8,451,339 Issues
2019-07-08 OIT files complaint against Canon Inc.
2020-12-22 U.S. Patent No. 10,873,685 Issues
2020-12-29 U.S. Patent No. 10,877,266 Issues
2023-10-18 OIT files complaint against Panasonic Corp. in E.D. Tex.
2024-04-25 Panasonic files this Complaint for Declaratory Judgment

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’s background section describes the numerous optical problems (e.g., lens aberrations like distortion and vignetting) and digital artifacts (e.g., moiré patterns) that degrade image quality in digital photography and traditionally required complex optical solutions or time-consuming post-production software to correct (Compl., Ex. A, ¶12; ’805 Patent, col. 4:40-51, col. 5:20-31).
  • The Patented Solution: The invention is an automated in-camera system that uses a combination of hardware and software to correct these aberrations before the image is stored ('805 Patent, Abstract). The system identifies the specific lens type attached to the camera, accesses an onboard database to retrieve data on that lens’s characteristic aberrations, and then applies a corresponding digital filtration process using a digital signal processor to correct the captured image ('805 Patent, Fig. 5; col. 10:45-50).
  • Technical Importance: This approach sought to automate complex image correction, moving it from a manual, post-production process into an integrated, real-time function within the camera itself, thereby improving workflow efficiency and final image quality (Compl., Ex. A, ¶13; ’805 Patent, col. 7:10-19).

Key Claims at a Glance

  • The complaint asserts at least independent claims 1, 4, 9, 11, 15, 18, 21, 24, 26, and 30 (Compl. ¶50; Compl., Ex. A, ¶22, ¶36).
  • Independent Claim 1 (representative of fixed-lens claims) requires:
    • A digital imaging system with specified hardware (digital camera, optical lens, sensor, microprocessor, DSP, ASIC, software, database management system, memory).
    • The optical lens mechanism is a fixed focal length.
    • Aberrations are corrected by digital filtration using the ASIC and DSP.
    • System software is organized to identify aberrations and access the database for specific corrections.
    • The DSP selects a specific procedure to optimize the image and correct aberrations.
    • The DSP applies a fast Fourier transform for a user-specified special effects function.
  • Independent Claim 9 (representative of zoom-lens claims) requires:
    • A digital imaging system with specified hardware components.
    • The lens type is a zoom lens.
    • The lens focal length alternates from specific fixed focal length settings.
    • Optical aberrations are corrected with digital filtration to modify multiple images from different focal lengths.
    • A modified data file is stored in memory.

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

The Invention Explained

  • Problem Addressed: Like the ’805 patent, the ’339 Patent addresses the technical challenge of correcting optical and digital aberrations inherent in camera lenses and digital sensors, which compromise image quality (’339 Patent, col. 3:9-12).
  • The Patented Solution: The invention is an in-camera system where a microprocessor uses software to access a database not only to identify an optical aberration but also to identify at least one specific algorithm to correct it (’339 Patent, Abstract). The image file is captured, forwarded to a digital signal processor, and corrected by applying the identified algorithm before being stored in memory (’339 Patent, col. 32:4-17).
  • Technical Importance: The invention focuses on an automated, algorithm-based approach within the camera, aiming to provide more sophisticated and tailored corrections than simple, fixed filters by selecting specific correction algorithms from a database based on the identified aberration (’339 Patent, col. 7:10-19).

Key Claims at a Glance

  • The complaint asserts at least independent claims 1, 6, and 14 (Compl. ¶56; Compl., Ex. A, ¶47, ¶62).
  • Independent Claim 1 (representative of fixed-lens claims) requires:
    • A digital imaging system with specified hardware components.
    • 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 use for correction.
    • The image file is corrected by applying the algorithm in the digital signal processor.
  • Independent Claim 14 (representative of zoom-lens claims) requires:
    • A digital imaging system with specified hardware components.
    • The optical lens mechanism is a zoom lens.
    • The microprocessor uses system software to access the database to identify an aberration at any focal length of the zoom lens.
    • The microprocessor accesses the database to obtain at least one filtration correction algorithm and forwards it to the DSP.
    • The image file is corrected by the DSP applying the algorithm.

U.S. Patent No. 10,873,685 - “Digital imaging system for correcting video image aberrations”

  • Technology Synopsis: This patent extends the core aberration correction technology specifically to the context of digital video (Compl., Ex. A, ¶70). It describes a system where an integrated circuit uses in-camera software to identify and correct at least one optical image aberration in at least one frame of the digital video, using correction data stored in a database (’685 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl., Ex. A, ¶73).
  • Accused Features: The accused "Lens Compensation" feature, which OIT alleges operates on both still photos and videos captured by the accused cameras (Compl., Ex. A, ¶16, ¶82).

U.S. Patent No. 10,877,266 - “Digital camera with wireless image transfer”

  • Technology Synopsis: This patent claims a method of image processing that includes performing image correction algorithms using data from a database, but adds the novel steps of receiving updated software and image correction data and upgrading the digital camera with this data (’266 Patent, Abstract). The method also includes the step of wirelessly transmitting the corrected images (Compl., Ex. A, ¶94).
  • Asserted Claims: At least independent claim 1 (Compl., Ex. A, ¶94, ¶105).
  • Accused Features: The ability of the accused Panasonic cameras to have their system software and lens correction database updated via download from Panasonic’s website, in combination with their ability to perform "Lens Compensation" and wirelessly transmit the resulting images (Compl., Ex. A, ¶101, ¶103).

III. The Accused Instrumentality

Product Identification

A range of Panasonic LUMIX digital cameras, including models from the S, GH, G, and GX series (e.g., LUMIX S5M2, GH6, G9) (Compl. ¶31; Compl., Ex. A, ¶17).

Functionality and Market Context

The complaint alleges that the accused products are digital cameras that incorporate a feature called “Lens Compensation,” which automatically corrects for various optical aberrations such as vignetting, color shading, and diffraction (Compl., Ex. A, ¶16, ¶32). This functionality is allegedly performed by an onboard image processing engine, identified as either the "L2 Technology" or "Venus Engine," which contains an application-specific integrated circuit (ASIC) and a digital signal processor (DSP) (Compl., Ex. A, ¶30-31). The complaint further alleges that these cameras store and use lens-specific correction data in an internal database, and that the camera's system software and associated database can be updated via downloads from Panasonic's website (Compl., Ex. A, ¶29, ¶101). A screenshot from the LUMIX S5II Owner's Manual shows the "Lens Compensation" menu, which offers options for correcting vignetting, color shading, and diffraction (Compl., Ex. A, p. 28).

IV. Analysis of Infringement Allegations

’805 Patent Infringement Allegations

Claim Element (from Independent Claim 9) Alleged Infringing Functionality Complaint Citation Patent Citation
A digital imaging system for image filtration comprising: ... a digital signal processor, an application specific integrated circuit, system software, a database management system and a memory storage sub-system The accused cameras allegedly contain an image processing engine (ASIC and DSP), system software, internal storage for lens correction data, and memory card slots. ¶25, ¶29-31, ¶35 col. 30:52-59
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 "Lens Compensation" feature allegedly uses the camera's image processing engine (e.g., Venus Engine) to correct aberrations. A provided image shows the Venus Engine chip (Compl., Ex. A, p. 27). ¶30, ¶32 col. 36:53-59
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's onboard software allegedly accesses the stored database of lens data to identify and apply the appropriate correction for the attached lens. ¶29, ¶32 col. 36:60-63
wherein the lens type is a zoom lens The accused cameras are compatible with and marketed for use with various zoom lenses. ¶27 col. 38:20
wherein optical aberrations are corrected with digital filtration to modify multiple images from different focal lengths in a succession of data files The "Lens Compensation" functionality allegedly corrects aberrations at different focal lengths selected by the user when operating a zoom lens. ¶32 col. 38:26-30
wherein the modified data file ... is stored in memory The camera allegedly stores the corrected image files on memory cards. A screenshot shows the camera's menu for managing dual card slots (Compl., Ex. A, p. 29). ¶35 col. 38:31-34
  • Identified Points of Contention:
    • Scope Question: Panasonic’s complaint for declaratory judgment directly contests whether the accused products contain a "database management system" as required by the claim (Compl. ¶50). A central issue will be whether the camera's firmware for storing and retrieving lens correction profiles meets the proper construction of this term.
    • Technical Question: The complaint alleges on "information and belief" that the accused products meet every limitation of the asserted claims (Compl., Ex. A, ¶26). However, for certain specific functions recited in other independent claims, such as applying a "fast Fourier transform" for a "special effects function" ('805 Patent, claim 1), the complaint provides no specific factual support. A point of contention may be whether the standard "Lens Compensation" feature performs these highly specific functions required by every asserted claim.

’339 Patent Infringement Allegations

Claim Element (from Independent Claim 14) Alleged Infringing Functionality Complaint Citation Patent Citation
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 cameras allegedly contain these hardware and software components, including the "Venus Engine" processor and memory card slots for storage. ¶50, ¶54-58 col. 33:17-23
wherein the optical lens mechanism is a zoom lens The accused cameras are allegedly used with a variety of compatible zoom lenses. ¶52 col. 33:24-25
wherein the microprocessor uses system software to access the database to identify at least one optical aberration in the image file at any focal length of a zoom lens configuration The "Lens Compensation" software allegedly accesses the camera's internal database of lens data to identify aberrations for the specific focal length being used. ¶57, ¶59 col. 33:31-34
wherein the microprocessor accesses the database to obtain at least one filtration correction algorithm to the optical aberrations and forwards the at least one filtration algorithms to the digital signal processor The camera's processor allegedly uses the lens database to obtain the appropriate correction algorithm (e.g., for vignetting) and provides it to the image processing engine (DSP). ¶59 col. 33:35-39
wherein the image file is forwarded to the digital signal processor which applies at least one filtration algorithm to optimize the image The image data from the CMOS sensor is allegedly forwarded to the image processor (e.g., Venus Engine), which applies the selected correction algorithm. ¶53, ¶55, ¶60 col. 33:40-45
wherein the modified image file ... is stored in memory The corrected digital image is allegedly stored on a memory card in the camera. ¶58, ¶61 col. 33:49-53
  • Identified Points of Contention:
    • Scope Question: As with the '805 Patent, the scope of the term "database management system" will be a primary issue, as it is a limitation Panasonic explicitly denies is present in the accused products (Compl. ¶56).
    • Technical Question: Claim 14 requires the microprocessor to access the database to "obtain at least one filtration correction algorithm" and "forward" it to the DSP. A potential dispute is whether the accused system's application of pre-calculated correction values or parameters constitutes obtaining and forwarding a distinct "algorithm" as the claim may be construed to require, or if it is a more integrated, singular process.

V. Key Claim Terms for Construction

  • The Term: "database management system"
  • Context and Importance: This term appears in the independent claims of all four patents-in-suit. Its construction is critical because Panasonic's complaint for declaratory judgment is premised on the argument that its accused products lack this element (Compl. ¶50, ¶56, ¶62, ¶68). OIT alleges the cameras' storage and use of lens correction data satisfies this limitation (Compl., Ex. A, ¶29, ¶57). Practitioners may focus on this term because its definition could be dispositive of the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification refers to the "DB MS" (Database Management System) as a component that stores corrections for specific lens aberrations ('805 Patent, col. 10:45-50; Fig. 5). The patent does not define the term or require any specific software architecture (e.g., SQL), which may support a broader construction covering any organized system for storing and retrieving data, such as the firmware lookup tables allegedly used in the accused cameras.
    • Evidence for a Narrower Interpretation: The term "system" itself implies a combination of components working together. A defendant may argue that in the context of computer science, a "database management system" is a term of art referring to a more complex software suite for creating and managing databases, not merely a static data file or lookup table. The use of a distinct "DB MS" block (190) in Figure 1 of the patents could be argued to imply a discrete, substantial component beyond simple firmware.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Panasonic induces infringement by providing user manuals, videos, and other materials that instruct customers on how to use the accused "Lens Compensation" feature, thereby causing them to directly infringe the asserted method claims (Compl., Ex. A, ¶38, ¶64).
  • Willful Infringement: The complaint alleges willfulness based on both pre- and post-suit knowledge. Pre-suit knowledge is alleged to have occurred as early as December 17, 2014, when the '805 patent family was cited by a patent examiner during the prosecution of one of Panasonic's own Japanese patents (Compl., Ex. A, ¶42, ¶68). Post-suit knowledge is based on the filing of OIT's complaint in Texas.

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

  • A core issue will be one of definitional scope: can the term "database management system," a term of art in software engineering, be construed to cover the embedded firmware and associated data files that store and apply pre-set lens correction profiles in the accused cameras, or does the term require a more complex, interactive software architecture not present in the products?
  • A key evidentiary question will be one of functional specificity: can OIT demonstrate that the accused cameras' standard "Lens Compensation" feature performs the highly specific functions recited across all asserted independent claims, such as applying a "fast Fourier transform" for "special effects" ('805 Patent, Claim 1) or identifying and forwarding a distinct "algorithm" for correction ('339 Patent, Claim 1), or is there a technical mismatch between the general operation of the accused feature and the detailed requirements of the claims?
  • A procedural question regarding corporate identity will be foundational: has OIT, in its underlying Texas lawsuit, brought an action against the correct Panasonic corporate entity that is responsible for the design, manufacture, and sale of the accused LUMIX products in the United States, an issue Panasonic raises as a primary defect in the Texas litigation?