DCT

5:25-cv-00053

AIST Solutions Co v. TCL Industries Holdings Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:25-cv-00053, E.D. Tex., 04/21/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants conduct business in the district, have committed acts of infringement in the district, and are foreign entities organized under the laws of a foreign jurisdiction.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphone and tablet products infringe six U.S. patents related to mobile device positioning, video and image processing, wireless data configuration, and electronic camera functions.
  • Technical Context: The asserted patents cover a range of software and hardware functionalities common in modern consumer electronic devices, addressing issues of power management, image quality, and user interface efficiency.
  • Key Procedural History: The complaint alleges that Defendant has been aware of the asserted patents since at least November 8, 2024, following delivery of a notice letter that identified specific patents and accused products, which forms the basis for Plaintiff’s allegations of willful infringement.

A. Case Timeline

Date Event
2005-05-12 U.S. Patent No. 8,244,179 Priority Date
2008-07-02 U.S. Patent No. 9,008,996 Priority Date
2009-12-25 U.S. Patent No. 9,117,139 Priority Date
2010-01-07 U.S. Patent No. 8,400,521 Priority Date
2011-02-04 U.S. Patent No. 9,584,676 Priority Date
2012-02-13 U.S. Patent No. 9,179,090 Priority Date
2012-08-14 U.S. Patent No. 8,244,179 Issued
2013-03-19 U.S. Patent No. 8,400,521 Issued
2015-04-14 U.S. Patent No. 9,008,996 Issued
2015-08-25 U.S. Patent No. 9,117,139 Issued
2015-11-03 U.S. Patent No. 9,179,090 Issued
2017-02-28 U.S. Patent No. 9,584,676 Issued
2024-11-08 Defendant allegedly received notice letter
2025-04-21 Complaint Filing Date

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

A. U.S. Patent No. 9,008,996 - “Moving Body Positioning Device”, issued April 14, 2015 (’996 Patent)

1. The Invention Explained

  • Problem Addressed: Positioning systems that rely on integrating measurements over time, such as those using GPS or dead reckoning, can accumulate errors. When a device is stationary, repeated measurements of the same location can contain small offsets, and integrating these erroneous "movements" leads to positional drift, where the device's calculated position appears to move even though it is still (’996 Patent, col. 1:11-40).
  • The Patented Solution: The invention proposes a positioning apparatus that first detects whether the device is in a "moving" state or a "not moving" state. It then processes the incoming positioning data differently based on this state. For example, when the device is determined to be stationary, the system can select a single representative position value or present an "absence of an output" to avoid integrating erroneous positional offsets, thereby reducing cumulative error (’996 Patent, col. 2:42-57; Abstract).
  • Technical Importance: This approach improves the accuracy of portable navigation and tracking systems, particularly in urban environments or indoors where continuous, high-quality positioning signals may be unavailable, by preventing error accumulation during stationary periods (’996 Patent, col. 1:11-23).

2. Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶65).
  • Claim 1 recites a moving body positioning apparatus comprising:
    • A section for detecting or measuring movement, speed, or travel distance.
    • A position acquiring section for acquiring a plurality of positions.
    • A processor configured to integrally process the positioning results.
    • A processor configured to preprocess the positioning results, which distinguishes between a first state (moving) and a second state (not moving).
    • Wherein data processing is different in the first and second states.
    • Wherein in the second state, the pre-processing processor selects one previously received positioning result as a representative value when a determined travel distance is below a threshold.
  • The complaint does not explicitly reserve the right to assert dependent claims (Compl. ¶65).

B. U.S. Patent No. 9,117,139 - “Video Processing Apparatus and Video Processing Method”, issued August 25, 2015 (’139 Patent)

1. The Invention Explained

  • Problem Addressed: Automatic exposure controls in cameras can struggle to distinguish a "night scene" from other high-contrast situations, like a backlit subject. A simple histogram showing both very bright and very dark areas is ambiguous and can lead to incorrect exposure settings, such as washed-out colors for neon lights in a night scene (’139 Patent, col. 1:19-32).
  • The Patented Solution: The invention describes a video processing apparatus that uses a multi-factor test to more reliably identify a night scene. It comprises a "first determination unit" that analyzes the overall luminance distribution (e.g., via a histogram) and a "second determination unit" that analyzes a more specific condition, such as the ratio of very bright pixels within a defined partial area of the video frame. A scene is determined to be a "night scene" only if both conditions are met, allowing for more accurate scene detection than a histogram analysis alone (’139 Patent, Abstract; col. 2:23-40).
  • Technical Importance: This method enables more robust automatic scene detection in electronic cameras, leading to better-exposed images and videos in challenging, high-contrast lighting conditions like cityscapes at night (’139 Patent, col. 1:33-39).

2. Key Claims at a Glance

  • The complaint asserts at least independent claim 22 (Compl. ¶79).
  • Claim 22 recites a video processing apparatus comprising:
    • A first determination unit that determines if a luminance distribution satisfies a predetermined condition.
    • A first acquisition unit that acquires the number of pixels with a luminance value larger than a predetermined value within a partial area.
    • A second determination unit that determines if the ratio of pixels from the first acquisition unit to the total pixels is higher than a predetermined value.
    • A night scene determination unit that determines the scene is a night scene if the first determination unit's condition is satisfied and the second determination unit's ratio is higher than the predetermined value.
  • The complaint does not explicitly reserve the right to assert dependent claims (Compl. ¶79).

C. U.S. Patent No. 9,179,090 - “Moving Image Recording Device, Control Method Therefor, and Non-Transitory Computer Readable Storage Medium”, issued November 3, 2015 (’090 Patent)

  • Technology Synopsis: The patent addresses the creation of representative images (thumbnails) for video files. The invention determines a representative image based on a change in the state of a superimposed item (e.g., text or graphics added by the user). An image over which an item has been superimposed is automatically determined to be the representative image for the video (Compl. ¶¶87, 89).
  • Asserted Claims: At least independent claim 1 (Compl. ¶90).
  • Accused Features: The complaint alleges infringement by TCL devices that provide functionality for recording moving images and generating representative images based on user interactions, such as superimposing items on the video (Compl. ¶¶90, 92).

D. U.S. Patent No. 9,584,676 - “Information Processing Apparatus and Control Method Therefor”, issued February 28, 2017 (’676 Patent)

  • Technology Synopsis: The patent describes a method for improving the precision of a travel route map (locus). The system receives log data (e.g., from a GPS) and separate image data that is associated with position and time (e.g., a geotagged photo). It corrects the initial locus created from only the log data by incorporating the position data from the image data, resulting in a more precise displayed route (Compl. ¶¶98, 100).
  • Asserted Claims: At least independent claim 8 (Compl. ¶101).
  • Accused Features: The accused features are functionalities in TCL devices that create and display travel routes and incorporate location data from images to refine or correct those routes (Compl. ¶¶101, 103).

E. U.S. Patent No. 8,244,179 - “Wireless Inter-Device Data Processing Configured Through Inter-Device Transmitted Data”, issued August 14, 2012 (’179 Patent)

  • Technology Synopsis: This patent discloses an apparatus for simplifying the setup of a wireless connection. It uses a secondary, short-range communication channel, such as Radio-Frequency Identification (RFID), to exchange "device-descriptive data." This data is then used by a processor to automatically configure and establish a primary, higher-bandwidth wireless communication channel (e.g., Bluetooth or Wi-Fi) between the devices (’179 Patent, Abstract).
  • Asserted Claims: At least independent claim 49 (Compl. ¶112).
  • Accused Features: The complaint targets features in TCL devices, such as Near Field Communication (NFC), that allow users to initiate a wireless connection (e.g., Bluetooth pairing) by tapping two devices together, which allegedly uses an RFID or similar transceiver to exchange configuration data (Compl. ¶¶112, 114).

F. U.S. Patent No. 8,400,521 - “Electronic Camera”, issued March 19, 2013 (’521 Patent)

  • Technology Synopsis: The patent describes an electronic camera that performs an advanced image processing sequence. It includes an "extractor" to identify a specific reference image within a scene, an "adjuster" to modify exposure by emphasizing that area, an "identifier" to determine the color of an object in that area, and a "corrector" to adjust the image's overall tonality based on the identified color. This allows for more targeted and accurate exposure and color correction (’521 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶123).
  • Accused Features: The accused features are the camera systems in TCL devices, which allegedly perform complex, object-aware exposure and tonality correction processes that satisfy the elements of the claims (Compl. ¶¶123, 125).

III. The Accused Instrumentality

A. Product Identification

  • The accused products include a wide range of TCL-branded smartphones and tablets, such as the TCL 50 XL 5G, TCL 40 X 5G, TCL 30 V 5G, TAB Pro 5G, and NXTPAPER 11 (Compl. ¶25, fn. 1).

B. Functionality and Market Context

  • The complaint alleges that these devices incorporate telecommunications technology that provides positioning services, video and image capture and processing, and wireless data transfer capabilities (Compl. ¶¶65, 79, 90, 101, 112, 123). The complaint notes that TCL ranked fourth in smartphone shipments and third in tablet shipments in the United States, positioning the Accused Products as significant in the consumer electronics market (Compl. ¶31). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references but does not attach exhibits containing detailed infringement claim charts. The following summarizes the narrative infringement theories for the lead patents.

A. ’996 Patent Infringement Allegations

  • The complaint alleges that the Accused Products contain a "moving body positioning apparatus" that infringes at least claim 1 (Compl. ¶¶64-65). The infringement theory suggests that the devices' hardware (e.g., GPS, accelerometers) and software can detect whether the device is moving or stationary (Compl. ¶68). Based on this state detection, the devices allegedly alter how they process location data to improve accuracy, such as by filtering or selecting specific data points when the device is stationary, thereby meeting the claim limitations (Compl. ¶68).
  • Identified Points of Contention: A central question may be one of claim scope and structure. The analysis may focus on whether the Accused Products have distinct "sections" and "processors" for performing the claimed detecting, acquiring, preprocessing, and integral processing functions, or if these functions are performed by a single, multi-purpose processor in a way that does not map onto the claim's structure. Further contention may arise over what constitutes a "different" data processing of the positioning results between the moving and stationary states.

B. ’139 Patent Infringement Allegations

  • The complaint alleges that the Accused Products contain a "video processing apparatus," such as the camera system, that infringes at least claim 22 (Compl. ¶¶78-79). The theory posits that when a user captures video, the device's software employs a multi-step process to identify night scenes (Compl. ¶81). This allegedly includes a "first determination unit" analyzing overall luminance distribution and a "second determination unit" analyzing the ratio of bright pixels in a specific area, with the final "night scene determination" being made only when both criteria are met (Compl. ¶78).
  • Identified Points of Contention: The dispute may turn on the specific operation of TCL's camera software. A key technical question will be whether the software's scene-detection algorithm can be mapped to the distinct "first," "second," and "night scene" determination units required by the claim. The definition of "partial area" and the specific calculations for determining if a luminance distribution "satisfies a predetermined condition" could also be points of significant technical and legal dispute.

V. Key Claim Terms for Construction

A. For the ’996 Patent

  • The Term: "a processor configured to preprocess" and "a processor configured to integrally process" (Claim 1).
  • Context and Importance: Claim 1 recites two distinct processors, one for preprocessing and one for integral processing. The validity and infringement analyses will depend on whether this language requires two physically separate processors or if it can be satisfied by a single processor executing two different software routines or operating in two different modes. Practitioners may focus on whether the specification provides antecedent basis for treating these as functionally, rather than necessarily structurally, distinct components.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language uses "a processor," which is typically construed as "one or more processors." This may support an interpretation where a single physical processor running different software modules could satisfy both limitations.
    • Evidence for a Narrower Interpretation: The patent repeatedly lists the two processors as separate elements in the claim structure (’996 Patent, col. 13:21-28). The detailed description may describe embodiments with distinct hardware or software modules for each function, which could support an argument that the claim requires more than just a general-purpose CPU performing all tasks.

B. For the ’139 Patent

  • The Term: "night scene determination unit" (Claim 22).
  • Context and Importance: This term is central to the claim, as it performs the final logic step. Its construction will determine the scope of the claimed invention. Practitioners may focus on this term because the infringement analysis will depend on whether TCL's general-purpose camera software performs the specific two-part logical AND operation (first unit's condition is met AND second unit's ratio is higher) required to be a "night scene determination unit."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "unit" is a functional term that does not necessarily require a specific hardware structure and can often be met by a software module performing the recited function.
    • Evidence for a Narrower Interpretation: The claim explicitly defines the logic of this unit: it "determines that a scene... is a night scene if said first determination unit determines that the predetermined condition is satisfied and if said second determination unit determines that the ratio is higher" (’139 Patent, col. 16:13-17). This explicit "if... and if" language suggests a narrow functional definition requiring a specific logical combination of two prior determinations, not just any method of identifying a night scene.

VI. Other Allegations

A. Indirect Infringement

  • The complaint alleges induced infringement for all asserted patents, stating that TCL provides instruction materials, advertising, and distributes the Accused Products, thereby encouraging and aiding end users to perform the infringing acts (Compl. ¶¶69, 82, 93, 104, 115, 126).

B. Willful Infringement

  • Willfulness is alleged for all asserted patents based on pre-suit knowledge. The complaint asserts that TCL has been aware of the patents and its alleged infringement since at least November 8, 2024, upon receiving a notice letter, and that its continued infringing activity despite this knowledge is willful (Compl. ¶¶71-73, 83-84, 94-95, 106, 117, 127-128).

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

  • A central issue will be one of technological correspondence: can patent claims drafted for technologies from the 2005-2012 era, such as the claim for an "RFID transceiver" in the ’179 Patent, be construed to cover the technically distinct, albeit functionally similar, NFC systems implemented in modern smartphones? This will require a detailed analysis of both the patent's intrinsic evidence and the specific operation of the accused technology.
  • A key evidentiary question will be one of algorithmic specificity: for software-centric patents like the ’139 (video processing) and ’996 (positioning logic), can the Plaintiff produce sufficient evidence, likely through source code review, to demonstrate that the accused devices' complex, multi-purpose algorithms perform the specific, multi-step logical operations recited in the claims, or will there be a fundamental mismatch in their technical operation?
  • A third core issue will be one of structural mapping: for apparatus claims reciting multiple distinct functional "units" or "processors" (e.g., ’996 and ’139 Patents), the case may turn on whether these claim limitations require distinct software modules or hardware components in the accused devices, or if they can be met by a single, integrated processor executing different functions, raising fundamental questions of claim construction and infringement analysis for modern, highly integrated systems.