Compact Lens Tech LLC v. Huawei Device Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Compact Lens Technologies LLC (Texas)
  • Defendant: Huawei Device Co., Ltd. (China); Huawei Device (Dongguan) Co., Ltd. (China); Huawei Device USA Inc. (Texas)
  • Plaintiff’s Counsel: Nelson Bumgardner PC
• Case Identification: 6:18-cv-00043, E.D. Tex., 01/31/2018
• Venue Allegations: Venue is alleged based on Defendants’ commission of infringing acts, transaction of business, and maintenance of regular and established places of business within the district. Defendant Huawei Device USA Inc. is alleged to reside in the district.
• Core Dispute: Plaintiff alleges that the camera lens modules in certain of Defendant’s smartphones and tablets infringe a patent related to the design and arrangement of a compact, four-element photographic lens.
• Technical Context: The technology at issue involves compact, multi-element lens systems designed to provide high-quality imaging in small-footprint digital cameras, such as those integrated into mobile phones.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history relevant to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 7,321,474 - “Photographic lens,” issued Jan. 22, 2008

The Invention Explained

• Problem Addressed: The patent addresses the challenge of creating small, lightweight, and low-cost photographic lenses for high-resolution cameras in devices like mobile phones. Conventional designs at the time allegedly had limitations in providing high-quality imaging for objects at both near and far distances while maintaining a compact size and a relatively long back focal length suitable for auto-focusing mechanisms (’474 Patent, col. 1:19-52).
• The Patented Solution: The invention proposes a four-element photographic lens system arranged in a specific order from the object being photographed. The system comprises a first lens with positive refractive power, a second with primarily negative power, a third with positive power, and a fourth with negative power. The unique optical properties of the second and/or fourth lenses—specifically, how their refractive power changes from the center to the edge—are described as key to achieving the desired compact size and high performance (’474 Patent, col. 1:54-col. 2:14; Fig. 1).
• Technical Importance: This lens configuration is presented as a way to enable compact camera modules that can maintain high image quality across a range of focal distances, a critical feature for effective auto-focusing in the increasingly high-pixel cameras of consumer electronics (’474 Patent, col. 1:54-62).

Key Claims at a Glance

• The complaint asserts independent claim 12 and dependent claims 13, 19, 20, and 21 (Compl. ¶17).
• Independent Claim 12 recites the following essential elements:
  • A photographic lens comprising:
  • a first lens having positive refractive power;
  • a second lens having negative refractive power at a center portion, in which the negative refractive power becomes weaker from the center portion toward the peripheral portion of the second lens, and having a positive refractive power at the peripheral portion thereof;
  • a third lens having positive refractive power; and
  • a fourth lens having negative refractive power,
  • wherein the lenses are numbered in order of location from the object.
• The complaint reserves the right to assert additional claims.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are smartphones and tablets incorporating a specific lens module, including but not to the Huawei Elate smartphone and the Huawei Honor 6X smartphone (collectively, "the Huawei Accused Devices") (Compl. ¶17).

Functionality and Market Context

The complaint alleges that each accused device incorporates a camera with a lens module (a photographic lens) comprising four individual lenses (Compl. ¶18). The core of the infringement allegation is that this four-lens assembly has the specific physical and optical characteristics claimed in the ’474 patent. The complaint provides visual evidence in the form of annotated cross-section photographs of the lens modules from the Huawei Elate and Huawei Honor 6X, which purport to show four distinct lens elements labeled I, II, III, and IV (Compl. p. 5, Figs. 1-2). The complaint does not contain specific allegations regarding the products' market positioning beyond their identification as smartphones.

IV. Analysis of Infringement Allegations

’474 Patent Infringement Allegations

Identified Points of Contention

• Technical Questions: A primary technical question will be whether the accused lenses, particularly the second lens, actually exhibit the specific refractive power profiles required by the claims. The complaint asserts this in a conclusory manner, but the provided photographs show only the physical shape of the lenses and do not include optical measurement data. The litigation will likely require expert analysis and testing to determine if the accused second lens has negative refractive power at its center that "becomes weaker" toward the periphery and is positive at the periphery itself, as claimed.

V. Key Claim Terms for Construction

The Term: "negative refractive power becomes weaker from the center portion toward the peripheral portion"

Context and Importance: This phrase describes a highly specific optical gradient that is a core technical feature of the claimed second lens. The entire infringement analysis for this critical element depends on how this term is defined. Practitioners may focus on this term because its construction will determine what type of evidence is needed to prove or disprove infringement of this limitation.

Intrinsic Evidence for Interpretation:

• Evidence for a Broader Interpretation: The plain language of the claim and the summary of the invention recite that the power "becomes weaker" without imposing a specific mathematical rate of change or functional form (’474 Patent, col. 2:9-10). This could support an argument that any measurable decrease in negative refractive power from the center outwards meets the limitation.
• Evidence for a Narrower Interpretation: The patent’s detailed description includes specific embodiments with graphs (e.g., Fig. 13) and extensive numerical tables (e.g., Tables 7-8) that characterize a particular, smooth, continuous change in refractive power for the lenses. A party could argue that these embodiments limit the scope of "becomes weaker" to profiles with similar quantitative and qualitative characteristics, potentially excluding other types of power gradients.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendants had knowledge of the ’474 patent at least since the service of the complaint (Compl. ¶24-25). It further alleges that Defendants specifically intend to cause infringement by providing instructional materials, user guides, and marketing materials that "specifically cause, teach, and encourage" customers to use the camera feature of the accused devices, which results in the use of the allegedly infringing lens module (Compl. ¶27).

Willful Infringement

The complaint does not use the word "willful," but it alleges that Defendants have continued their allegedly infringing conduct despite having knowledge of the ’474 patent post-filing (Compl. ¶26). These allegations could form the basis for a claim of post-filing willfulness and a request for enhanced damages under 35 U.S.C. § 284.

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

• A central issue will be one of technical verification: what factual evidence will be presented to demonstrate that the accused Huawei lenses possess the specific, complex refractive power gradients required by claim 12? The outcome will likely depend on expert testimony and optical testing that goes beyond the physical representations provided in the complaint.
• The case may also turn on a key question of claim construction: how will the court define the phrase "becomes weaker" as it applies to the optical power of the second lens? Whether this term is given a broad, qualitative meaning or a narrower, quantitative definition constrained by the patent’s specific embodiments will be critical to determining the scope of the claim and, ultimately, the infringement outcome.