Vision Augmentation Technology LLC v. Sick AG

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Vision Augmentation Technology LLC (Texas)
  • Defendant: Sick AG (Germany), SICK, Inc. (Minnesota), and SICK Product & Competence Center Americas, LLC (Minnesota)
  • Plaintiff’s Counsel: BRADFORD BLACK P.C.
• Case Identification: 4:25-cv-05231, S.D. Tex., 11/02/2025
• Venue Allegations: Venue is alleged to be proper as to Sick AG because it is a foreign corporation. Venue is alleged to be proper as to the U.S. subsidiaries because they maintain a regular and established place of business in the district and have allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s Visionary-S line of 3D vision sensors infringes a patent related to stereoscopic systems for determining the three-dimensional position of objects.
• Technical Context: The technology involves using two spaced-apart image sensors to calculate an object's position in 3D space through triangulation, a technique foundational to machine vision, robotics, and automated manufacturing.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2004-08-10	’021 Patent Priority Date
2008-10-07	’021 Patent Issue Date
2025-07-22	Alleged date Defendant received notice of infringement
2025-10-10	Alleged continuation of infringement through this date
2025-11-02	Complaint Filing Date

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

U.S. Patent No. 7,433,021 - Stereoscopic Targeting, Tracking and Navigation Device, System and Method

• Patent Identification: U.S. Patent No. 7,433,021, “Stereoscopic Targeting, Tracking and Navigation Device, System and Method,” issued October 7, 2008.

The Invention Explained

• Problem Addressed: The patent’s background section identifies the need for an effective method to determine the origin of military attacks from small, fast-moving projectiles like mortars, which existing radar systems allegedly could not track effectively (’021 Patent, col. 1:16-30). The stated goal is to track such incoming ordnance and "reverse interpolate where these ordinance originated" (’021 Patent, col. 1:22-25).
• The Patented Solution: The invention proposes a system using at least two sensors, each with a two-dimensional array of pixels (’021 Patent, col. 1:57-59). The core concept, illustrated in Figure 1, is that the system stores "computerized data" that pre-associates every pixel on each sensor with a specific azimuth and elevation angle relative to that sensor (’021 Patent, col. 1:60-63). When a target is detected simultaneously by pixels on both sensors, the system uses the pre-associated angles from each sensor, along with the known distance between the sensors, to calculate the target's precise three-dimensional coordinates via triangulation (’021 Patent, col. 2:1-5).
• Technical Importance: This approach provides a method for real-time 3D position tracking of objects, which, at the time of the invention, was presented as a solution for pinpointing the origin of battlefield threats that were otherwise difficult to locate (’021 Patent, col. 1:31-37).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶43).
• The essential elements of Claim 1 are:
  • A sensor system comprising two sensors, each with a two-dimensional plurality of discrete detection pixels.
  • For each sensor, computerized data that associates each detection pixel with a predetermined azimuth and elevation angle.
  • A computerized device that automatically determines the azimuth and elevation angles of a target simultaneously detected by each sensor, based on the stored computerized data.
  • A requirement that more than one detection pixel on each sensor is capable of detecting a target at the same time.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The SICK Visionary-S 3D Vision Sensors (the "Accused Instrumentalities") (Compl. ¶36).

Functionality and Market Context

• The Accused Instrumentalities are described as stereoscopic camera systems used for industrial and factory automation tasks such as "Dimensioning of goods," "Bin-Picking," "Palletizing and depalletizing," and "Container positioning" (Compl. ¶37). The complaint includes a marketing image showing these industrial applications (Compl. ¶37, Figure at p. 8). Functionally, the products allegedly use "two synchronized imagers," each with a two-dimensional pixel array, to capture stereo image data (Compl. ¶38). The system is alleged to use "intrinsic camera parameters" to perform "a mapping from pixel indices ... into a metric coordinate system," which allows it to automatically determine the viewing direction (azimuth/elevation) to a target based on which pixel detects it and thereby generate "calibrated 3D outputs" (Compl. ¶¶38-40).

IV. Analysis of Infringement Allegations

’021 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
two sensors, each sensor comprising a two-dimensional plurality of discrete detection pixels;	The Visionary-S systems contain "two synchronized imagers" which are described as stereo cameras, each comprising a "two-dimensional array of pixels" with a resolution of 640 x 512 pixels.	¶¶38, 41	col. 7:41-43
for each said sensor, computerized data associating each said detection pixel thereof with a predetermined azimuth angle and a predetermined elevation angle;	The systems allegedly use "intrinsic camera parameters" that map pixel indices from the imager chip into a "metric coordinate system," which is used to determine the viewing direction to a target.	¶¶39, 40	col. 7:44-47
a computerized device for automatically determining azimuth angles and elevation angles of a target or beacon simultaneously detected by each of said sensors...based on said computerized data;	The Visionary-S systems allegedly capture synchronized images and, using stored parameters, "automatically determine[], for each sensor, the viewing direction to that target (i.e., azimuth/elevation) based on the pixel(s) that registered it."	¶40	col. 7:48-52
wherein...more than one of the detection pixels at the same time, is capable of detecting a target or beacon.	Each image exposure allegedly "involves multiple pixels detecting the scene concurrently," with the system capturing over "320,000 depth and color intensity values in a single recording."	¶41	col. 8:1-3

Identified Points of Contention

• Scope Questions: A central question may be whether the term "target or beacon," as used in the patent, can be construed to cover the static or moving industrial objects (e.g., boxes, machine parts) imaged by the accused systems. The patent's background is exclusively focused on tracking military ordnance, which may give rise to arguments about whether the claim scope is implicitly limited to that context.
• Technical Questions: The infringement theory relies on the accused product's "intrinsic camera parameters" and "mapping from pixel indices into a metric coordinate system" meeting the claim limitation of "computerized data associating each...pixel...with a predetermined azimuth angle and a predetermined elevation angle." A potential dispute is whether the accused system's method—which may involve real-time calculations or algorithmic transformations—is the same as the patent's disclosed method, which emphasizes a pre-calculated, stored association akin to a lookup table.

V. Key Claim Terms for Construction

The Term: "target or beacon"

• Context and Importance: The construction of this term appears critical. The patent’s specification exclusively discusses military projectiles as the "target," while the accused products are used in industrial automation. Practitioners may focus on this term because its scope could determine whether the patent applies outside the military context.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is not expressly limited to a military context, using the general terms "target or beacon" (’021 Patent, col. 7:50). The abstract also refers more broadly to identifying "precise locations of remote objects" (’021 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The "Background of the Invention" section frames the entire problem to be solved in terms of tracking "incoming ordnance, e.g., missiles and mortar" to determine the "origin of the attack" (’021 Patent, col. 1:16-25). A defendant may argue this context limits the scope of "target" to such objects.

The Term: "computerized data associating each said detection pixel thereof with a predetermined azimuth angle and a predetermined elevation angle"

• Context and Importance: This term defines the core mechanism of the invention. The dispute will likely center on what constitutes the required "associating" data structure. The complaint alleges that the accused product's "intrinsic parameters" which map pixel indices to a metric coordinate system satisfy this element.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language does not specify the form of the "computerized data," suggesting any data structure that functionally links a pixel to a direction could suffice.
  • Evidence for a Narrower Interpretation: The specification's preferred embodiment describes a system that "employs a table lookup for the azimuth and elevation angle for each sensor using indexed addressing," storing the pre-calculated angles in a "unique storage location" for each pixel (’021 Patent, col. 5:26-34). This could support an argument that the claim requires a direct, pre-stored data mapping rather than an algorithmic calculation.

VI. Other Allegations

Indirect Infringement

• The complaint alleges active inducement, asserting that since at least July 22, 2025, SICK had knowledge of the ’021 patent and intended to cause infringement by supplying the accused systems along with "user manuals, product support, training, and other instructions that encourage and direct customers...to operate the products in a way that meets the claim limitations" (Compl. ¶¶44, 46).

Willful Infringement

• The complaint alleges that SICK's infringement continued after receiving notice on July 22, 2025, and that this conduct constitutes "reckless disregard of VAT's patent rights" (Compl. ¶47).

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

• A core issue will be one of definitional scope: can the term "target or beacon," which is described in the patent's specification exclusively in the context of tracking military projectiles, be construed broadly enough to read on the industrial parts and packages imaged by the accused factory automation systems?
• A key technical question will be one of structural and functional correspondence: does the accused system's use of "intrinsic camera parameters" to perform a "mapping from pixel indices into a metric coordinate system" constitute the claimed "computerized data associating each said detection pixel...with a predetermined azimuth angle and a predetermined elevation angle," particularly in light of the patent's disclosure emphasizing a direct data lookup structure?