DCT
1:21-cv-01115
Radiant Vision Systems LLC v. Admesy BV
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Radiant Vision Systems, LLC (Delaware)
- Defendant: Admesy B.V. (Netherlands)
- Plaintiff’s Counsel: Perkins Coie LLP
- Case Identification: 1:21-cv-01115, W.D. Tex., 12/08/2021
- Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign corporation and has committed acts of infringement in the district, including selling the accused products to entities located in Austin, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s "Nova" imaging colorimeter infringes a patent related to an apparatus and method for selectively diverting light within an imaging device to a spectrometer for calibration purposes.
- Technical Context: The technology addresses the need for compact, accurate imaging colorimeters, which are used for quality control in the manufacturing of high-performance displays, by integrating spectrometer calibration optics into the existing mechanical structure of a camera.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement on October 4, 2019, including a claim chart detailing the alleged infringement. This allegation forms the basis for the claim of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2009-03-27 | U.S. Patent No. 8,482,652 Priority Date |
| 2013-07-09 | U.S. Patent No. 8,482,652 Issue Date |
| 2019-02-01 | Defendant allegedly exhibits accused product at U.S. tradeshow |
| 2019-10-04 | Plaintiff sends Defendant pre-suit notice letter of infringement |
| 2021-12-08 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,482,652 - Imaging Devices with Components for Reflecting Optical Data and Associated Methods of Use and Manufacture
The Invention Explained
- Problem Addressed: The patent’s background section describes the technical challenge of calibrating a digital camera’s image sensor against a more accurate spectrometer. Conventional solutions either block the main image sensor when sampling light for the spectrometer, or they use a beamsplitter which reduces the amount of light reaching both the image sensor and the spectrometer. (’652 Patent, col. 1:36-54). Furthermore, modern digital cameras have very limited internal space to add the necessary optical components for such a calibration system. (’652 Patent, col. 4:11-18).
- The Patented Solution: The invention integrates a movable reflector (e.g., a mirror) onto an existing component within the camera—the filter wheel. (’652 Patent, col. 4:50-53). A filter wheel is a rotating disk that holds different optical filters and positions them in the light path. By mounting the reflector in a space on this wheel, the existing rotation mechanism can be used to move the reflector into the optical path to divert light to a spectrometer input, and then move it out of the path to allow the camera’s main sensor to capture an image. This dual-use of the filter wheel mechanism allows for the integration of a spectrometer pickoff without requiring significant extra space or separate mechanisms. (’652 Patent, Abstract; Fig. 4).
- Technical Importance: This approach provided a space-efficient method for combining high-accuracy spectrometer measurements with standard imaging in a single, compact device, which is advantageous for production-line quality control of light-emitting products like displays. (’652 Patent, col. 3:40-49).
Key Claims at a Glance
- The complaint asserts infringement of one or more claims, focusing on independent device claim 1 and independent method claim 18 as non-limiting examples. (Compl. ¶¶ 26, 27, 32).
- Independent Claim 1 (device) requires:
- A lens to introduce light along an optical path.
- An image sensor to receive the light.
- A filter assembly positioned between the lens and sensor, comprising a filter wheel that rotates on an axis parallel to the optical path.
- A reflector carried by the filter assembly, which can be moved by the assembly into a first position (in the optical path, reflecting light to a different input) and a second position (outside the optical path).
- Independent Claim 18 (method) requires:
- Selectively moving a filter assembly to move a reflector between a first and second position, which includes rotating a filter wheel.
- Reflecting a portion of light when the reflector is in the optical path.
- Collecting the reflected light with an optical input.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is the Admesy "Nova" imaging colorimeter. (Compl. ¶2).
Functionality and Market Context
- The complaint alleges the Nova imaging colorimeter is an imaging device that contains two filter wheels positioned between its lens and imaging device. (Compl. ¶29).
- One of these filter wheels is allegedly used for a neutral density (ND) filter, while the other is used for "rotating an optical switch (mirror) in front of the imaging device." (Compl. ¶29).
- The complaint describes the mirror’s operation: in a first "on" position, it is aligned with the optical path to redirect light to a spot meter, and in a second "off" position, it is moved outside the optical path so the camera can capture an image. (Compl. ¶29).
- Plaintiff alleges the accused device is used in the manufacturing process for display screens for products that are imported and sold in the U.S., including for customers such as Apple. (Compl. ¶¶ 9, 32).
Visual Evidence
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’652 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a lens configured to introduce light into the imaging device along an optical path | The Nova imaging colorimeter is an imaging device with a lens that is used to introduce light along an optical path. | ¶29 | col. 2:62-63 |
| an image sensor spaced apart from the lens and configured to receive at least a portion of the light along the optical path | The Nova includes a 2D RGB imaging device spaced apart from the lens, which receives light along the optical path when the mirror is switched off. | ¶29 | col. 2:64-col. 3:1 |
| a filter assembly positioned between the lens and the image sensor, wherein the filter assembly comprises a filter wheel configured to rotate about a rotational axis that is generally parallel to the optical path | The Nova contains two filter wheels between the lens and imaging device; one wheel is for rotating an optical switch (mirror). | ¶29 | col. 4:45-49 |
| a reflector carried by the filter assembly, wherein the filter assembly is configured to move the reflector between first and second positions, and wherein in the first position the reflector...reflects...light toward an input different than the image sensor, and in the second position...outside of the optical path. | A filter wheel has an optical switch (mirror) mounted on it, which is moved to an "on" position to redirect light to a spot meter, or an "off" position where the mirror is positioned outside the optical path allowing the camera to take a snapshot. | ¶29 | col. 4:50-58 |
Identified Points of Contention
- Scope Questions: Claim 1 recites "a filter assembly comprises a filter wheel." The complaint alleges the accused product uses two filter wheels, with one dedicated to carrying the mirror. (Compl. ¶29). A dispute may arise over whether the claimed "filter assembly" can encompass a two-wheel configuration. The patent’s mention of "one or more filter wheels" may support a broader construction, but the focus of the detailed description on single-wheel embodiments could be used to argue for a narrower scope. (’652 Patent, col. 4:21-23).
- Technical Questions: The complaint asserts that one of the two filter wheels "has an optical switch (mirror) mounted on it." (Compl. ¶29). The infringement analysis will depend on the specific mechanical details of this arrangement. A key question for discovery will be whether the mirror is "carried by" the wheel in a manner analogous to the patent's teaching (e.g., occupying a slot typically reserved for a filter), or if it is part of a distinct, separate mechanism. (’652 Patent, col. 4:50-53).
V. Key Claim Terms for Construction
"filter assembly"
- Context and Importance: This term's construction is critical because the accused product is alleged to have two filter wheels, whereas many patent figures depict one. Whether a two-wheel system meets the "filter assembly" limitation will be a central point of contention.
- Intrinsic Evidence for a Broader Interpretation: The general term "assembly" implies a collection of components. The specification discloses that an imaging device can include "one or more filter wheels," which suggests that an "assembly" could comprise multiple wheels. (’652 Patent, col. 4:21-23, col. 6:12-16).
- Intrinsic Evidence for a Narrower Interpretation: A party could argue that the core inventive concept of saving space is achieved by placing the reflector on a filter wheel that also carries optical filters, as depicted in the primary embodiment. (’652 Patent, Fig. 4). An interpretation that limits the "filter assembly" to a single physical wheel carrying both filters and the reflector might be advanced to exclude the accused two-wheel design.
"reflector carried by the filter assembly"
- Context and Importance: This phrase defines the required physical relationship between the moving reflector and the rotating wheel. The infringement determination hinges on whether the accused mirror is "carried by" its filter wheel in the manner required by the claim.
- Intrinsic Evidence for a Broader Interpretation: The specification describes the reflector as "mounted on the filter wheel" and "carried by an existing mechanism," suggesting that "carried by" should be interpreted broadly to mean supported by and moving with the wheel. (’652 Patent, col. 4:50-53, col. 4:57-59).
- Intrinsic Evidence for a Narrower Interpretation: The patent also teaches placing the mirror "in the space typically reserved for a filter." (’652 Patent, col. 4:52-53). A defendant might argue that "carried by" should be narrowly construed to require this specific integration, potentially excluding other forms of attachment if the accused device's mirror is mounted differently.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement under 35 U.S.C. § 271(b). It asserts that Admesy encourages its customers to infringe method claim 18 by providing "user manuals, product documentation, advertising, marketing, and other materials" that instruct on the use of the infringing features of the Nova colorimeter. (Compl. ¶¶ 30-31).
Willful Infringement
The complaint alleges willful infringement based on pre-suit knowledge. Plaintiff claims it sent Admesy a letter on October 4, 2019, which included a claim chart and provided actual notice of infringement. (Compl. ¶¶ 21, 38). The allegation is that Admesy’s continued sales after this date constitute willful and egregious conduct. (Compl. ¶¶ 22, 38).
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of architectural scope: can the term "a filter assembly", which is described in key patent embodiments as a single component, be construed to read on the accused product’s alleged two-wheel architecture where the reflector and other filters are on separate wheels? The outcome will likely depend on how much weight is given to the specification’s brief mention of "one or more filter wheels" versus its detailed explanation of a single-wheel embodiment.
A key evidentiary question will be one of mechanical equivalence: does the accused product's "optical switch (mirror)" constitute a "reflector carried by the filter assembly" as claimed? Resolution will require detailed evidence from discovery on how the mirror is physically integrated with and moved by the rotating wheel, and whether that implementation aligns with the teachings of the patent.
Given the allegation of a pre-suit notice letter with a claim chart, a central question for damages will be objective recklessness: if infringement is found, did the Defendant act with a state of mind that rises to the level of willfulness, thereby exposing it to the possibility of enhanced damages under 35 U.S.C. § 284?