Cedar Lane Tech Inc v. Goepel Electronics LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Goepel Electronics L.L.C. (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 6:21-cv-01279, W.D. Tex., 12/09/2021
• Venue Allegations: Venue is alleged to be proper in the Western District of Texas because Defendant has an established place of business in the district and has committed alleged acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe three patents related to image sensor interfaces and methods for automatically adjusting illumination in machine-vision systems.
• Technical Context: The patents address two distinct areas: efficiently interfacing CMOS image sensors with computer processors, and dynamically optimizing lighting conditions for automated quality-control inspections.
• Key Procedural History: U.S. Patent No. **8,537,242** is a divisional of the application that resulted in U.S. Patent No. **6,972,790**, meaning they share a common specification and priority date; this relationship may have implications for claim construction and potential invalidity arguments such as double patenting.

Case Timeline

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

U.S. Patent No. 6,972,790 - “Host interface for imaging arrays” (Issued Dec. 6, 2005)

The Invention Explained

• Problem Addressed: The patent’s background section states that the continuous, video-style data stream from conventional CMOS image sensors is incompatible with the data interface of commercial microprocessors, requiring extra "glue logic" that diminishes the cost-effectiveness and integration benefits of CMOS technology (’790 Patent, col. 1:47-60).
• The Patented Solution: The invention proposes an integrated interface that decouples the image sensor from the processor system. It uses a memory, such as a First-In-First-Out (FIFO) buffer, to store image data as it arrives from the sensor at a high, fixed rate. The interface then signals the processor (e.g., via an interrupt) when a certain amount of data is ready, and a control circuit manages the transfer of this data to the processor system at a rate determined by the processor, not the sensor (’790 Patent, Abstract; col. 4:11-21).
• Technical Importance: This architecture provided a method for efficiently integrating an image sensor and a general-purpose processor on a single die, a key step toward developing more compact and powerful system-on-a-chip (SoC) imaging devices (’790 Patent, col. 1:26-31).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" but does not specify which, instead incorporating by reference claim charts from an exhibit not provided with the complaint (Compl. ¶13, ¶18). Independent claim 1 is a representative system claim.
• Independent Claim 1: An interface for transferring data from an image sensor to a processor system, comprising:
  • a memory for storing imaging array data and clocking signals at a rate determined by the clocking signals;
  • a signal generator for generating a signal for transmission to the processor system in response to the quantity of data in the memory; and
  • a circuit for controlling the transfer of the data from the memory at a rate determined by the processor system.
• The complaint reserves the right to assert infringement of other claims, which may include dependent claims (Compl. ¶13).

U.S. Patent No. 7,557,920 - “Method and apparatus for auto-adjusting illumination” (Issued Jul. 7, 2009)

The Invention Explained

• Problem Addressed: Conventional machine-vision systems lack a convenient way to electronically vary the angle and mode of illumination. This requires time-consuming and inconsistent manual adjustments to optimize lighting for detecting different types of defects (e.g., scratches versus surface irregularities) (’920 Patent, col. 2:35-55).
• The Patented Solution: The patent describes a method and system for automatically optimizing illumination. The system sets initial lighting parameters, illuminates an object, and captures an image. An image processor then analyzes a region of interest to generate a "quality parameter." This process is iterated—the system changes the illumination parameters and captures new images—until an acceptable or optimal image quality is achieved, without physical modification of the hardware (’920 Patent, Abstract; Fig. 5).
• Technical Importance: Automating the illumination process allows for faster, more consistent, and more accurate machine-vision inspection across a variety of parts and potential defects, improving manufacturing quality control and throughput (’920 Patent, col. 2:15-24).

Key Claims at a Glance

• The complaint does not specify asserted claims, incorporating them by reference to an exhibit not included with the complaint (Compl. ¶22, ¶24). Independent claim 1 is a representative method claim.
• Independent Claim 1: A computerized machine-vision method for inspecting an object, comprising:
  • illuminating the object based on a first set of obtained illumination parameters and obtaining a first image;
  • image processing a region of interest in the first image;
  • illuminating the object based on a different set of obtained illumination parameters and obtaining an additional image;
  • image processing a region of interest in the additional image; and
  • making a determination of a characteristic of the object based on at least one of the images.
• The complaint reserves the right to assert infringement of other claims, which may include dependent claims (Compl. ¶22).

U.S. Patent No. 8,537,242 - “Host interface for imaging arrays” (Issued Sep. 17, 2013)

Technology Synopsis

As a divisional of the '790 Patent's application, this patent claims a similar integrated interface for linking an imaging array with a processor system. The invention uses a memory buffer to manage differing data rates between the sensor and processor. It particularly details an architecture where the interface can request and gain control of the system bus via a bus arbitration unit, allowing it to transfer image data directly to system memory without requiring continuous management by the central processor (’242 Patent, Abstract; col. 2:9-17).

Asserted Claims

The complaint does not identify specific claims, incorporating them by reference from an exhibit not provided with the complaint (Compl. ¶28, ¶33).

Accused Features

The complaint alleges infringement by Defendant's "Exemplary Defendant Products" but provides no specific product names or descriptions of the accused features, incorporating these details by reference to an exhibit not provided with the complaint (Compl. ¶28).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products or services. It refers generally to "Exemplary Defendant Products" that are identified in claim chart exhibits (Exhibits 4, 5, and 6), which were not filed with the complaint document (Compl. ¶13, ¶22, ¶28).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused instrumentalities. It alleges that the products "practice the technology claimed" but includes no technical descriptions, incorporating all such details by reference to the unattached exhibits (Compl. ¶18, ¶24, ¶33).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

’790 Patent Infringement Allegations

The complaint’s infringement theory is incorporated by reference from an external exhibit (Compl. ¶19). The table below outlines the elements of representative independent claim 1 and notes the absence of specific factual allegations in the complaint document itself.

• Identified Points of Contention:
  • Technical Questions: A primary question will be evidentiary: what proof demonstrates that the accused products implement the specific three-part architecture of Claim 1? The dispute may focus on whether the accused products truly use a "signal generator" responsive to the "quantity of data in the memory" to initiate a transfer, or if they employ a different data management scheme.
  • Scope Questions: The interpretation of "a rate determined by the processor system" may be contested. This raises the question of whether this requires a direct, processor-managed read operation following an interrupt, or if it could also read on a more autonomous Direct Memory Access (DMA) transfer that is merely configured by the processor.

’920 Patent Infringement Allegations

The complaint’s infringement theory is incorporated by reference from an external exhibit (Compl. ¶25). The table below outlines the elements of representative independent claim 1.

• Identified Points of Contention:
  • Technical Questions: The central technical question is whether the accused products perform the claimed iterative, feedback-driven process. What evidence shows that they change illumination parameters based on the results of "image processing," as opposed to simply offering a menu of user-selectable, static lighting options?
  • Scope Questions: The scope of "image processing a region of interest" will be critical. Does this limitation require a sophisticated analysis of image "quality" to guide the next iteration, as suggested by the specification's focus on defect detection (’920 Patent, col. 10:45-49), or could it be met by a simple brightness or contrast measurement?

V. Key Claim Terms for Construction

For the ’790 Patent (and related ’242 Patent)

• The Term: "a circuit for controlling the transfer of the data ... at a rate determined by the processor system" (from Claim 1 of '790 Patent)
• Context and Importance: This limitation defines the core functional relationship between the interface and the processor. Practitioners may focus on this term because its construction will determine whether the claim reads on systems with varying degrees of processor involvement, from direct, hands-on data management to more supervisory roles in DMA-based architectures.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the control circuit as potentially including a command decoder that receives signals from the processor system (’790 Patent, col. 2:17-20). This could support a construction covering any data transfer initiated or configured by the processor.
  • Evidence for a Narrower Interpretation: The description of the interrupt-based embodiment suggests a specific sequence where the interface signals the CPU, which then "responds by having the data downloaded" (’790 Patent, col. 6:29-32). This could support a narrower reading that requires an active, responsive role for the processor in the data transfer itself, rather than just pre-configuring it.

For the ’920 Patent

• The Term: "image processing a region of interest" (from Claim 1 of '920 Patent)
• Context and Importance: This term is the foundation of the claimed feedback loop. Practitioners may focus on this term because the infringement analysis will depend on whether the accused products perform mere measurement or the kind of analytical "processing" necessary to drive an optimization loop.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is general and does not explicitly require a specific type or outcome of the processing. One could argue that any automated analysis of pixel data within a designated area meets the plain meaning of the term.
  • Evidence for a Narrower Interpretation: The specification repeatedly frames the invention in the context of quality control and improving image clarity for inspection (’920 Patent, col. 2:15-24). The flowchart embodiment shows this step as "determine image quality" and "compare quality vs. standard" (’920 Patent, Fig. 5, blocks 540, 550), which suggests the "processing" must be substantive enough to generate a metric for optimization, not just a raw data reading.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement of the ’790 and ’242 patents, asserting that Defendant provides "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶16-17, ¶31-32). The complaint does not allege indirect infringement of the ’920 patent.

Willful Infringement

The complaint alleges that service of the complaint itself provides Defendant with "actual knowledge of infringement" for all three patents-in-suit. It further alleges that despite this knowledge, Defendant continues to infringe, forming a basis for post-suit willful infringement (Compl. ¶15-16, ¶30-31). The prayer for relief requests that the case be declared exceptional (Compl. ¶J.i).

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

1. Evidentiary Sufficiency: The case's immediate and most significant challenge is one of evidentiary sufficiency. The complaint's reliance on unattached exhibits for all critical details—from identifying the accused products to explaining how they allegedly function—raises the question of whether the Plaintiff can produce discovery evidence to substantiate its bare allegations and show that the accused products actually practice the specific technologies of the asserted patents.

2. Functional Operation: A core technical issue will be one of functional operation. For the '790 and '242 patents, does the accused interface merely buffer data, or does it implement the claimed control architecture that decouples sensor and processor timing via a signaling mechanism? For the '920 patent, does the accused system perform a true closed-loop, iterative optimization based on analyzing image quality, or does it simply provide a static set of user-selectable lighting modes, which may not meet the "image processing" and "illuminating ... based on a different set" limitations?