DCT

6:22-cv-00082

Cedar Lane Tech Inc v. SensoPart Industriesensorik GmbH

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:22-cv-00082, W.D. Tex., 01/21/2022
  • Venue Allegations: Venue is alleged to be proper because the defendant is a foreign corporation and has allegedly committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s industrial vision sensor products infringe patents related to an on-chip interface for transferring data from an imaging array to a processor system.
  • Technical Context: The technology concerns methods and systems for efficiently managing the flow of data from a CMOS image sensor to a host processor, a fundamental challenge in digital imaging systems.
  • 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, indicating a shared specification and a direct lineage between the asserted patents.

Case Timeline

Date Event
2000-01-21 Priority Date for ’790 and ’242 Patents
2000-12-21 ’790 Patent Application Filing Date
2005-10-27 ’242 Patent Application Filing Date
2005-12-06 ’790 Patent Issue Date
2013-09-17 ’242 Patent Issue Date
2022-01-21 Complaint Filing Date

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 describes an incompatibility between the "video style" synchronous data stream produced by CMOS image sensors and the random-access data interface of commercial microprocessors. This mismatch requires additional "glue logic," which increases cost and complexity, thereby diminishing the advantages of integrating sensors and processing elements on a single chip (ʼ790 Patent, col. 1:38-54).
    • The Patented Solution: The invention proposes an on-chip interface that bridges this gap. It features a memory, such as a FIFO buffer, that stores data from the imaging array at the sensor's clock rate. A signal generator monitors the amount of data in the memory and, upon reaching a certain level, sends a signal (e.g., an interrupt) to the host processor. A control circuit then allows the processor to read the buffered data at its own rate, as if accessing standard memory, eliminating the need for external interface circuitry (ʼ790 Patent, Abstract; col. 3:9-21; Fig. 2).
    • Technical Importance: This architecture facilitates the creation of more highly integrated and cost-effective "system-on-a-chip" imaging devices by combining the sensor, interface, and processing elements on a single CMOS substrate (ʼ790 Patent, col. 1:25-31).
  • Key Claims at a Glance:
    • The complaint does not identify specific asserted claims in its body, instead incorporating them by reference in an exhibit not attached to the filed complaint (Compl. ¶12). Assuming assertion of the primary independent claim, the elements are:
    • Claim 1: An interface for receiving data from an image sensor and transferring it 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 alleges infringement of "one or more claims," reserving the right to assert others (Compl. ¶12).

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

  • The Invention Explained:
    • Problem Addressed: As a divisional of the '790 patent application, this patent addresses the same technical problem of incompatibility between image sensor data output and microprocessor data input (ʼ242 Patent, col. 1:42-53).
    • The Patented Solution: The '242 patent claims a method for processing imaging signals that embodies the functionality of the '790 patent's apparatus. The claimed method involves steps of receiving and storing image data in a FIFO memory, using a counter to track the amount of stored data, comparing that count to a defined limit, and generating an interrupt signal to a processor to initiate data transfer when the limit is reached ('242 Patent, Abstract; col. 2:1-14).
    • Technical Importance: The method claims provide a different scope of protection for the same core inventive concept of decoupling the sensor's timing from the processor's timing via an intelligent on-chip buffer ('242 Patent, col. 1:25-30).
  • Key Claims at a Glance:
    • The complaint incorporates asserted claims by reference in a missing exhibit (Compl. ¶21). Assuming assertion of the first independent method claim, the elements are:
    • Claim 1: A method of processing imaging signals, comprising the steps of:
      • receiving image data from an imaging array;
      • storing the image data in a FIFO memory;
      • updating a FIFO counter to maintain a count of the image data in response to memory reads and writes;
      • comparing the count of the FIFO counter with a FIFO limit;
      • generating an interrupt signal to a processor in response to an interrupt enable signal being valid and the FIFO counter's count having a predetermined relationship to the FIFO limit; and
      • transferring image data from the FIFO memory to the processor in response to the interrupt signal.
    • The complaint alleges infringement of "one or more claims," reserving the right to pursue other claims (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" but does not name or describe them in the body of the document (Compl. ¶12, ¶21). It states that these products are identified in claim charts attached as Exhibits 3 and 4, which were not included with the publicly filed complaint.

Functionality and Market Context

The complaint does not provide any description of the accused products' specific technical functionality, commercial importance, or market positioning. It alleges in a conclusory manner that the products "practice the technology claimed" by the patents-in-suit (Compl. ¶17, ¶26).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim charts in Exhibits 3 and 4, which are not available for analysis (Compl. ¶18, ¶27). The narrative theory is summarized below.

The complaint alleges that the Defendant's "Exemplary Defendant Products" directly infringe the '790 and '242 patents because they are made, used, sold, or imported in the United States and allegedly contain all the elements of at least one claim of each patent (Compl. ¶12, ¶21). The infringement allegations are conclusory, stating that the accused products "satisfy all elements" of the asserted claims without providing specific factual support in the body of the complaint (Compl. ¶17, ¶26).

  • Identified Points of Contention:
    • Technical Questions: A primary question will be evidentiary: what proof demonstrates that the accused products contain the specific architecture claimed in the '790 patent, including a memory, a dedicated signal generator, and control circuitry that operate interdependently as claimed? For the '242 patent, what evidence shows that the accused products necessarily perform all the steps of the claimed data-handling method, particularly the step of comparing a data count to a limit to trigger a processor request?
    • Scope Questions: The infringement analysis may turn on the scope of the phrase "in response to the quantity of data in the memory" ('790 Patent, Claim 1). The question for the court will be whether this requires a direct causal link, such as comparing a buffer fill level to a threshold, or if a more indirect or system-level notification related to data availability falls within the claim's scope.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a definitive analysis, but based on the patent language, the following term is likely to be central to the dispute.

  • The Term: "in response to the quantity of data in the memory" ('790 Patent, Claim 1)
  • Context and Importance: This phrase defines the core causal relationship of the invention: the data buffer's fill level triggers the communication with the host processor. The construction of this term will be critical for determining infringement, as it establishes the required link between the memory state and the signal generation. Practitioners may focus on this term because it distinguishes the claimed invention from a system where data is simply placed in a buffer and read by a processor on a fixed schedule, irrespective of the buffer's status.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's summary describes the invention in general terms, stating that "In response to the quantity of data in the memory, a signal generator generates a signal for transmission to the processor system," without mandating a specific mechanism (ʼ790 Patent, col. 2:8-10). This language could support a construction that covers any system where the signal is logically related to data being present in the memory.
    • Evidence for a Narrower Interpretation: The detailed description discloses a specific embodiment where an interrupt generator (48) "compares the FIFO counter output Sc and the FIFO limit SL" and asserts the signal only if the count is greater than or equal to the limit ('790 Patent, col. 6:11-14). A defendant may argue this disclosure limits the claim scope to systems implementing this specific comparison logic.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for both patents. The factual basis is the allegation that Defendant provides "product literature and website materials" that instruct customers on how to use the accused products in an infringing manner (Compl. ¶15, ¶24). Knowledge is alleged to exist "[a]t least since being served by this Complaint" (Compl. ¶16, ¶25).
  • Willful Infringement: Willfulness is alleged based on knowledge obtained through service of the complaint and its attached (but missing) claim charts (Compl. ¶14, ¶23). The complaint alleges that despite this actual knowledge, Defendant continues its infringing activities, forming the basis for a claim of post-filing willful infringement (Compl. ¶15, ¶24).

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

  1. An Evidentiary Question: As the complaint lacks any specific factual allegations about the accused products' operation and relies entirely on non-public exhibits, a central issue will be whether Plaintiff can produce sufficient evidence to show that the accused industrial sensors actually implement the specific data-buffering, counting, and signaling architecture required by the patent claims.
  2. A Question of Causal Scope: The case will likely hinge on the construction of the key causal limitation: "in response to the quantity of data in the memory." A core dispute will be whether this phrase requires proof of the specific "counter-compare-interrupt" mechanism detailed in the patent's embodiments, or if it can be read more broadly to cover any system where a processor is notified of data availability in a buffer, raising a fundamental question about the boundary between the claimed invention and conventional data handling.