DCT

6:22-cv-00699

Cedar Lane Tech Inc v. Hitron Systems Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:22-cv-00699, W.D. Tex., 06/29/2022
  • Venue Allegations: Venue is asserted on the basis that the defendant is a foreign corporation, and further that the defendant has committed acts of patent infringement in the district, causing harm to the plaintiff there.
  • Core Dispute: Plaintiff alleges that Defendant’s unnamed products, which relate to image processing, infringe three patents concerning methods for interfacing image sensors and processing components.
  • Technical Context: The patents address methods for managing the flow of digital image data between components, such as from an analog-to-digital converter or an image sensor to a compression chip or a host processor.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or specific licensing history related to the patents-in-suit.

Case Timeline

Date Event
1999-06-01 Priority Date for U.S. Patent No. 6,473,527
2000-01-21 Priority Date for U.S. Patent Nos. 6,972,790 and 8,537,242
2002-10-29 U.S. Patent No. 6,473,527 Issued
2005-12-06 U.S. Patent No. 6,972,790 Issued
2013-09-17 U.S. Patent No. 8,537,242 Issued
2022-06-29 Complaint Filed

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

U.S. Patent No. 6,473,527 - "Module and method for interfacing analog/digital converting means and JPEG compression means," issued October 29, 2002

The Invention Explained

  • Problem Addressed: The patent describes that conventional systems for JPEG image compression required an extra, costly RAM buffer to reformat image data received line-by-line from an analog-to-digital converter into the 8x8 pixel block format required by a standard JPEG compression integrated circuit (’527 Patent, col. 1:36-58).
  • The Patented Solution: The invention proposes an interface module situated between the converter and the compression device. This module includes its own memory, which reads and stores a predetermined number of image lines (e.g., eight lines). Once enough lines are stored, the module's output control logic sequentially reads out image data in 8x8 pixel blocks, a format that can be directly accepted and processed by the JPEG compression device, thereby eliminating the need for the separate, external RAM buffer (’527 Patent, col. 2:2-24; Fig. 2).
  • Technical Importance: This design sought to reduce the component count, cost, and complexity of digital imaging devices like scanners by streamlining the data pathway to the compression hardware (’527 Patent, col. 1:55-58).

Key Claims at a Glance

  • The complaint does not identify the specific independent or dependent claims of the ’527 Patent that are asserted, instead referring to "one or more claims" and incorporating by reference an external exhibit not provided with the complaint (Compl. ¶¶ 13, 15-16).

U.S. Patent No. 6,972,790 - "Host interface for imaging arrays," issued December 6, 2005

The Invention Explained

  • Problem Addressed: The patent notes that the continuous, synchronized "video style output" from a CMOS image sensor is fundamentally incompatible with the data interface of a typical microprocessor, which is designed to access memory at its own pace. Bridging this gap required "additional glue logic," which diminished the cost-effectiveness of using integrated CMOS sensors (’790 Patent, col. 1:37-60).
  • The Patented Solution: The invention discloses an interface, preferably integrated onto the same semiconductor die as the image sensor, that contains a memory buffer (such as a FIFO buffer) to temporarily store pixel data from the sensor. This interface monitors the amount of data in the buffer and, when a certain threshold is reached, sends a signal (e.g., an interrupt) to the host processor. This alerts the processor that data is ready to be read, decoupling the sensor's fixed data-generation rate from the processor's variable data-access rate (’790 Patent, Abstract; col. 2:4-13).
  • Technical Importance: This architecture facilitates the direct and efficient integration of CMOS image sensors with standard processor systems, a key step toward creating more compact and cost-effective "system on a chip" digital imaging products (’790 Patent, col. 1:28-31).

Key Claims at a Glance

  • The complaint does not identify the specific independent or dependent claims of the ’790 Patent that are asserted, instead referring to "one or more claims" and incorporating by reference an external exhibit not provided with the complaint (Compl. ¶¶ 19, 24-25).

U.S. Patent No. 8,537,242 - "Host interface for imaging arrays," issued September 17, 2013

The Invention Explained

As a divisional of the application leading to the ’790 Patent, the ’242 Patent addresses the same technical challenge of interfacing a CMOS image sensor with a host processor. It describes an integrated circuit with a buffer memory (e.g., FIFO) that stores image data from the sensor and uses a signaling mechanism, such as an interrupt or a bus request, to manage the transfer of this data to the processor system at a rate determined by that system (’242 Patent, Abstract).

Key Claims at a Glance

The complaint asserts "one or more claims" of the ’242 Patent, referencing an external exhibit not provided with the complaint (Compl. ¶¶ 28, 33-34).

Accused Features

The complaint alleges infringement by the "Exemplary Defendant Products" but does not provide details on the specific features accused of infringing this patent in the body of the complaint (Compl. ¶28).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, methods, or services by name. It refers generally to "Exemplary Defendant Products" throughout the document (Compl. ¶13).

Functionality and Market Context

The complaint provides no description of the technical functionality, features, or market context of the accused products. It alleges only in a conclusory manner that the products "practice the technology claimed" by the patents-in-suit (Compl. ¶15).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of all three patents-in-suit but incorporates its detailed allegations by reference to Exhibits 4, 5, and 6, which are claim charts that were not filed with the complaint (Compl. ¶¶ 16, 25, 34). The narrative allegations are limited to conclusory statements that the unnamed "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶¶ 15, 24, 33). Due to the absence of the referenced exhibits and any substantive factual allegations of infringement in the complaint's text, a detailed infringement analysis is not possible.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of key claim terms, as it does not identify the specific claims asserted or provide the referenced claim chart exhibits upon which its infringement allegations rely (Compl. ¶¶ 15, 24, 33).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement of the ’790 Patent and the ’242 Patent. The factual basis for these allegations is that Defendant allegedly distributes "product literature and website materials" that instruct and encourage end users to operate the accused products in an infringing manner (Compl. ¶¶ 22-23, 31-32). The allegations are premised on conduct occurring "at least since being served by this Complaint" (Compl. ¶¶ 23, 32). No indirect infringement is alleged for the ’527 Patent.

Willful Infringement

The complaint asserts that Defendant has had "Actual Knowledge of Infringement" of the ’790 and ’242 Patents, with this knowledge established by the service of the complaint itself (Compl. ¶¶ 21, 30). These allegations appear to form the basis for a claim of post-suit willful infringement, for which the plaintiff seeks enhanced damages (Compl. ¶H). No willfulness is alleged with respect to the ’527 Patent.

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

Pleading Sufficiency

An immediate question is whether the complaint's allegations are sufficient to state a plausible claim for relief. The complete absence of identified accused products and the reliance on unfiled exhibits for the factual basis of infringement may raise questions regarding whether the complaint meets the pleading standards established by federal court precedents.

Infringement Theory

The central technical and factual question will be how, specifically, Defendant's products are alleged to infringe. As the case proceeds, discovery will be required to identify the accused products and understand Plaintiff's theory of how their specific architecture and operation map to the limitations of the asserted patent claims.

Claim Scope and Construction

Once specific claims are identified, the case will likely turn on the construction of key terms. For the ’527 Patent, the definitions of "interface module" and "read control device" will be critical. For the ’790 and ’242 Patents, the scope of terms like "interface," "memory," and "signal generator" will be central to determining whether the architecture of Defendant’s products falls within the scope of the claims.