Cedar Lane Tech Inc v. Pryntec

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Pryntec (France)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 6:22-cv-00955, W.D. Tex., 09/15/2022
• Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign corporation, and the complaint asserts that Defendant has committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products, which appear to relate to imaging systems, infringe two patents directed to an interface between an image sensor and a host processor system.
• Technical Context: The technology concerns methods and systems for efficiently transferring image data from a dedicated image sensor to a general-purpose processor by using an on-chip buffer and signaling mechanism to decouple the two components.
• 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. The file history of the ’242 patent includes a terminal disclaimer, which may tie its expiration date to that of the ’790 patent and could be relevant to the calculation of damages. The complaint does not mention any prior litigation or administrative proceedings involving these patents.

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 describes a problem where the continuous, video-style data output from an image sensor is incompatible with the data interface of a commercial microprocessor, which is designed for random data access (Compl., Ex. 1, ’790 Patent, col. 1:38-52). Bridging this gap required "additional glue logic," which diminished the cost and integration benefits of using modern CMOS image sensor technology (Compl., Ex. 1, ’790 Patent, col. 1:53-62).
• The Patented Solution: The invention proposes an interface, preferably integrated onto the same semiconductor die as the image sensor, that acts as an intermediary (’790 Patent, col. 2:25-34). This interface uses a memory buffer to store image data as it arrives from the sensor. Once a certain amount of data accumulates in the buffer, the interface sends a signal, such as a processor interrupt, to the main computer system, which can then read the buffered data at its own pace (’790 Patent, Abstract). This decouples the sensor's fixed data-collection rate from the processor's variable data-handling rate.
• Technical Importance: This architecture allows for more flexible and efficient system design by eliminating the need for external interface components and freeing the main processor from the task of constantly monitoring the image sensor’s data stream (’790 Patent, col. 2:3-14).

Key Claims at a Glance

• The complaint does not specify claims but refers to "Exemplary '790 Patent Claims" in an unattached exhibit (Compl. ¶12). Independent claim 1 is representative of the invention's core system.
• Independent Claim 1: An interface 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, which may include dependent claims (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’s application, the ’242 patent addresses the same technical problem: the inherent incompatibility between the data output format of an IC image sensor and the data input requirements of a commercial microprocessor (Compl., Ex. 2, ’242 Patent, col. 1:20-44).
• The Patented Solution: The ’242 patent claims a method for implementing the interface concept. The method involves receiving and storing image data in a buffer (specifically a FIFO memory), tracking the amount of stored data with a counter, comparing that count to a preset limit, and then generating an interrupt signal to a processor when a "predetermined relationship" to that limit is met (’242 Patent, Claim 1). The processor then transfers the data from the buffer in response to the interrupt.
• Technical Importance: This patented method provides a specific, programmatic way to manage data flow between a sensor and a processor, enabling the efficiencies described in the parent ’790 patent (’242 Patent, col. 1:54-62).

Key Claims at a Glance

• The complaint refers to "Exemplary '242 Patent Claims" in an unattached exhibit (Compl. ¶21). Independent claim 1 is a representative method claim.
• Independent Claim 1: A method of processing imaging signals, comprising the steps of:
  • receiving and storing image data in a FIFO memory;
  • updating a FIFO counter to track the amount of data;
  • comparing the counter's count with a FIFO limit;
  • generating an interrupt signal for a processor when the count has a "predetermined relationship to the FIFO limit" and an enable signal is valid; and
  • transferring the data from the FIFO memory to the processor in response to the interrupt.
• The complaint alleges infringement of one or more claims, which may include dependent claims (Compl. ¶21).

III. The Accused Instrumentality

The complaint references "Exemplary Defendant Products" that are allegedly identified in Exhibits 3 and 4 (Compl. ¶¶12, 21). As these exhibits were not included with the complaint, the specific accused products, their technical functions, and their market context cannot be identified. The complaint does not provide sufficient detail for analysis of the accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint's substantive infringement allegations are incorporated by reference from claim chart Exhibits 3 and 4, which are not provided (Compl. ¶¶18, 27). The complaint asserts narratively that the unspecified "Exemplary Defendant Products" practice the claimed technology and satisfy all elements of the asserted claims (Compl. ¶¶17, 26). Without the claim charts detailing the plaintiff's infringement theories, a direct analysis of the allegations is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

’790 Patent

• The Term: "in response to the quantity of data in the memory" (from Claim 1)
• Context and Importance: This phrase defines the trigger for the signal sent to the processor. The interpretation of this causal link is central to infringement, as it distinguishes the invention from systems that might signal a processor based on other events (e.g., a fixed timer or an end-of-frame signal). Practitioners may focus on this term to determine if the accused system's signaling mechanism is truly based on the data fill level.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain language of the claim and the general description in the Summary of the Invention are broad, stating only that the signal is generated "in response to the quantity of data" (’790 Patent, col. 2:8-10), which could arguably encompass any system where the data quantity is a causal factor.
  • 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 S₁" to trigger the signal (’790 Patent, col. 6:11-14). A party might argue that "in response to" should be limited to this more specific implementation of comparing a data count to a threshold.

’242 Patent

• The Term: "predetermined relationship to the FIFO limit" (from Claim 1)
• Context and Importance: This term is the core condition for the interrupt-generation step in the claimed method. The scope of "relationship" will be critical; infringement will depend on whether the accused method's logic for triggering a data transfer falls within the construed meaning of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "relationship" itself is not inherently limiting and could be argued to cover a variety of logical conditions, such as "equal to," "greater than," "less than," or "within a range of," as long as the condition is "predetermined."
  • Evidence for a Narrower Interpretation: The specification, which is shared with the ’790 patent, discloses an exemplary condition where the interrupt is asserted "If Sc≥S₁" (’790 Patent, col. 6:11-12). A party could argue that the "predetermined relationship" should be construed more narrowly in light of this specific "greater than or equal to" embodiment.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents. The factual basis alleged is Defendant's sale of the accused products along with "product literature and website materials inducing end users" to operate the products in an infringing manner (Compl. ¶¶15, 24). Knowledge is alleged to exist at least from the date of service of the complaint (Compl. ¶¶16, 25).
• Willful Infringement: The complaint does not use the term "willful." However, it alleges that Defendant has continued to infringe despite having "actual knowledge" of the patents from the service of the complaint (Compl. ¶¶15, 24). These allegations could form the basis for a future claim of post-suit willful infringement and a request for enhanced damages under 35 U.S.C. § 284.

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

• A Primary Evidentiary Question: As the complaint lacks specifics on the accused products and the infringement theories, a foundational question is evidentiary: what specific features of Defendant’s products are alleged to perform the claimed functions of buffering image data and signaling a processor "in response to the quantity of data," and what evidence supports these allegations?
• A Core Claim Construction Question: The case may turn on a question of definitional scope: how should the triggering mechanism for processor communication be defined? For the ’790 patent, can "in response to the quantity of data" cover any signaling system where fill level is a factor, or is it limited to a direct comparison with a threshold? For the ’242 patent, what is the scope of a "predetermined relationship" between the data count and a limit?
• A Key Procedural and Damages Question: Given that the ’242 patent is a terminally disclaimed divisional of the ’790 patent, a central question for damages will be the interplay between the two patents. This raises issues of how damages are calculated to avoid double recovery for a single act of infringement and clarifies that the enforceable term of the ’242 patent is limited by the expiration of the ’790 patent.