DCT
6:22-cv-01197
Cedar Lane Tech Inc v. Enterprise Holdings Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Cedar Lane Technologies Inc. (Canada)
- Defendant: Enterprise Holdings, Inc. (Missouri)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 6:22-cv-01197, W.D. Tex., 11/17/2022
- Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the Western District of Texas.
- Core Dispute: Plaintiff alleges that certain unidentified products of Defendant infringe patents related to a host interface for managing data transfer between an image sensor and a processor system.
- Technical Context: The technology addresses the efficient transfer of data from a CMOS image sensor to a host processor by using an on-chip buffer, a common architecture in digital imaging devices.
- Key Procedural History: The complaint does not reference prior litigation or administrative proceedings. U.S. Patent No. 8,537,242 is a divisional of the application that led to U.S. Patent No. 6,972,790 and is subject to a terminal disclaimer, which may link their enforceable patent terms.
Case Timeline
| Date | Event |
|---|---|
| 2000-01-21 | Earliest Priority Date for '790 and '242 Patents |
| 2005-12-06 | Issue Date for U.S. Patent No. 6,972,790 |
| 2013-09-17 | Issue Date for U.S. Patent No. 8,537,242 |
| 2022-11-17 | 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 describes that the continuous, high-speed video-style data output from early image sensors was "incompatible with the data interface of commercial microprocessors" without requiring additional, costly "glue logic" and consuming significant processor resources to handle the data stream in real time ('790 Patent, col. 1:47-62).
- The Patented Solution: The invention proposes an interface, preferably integrated onto the same semiconductor die as the image sensor, that acts as an intermediary. This interface uses a memory buffer (e.g., a FIFO buffer) to store image data as it is captured. Once a certain amount of data is stored, the interface generates a signal, such as a processor interrupt, to notify the host system that data is ready to be read. This decouples the sensor's fixed-rate data generation from the processor's more variable data consumption rate ('790 Patent, Abstract; col. 2:3-14).
- Technical Importance: This architecture allows for more efficient system design by freeing the main CPU from the constant task of sampling image data, which is a key advantage of using CMOS technology for imaging applications ('790 Patent, col. 1:26-30).
Key Claims at a Glance
- The complaint does not identify specific claims, instead referring to "Exemplary '790 Patent Claims" contained in a non-provided exhibit (Compl. ¶12). Independent claim 1 is representative of the core apparatus invention.
- Independent Claim 1:
- An interface for receiving data from an image sensor having an imaging array and a clock generator for transfer 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 additional claims (Compl. ¶12).
U.S. Patent No. 8,537,242 - Host interface for imaging arrays (Issued Sep. 17, 2013)
The Invention Explained
- Problem Addressed: The '242 Patent addresses the same technical problem of efficiently managing data flow between an image sensor and a host processor as its parent, the '790 Patent ('242 Patent, col. 1:11-61).
- The Patented Solution: As a divisional of the '790 patent application, this patent claims a method for implementing the data transfer process. The claimed method involves the steps of receiving and storing image data in a FIFO memory, maintaining a count of the data in that memory, comparing the count to a predefined limit, and then generating an interrupt signal to prompt a processor to transfer the buffered data ('242 Patent, Abstract; col. 8:55-68).
- Technical Importance: This patent protects the process of using the buffered interface, complementing the apparatus claims of the parent '790 Patent.
Key Claims at a Glance
- The complaint does not identify specific claims, instead referring to "Exemplary '242 Patent Claims" contained in a non-provided exhibit (Compl. ¶21). Independent claim 1 is representative of the core method invention.
- Independent Claim 1:
- A method of processing imaging signals, the method comprising:
- 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 the FIFO memory...;
- comparing the count of the FIFO counter with a FIFO limit;
- generating an interrupt signal to request a processor to transfer image data...in response to...the 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 reserves the right to assert additional claims (Compl. ¶21).
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" that are purportedly identified in claim charts attached as Exhibits 3 and 4 (Compl. ¶12, ¶21). These exhibits were not provided with the complaint.
- Functionality and Market Context: The complaint does not provide any description of the relevant technical features, functions, or market positioning of the accused instrumentalities. All such details are incorporated by reference to the non-provided exhibits (Compl. ¶17, ¶26).
IV. Analysis of Infringement Allegations
The complaint alleges infringement but relies entirely on claim chart exhibits that were not provided. The narrative alleges that these charts demonstrate that the "Exemplary Defendant Products" practice the technology claimed in the patents-in-suit (Compl. ¶17, ¶26). No probative visual evidence provided in complaint.
- '790 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a memory for storing imaging array data and clocking signals at a rate determined by the clocking signals; | The complaint alleges, via incorporation of non-provided exhibits, that the "Exemplary Defendant Products" contain a memory that performs this function (Compl. ¶17). | ¶17 | col. 2:7-9 |
| a signal generator for generating a signal for transmission to the processor system in response to the quantity of data in the memory; and | The complaint alleges, via incorporation of non-provided exhibits, that the "Exemplary Defendant Products" contain a signal generator that performs this function (Compl. ¶17). | ¶17 | col. 2:9-11 |
| a circuit for controlling the transfer of the data from the memory at a rate determined by the processor system. | The complaint alleges, via incorporation of non-provided exhibits, that the "Exemplary Defendant Products" contain a circuit for controlling data transfer that performs this function (Compl. ¶17). | ¶17 | col. 2:11-14 |
- '242 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving image data from an imaging array; | The complaint alleges, via incorporation of non-provided exhibits, that the "Exemplary Defendant Products" are used to perform this step (Compl. ¶26). | ¶26 | col. 8:56 |
| storing the image data in a FIFO memory; | The complaint alleges, via incorporation of non-provided exhibits, that the "Exemplary Defendant Products" are used to perform this step (Compl. ¶26). | ¶26 | col. 8:57 |
| updating a FIFO counter to maintain a count of the image data in the FIFO memory...; | The complaint alleges, via incorporation of non-provided exhibits, that the "Exemplary Defendant Products" are used to perform this step (Compl. ¶26). | ¶26 | col. 8:58-60 |
| comparing the count of the FIFO counter with a FIFO limit; | The complaint alleges, via incorporation of non-provided exhibits, that the "Exemplary Defendant Products" are used to perform this step (Compl. ¶26). | ¶26 | col. 8:61 |
| generating an interrupt signal to request a processor to transfer image data from the FIFO memory...; | The complaint alleges, via incorporation of non-provided exhibits, that the "Exemplary Defendant Products" are used to perform this step (Compl. ¶26). | ¶26 | col. 8:62-66 |
| transferring image data from the FIFO memory to the processor in response to the interrupt signal. | The complaint alleges, via incorporation of non-provided exhibits, that the "Exemplary Defendant Products" are used to perform this step (Compl. ¶26). | ¶26 | col. 8:67-68 |
- Identified Points of Contention:
- Evidentiary Questions: The most immediate point of contention is evidentiary. The complaint provides no factual allegations to support infringement beyond incorporating by reference non-provided exhibits. A central question will be what evidence, if any, supports the assertion that the unidentified "Exemplary Defendant Products" contain the specific components ('790 patent) or are used to perform the specific steps ('242 patent) required by the claims.
- Scope Questions: For the '790 patent, a potential dispute may arise over the scope of the term "interface." While the claim does not require it, the specification emphasizes integration on the same die as the image sensor as a key benefit, which could be used to argue for a narrower construction ('790 Patent, col. 2:25-29).
V. Key Claim Terms for Construction
- The Term: "memory" ('790 Patent, Claim 1)
- Context and Importance: The definition of "memory" is foundational to the claimed apparatus. Whether it can read on any digital storage or is limited to the specific buffer types described in the patent will be critical to determining the scope of infringement.
- Evidence for a Broader Interpretation: Claim 1 uses the generic term "a memory" without further qualification, which may support an interpretation covering any form of data storage that meets the claim's functional requirements.
- Evidence for a Narrower Interpretation: The specification predominantly describes the memory as "a first-in first-out (FIFO) buffer or an addressable memory" ('790 Patent, Abstract; col. 2:12-14). A defendant may argue that the claims should be interpreted in light of these specific embodiments.
- The Term: "in response to the quantity of data in the memory" ('790 Patent, Claim 1)
- Context and Importance: This phrase defines the triggering condition for the signal generator. Its construction will determine how direct the link must be between the amount of data in the buffer and the generation of the signal to the processor.
- Evidence for a Broader Interpretation: The phrase itself does not specify a mechanism, suggesting that any system where the signal is causally linked to the data quantity could be covered.
- Evidence for a Narrower Interpretation: The patent discloses a specific implementation where a counter's output is compared to a "FIFO limit" value in a register to generate the signal ('790 Patent, col. 6:11-14). An argument could be made that the claim requires such a direct comparison or threshold-based mechanism.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use its products in a manner that infringes the patents-in-suit (Compl. ¶15, ¶24).
- Willful Infringement: The complaint does not use the word "willful" but alleges Defendant has "Actual Knowledge of Infringement" from at least the date of service of the complaint (Compl. ¶14, ¶23). It further alleges that Defendant continues to infringe "Despite such actual knowledge," which provides a basis for post-suit willfulness allegations (Compl. ¶15, ¶24).
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of factual sufficiency and evidence: The complaint's complete reliance on non-provided exhibits to identify accused products and articulate infringement theories raises a fundamental question of whether the plaintiff can produce evidence to substantiate its conclusory allegations and show that any of the defendant's products actually practice the specific elements of the asserted claims.
- The case may turn on a question of claim scope and construction: A central legal dispute will likely involve the construction of the term "memory" in the '790 patent. Whether this term is given its broad, plain meaning or is limited to the more specific "FIFO buffer" or "addressable memory" embodiments detailed in the specification could be determinative of infringement.
- A key question for the inducement claim will be one of specific intent: Can the plaintiff demonstrate that the defendant's product manuals and marketing materials not only describe the operation of its products but specifically instruct or encourage users to operate them in a manner that directly maps to the patented method steps of the '242 patent?