Cedar Lane Tech Inc v. Avis Budget Group Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Avis Budget Group Inc (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 6:22-cv-01232, W.D. Tex., 11/29/2022
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s unidentified products and services infringe patents related to interfaces for digital imaging arrays that manage data transfer between a sensor and a host processor.
• Technical Context: The technology addresses the efficient integration of CMOS image sensors with processor-based systems by using an on-chip memory buffer to decouple the sensor's fixed data rate from the processor's variable data access rate.
• 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. The complaint does not mention any other prior litigation, licensing, or administrative proceedings.

Case Timeline

Date	Event
2000-01-21	Priority Date ('790 and '242 Patents)
2000-12-21	'790 Patent Application Filed
2005-12-06	'790 Patent Issued
2005-10-27	'242 Patent Application Filed
2013-09-17	'242 Patent Issued
2022-11-29	Complaint Filed

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 technical incompatibility between image sensors and microprocessors. Image sensors typically output a continuous, high-speed stream of pixel data synchronized to a sensor clock, whereas microprocessors are designed to access data in memory using address and control signals at their own pace. Bridging this gap traditionally required "additional glue logic," which increased system cost and complexity, undermining the economic advantages of using CMOS sensor technology (ʼ790 Patent, col. 1:47-66).
• The Patented Solution: The invention proposes an interface, preferably integrated onto the same semiconductor die as the image sensor, to act as a bridge. This interface contains a memory (such as a first-in-first-out, or FIFO, buffer) that stores incoming pixel data at the sensor's rate. When the buffer accumulates a certain quantity of data, a signal generator alerts the main processor (e.g., via an interrupt), which can then read the data from the buffer at its own speed ('790 Patent, Abstract; col. 2:4-14). This decouples the sensor's timing from the processor's timing.
• Technical Importance: This architecture simplifies the integration of image sensors into processor-controlled devices (e.g., digital cameras, scanners) by handling the data rate mismatch on-chip, freeing the main processor to perform other tasks until a full batch of image data is ready for processing (ʼ790 Patent, col. 5:15-19).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, but Claim 1 is the first independent claim.
• Independent Claim 1 requires:
  • 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 a processor system in response to the quantity of data in the memory.
  • A circuit for controlling the transfer of data from the memory at a rate determined by the processor system.
• The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations of infringement.

U.S. Patent No. 8,537,242 - Host interface for imaging arrays

Issued Sep. 17, 2013

The Invention Explained

• The '242 Patent is a divisional of the application for the '790 Patent and shares an identical specification. Therefore, the technical problem, patented solution, and importance are the same as described above for the '790 Patent.

Key Claims at a Glance

• The complaint does not specify which claims are asserted, but Claim 1 is the first independent method claim.
• Independent Claim 1 recites a method of processing imaging signals with the following steps:
  • 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.
  • Comparing the count of the FIFO counter with a FIFO limit.
  • Generating an interrupt signal to request a processor to transfer data, based on the comparison and an interrupt enable signal being valid.
  • Transferring the image data from the FIFO memory to the processor in response to the interrupt signal.
• The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations of infringement.

III. The Accused Instrumentality

The complaint does not identify any specific accused products, methods, or services by name (Compl. ¶12, ¶21). It refers generally to "Exemplary Defendant Products" that are purportedly identified in claim charts attached as Exhibit 3 and Exhibit 4 (Compl. ¶17, ¶26). However, these exhibits were not included with the publicly filed complaint. As a result, the complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the unspecified "Exemplary Defendant Products" infringe the patents-in-suit, but it incorporates the substance of these allegations by reference to external claim chart exhibits that were not provided with the filed complaint (Compl. ¶18, ¶27). The complaint asserts that these charts demonstrate that the accused products "satisfy all elements of the Exemplary... Patent Claims" (Compl. ¶17, ¶26). Without these exhibits, a detailed element-by-element analysis is not possible.

• Identified Points of Contention:
  • Evidentiary Question: A threshold issue for the court will be the identification of the accused instrumentalities. The complaint's failure to name any specific products or services from Avis Budget Group will likely be a central focus of early discovery and potential motions practice.
  • Technical Question: Once a product is identified, a key question will be whether its architecture maps onto the claimed invention. For instance, does the accused system contain the distinct "interface," "memory," "signal generator," and "control circuit" recited in Claim 1 of the '790 Patent, or does it utilize a more integrated System-on-a-Chip (SoC) that achieves a similar outcome through a different, potentially non-infringing, architecture? For the '242 Patent, the dispute may center on whether the accused system performs the specific, ordered sequence of method steps recited in the claims.

V. Key Claim Terms for Construction

For the '790 Patent:

• The Term: "processor system" (from Claim 1)
• Context and Importance: The definition of this term is critical for determining the scope of devices to which the patented interface can connect. The infringement analysis depends on whether the accused device's central processing architecture qualifies as a "processor system" as contemplated by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the "processor system" as including a "central processing unit (CPU) 10, other memory and system components 11" ('790 Patent, col. 4:10-12), suggesting the term could encompass a variety of general-purpose computing environments.
  • Evidence for a Narrower Interpretation: The figures consistently depict the "CPU 10" as a block-level component separate from the "interface" and "imaging array" ('790 Patent, Fig. 1, Fig. 6). This may support an argument that the term requires a physically or architecturally distinct processing unit, as opposed to a highly integrated SoC where processing, interface, and memory control functions are consolidated.

For the '242 Patent:

• The Term: "predetermined relationship" (from Claim 1)
• Context and Importance: This term defines the logical condition that triggers the interrupt signal to the processor. The validity of the infringement allegation will hinge on whether the trigger mechanism in an accused device meets this claimed "predetermined relationship" between the data count and a limit.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes a specific embodiment where the "interrupt generator 48 compares the FIFO counter output S\c and the FIFO limit S\L" and asserts an interrupt if "S\c ≥ S\L" ('790 Patent, col. 6:11-15). A party could argue this is merely an example and that any pre-set logical rule for triggering the interrupt would suffice.
  • Evidence for a Narrower Interpretation: A party could argue that the term is tied to the specific embodiment described—a direct numerical comparison against a set limit. The patent does not appear to describe other types of relationships, which could be used to argue for a narrower construction limited to such threshold comparisons.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement based on Defendant distributing "product literature and website materials" that allegedly instruct users on how to use the accused products in an infringing manner (Compl. ¶15, ¶24). The allegations are tied to knowledge obtained "at least since being served by this Complaint" (Compl. ¶16, ¶25).
• Willful Infringement: The complaint alleges that service of the complaint itself provides Defendant with "Actual Knowledge of Infringement" (Compl. ¶14, ¶23). This allegation appears to support a claim for post-filing willful infringement only, as no facts supporting pre-suit knowledge are alleged.

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

1. A primary issue will be evidentiary and factual: What specific Avis Budget Group products, internal systems, or services are being accused of infringement? The complaint's failure to identify any accused instrumentality will be the immediate hurdle for the Plaintiff to overcome.
2. A second key issue will be one of architectural scope: Assuming an imaging system is identified, can the discrete components described in the patents (e.g., a distinct "interface" with a "memory" and "signal generator") be mapped onto the architecture of any accused products, which may use modern, highly integrated Systems-on-a-Chip (SoCs)? This raises fundamental questions of both literal infringement and the doctrine of equivalents.