DCT
6:25-cv-00189
Spin Screen Inc v. Kino Mo Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Spin Screen, Inc. (Florida)
- Defendant: Kino-mo Ltd. d/b/a HYPERVSN (England) and Yoongli LLC (Texas)
- Plaintiff’s Counsel: houstonip
- Case Identification: 6:25-cv-00189, W.D. Tex., 05/07/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Yoongli LLC maintains a place of business in the district, and alleged acts of infringement occur there.
- Core Dispute: Plaintiff alleges that Defendant’s holographic "Persistence of Vision" (POV) display systems infringe patents related to methods for displaying undistorted, level images on a rotating array of illuminating elements.
- Technical Context: The technology concerns creating two-dimensional and three-dimensional images that appear to float in mid-air by rapidly spinning LED-equipped blades, a technique widely used in modern advertising and visual displays.
- Key Procedural History: The complaint details the prosecution history for the patents-in-suit and their family, noting arguments made to distinguish the inventions from prior art based on the ability to display images without circular distortion. Plaintiff also alleges it has successfully licensed its patent portfolio to two other companies.
Case Timeline
| Date | Event |
|---|---|
| 2004-07-21 | ’214 and ’108 Patents Priority Date |
| 2012-10-09 | U.S. Patent No. 8,284,214 Issued |
| 2013-04-02 | U.S. Patent No. 8,411,108 Issued |
| 2025-02-07 | Plaintiff allegedly sent letter to Defendant Hypervsn |
| 2025-05-07 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,284,214 - "Rotational Display System," Issued Oct. 9, 2012
The Invention Explained
- Problem Addressed: The patent addresses limitations of early POV displays, which were unable to show clear, high-quality images from standard digital sources (Compl. ¶¶71, 78). A primary technical hurdle was that images intended for rectangular screens (using Cartesian X,Y coordinates) would appear distorted, with text and images bending circularly around the device’s axis of rotation when displayed on a spinning LED array (’108 Patent, col. 5:13-36; Compl. ¶¶89-90).
- The Patented Solution: The invention describes a system that overcomes this distortion by mathematically converting standard rectangular image data into polar coordinates (radius and angle) (’108 Patent, col. 13:45-14:40; Compl. ¶97). This conversion process allows the system’s controller to precisely time the illumination of LEDs on the rotating assembly to reproduce a clear, level image that is not bent or warped, creating what the patent refers to as an image displayed without bending its "horizontal ground plane" around the axis (’214 Patent, claim 1).
- Technical Importance: This method provided a pathway for POV displays to evolve from simple novelty items showing distorted text into high-definition devices capable of displaying television-quality, user-selected photos and videos from any standard digital source (Compl. ¶¶96-97, 101).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶178).
- Claim 1 of the ’214 Patent recites the following essential elements:
- A computer for storage and recall of data representing at least one visual image.
- A controller in wireless communication with the computer, operable to receive the data.
- A rotatable assembly for displaying the image, which includes an illuminating assembly with at least one illuminating element, operably connected to the controller.
- The rotatable assembly is constructed for attachment to a support for rotation about an axis.
- A power delivery means for providing power to the rotatable assembly.
- An image displayed by the rotating assembly "without bending the horizontal ground plane around said axis."
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 8,411,108 - "Rotational Display System," Issued Apr. 2, 2013
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’214 Patent, the ’108 Patent addresses the same fundamental problem: the circular distortion of images on conventional POV displays and the lack of a method to convert standard rectangular image data for clear, level display on a rotating device (Compl. ¶¶71, 78, 88-90; ’108 Patent, col. 5:13-36).
- The Patented Solution: The ’108 Patent discloses the same solution of using a system that processes image data by converting it from a Cartesian (X,Y) coordinate system to a polar (radius, angle) coordinate system (’108 Patent, col. 13:45-14:40). This enables the controller to synchronize the illumination of LEDs to form a stable, high-quality image that appears level and is free from the bending distortion that plagued earlier devices (’108 Patent, claim 16).
- Technical Importance: The technology described was critical in enabling rotating LED displays to compete with traditional screens by allowing them to render high-fidelity, user-selectable digital media without visual artifacts inherent to their mechanical operation (Compl. ¶¶96-97, 101).
Key Claims at a Glance
- The complaint asserts at least independent Claim 16 (Compl. ¶201).
- Claim 16 of the ’108 Patent recites the following essential elements:
- A computer for storage and recall of data representing at least one visual image.
- A controller in electrical communication with the computer, operable to receive the data.
- A rotatable assembly for displaying the image, which includes an illuminating assembly with at least one illuminating element, operably connected to the controller.
- The rotatable assembly is constructed for attachment to a support for rotation about an axis.
- A power delivery means for providing power to the rotatable assembly.
- An image displayed by the rotating assembly "without bending the horizontal ground plane around said axis."
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendants' "Holographic display systems," which include hardware such as the Hypervsn Solo Device, SmartV Solo Device, and SmartV Wall Device, and associated software, including the Hypervsn CMS Application, Hypervsn App Mobile Application, and Hypervsn 3D Studio (Compl. ¶¶179, 202).
Functionality and Market Context
- The accused products are described as "four-ray LED-based rotor[s]" that rotate at high speeds to create 3D visuals that appear to be "floating in mid-air" (Compl. p. 81). Users interact with the system via software on a computing device (e.g., laptop, mobile phone) to upload, manage, and display content (Compl. ¶183). A visual from Defendants' marketing materials, referenced in the complaint, shows the "HYPERVSN Device" with its four LED-equipped blades (Compl. p. 81). These systems are marketed as advanced advertising and visual effect tools capable of generating high-definition 3D visuals (Compl. p. 81).
IV. Analysis of Infringement Allegations
'214 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a computer for storage and recall of data representing at least one visual image | The system uses a computing device, such as a laptop or mobile phone, running Hypervsn software to store and recall image and video data from a "Cloud tab" or "Library tab" for display. | ¶183-185 | col. 9:65-10:7 |
| a controller in wireless communication with the computer and operable to receive at least some of said data | The system includes hardware and software that permit wireless communication (e.g., Wi-Fi) between a user's computer and the rotatable display device for transferring image data. A diagram in the complaint illustrates this wireless connection (Compl. p. 94). | ¶186-187 | col. 10:16-25 |
| a rotatable assembly for displaying an image represented by at least a portion of the data transferred...said rotatable assembly including an illuminating assembly...including at least one illuminating element | The accused "HYPERVSN Device" is a "four-ray LED-based rotor" that functions as the rotatable assembly, with the LED arrays on the rays serving as the illuminating assembly and elements. | ¶188-189 | col. 10:33-37 |
| a power delivery means for providing power to said rotatable assembly | The accused devices are powered by an internal battery or by connecting to an external AC power source. | ¶191 | col. 11:53-12:24 |
| an image represented by said data...displayed without bending the horizontal ground plane around said axis | The system is alleged to create a POV image from the received data in a manner that does not distort the image around the axis of rotation. The complaint includes a visual from Defendants' materials depicting a "Non-bending image" (Compl. p. 118). | ¶192 | col. 12:35-40 |
'108 Patent Infringement Allegations
| Claim Element (from Independent Claim 16) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a computer for storage and recall of data representing at least one visual image | The system uses a user's computing device running Hypervsn software to store, recall, and manage media content for display. A screenshot of the software suite illustrates content management capabilities (Compl. p. 83). | ¶206-208 | col. 33:8-16 |
| a controller in electrical communication with the computer and operable to receive at least some of said data | The system controller communicates with the computer either wirelessly (Wi-Fi) or via a wired connection (Ethernet) to receive user-selected image data. | ¶209-210 | col. 33:17-25 |
| a rotatable assembly for displaying an image...said rotatable assembly including an illuminating assembly...including at least one illuminating element | The accused "HYPERVSN Device" is the rotatable assembly, which comprises a rotor with multiple rays containing LEDs that function as the illuminating assembly and elements. | ¶211-212 | col. 33:26-34 |
| a power delivery means for providing power to said rotatable assembly | The accused devices are powered by internal batteries or an external AC power connection, which provides electrical current to the rotating assembly. | ¶214 | col. 36:5-12 |
| an image...displayed by said rotatable assembly...said image displayed without bending the horizontal ground plane around said axis | The accused system allegedly displays images without the circular distortion of prior art devices, presenting them with a stable orientation. The complaint points to software features allowing users to "adjust the horizontal orientation" (Compl. p. 113), which suggests the existence of a non-bent ground plane. | ¶215 | col. 45:7-13 |
- Identified Points of Contention:
- Scope Questions: A potential issue may be whether a user's general-purpose device (laptop, phone) running Defendant's software constitutes "a computer" as recited in the system claims, or if it is an external component separate from the claimed invention.
- Technical Questions: The central dispute will likely focus on the claim limitation "without bending the horizontal ground plane around said axis." The analysis will raise the question of what technical evidence demonstrates that the Hypervsn system's method of image processing and display meets this limitation. The case may turn on how the accused technology achieves its visual effect compared to the specific trigonometric conversion process described in the patents' shared specification.
V. Key Claim Terms for Construction
- The Term: "horizontal ground plane"
- Context and Importance: This term appears in the final, and arguably most critical, limitation of the asserted independent claims ('214 Claim 1; '108 Claim 16). Its construction is central to the dispute because it is the feature that Plaintiff alleges distinguishes its invention from prior art POV displays that "twist the (normally horizontal) ground plane of the image or text around the axis of rotation" (Compl. ¶90). Practitioners may focus on this term as its definition will likely determine whether the accused products, which also aim to create stable, non-distorted images, fall within the scope of the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the problem being solved as images where a user must "read text that bends around the circle of rotation" (’108 Patent, col. 5:17-23). This may support a functional interpretation where any system that displays a perceptually level and undistorted image, regardless of the underlying algorithm, meets the limitation.
- Evidence for a Narrower Interpretation: The detailed description links the achievement of a non-bent display to a specific mathematical process: converting Cartesian coordinates to polar coordinates (’108 Patent, col. 13:45-14:40). A defendant could argue that the term "horizontal ground plane" is not merely a desired result but is inextricably linked to this disclosed trigonometric method, thereby narrowing the claim scope to systems that use a similar process.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by asserting that Defendants provide software, user manuals, and instructions that actively encourage and guide customers to use the Hypervsn systems in an infringing manner (Compl. ¶¶194, 217). Contributory infringement is alleged on the basis that the accused systems are not staple articles of commerce and are specially adapted for the infringing use of displaying images on a rotating POV device (Compl. ¶¶195, 218).
- Willful Infringement: Willfulness is alleged based on both pre- and post-suit knowledge. The complaint alleges Defendants had constructive notice since the patents issued and received actual notice via a letter in February 2025 and the filing of this complaint (Compl. ¶¶193, 198, 216). Crucially, the complaint also alleges that the ’214 Patent was cited in Defendant Hypervsn’s own British Patent No. GB2,573,123, which may suggest pre-suit knowledge of the patent (Compl. ¶193).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: will the term "horizontal ground plane" be construed functionally to cover any system that produces a visually level image on a rotating display, or will it be limited more narrowly to the specific Cartesian-to-polar coordinate conversion method detailed in the patent specification?
- A key evidentiary question will be one of technical implementation: what is the precise algorithm and hardware process the accused Hypervsn systems use to render images, and does that process, in fact, create an image "without bending the horizontal ground plane" as that term is ultimately construed by the court?
- A critical question for damages will be one of scienter: does the alleged citation of the ’214 Patent in Defendant’s own patent application establish pre-suit knowledge, thereby strengthening the claim for willful infringement and the potential for enhanced damages if liability is found?