DCT
7:25-cv-00249
C47 Tech LLC v. Apple Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: C47 Technologies LLC (Nevada)
- Defendant: Apple Inc. (California)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 7:25-cv-00249, W.D. Tex., 05/27/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant has transacted business, committed acts of infringement, and maintains regular and established places of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s multi-camera systems in various iPhone and iPad models, which enable features like Portrait Mode, infringe a patent related to capturing and merging images from multiple cameras using different parameters.
- Technical Context: The lawsuit concerns the field of computational photography, where image data from multiple sources is processed and combined to create a single, enhanced image, a technology central to modern smartphone camera capabilities.
- Key Procedural History: The complaint notes that the patent-in-suit was assigned to Plaintiff C47 Technologies LLC, with assignments recorded in January and May 2024. Plaintiff also states that no products have ever been commercialized or licensed by the patent owner under the patent-in-suit, which may have implications for damages calculations and potential defenses.
Case Timeline
| Date | Event |
|---|---|
| 2001-10-12 | '605 Patent Priority Date |
| 2021-04-20 | U.S. Patent No. 10,984,605 Issues |
| 2021-04-20 | Alleged Infringement Start Date |
| 2022-10-15 | Alleged Infringement End Date (as specified in complaint) |
| 2024-01-23 | First Assignment of '605 Patent to Plaintiff Recorded |
| 2024-05-10 | Second Assignment of '605 Patent to Plaintiff Recorded |
| 2025-05-27 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,984,605 - "Camera Arrangements with Backlighting Detection and Methods of Using Same", issued April 20, 2021
The Invention Explained
- Problem Addressed: The patent describes a problem in early multi-camera and telepresence systems where combining images could lead to an "unnatural appearance" ('605 Patent, col. 2:32-35). This issue arose when merging images with different lighting conditions, or when superimposing a virtual reality object onto a real-world scene, causing brightness inconsistencies ('605 Patent, col. 2:20-44; Compl. ¶8).
- The Patented Solution: The invention proposes a system using an array of cameras to capture not only pixel data but also illumination data ('605 Patent, col. 3:1-7). By capturing images using distinct parameters and creating a data file that associates pixel and illumination data, the system allows for more accurate and realistic merging of multiple images into a single composite image ('605 Patent, col. 3:11-27; Compl. ¶9). The system is described as comprising multiple camera units on a circuit board, with circuitry to merge the data into a common output stream ('605 Patent, col. 3:11-27).
- Technical Importance: The complaint alleges this technology improved systems for capturing and merging multiple digital images, allowing for the creation of more realistic combined images by better managing illumination and other data from different camera sources (Compl. ¶12-13).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claims 1, 28, 30, 35, 60, 62, and 64 (Compl. ¶23).
- Independent Claim 1, a system claim, recites the following essential elements:
- A first camera configured to transmit a set of first camera data.
- A second camera configured to transmit a set of second camera data.
- Data communication circuitry coupled to the outputs of the first and second cameras.
- At least one processing chip configured to merge the first and second camera data into a set of merged camera data.
- The first and second camera data are "representative of images taken with different camera parameters."
- The merged data is "capable of being displayed as a single image."
- The complaint reserves the right to assert numerous dependent claims (Compl. ¶23).
III. The Accused Instrumentality
Product Identification
- The accused products include numerous Apple mobile devices, such as the iPhone X through the iPhone 13 series and various iPad Pro models (collectively, the "Accused Products") (Compl. ¶16).
Functionality and Market Context
- The complaint targets the functionality of the multi-camera systems in the Accused Products, specifically citing features like "Portrait Mode" (Compl. ¶16, ¶21). The alleged infringing functionality involves using multiple digital cameras "in conjunction with circuitry, at least one processor, and software/firmware" to combine images that are captured using different parameters into a single, improved image for display (Compl. ¶16, ¶21). The complaint does not provide specific details on the commercial importance of these features, but notes they are found in "numerous Apple mobile devices" (Compl. ¶16). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
U.S. Patent No. 10,984,605 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first camera configured to transmit a set of first camera data through a first output connection; | The Accused Products contain camera arrays with multiple digital cameras and/or sensors (Compl. ¶21). | ¶21 | col. 15:31-34 |
| a second camera configured to transmit a set of second camera data through a second output connection; | The Accused Products contain camera arrays with multiple digital cameras and/or sensors (Compl. ¶21). | ¶21 | col. 15:35-37 |
| data communication circuitry coupled to said first output connection and said second output connection; | The Accused Products use "associated circuitry, software, firmware, processors" to enable features that combine multiple digital images (Compl. ¶16). | ¶16 | col. 15:38-40 |
| at least one processing chip coupled to said data communication circuitry, said at least one processing chip configured to merge said set of first camera data and said set of second camera data into a set of merged camera data; | The Accused Products contain "at least one processor" that merges data from the multiple cameras to ultimately display the merged data as a single image (Compl. ¶17, ¶21). | ¶17, ¶21 | col. 15:41-47 |
| wherein said set of first camera data and said set of second camera data are representative of images taken with different camera parameters; | The complaint alleges that the Accused Products "combine multiple digital images that are captured using different parameters" (Compl. ¶16). | ¶16 | col. 15:48-50 |
| wherein said set of merged camera data is capable of being displayed as a single image. | The complaint alleges the Accused Products combine data "for display as a single improved image" (Compl. ¶11). | ¶11 | col. 15:51-53 |
- Identified Points of Contention:
- Scope Questions: The complaint alleges infringement by highly integrated devices (i.e., iPhones and iPads). A potential point of contention is whether the discrete components recited in Claim 1 (e.g., "first output connection," "second output connection," "data communication circuitry") can be identified as distinct corresponding structures within the integrated System-on-a-Chip (SoC) architecture of the Accused Products, or if Plaintiff will need to rely on a broader interpretation of these terms.
- Technical Questions: The complaint alleges the Accused Products capture images using "different parameters" but does not specify what those parameters are (Compl. ¶16). The infringement analysis will depend on evidence showing that Apple's multi-camera features, such as Portrait Mode, actually operate by capturing images with "different parameters" as that term is construed in the context of the patent (e.g., exposure, focus, focal length).
V. Key Claim Terms for Construction
The Term: "different camera parameters" (Claim 1)
Context and Importance: This term is critical to the infringement analysis, as it defines the specific condition under which the merging of data from two cameras falls within the scope of the claim. The case may turn on whether the operation of Apple's Portrait Mode or other multi-camera features meets this limitation. Practitioners may focus on this term because its definition will determine what types of multi-camera image processing are covered by the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of applications, including merging actual pixel data captured with "distinct parameters" (Compl. ¶9; ’605 Patent, col. 4:50-55). This could support a reading that covers any difference in camera settings, such as focal length, aperture, or focus, not just a specific type of parameter.
- Evidence for a Narrower Interpretation: Dependent claims 12 and 14 explicitly recite "different exposure settings." An argument could be made that "different camera parameters" in the independent claim should be interpreted consistently with, but not necessarily limited to, this more specific disclosure. The patent's detailed description of a camera specification table, while broad, might be used to argue the term is limited to the types of parameters disclosed therein ('605 Patent, col. 13:42-14:65).
The Term: "processing chip" (Claim 1)
Context and Importance: The complaint alleges infringement by Apple's "processors" (Compl. ¶16). The construction of "processing chip" will determine whether it can read on a general-purpose CPU core within a complex SoC, or if it implies a more specialized or discrete component.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent itself does not appear to strictly define "processing chip." The complaint refers to the patent disclosing a "processor or application specific IC" (Compl. ¶12), suggesting the term could encompass a range of processing hardware.
- Evidence for a Narrower Interpretation: The patent describes the "processing chip" in the context of a system with other distinct hardware components like "data communication circuitry" ('605 Patent, col. 15:38-44). A defendant might argue that in a highly integrated SoC, these functions are not performed by distinct components in the manner envisioned by the patent, potentially narrowing the term's application to systems with more discrete architectures.
VI. Other Allegations
The complaint does not provide sufficient detail for analysis of indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute may depend on the court's determination of several key questions:
- A central issue will be one of definitional scope: How will the court construe the term "different camera parameters"? The viability of the infringement claim will depend on whether this term is interpreted broadly to cover any differential camera settings (such as the different focal lengths used in Portrait Mode) or is limited to more specific examples disclosed in the patent, such as exposure settings.
- A second core issue will be structural mapping: Can the patent’s recitation of discrete system components—such as separate "output connections" for each camera, "data communication circuitry," and a "processing chip"—be mapped onto the highly integrated SoC architecture of the accused Apple products? The infringement analysis will require a detailed examination of how these claimed functions are implemented in Apple's hardware and software.