Flick Intelligence LLC v. Snap Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Flick Intelligence, LLC (New Mexico)
  • Defendant: Snap Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00263, W.D. Tex., 09/23/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s smartglasses infringe a patent related to eyeglasses that automatically adjust their focus based on the user's gaze distance and vision prescription.
• Technical Context: The technology resides in the field of wearable computing and augmented reality, specifically addressing the integration of dynamic vision correction into smartglass devices.
• Key Procedural History: The filing is a First Amended Complaint, submitted in response to a motion to dismiss filed by the Defendant. The complaint also notes that Plaintiff is a non-practicing entity and has previously entered into settlement licenses related to its patent portfolio, but argues these licenses did not create a marking obligation under 35 U.S.C. § 287 because the licensees did not admit infringement or agree to produce a patented article.

Case Timeline

Date	Event
2013-12-27	'237 Patent Priority Date
2016-10-11	'237 Patent Issue Date
2025-09-23	Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,465,237 - "Automatic focus prescription lens eyeglasses"

• Patent Identification: U.S. Patent No. 9,465,237, "Automatic focus prescription lens eyeglasses," issued October 11, 2016 (the "’237 Patent").

The Invention Explained

• Problem Addressed: The patent describes the limitations of conventional vision correction for users who require different prescriptions for different distances, such as those needing bifocal or trifocal lenses. It characterizes the need to look through distinct portions of a lens as an "awkward user interface for electronic devices and systems" (’237 Patent, col. 1:30-32).
• The Patented Solution: The invention is a system of "autofocus eyeglasses" that dynamically adjust their focal length. The system uses "focus distance components," such as eye sensors, to detect the distance at which a user's eyes are focused. A controller then uses this information to direct actuators to change the focus of variable focus lenses, applying an adjustment based on the user's specific vision prescription to ensure clarity at that distance (’237 Patent, Abstract; col. 2:20-26).
• Technical Importance: The technology aims to automate vision correction seamlessly, allowing a single pair of glasses to provide correct focus for near, middle, and far distances without conscious effort from the user, thereby enabling a more natural interaction with both the real world and integrated digital displays (’237 Patent, col. 3:50-54).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-16 (Compl. ¶15). Independent claim 1 is an apparatus claim.
• The essential elements of independent claim 1 include:
  • One or two variable focus lenses.
  • One or two lens actuators to change the focus of the lenses.
  • One or more focus distance components to detect the focus distance of the user's eye(s), which includes an "eye sensor to continuously determine widths of a lens of an eye of the user."
  • A control mechanism wherein the actuators set the focal distance of the lenses in response to the detected focus distance.
  • The focal distance setting includes an "adjustment for a vision prescription of the user."
• The complaint's assertion of claims 1-16 suggests it is also asserting dependent claims that add further limitations to the invention.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Defendant's smartglasses, including, but not limited to, the M400 Smart Glasses" and "Passthrough and related systems" (Compl. ¶¶ 15-16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused product's specific functionality. It alleges in general terms that the products are "smartglasses" that infringe the ’237 Patent but does not describe the mechanism of operation for the accused features (Compl. ¶¶ 15-16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that support for its infringement allegations may be found in a "preliminary exemplary table attached as Exhibit B" (Compl. ¶16). This exhibit was not included with the provided complaint. The infringement theory, based on the complaint's narrative, is that Defendant's smartglasses incorporate the system claimed in the ’237 Patent by using sensors to detect a user's focus distance and automatically adjusting the device's lenses to correct for the user's vision prescription (Compl. ¶¶ 14-16).

Identified Points of Contention

• Technical Questions: A primary question for the court will be evidentiary: what technical evidence demonstrates that the accused "M400 Smart Glasses" actually perform the functions required by the claims? Specifically, the complaint does not allege facts showing how the accused products meet the limitation of an "eye sensor to continuously determine widths of a lens of an eye of the user" (’237 Patent, claim 1).
• Scope Questions: The case may present a significant claim scope dispute over what technologies satisfy the "focus distance components" limitation. The analysis may question whether the accused products, if they use methods like outward-facing rangefinders or gaze-vector analysis, practice a method that falls within the scope of a claim that recites a sensor measuring the biological lens of the user's eye.

V. Key Claim Terms for Construction

"focus distance components"

Context and Importance

This term is foundational to the invention, defining the sensing mechanism that triggers the automatic focus adjustment. Its construction will determine which types of sensor technologies can be found to infringe. Practitioners may focus on this term because the specific language of claim 1 appears to narrow its scope to a particular biological measurement.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification states that the "determination of a focus distance of a user may be performed in multiple different ways" and describes embodiments with "one or more eye trackers" (’237 Patent, col. 2:62-65). This language may support an argument that the term should not be confined to a single disclosed method.
• Evidence for a Narrower Interpretation: Independent claim 1 explicitly requires that the "focus distance components" include "an eye sensor to continuously determine widths of a lens of an eye of the user" (’237 Patent, col. 18:51-54). This language may support a narrower construction limited to devices that perform this specific physiological measurement, as opposed to devices that determine focus distance through other means, such as gaze triangulation or object detection.

"adjustment for a vision prescription of the user"

Context and Importance

This term defines the corrective function of the apparatus. The dispute will likely center on what level of vision correction is required to meet this limitation.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification describes a "focus training mode" where the eyeglasses "automatically learn the compensation necessary for an individual's unique prescription" (’237 Patent, col. 5:14-17). This could support a reading where any user-specific optical offset, however derived, constitutes a "prescription."
• Evidence for a Narrower Interpretation: The specification notes that the autofocus mechanism can correct for specific conditions including "myopia, hyperopia, presbyopia, and astigmatism" (’237 Patent, col. 2:58-61). This language could be cited to argue that the term requires correction for clinically defined refractive errors, not merely a generic focus adjustment.

VI. Other Allegations

Indirect Infringement

The complaint includes a general allegation that Defendant "indirectly develops, designs, manufactures, distributes, markets, offers to sell and/or sells infringing products" (Compl. ¶3). However, it does not plead specific facts to support the knowledge and intent elements required for claims of induced or contributory infringement.

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

• A core issue will be one of technical evidence: The complaint's lack of detail raises a fundamental evidentiary question: does the accused product line, specifically the "M400 Smart Glasses," actually incorporate the technology claimed in the ’237 Patent? The viability of the case will depend on whether discovery reveals that the accused products contain variable focus lenses and, crucially, a sensor system that performs the function of continuously measuring the width of the user's own eye lens to determine focus distance.
• A second key issue will be one of claim scope: can the term "focus distance components," which is explicitly tied in claim 1 to a sensor that measures the user's biological eye lens, be construed to cover other non-biological methods of determining focal distance, such as camera-based gaze tracking or depth sensing? The outcome of this construction could be dispositive.