DCT

7:26-cv-00015

Clairpath LLC v. Apple Inc

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:26-cv-00015, W.D. Tex., 01/14/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Apple maintains regular and established places of business in the district—including offices, retail stores, a manufacturing facility, and an engineering center—and has allegedly committed acts of infringement there.
  • Core Dispute: Plaintiff alleges that a wide range of Defendant’s consumer electronics, including its iPhone, Mac, and iPad product lines, infringes three patents related to semiconductor image sensor architecture, integrated location-sharing via messenger applications, and dynamic content delivery to navigation devices.
  • Technical Context: The patents-in-suit cover distinct technologies in hardware and software that are central to the functionality of modern smartphones, computers, and connected vehicles.
  • Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents.

Case Timeline

Date Event
2007-12-31 U.S. Patent No. 8,483,948 Priority Date
2008-07-03 U.S. Patent No. 8,996,708 Priority Date
2008-12-24 U.S. Patent No. 8,129,809 Priority Date
2012-03-06 U.S. Patent No. 8,129,809 Issued
2013-07-09 U.S. Patent No. 8,483,948 Issued
2015-03-31 U.S. Patent No. 8,996,708 Issued
2026-01-14 Complaint Filed

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

U.S. Patent No. 8,129,809 - *"Image Sensor and Manufacturing Method Thereof,"*

  • Patent Identification: U.S. Patent No. 8,129,809, "Image Sensor and Manufacturing Method Thereof," issued March 6, 2012 (Compl. ¶17).

The Invention Explained

  • Problem Addressed: The patent addresses the technical challenge of improving the light-sensing efficiency of Complementary Metal-Oxide-Semiconductor (CMOS) image sensors while preventing optical "crosstalk," where light intended for one pixel spills over and influences an adjacent pixel, degrading image quality (’809 Patent, col. 1:40-43).
  • The Patented Solution: The invention describes a backside-illuminated image sensor architecture. It features trenches etched into the back surface of the semiconductor substrate along the boundaries of each pixel. These trenches are filled with a light-blocking material to form a physical barrier, which is claimed to inhibit slantingly incident light from reaching adjacent pixels (’809 Patent, Abstract; col. 4:46-54). The claims further require a "second light blocking layer" between the photodiodes that includes an isolation layer and vertically overlaps the first light-blocking layer in the trenches (’809 Patent, col. 6:35-44).
  • Technical Importance: As manufacturers increased the pixel density of image sensors, preventing optical crosstalk became a critical factor in maintaining color fidelity and overall image sharpness (Compl. ¶20).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶41).
  • Essential elements of Claim 1 include:
    • An image sensor comprising: a circuit layer on a first surface of a semiconductor substrate and a metal interconnection layer on the circuit layer;
    • trenches formed in a second (back) surface of the substrate along a pixel boundary;
    • a "first light blocking layer" located in the trenches;
    • photodiodes located in the first (front) surface of the substrate;
    • a "second light blocking layer" that includes an "isolation layer" extending from the first surface towards the second surface and is formed between the photodiodes; and
    • a requirement that the second light blocking layer "vertically overlaps" with the first light blocking layer.

U.S. Patent No. 8,483,948 - *"Navigation System and Method for Exchange Mutual Location Information Using Messenger,"*

  • Patent Identification: U.S. Patent No. 8,483,948, "Navigation System and Method for Exchange Mutual Location Information Using Messenger," issued July 9, 2013 (Compl. ¶21).

The Invention Explained

  • Problem Addressed: Prior to the invention, navigation systems were typically standalone devices that could not easily share location information with other users, forcing reliance on separate communication tools to coordinate travel, which created "inefficiencies and increased the risk of errors" (Compl. ¶26; ’948 Patent, col. 1:50-57).
  • The Patented Solution: The patent describes a navigation system that integrates a messenger program with a navigation program. This allows a navigation device to transmit and receive "messenger information"—including device location, destination details, and text—with other devices and display the received location information directly on the device's map (’948 Patent, Abstract; Fig. 1). This creates a unified system for navigation and location-based communication (Compl. ¶25).
  • Technical Importance: The claimed integration of messaging and navigation functionalities provided a more interactive and collaborative user experience, foreshadowing location-sharing features now common in mobile applications (Compl. ¶29).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶59).
  • Essential elements of Claim 1 include:
    • A navigation system comprising a navigation device, wherein the device includes:
    • a "control module including a messenger program and a navigation program";
    • a "communication module" for transmitting and receiving messenger information, including location information, with another navigation device;
    • an "output module" for displaying the received location information on a map; and
    • a requirement that the "messenger information" includes at least one of destination information, device location information, destination description, or communication information.

U.S. Patent No. 8,996,708 - *"Method of Providing Content Information Using Wireless Communication Device and Navigation Device Performing the Same,"*

  • Patent Identification: "Method of Providing Content Information Using Wireless Communication Device and Navigation Device Performing the Same," issued March 31, 2015 (Compl. ¶30).
  • Technology Synopsis: The patent addresses the limitations of navigation systems that rely on static, pre-stored map data (Compl. ¶33). The invention describes a system where a navigation device can connect to a nearby wireless communication terminal (e.g., a mobile phone) to receive and display dynamic, real-time content such as traffic updates, "life information," and mobile application data, thereby enhancing its functionality beyond simple route guidance (Compl. ¶32-34; ’708 Patent, Abstract).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶77).
  • Accused Features: The complaint accuses Apple products with "device pairing and content sharing features," which suggests functionalities like Apple CarPlay where an iPhone provides data and application content to a vehicle's infotainment system (Compl. ¶77, ¶79).

III. The Accused Instrumentality

Product Identification

The complaint accuses a broad set of Apple's hardware products. Accused of infringing the ’809 Patent are devices containing image sensors, such as iPhones, Macs, iPads, and the Apple Vision Pro (Compl. ¶41). Accused of infringing the ’948 and ’708 Patents are devices with navigation and communication capabilities, including iPhones, iPads, Apple Watches, and Mac computers (Compl. ¶59, ¶77).

Functionality and Market Context

The complaint alleges that the accused products embody the claimed technologies. For the ’809 Patent, the relevant functionality is the physical architecture of the image sensors within the devices (Compl. ¶43). For the ’948 Patent, it is the software functionality allowing users to share their location through a messaging application for display on a map (Compl. ¶61). For the ’708 Patent, it is the ability of a primary device (like an iPhone) to wirelessly connect to another system to provide it with dynamic content and services (Compl. ¶79). The complaint does not provide further technical details on the operation of these features.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint states that claim charts for the asserted patents are attached as Exhibits D, E, and F; however, these exhibits were not included with the complaint document itself (Compl. ¶43, ¶61, ¶79). The analysis below is therefore based on the narrative allegations.

’809 Patent Infringement Allegations

The complaint alleges that the image sensors incorporated into the accused Apple products contain all the structural limitations of claim 1 (Compl. ¶43). The infringement theory appears to rest on the assertion that these sensors are manufactured with a physical architecture that includes trenches on the backside of the semiconductor substrate filled with a light-blocking material, as well as a distinct second light-blocking and isolation structure between photodiodes that vertically overlaps the first, thereby mapping directly onto the claim elements (Compl. ¶42). The core of this allegation is a direct correspondence between the claimed microscopic structure and the physical structure of the accused sensors.

’948 Patent Infringement Allegations

The complaint alleges that the accused Apple products, when operating together (e.g., using Apple Maps and iMessage), form the claimed "navigation system" (Compl. ¶59, ¶61). The infringement theory is that the device's operating system and associated applications function as the claimed "control module" that includes both navigation and messenger programs. It further alleges these devices use their wireless radios as the "communication module" to send and receive location data, and their screens as the "output module" to display that data on a map, thus meeting all limitations of claim 1 (Compl. ¶60).

Identified Points of Contention

  • Scope Questions: A primary question for the ’948 Patent will be whether a general-purpose operating system running separate, distinct applications (e.g., Apple Maps and iMessage) can be considered a single "control module including a messenger program and a navigation program" as recited in the claim. The defense may argue that this claim language requires a more tightly integrated, monolithic software architecture. For the ’708 patent, a similar question arises as to whether a general-purpose smartphone tethered to another device constitutes the claimed "computer implemented navigation device."
  • Technical Questions: For the ’809 Patent, the dispute will likely center on highly technical, evidentiary questions. The plaintiff will need to prove, through reverse engineering or discovery, that the microscopic structures within Apple's sensors precisely match the claimed architecture, including the specific composition and relative positioning of the "first light blocking layer," the "second light blocking layer," and the "isolation layer," as well as their required "vertical overlap."

V. Key Claim Terms for Construction

For the ’809 Patent

  • The Term: "a second light blocking layer, wherein the second light blocking layer includes an isolation layer" (Claim 1).
  • Context and Importance: This term is critical because infringement depends on whether a structural feature used for electrical isolation between pixels in the accused sensors is also legally considered part of a "second light blocking layer." Practitioners may focus on this term to dispute whether the accused products have the specific two-part structure claimed or merely separate isolation and light-blocking features.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not appear to strictly define what materials constitute a "light blocking layer," which may support an argument that any structure that performs this function, including an isolation layer, falls within the term's scope.
    • Evidence for a Narrower Interpretation: The claim recites the layer includes an isolation layer, suggesting the two are not coextensive. The detailed description also depicts the isolation layer 101 as a distinct structure (’809 Patent, Fig. 1; col. 3:41-45). This could support an argument that the claim requires a composite structure not present in the accused devices.

For the ’948 Patent

  • The Term: "a control module including a messenger program and a navigation program" (Claim 1).
  • Context and Importance: The definition of this term is central to whether software on a general-purpose device like an iPhone infringes. Practitioners may focus on this term because the case may turn on whether the loosely coupled interaction between two separate apps satisfies the "including" requirement, or if a single, integrated software module is required.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes the control module in functional terms, stating it "processes messenger information transmitted through the messenger program using the navigation program" (’948 Patent, col. 4:1-4). This functional language may support a broader interpretation that covers the interoperability of separate applications.
    • Evidence for a Narrower Interpretation: The block diagram in Figure 1 depicts the "CONTROL MODULE" as a single, discrete box within the "NAVIGATION DEVICE 1" (’948 Patent, Fig. 1). This depiction could support a narrower construction requiring a single, unified software component.

VI. Other Allegations

Indirect Infringement

For all three patents, the complaint alleges induced infringement, stating that Apple encourages infringement through its advertising, marketing, product manuals, and technical support (Compl. ¶49, ¶67, ¶85). The complaint also pleads contributory infringement, alleging the accused products are a material component of the invention, are not staple articles of commerce suitable for substantial non-infringing use, and are specifically designed to practice the patent claims (Compl. ¶50, ¶68, ¶86).

Willful Infringement

The willfulness allegations for all three patents are based on Apple having knowledge of the patents and the alleged infringement "no later than the filing of this Complaint" (Compl. ¶45, ¶63, ¶81). This suggests the claim for willful infringement is prospective, based on alleged continuation of infringement after the suit was filed.

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

  • A core issue will be one of architectural scope: for the software-related ’948 Patent, can the functional interoperability between separate applications on a general-purpose operating system be construed as the integrated "control module including a messenger program and a navigation program" required by the claim, or is there a fundamental mismatch in software architecture?
  • A key evidentiary question will be one of structural identity: for the hardware-related ’809 Patent, will discovery and technical analysis reveal that the microscopic layers within the accused image sensors have the exact physical arrangement and overlapping relationship of the multiple "light blocking layers" and "isolation layer" recited in claim 1?
  • A central definitional question will be one of system classification: for the ’948 and ’708 patents, can a multipurpose consumer device like a smartphone or tablet, for which navigation is one of many functions, be properly categorized as the "navigation device" claimed in the patents, or does the intrinsic evidence limit the claims to a more specialized class of devices?