DCT

1:25-cv-00081

VDPP LLC v. Juniper Systems Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00081, D. Utah, 09/30/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Utah because Defendant is a resident of Utah, maintains a regular and established place of business in the district, and has committed alleged acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s image processing and image capture systems, products, and services infringe two expired patents related to electronically controlled spectacles and methods for modifying video images.
  • Technical Context: The patents-in-suit relate to technologies for generating 3D visual effects from 2D video using active shutter glasses and for creating illusions of continuous motion by manipulating and blending video frames.
  • Key Procedural History: The operative pleading is a First Amended Complaint, filed following the Defendant's Motion to Dismiss the original complaint. Plaintiff identifies as a non-practicing entity and notes that both asserted patents have expired, limiting any potential recovery to past damages. The complaint also discloses prior settlement licenses with other entities, stating that none were for the production of a patented article.

Case Timeline

Date Event
2001-01-23 ’452 and ’380 Patents Priority Date
2016-08-23 ’452 Patent Issue Date
2018-07-10 ’380 Patent Issue Date
2022-01-22 ’452 Patent Expiration Date
2022-08-15 ’380 Patent Expiration Date
2025-09-17 Defendant's Motion to Dismiss Filed
2025-09-30 First Amended Complaint Filed

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

U.S. Patent No. 9,426,452 - "Faster State Transitioning for Continuous Adjustable 3Deeps Filter Spectacles Using Multi-Layered Variable Tint Materials"

  • Patent Identification: U.S. Patent No. 9,426,452, “Faster State Transitioning for Continuous Adjustable 3Deeps Filter Spectacles Using Multi-Layered Variable Tint Materials,” issued August 23, 2016 (Compl. ¶7).

The Invention Explained

  • Problem Addressed: The patent specification describes the problem of "slow transition time" in electronically controlled lenses used for creating 3D visual effects from 2D movies. This slowness allegedly prevents the lenses from optimally synchronizing their tint levels with rapid on-screen motion, diminishing the 3D effect. The patent also notes the limited "cycle life" of some optoelectronic materials as a related problem. (’452 Patent, col. 2:25-59).
  • The Patented Solution: The invention proposes using multiple layers of electronically controlled variable tint materials to construct the spectacle lenses. This multi-layer approach is claimed to enable "faster transition times" between light and dark states than a single layer can achieve. This architecture, depicted in Figures 6a and 6b, is also described as a way to increase the operational 'cycle life' of the device. (’452 Patent, col. 2:48-62; Fig. 6a-6b).
  • Technical Importance: This approach was intended to improve the performance and durability of active eyewear for 2D-to-3D video conversion, aiming to make the resulting 3D effect more synchronized and convincing for the viewer. (’452 Patent, col. 2:28-39).

Key Claims at a Glance

  • The complaint asserts claims 1-4, with Claim 1 being the sole independent claim. (Compl. ¶9).
  • Claim 1 recites the essential elements of the apparatus as:
    • a storage adapted to store one or more image frames;
    • a processor adapted to reshape a portion of at least one of the image frames and cause the frames to be displayed; and
    • an electrically controlled spectacle.
  • The complaint notes that its allegations of infringement include "one or more of claims 1-4," reserving the right to assert the dependent claims. (Compl. ¶9).

U.S. Patent No. 10,021,380 - "Faster State Transitioning for Continuous Adjustable 3Deeps Filter Spectacles Using Multi-Layered Variable Tint Materials"

  • Patent Identification: U.S. Patent No. 10,021,380, “Faster State Transitioning for Continuous Adjustable 3Deeps Filter Spectacles Using Multi-Layered Variable Tint Materials,” issued July 10, 2018 (Compl. ¶12).

The Invention Explained

  • Problem Addressed: The patent background addresses the technical challenge of creating "visual illusions of figures and spaces in continuous movement" from a finite number of still pictures, a process which can appear unnatural or require large amounts of data in conventional video. (’380 Patent, col. 7:50-54).
  • The Patented Solution: The invention discloses a method for generating modified video by acquiring a sequence of image frames, creating "modified image frames" (e.g., by expanding them), generating "bridge frames," and then blending the various frames together. The process, illustrated in the flowchart of Figure 32, is intended to create an illusion of "continuous, seamless and sustained directional movement" from a limited set of source images. (’380 Patent, Abstract; col. 8:22-38; Fig. 32).
  • Technical Importance: The described technique offers a method for creating specialized visual effects of smooth motion, potentially using less data than traditional frame-by-frame animation or video capture. (Compl. ¶13; ’380 Patent, col. 8:22-38).

Key Claims at a Glance

  • The complaint asserts claims 1-30. (Compl. ¶14). Claim 1 is an independent method claim.
  • Claim 1 recites the essential steps of the method as:
    • acquiring a source video comprising a sequence of image frames;
    • identifying a first and second image frame from the sequence;
    • expanding the first image frame to generate a first modified image frame;
    • expanding the second image frame to generate a second modified image frame;
    • combining the modified image frames to generate a modified combined image frame having specified dimensions; and
    • displaying the modified combined image frame.
  • The complaint asserts "one or more of claims 1-30," which includes multiple independent apparatus and method claims. (Compl. ¶14).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses Defendant’s "systems, products, and services in the field of image processing" and "image capture devices." (Compl. ¶¶9, 14). A footnote in the complaint points to a URL for Defendant's "CP3" rugged handheld computer, suggesting this product line is at issue. (Compl. ¶2, fn. 1).

Functionality and Market Context

  • The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality. It alleges in a conclusory manner that the products perform infringing methods but does not describe the technical operation of any accused feature. (Compl. ¶¶9, 14).

IV. Analysis of Infringement Allegations

The complaint references preliminary infringement charts attached as Exhibits B and D but does not include them in the provided filing. (Compl. ¶¶10, 15). Accordingly, the infringement theory is summarized below in prose.

No probative visual evidence provided in complaint.

’452 Patent Infringement Allegations

The complaint alleges that Defendant’s systems and services directly infringe the ’452 Patent. (Compl. ¶9). The narrative infringement theory suggests that Defendant’s products constitute the claimed "apparatus" by providing the recited "storage" and "processor" for reshaping and displaying images. (Compl. ¶9). The complaint does not, however, allege any facts regarding the third essential element of the claim: "an electrically controlled spectacle."

’380 Patent Infringement Allegations

The complaint alleges that Defendant’s systems and services, particularly its "image capture devices," directly infringe the ’380 Patent. (Compl. ¶14). The infringement theory is that these devices practice the claimed methods for modifying images. (Compl. ¶13). The complaint does not provide specific factual allegations detailing how the accused devices perform the recited steps of "expanding," "combining," and "displaying" modified image frames.

Identified Points of Contention

  • Scope Questions: For the ’452 Patent, a central question may be whether the claimed "apparatus" requires the processor and the "electrically controlled spectacle" to be part of a single, integrated device. The complaint's failure to identify an accused "spectacle" raises the question of whether the claim can be read on a distributed system where Defendant provides only the image processing components.
  • Technical Questions: For the ’380 Patent, a key technical question will be whether the general image processing performed by the accused devices meets the specific, multi-step process of "expanding" and "combining" frames as recited in Claim 1. The complaint provides no evidence that the accused products perform this specific technical operation.

V. Key Claim Terms for Construction

’452 Patent

  • The Term: "an electrically controlled spectacle"
  • Context and Importance: This term is a required element of the sole independent claim. The complaint provides no facts alleging that Defendant makes, uses, sells, or otherwise provides an "electrically controlled spectacle." Therefore, the construction of this term and its relationship to the other elements of the "apparatus" will be critical to the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim requires an "apparatus comprising... an electrically controlled spectacle," which does not explicitly require all components to be in a single housing. The specification depicts the spectacle receiving wireless signals (110) from an external source, which may support an argument that the claimed "apparatus" is a system of distinct components. (’452 Patent, Fig. 1).
    • Evidence for a Narrower Interpretation: The patent's abstract describes the invention as "An electrically controlled spectacle [that] includes a spectacle frame... and a control unit housed in the frame." (’452 Patent, Abstract). This language, along with figures showing a self-contained device, could support a narrower construction requiring an integrated unit. (’452 Patent, Fig. 1).

’380 Patent

  • The Term: "expanding the first image frame to generate a first modified image frame"
  • Context and Importance: This term recites a core technical step of the claimed method. The dispute will likely focus on whether the image modification functions performed by the accused devices can be characterized as "expanding" in the manner claimed. Practitioners may focus on this term because it appears to be a central action of the claimed invention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "expanding" is not explicitly defined. A party may argue for its plain and ordinary meaning, which could cover a range of image manipulations. The specification mentions creating the appearance of a window "enlarging or shrinking in size," which could support a broader reading beyond a single, specific algorithm. (’380 Patent, col. 10:22-23).
    • Evidence for a Narrower Interpretation: The specification heavily contextualizes the invention as a method for creating specific visual illusions of continuous motion, termed "Eternalisms." (’380 Patent, col. 8:31-38). A party could argue that "expanding" must be construed within this specific, unconventional context and not as any generic image-scaling function.

VI. Other Allegations

The complaint does not contain allegations of willful or indirect infringement.

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

  • A core issue will be one of system scope: can the term "apparatus" in the ’452 Patent, which comprises both a processor and "an electrically controlled spectacle," be construed to cover a system where the defendant allegedly provides only the processing components, with no factual allegations tying them to the required spectacle?
  • A key evidentiary question will be one of operational correspondence: does the functionality of Defendant's accused image capture devices map onto the specific, multi-step method of "expanding" and "combining" image frames to generate a "modified combined image frame," as recited in claim 1 of the ’380 Patent, or is there a fundamental mismatch in technical operation?
  • A central factual question for the litigation will be establishing a nexus: the complaint raises the question of what connection exists between the defendant’s general-purpose rugged computing devices and the highly specialized technologies of 3D-effect spectacles and esoteric video modification techniques described in the patents-in-suit.