DCT

2:23-cv-00001

Cedar Lane Tech Inc v. Alps Alpine North America Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00001, W.D. Wash., 01/01/2023
  • Venue Allegations: Venue is alleged to be proper as Defendant maintains an established place of business in the Western District of Washington and has allegedly committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that certain of Defendant's products infringe patents related to a host interface for managing data transfer between an image sensor and a processor system.
  • Technical Context: The technology addresses the challenge of efficiently connecting a CMOS image sensor, which produces a constant stream of data, to a general-purpose computer processor, which accesses data asynchronously.
  • Key Procedural History: U.S. Patent No. 8,537,242 is a divisional of the application that issued as U.S. Patent No. 6,972,790. Both patents claim priority to the same provisional application.

Case Timeline

Date Event
2000-01-21 Priority Date for '790 and '242 Patents
2000-12-21 Application for '790 Patent Filed
2005-10-27 Application for '242 Patent Filed
2005-12-06 '790 Patent Issued
2013-09-17 '242 Patent Issued
2023-01-01 Complaint Filed

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

U.S. Patent No. 6,972,790, "Host interface for imaging arrays," issued Dec. 6, 2005

  • The Invention Explained:
    • Problem Addressed: The patent’s background section describes an incompatibility between image sensors, which typically provide a continuous "video style output," and commercial microprocessors, which are designed for random access to memory. This mismatch historically required "additional glue logic" and circuitry, diminishing the cost-effectiveness of integrating imaging and processing components on a single CMOS chip (ʼ790 Patent, col. 1:47-60).
    • The Patented Solution: The invention is an interface that decouples the image sensor from the processor system. It uses a memory, such as a First-In First-Out (FIFO) buffer, to store incoming image data at the rate determined by the sensor's clocking signals. A signal generator then monitors the amount of data in the memory and, in response, sends a signal (e.g., an interrupt) to the processor system, which can then retrieve the buffered data at its own pace (ʼ790 Patent, Abstract; col. 2:3-14).
    • Technical Importance: This interface architecture is intended to simplify the integration of an image sensor into a computer system, thereby reducing the cost and complexity that would otherwise be required to bridge the different operational styles of the sensor and the processor (ʼ790 Patent, col. 1:60-67).
  • Key Claims at a Glance:
    • The complaint asserts "one or more claims" of the '790 Patent (Compl. ¶12). Independent claim 1 is representative and recites:
      • An interface for receiving data from an image sensor and transferring it to a processor system, comprising:
      • a memory for storing imaging array data and clocking signals at a rate determined by the clocking signals;
      • a signal generator for generating a signal for transmission to the processor system in response to the quantity of data in the memory; and
      • a circuit for controlling the transfer of the data from the memory at a rate determined by the processor system.
    • The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶12).

U.S. Patent No. 8,537,242, "Host interface for imaging arrays," issued Sep. 17, 2013

  • The Invention Explained:
    • Problem Addressed: As a divisional of the '790 Patent's application, the '242 Patent addresses the same technical problem: the incompatibility between the continuous data stream from an image sensor and the asynchronous access model of a microprocessor, which necessitates additional interface logic (ʼ242 Patent, col. 1:44-51).
    • The Patented Solution: The '242 Patent describes a method for processing imaging signals that mirrors the system of the '790 Patent. The method involves receiving and storing image data in a FIFO memory, using a counter to track the amount of data, comparing that count to a preset limit, and then generating an interrupt to prompt a processor to transfer the buffered data (ʼ242 Patent, Abstract; col. 7:55-8:2).
    • Technical Importance: The method provides a structured process for managing data flow between a sensor and a processor, aiming to achieve the same benefits of simplified integration and reduced cost as the system described in the parent patent (ʼ242 Patent, col. 1:55-63).
  • Key Claims at a Glance:
    • The complaint asserts "one or more claims" of the '242 Patent (Compl. ¶21). Independent claim 1 is a representative method claim and recites steps for:
      • receiving image data from an imaging array;
      • storing the image data in a FIFO memory;
      • updating a FIFO counter to maintain a count of the data;
      • comparing the FIFO counter's count with a FIFO limit;
      • generating an interrupt signal to a processor in response to the comparison and a valid interrupt enable signal; and
      • transferring the image data from the FIFO memory to the processor in response to the interrupt.
    • The complaint reserves the right to assert other claims (Compl. ¶21).

III. The Accused Instrumentality

  • Product Identification: The complaint does not name specific accused products. It refers to "Exemplary Defendant Products" that are identified in claim chart exhibits incorporated by reference into the complaint (Compl. ¶¶12, 21). These exhibits were not filed with the public complaint.
  • Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context, beyond the general allegation that they are made, used, sold, or imported by Defendant and infringe the patents-in-suit (Compl. ¶¶12, 21).

IV. Analysis of Infringement Allegations

The complaint alleges infringement by incorporating by reference claim charts in Exhibits 3 and 4, which were not publicly filed. As such, a detailed claim chart summary cannot be constructed. The narrative infringement theory is summarized below.

No probative visual evidence provided in complaint.

'790 Patent Infringement Allegations

The complaint alleges that Defendant's "Exemplary Defendant Products" directly infringe the '790 Patent by containing systems that satisfy all elements of the asserted claims (Compl. ¶¶12, 17). The core of the narrative theory is that these products include an interface with a memory for buffering image data, a signal generator that is responsive to the amount of data in that memory, and a control circuit for transferring the data to a processor, thereby practicing the invention claimed in the '790 Patent.

'242 Patent Infringement Allegations

The complaint alleges that Defendant's products directly infringe the '242 Patent by performing the steps of the asserted method claims (Compl. ¶¶21, 26). The narrative theory suggests that the normal operation of the accused products involves receiving image data, storing it in a FIFO-type memory, monitoring the data level with a counter and limit, generating an interrupt signal based on that monitoring, and transferring the data to a processor, thereby practicing the claimed method.

  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the components within the accused products can be fairly characterized as the elements required by the claims. For example, the dispute may focus on whether a particular hardware block in the accused device functions as a "signal generator" that operates "in response to the quantity of data in the memory" ('790 Patent, Claim 1), or if its function is triggered by another event.
    • Technical Questions: A key evidentiary question will be whether the accused products' operation matches the specific logic of the claims. For the '242 Patent's method, this raises the question of whether the accused device actually performs the sequence of "updating a FIFO counter," "comparing the count...with a FIFO limit," and then "generating an interrupt signal" as a direct result of that comparison, or if it employs a technically distinct process for managing data transfer.

V. Key Claim Terms for Construction

  • The Term: "a memory for storing imaging array data and clocking signals" ('790 Patent, Claim 1)
    • Context and Importance: The definition of what must be stored in the "memory" is critical for determining infringement. The dispute may turn on whether the accused device's memory stores both data and the literal clock signals, or if it only stores data that is timed by clock signals managed elsewhere.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification discloses an embodiment where the image data, row clock, and frame clock "are bundled onto a single bus... for storage in the buffer," which may support an interpretation that the claim covers storing both data and clock information together (ʼ790 Patent, col. 5:11-14).
      • Evidence for a Narrower Interpretation: An argument could be made that the invention's primary purpose is to buffer "pixel intensities" (ʼ790 Patent, col. 1:45-46), suggesting the "clocking signals" element could be narrowly construed to require storage of the actual clock signals themselves, not just data synchronized with them.
  • The Term: "in response to the quantity of data in the memory" ('790 Patent, Claim 1)
    • Context and Importance: This term establishes a causal link between the state of the memory buffer and the action of the signal generator. Practitioners may focus on this term because infringement requires proof that the signal is triggered by the amount of data, not merely correlated with it.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent describes an embodiment where an "interrupt generator compares the FIFO counter output and the FIFO limit," and asserts an interrupt if the count exceeds the limit. This supports a reading where any mechanism triggered by a data-level threshold (e.g., a high-water mark) would satisfy the limitation (ʼ790 Patent, col. 6:11-15).
      • Evidence for a Narrower Interpretation: A party might argue the claim requires a direct, quantitative assessment of the data amount. The specification’s detailed embodiment shows a counter (Fig. 5, item 54) and a comparator (Fig. 2, item 48), which could be used to argue that systems triggered by a different type of event (e.g., an end-of-frame flag) do not meet this limitation, even if that event reliably occurs when the buffer is full.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for both patents. It claims that Defendant provides "product literature and website materials" that instruct and encourage end users to operate the accused products in a manner that directly infringes the patents (Compl. ¶¶15, 25). The allegations of knowledge and intent are tied to the date of service of the complaint (Compl. ¶¶16, 25).
  • Willful Infringement: The complaint alleges that service of the complaint and its attached claim charts provided Defendant with "actual knowledge" of infringement. It further alleges that despite this knowledge, Defendant continued its infringing activities, which may form the basis for a claim of post-suit willful infringement (Compl. ¶¶14-15, 23-24).

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

  1. Evidentiary Sufficiency: As the complaint's specific infringement allegations are contained in exhibits that were not publicly filed, a primary issue will be factual and evidentiary: can the Plaintiff produce technical evidence demonstrating that the internal architecture and real-world operation of the accused products map onto the specific elements and steps recited in the asserted claims?
  2. Causation and Functional Scope: The infringement analysis for the '790 Patent may turn on a question of causation: does the accused system's mechanism for initiating a data transfer operate "in response to the quantity of data in the memory" as the claim requires, or is it triggered by a different condition? The distinction between direct causation and mere correlation will be a central point of contention.
  3. Methodological Precision: For the method claims of the '242 Patent, a key question will be one of operational equivalence: do the accused products, in their normal function, perform the precise logical sequence of updating a data counter, comparing that count to a predefined limit, and generating an interrupt as a direct result of that comparison, or is there a fundamental mismatch in the technical method employed?