DCT
2:23-cv-00053
Amazon.com Inc v. LightGuide Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Amazon.com, Inc. and Amazon.com Services LLC (Delaware / Washington)
- Defendant: LightGuide, Inc. (Delaware / Michigan)
- Plaintiff’s Counsel: Hueston Hennigan LLP; Perkins Coie LLP
- Case Identification: 2:23-cv-00053, W.D. Wash., 01/10/2023
- Venue Allegations: Plaintiff Amazon alleges venue is proper in the Western District of Washington as it is where Amazon is headquartered, where the accused technology is practiced, where Defendant LightGuide pitched its products to Amazon, and where agreements with relevant forum-selection clauses were executed.
- Core Dispute: Plaintiff seeks a declaratory judgment that its "Nike System" for guiding warehouse workers does not infringe three of Defendant’s patents related to augmented reality systems that use projected light for manual task guidance.
- Technical Context: The technology involves using projectors to cast light-based visual cues onto work surfaces and objects to guide personnel in complex industrial tasks like product assembly or order fulfillment.
- Key Procedural History: This declaratory judgment action was filed by Amazon in response to a patent infringement lawsuit initiated by LightGuide against Amazon on November 7, 2022, in the Eastern District of Texas. The complaint notes pre-suit correspondence, including an October 2021 demand letter from LightGuide, and highlights Amazon's position that it independently developed the accused system before any contact with LightGuide.
Case Timeline
| Date | Event |
|---|---|
| 2005-10-07 | ’981 Patent Priority Date |
| 2009-04-07 | '981 Patent Issue Date |
| 2011-02-11 | ’614 and ’036 Patents Priority Date |
| 2015-01-01 | Amazon begins development of the Nike System |
| 2016-06-01 | Amazon installs its first Nike System in a fulfillment center |
| 2016-01-01 | Discussions between Amazon and LightGuide begin |
| 2017-05-23 | '614 Patent Issue Date |
| 2018-01-01 | LightGuide sends a projector product to an Amazon facility |
| 2020-01-07 | '036 Patent Issue Date |
| 2021-10-11 | LightGuide sends demand letter to Amazon |
| 2022-11-07 | LightGuide files patent infringement suit against Amazon in E.D. Texas |
| 2023-01-10 | Amazon files this Complaint for Declaratory Relief |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,515,981 - Light Guided Assembly System (Issued Apr. 7, 2009)
The Invention Explained
- Problem Addressed: The patent addresses the challenge of ensuring human workers perform pre-designated operational steps correctly and within a standard time allowance, noting that failures lead to significant cost, complexity, and potential for scrapping or reworking products (’981 Patent, col. 1:20-34).
- The Patented Solution: The invention is an "operational guide system" that uses sensors to identify a workpiece, a controller to process that information, and at least one "directional light device" to project an "indicating light" onto a physical location to guide an operator through a sequence of tasks (’981 Patent, Abstract; Fig. 1). For example, it can illuminate a specific parts bin for picking and then illuminate the precise location on the workpiece for assembly (’981 Patent, col. 4:46-59).
- Technical Importance: The system provides a flexible, computer-guided method to improve the accuracy and efficiency of manual tasks in complex environments like assembly lines, reducing the potential for human error (’981 Patent, col. 4:50-col. 5:2).
Key Claims at a Glance
- The complaint notes that LightGuide’s prior suit asserted independent claim 12 (Compl. ¶38).
- Essential elements of independent method claim 12 include:
- Identifying a characteristic of a work piece requiring assembly actions.
- Communicating identification information to a controller.
- Communicating a first command signal to a directional light device.
- Selectively projecting an indicating light via the light device in response to the command signal.
- Communicating a confirmation signal to the controller upon completion of a first operation step.
- The complaint seeks a declaration of non-infringement of the ’981 Patent generally, which may implicate other claims (Compl. ¶¶ 47, 50).
U.S. Patent No. 9,658,614 - Light Guided Assembly System and Method (Issued May 23, 2017)
The Invention Explained
- Problem Addressed: This patent, from the same family, continues to address the need for error-proofing in manual human activities, from manufacturing to logistics, where omitting or improperly performing steps adds cost and risk (’614 Patent, col. 1:21-42).
- The Patented Solution: The invention evolves the concept by formally introducing a more data-driven architecture. It describes a guide system controller that includes a plurality of "addressed display features" (e.g., pre-programmed instructions or graphics) and "positional identifiers" (e.g., coordinates on a workpiece). An input signal, potentially from a high-level Manufacturing Execution System (MES), causes the controller to select a specific display feature and project it as a visual indicator to a specific location on a physical object (’614 Patent, Abstract; col. 13:13-25). This structure is illustrated in the patent's Figure 3A, which depicts a table mapping display features (like "Inspect" or "Pick") to address identifiers.
- Technical Importance: This patent describes a more integrated system capable of dynamically generating real-time, augmented-reality work instructions based on data from factory-wide software, increasing the system's flexibility and power (’614 Patent, col. 14:40-49).
Key Claims at a Glance
- The complaint notes that LightGuide’s prior suit asserted claim 11 (Compl. ¶38). Claim 11 depends from independent claim 1.
- Essential elements of independent method claim 1 include:
- Providing a guide system with a controller and a projector, where the controller includes a plurality of selectable "addressed display features."
- Receiving a sequence of input signals at the controller.
- Selecting one or more addressed display features based on the input signals.
- Projecting one or more visual indicators corresponding to the selected features onto one or more physical objects.
- Claim 11 adds further limitations related to using a sensor apparatus to detect completion of an action and generate a confirmation signal. The complaint seeks a broad declaration of non-infringement of the ’614 Patent (Compl. ¶¶ 52, 55).
U.S. Patent No. 10,528,036 - Light Guided Assembly System and Method (Issued Jan. 7, 2020)
- Technology Synopsis: As a continuation of the ’614 Patent, this patent further details a system and method for guiding an individual's actions by projecting visual indicators. It emphasizes the use of a guide system controller that receives an input signal, selects from a plurality of "addressed display features" and "positional identifiers" based on that signal, and causes a projector to display a corresponding visual indicator at a specific location on a physical object to guide the user (’036 Patent, Abstract).
- Asserted Claims: The complaint states LightGuide’s prior suit asserted independent system claim 7 (Compl. ¶38).
- Accused Features: The complaint alleges that LightGuide accuses Amazon's Nike System, which uses projected lights to guide pick-and-stow activities in fulfillment centers, of infringement (Compl. ¶¶ 15-19, 26).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is Amazon’s "Nike System," which is a process and technology suite used to improve pick and stow operations in its fulfillment centers (Compl. ¶¶ 3, 11).
Functionality and Market Context
The complaint describes the Nike System as a multi-faceted improvement over traditional, manual-scanner-based workflows (Compl. ¶25). Its relevant functionality includes the use of lights, which Amazon characterizes as a "minor element" of the overall system (Compl. ¶26). At "stow" stations, the system projects magenta lights onto storage bins to indicate to an associate where not to place an item (Compl. ¶26). At "pick" stations, it projects a white light to indicate the specific bin from which an item should be retrieved (Compl. ¶26). The complaint includes an image of an associate at a stow station using a mounted scanner while magenta lights illuminate several bins on a storage pod. This image shows the magenta lights indicating bins to be avoided for stowing (Compl. ¶27, p. 8). Another image depicts the general associate workstation, including the mounted scanner and storage pods (Compl. ¶24, p. 7). Amazon alleges this system was independently developed and first installed in June 2016, prior to substantive discussions with LightGuide (Compl. ¶¶ 21, 28).
IV. Analysis of Infringement Allegations
U.S. Patent No. 7,515,981 Infringement Allegations
| Claim Element (from Independent Claim 12) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| identifying a characteristic of a work piece requiring assembly actions; | The Nike System identifies an item to be stowed or an order to be picked, which dictates the subsequent physical action. | ¶25 | col. 4:38-41 |
| communicating identification information to a controller... | The system's software and scanner infrastructure processes item and order data to determine the required pick or stow guidance. | ¶25 | col. 4:41-45 |
| communicating a first command signal to at least one directional light device... | The system controller sends a signal to the overhead light projectors to illuminate specific bins. | ¶26 | col. 4:50-53 |
| selectively projecting at least one indicating light via the directional light device in response to the first command signal; | The projectors shine white light on a bin for picking, or magenta lights on bins to be avoided for stowing. | ¶26 | col. 4:53-56 |
| communicating a confirmation signal to the controller upon completion of a first operation step. | The complaint alleges a machine-learning algorithm automatically determines which bin received an item, which may be argued to function as a confirmation. | ¶25 | col. 5:29-35 |
U.S. Patent No. 9,658,614 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing a guide system having a guide system controller and a projector, said guide system controller including a plurality of selectable addressed display features... | The Nike System includes software controllers and overhead projectors; LightGuide may argue that the pick/stow light instructions constitute "addressed display features." | ¶¶3, 25, 26 | col. 14:40-49 |
| receiving a sequence of one or more input signals at said guide system controller... | The system receives data about the item to be picked or stowed, which serves as the input to trigger the light guidance. | ¶25 | col. 13:18-21 |
| selecting one or more particular addressed display features... based on said input signals... | Based on the item data, the system selects either the "pick here" (white light) or "don't stow here" (magenta light) instruction. | ¶26 | col. 14:50-55 |
| projecting one or more visual indicators corresponding to said selected particular addressed display features onto one or more physical objects... | The projectors display the white or magenta lights onto the physical storage pod bins to guide the associate. | ¶¶26, 27 | col. 15:35-44 |
Identified Points of Contention
- Scope Questions: A central question for the ’614 and ’036 patents will be whether Amazon’s relatively simple "pick here" or "don't stow here" light signals qualify as "addressed display features" selected from a "plurality" as contemplated by the patents, which describe more complex, data-driven VDF tables (see '614 Patent, Fig. 3A). The complaint's description of the Nike System may support an argument that its functionality is fundamentally simpler than the patented method.
- Technical Questions: A key factual dispute will concern the "confirmation signal" step of the ’981 Patent. The complaint states the Nike System uses cameras and machine learning to "automatically determine which bin on a pod had received an item" (Compl. ¶25). The court may need to determine if this automated detection constitutes the "communicating a confirmation signal" required by the claim, or if the claim requires a more discrete, operator-initiated signal as exemplified by the patent's discussion of a foot pedal (’981 Patent, col. 5:30-35).
- Functional Mismatch: The complaint alleges that for stowing, the Nike System uses magenta lights to show where an associate should not place an item (Compl. ¶26). This presents a question of whether a negative instruction ("don't stow here") falls within the scope of claims that describe projecting an "indicating light" to "guide the operator," which may be interpreted as implying positive guidance ("stow here").
V. Key Claim Terms for Construction
"confirmation signal" (’981 Patent, Claim 12)
- Context and Importance: The existence of this step is a prerequisite for infringement of method claim 12. Whether the Nike System's automated camera-based detection of item placement meets this limitation will be a critical point of dispute. Practitioners may focus on this term because the patent discloses both manual (foot pedal) and automated (vision system) embodiments, creating ambiguity.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests that a confirmation signal can be generated automatically by a "vision system that is able to detect the presence or absence of a component at a location" (’981 Patent, col. 10:46-49). This could support reading the term on Amazon's automated system.
- Evidence for a Narrower Interpretation: The primary embodiment described for operator confirmation is a "foot pedal 30" that the operator "simply depresses...upon completion of the directed activity" (’981 Patent, col. 10:10-16). This could support an argument that the signal must be a discrete, operator-initiated event separate from the primary task itself.
"addressed display feature" (’614 Patent, Claim 1)
- Context and Importance: This term is at the core of the asserted '614 and '036 patents and represents a key evolution from the earlier '981 patent. The infringement analysis will turn on whether Amazon's system of projecting simple colored lights constitutes selecting from a plurality of "addressed display features."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states the feature can be a "display graphic or visual display feature ('VDF') exhibited by an indicating light" (’614 Patent, col. 9:8-12). One might argue this broad language encompasses any projected graphic, including a simple colored light.
- Evidence for a Narrower Interpretation: The specification's detailed embodiment is a "VDF address table" (Fig. 3A) where numerous, distinct features (e.g., "Inspect," "Align," "Torque," "Pick," along with associated videos and drawings) are stored and selected via unique identifiers (’614 Patent, col. 15:23-34). This suggests "addressed display feature" requires a more complex, pre-programmed, database-like structure that Amazon will argue its Nike System lacks.
VI. Other Allegations
Indirect Infringement
The complaint makes conclusory denials of contributory and induced infringement (Compl. ¶¶ 47, 52, 57). As this is a declaratory judgment action focused on Amazon's own use of the Nike System, the complaint does not provide specific facts regarding LightGuide's potential allegations of indirect infringement.
Willful Infringement
The complaint, being filed by the accused infringer, does not contain an allegation of willfulness. However, it establishes a timeline of LightGuide's allegations that would be relevant to a future willfulness claim by LightGuide. The complaint acknowledges LightGuide's October 11, 2021 demand letter and the filing of the Texas lawsuit on November 7, 2022, both of which establish Amazon's knowledge of the patents-in-suit (Compl. ¶¶ 36, 38).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of independent development versus copying: The complaint frames a core factual dispute around Amazon's claim to have developed and deployed its Nike System before any substantive contact with LightGuide. While not a formal defense to infringement, this narrative will likely be central to the litigation and could influence damages or a willfulness analysis.
- A key question of claim scope will be whether the relatively simple light projections of the Nike System—particularly the negative guidance of "do not stow here"—fall within the definition of the patents' "indicating light" and "addressed display feature" limitations, which appear to describe more complex, positive guidance.
- The case will also turn on a functional and definitional question: Does the Nike System’s automated, camera-based process for detecting where an item has been placed constitute the "communicating a confirmation signal" step required by the '981 patent, or does the claim require a more explicit, separate action by the operator?