DCT

1:02-cv-01132

Luma Corp v. Stryker Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:02-cv-01132, S.D.W. Va., 09/11/2002
  • Venue Allegations: The complaint does not specify the basis for venue, asserting only that it is proper pursuant to 28 U.S.C. §§ 1391(b), (c), (d) and/or 1400(b).
  • Core Dispute: Plaintiff alleges that Defendants’ devices and components infringe a patent related to managing information and user preferences in endoscopy systems.
  • Technical Context: The technology concerns integrated medical imaging systems that allow for the capture, processing, and display of images during procedures like endoscopy, customized to the preferences of individual users or specific procedures.
  • Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other significant procedural events.

Case Timeline

Date Event
1993-03-31 U.S. Patent No. 5,740,801 Priority Date
1998-04-21 U.S. Patent No. 5,740,801 Issue Date
2002-09-11 Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 5,740,801, MANAGING INFORMATION IN AN ENDOSCOPY SYSTEM, issued April 21, 1998.

The Invention Explained

  • Problem Addressed: The patent's background section notes that during endoscopic procedures, different physicians often use video equipment in different ways, implying a need for customization and efficiency in system setup and operation (Compl. Ex. A, ’801 Patent, col. 1:33-35).
  • The Patented Solution: The invention is a system for managing medical images that uses a central "preference database" to store user-specific information. This database contains settings for how images should be acquired, processed, and displayed for each user, procedure, or device (Compl. Ex. A, ’801 Patent, Abstract; col. 1:36-47). The system's processor responds to the identity of the current user, retrieves their preferences, and automatically configures the input and output devices accordingly. Figure 1 of the patent illustrates this architecture, showing a central Personal Computer (12) connected to a Preference Database (20) that governs the operation of various image input (16) and output (18) devices (Compl. Ex. A, ’801 Patent, Fig. 1).
  • Technical Importance: This approach aimed to standardize and streamline the use of complex video endoscopy equipment in operating rooms, allowing for rapid, repeatable, and personalized system configurations for different surgeons and medical procedures (Compl. Ex. A, ’801 Patent, col. 3:24-29).

Key Claims at a Glance

  • The complaint does not specify which claims are asserted. Independent claim 1 is a representative system claim.
  • Independent Claim 1 elements include:
    • At least one input device for obtaining images.
    • At least one output device for communicating image data to a medical practitioner.
    • A preference database for pre-storing, for each of a plurality of users, respective preference information indicating one or more processing operations and a configuration of at least one of the input and output devices.
    • The preference information further indicates a sequence of images to be obtained during the medical procedure.
    • The system includes means for prompting the user to obtain the images in said sequence.
    • A processor for receiving an indication of a user's identity, retrieving that user's preference information, performing processing operations on the images, and establishing the configuration of the devices based on that retrieved information.

III. The Accused Instrumentality

Product Identification

  • The complaint does not identify any specific accused product(s), method(s), or service(s) by name (Compl. ¶¶ 10-12).

Functionality and Market Context

  • The complaint alleges in general terms that the defendants make, use, sell, or import "devices and components protected by the '801 patent" (Compl. ¶¶ 10-12). No specific functionalities of any accused products are described.
  • The complaint does not provide sufficient detail for analysis of the accused instrumentalities' market context.

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for a claim chart summary. The allegations are conclusory and do not map any specific features of an accused product to the elements of any asserted patent claim (Compl. ¶14).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint provides no basis for claim construction analysis. However, based on the patent's disclosure, any dispute would likely involve the following terms from the independent claims:

  • The Term: "preference database"

  • Context and Importance: This term is the central component of the claimed invention. Its construction will determine what types of data storage and retrieval systems fall within the scope of the claims. Practitioners may focus on this term because the scope could depend on whether the "database" must be a formally structured, relational database or could encompass simpler data structures like configuration files or linked records as described in the patent.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent describes the preference information as being stored in a "plurality of linked records," which may suggest that a formal database structure is not required (Compl. Ex. A, ’801 Patent, col. 2:20-24).
    • Evidence for a Narrower Interpretation: The detailed description refers to the database using specific schema definitions, such as the "what/Its" schema, and discusses its relational nature, which could support an argument that a more structured data-management system is required (Compl. Ex. A, ’801 Patent, col. 39:20-40:65; Fig. 21).

  • The Term: "identity of one of said users"

  • Context and Importance: The system's operation is triggered by receiving a user's "identity." The definition of this term is critical for determining how the system must recognize a user to infringe. The question is whether this requires an explicit login or if it can be inferred by other means.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent summary states the processor responds to the identity of the user "or the identity of a medical procedure that is currently to be performed," suggesting "identity" is not strictly limited to a specific person but can be context-based (Compl. Ex. A, ’801 Patent, col. 2:3-8).
    • Evidence for a Narrower Interpretation: The detailed description repeatedly discusses a user login process with a user name and password, which implies that a specific, authenticated user identification is contemplated (Compl. Ex. A, ’801 Patent, col. 38:1-6).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges contributory and induced infringement but provides no specific facts to support the requisite knowledge or intent (Compl. ¶14).
  • Willful Infringement: The complaint alleges that the defendants' infringement "has been and continues to be willful and deliberate" but does not plead any facts to support this assertion, such as pre-suit knowledge of the patent (Compl. ¶16).

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

Given the limited detail in the complaint, the initial phase of this case will likely focus on procedural and foundational issues before reaching technical disputes. The central questions are:

  • Product Identification: The primary threshold question is one of specificity: what specific products or systems are accused of infringement? Without this identification, no meaningful technical analysis of infringement can occur.
  • Definitional Scope: A core issue will be one of technical scope: assuming accused products are identified, does their method for storing and applying user- or procedure-specific settings meet the claimed "preference database" limitation, or do they use a fundamentally different architecture for system configuration?
  • Evidentiary Basis: A key challenge for the plaintiff will be one of evidence: what facts will be presented to support the conclusory allegations of indirect and willful infringement, which require showing that the defendants had knowledge of the '801 patent and intended to cause infringement?