KT Imaging has filed six complaints against HP, Acer America Corporation, ASUSTeK Computer Inc., Dynabook, LG Electronics, Inc., and Samsung Electronics Co., for patent infringement. The complaints were filed in the Texas Eastern and Western District Courts. KT Imaging is represented by The Stafford Davis Firm and Kheyfits Belenky. The cases were brought against laptop and smartphone manufacturers who designed phones with cameras mounted on circuit boards.
The patents-in-suit are U.S. Patent Nos. 6,876,544 (“the ’544 Patent”), 7,196,322 (“the ’322 Patent”), 8,004,602 (“the ’602 Patent”), 8,314,481 (“the ’481 Patent”), 6,590,269(“the ’269 Patent”), and the 7,511,261 (“the ’261 Patent”). KTI is the owner and assignee of said patents.
KTI alleges that HP, ASUSTeK Computer, Dynabook, LG, and Samsung infringe on at least claim 1 of the ’544 patent by “including an image sensor module to be mounted to a printed circuit board in the” Accused Products. Further, KT Imaging states that the “image sensor module in the Accused Products comprises a substrate having an upper surface formed with a plurality of first connection points and a lower surface formed with a plurality of second connection points, which is electrically connected to the printed circuit board.” KTI makes similar claims against the same five defendants with regards to claiming 1 of the ‘322 patent.
In a claim common to all six cases, KT Imaging alleges infringement of the ’602 patent, specifically at least claim 1 of the patent by “including an image sensor structure with an integrated lens module in the” Accused Products. This image sensor “comprises a chip having a plurality of light-sensing elements arranged on a light sensing area of a first surface of the chip, a plurality of first conducting pads arranged around the light-sensing area and electrically connected to the light-sensing elements.” This image sensor on the Accused Products allegedly utilizes KT’s patented technology.
KTI additionally alleges that smartphone manufacturers LG and Samsung infringe on at least claim 2 of the ’269 patent by including a front or rear “facing package structure including a photosensitive chip in the” LG G5 and Samsung Note 3 products, respectively. Additionally, the front and rear “facing package structure[s] further [comprise] a plurality of wires for electrically connecting the substrate to the photosensitive chip.” KT Imaging claims that these elements are part of its patent, and as a result, LG and Samsung infringe the ’269 patent.
The plaintiff alleges that these infringements were willful and that they also induced infringement when others used, sold, and imported its infringing products. They have sought judgment in its favor and a finding that the defendants willfully infringed, an order permanently enjoining the companies from further infringing the patents-in-suit, an award for damages, an award for costs and fees, pre- and post-judgment interest, and other relief as determined by the court.
