This case was last updated from PACER on 05/31/2021 at 08:42:02 (UTC).

Aperture IP LLC v. FrontPoint Security Solutions LLC

Case Summary

On April 01, 2021, Aperture IP LLC (“Aperture” or “Plaintiff”), represented by Cecil Elvis Key, Jr. of Law Offices of Cecil Key filed an Intellectual property lawsuit against Frontpoint Security Solutions LLC. (“Frontpoint Security'' or “Defendant”), seeking damages, prejudgment and post-judgement interest for unlawful infringement of image Sensor module package structure with supporting element technology owned by Plaintiff. This case was filed in the U.S. District Court for the Eastern District of Virginia with Judges Claude M. Hilton and John F. Anderson presiding. 


The Plaintiff is the legal owner by assignment of all rights, title and interest in numerous United States and foreign patents and applications including United States Patent No. 7,598,580 (the “’580 patent”), entitled “Image Sensor Module Package Structure with Supporting Element.” The Plaintiff has provided a description of ’580 patent in its submissions, including but not limited to the deficiencies addressed and functions performed by the product.


In its complaint, the Plaintiff alleged that “An image sensor module package structure with a supporting element, comprising 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 electrically connected to the light-sensing elements, and at least one conducting channel passing through the chip and electrically connected to the first conducting pads at one end the supporting element, which is a flat plate having an opening, a first coupling surface, and a second coupling surface, wherein the opening corresponds to the light-sensing area and the first coupling surface is combined with the first surface; and a light-transmitting element combines with the second coupling surface. Without license or authorization and in violation of 35 U.S.C. § 271(a), defendant has infringed and continues to infringe the ’580 Patent by making, using, importing, offering for sale, and/or selling the Accused Product”.


The Plaintiff further alleged that “Defendant knowingly or with reckless disregard continues to wilfully infringe the ’580 Patent. Defendant has had actual notice of infringement of the ’580 Patent and has acted, despite an objectively high likelihood that its actions constituted infringement of Plaintiff’s valid patent rights, either literally or equivalently. At least as of service of this Complaint, this objective risk was either known or so obvious that it should have been known to Defendant”.


There is one claim for relief laid down by the Plaintiff, which specifies alleged infringement of ’580 patent because Defendant has knowingly and intentionally contributed to direct infringement by its customers of one or more claims of the ’580 Patent, including, by: (1) providing instructions or information, and (2) touting these uses of the Accused Instrumentalities in advertisements, including but not limited to, those on its website.


In its prayer for relief, the Plaintiff has requested the court to adjudicate that the defendant has allegedly directly, indirectly, and wilfully infringed the ’580 Patent, an award of damages to be paid by the defendant adequate to compensate aperture for defendant's past infringement of the ’580 Patent, and any continuing or future infringement through the date such judgment is entered, including interest, costs, expenses and an accounting of all infringing acts, pre-judgment and post-judgment interest, a declaration that this case is exceptional under 35 U.S.C. § 285, and such further relief at law or in equity as the Court deems just and proper.


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Case Details Parties Documents Dockets


Case Details

  • Case Number:


  • Filing Date:


  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Claude M. Hilton

Referral Judge

John F. Anderson


Party Details


Aperture IP LLC


FrontPoint Security Solutions LLC

Attorney/Law Firm Details

Plaintiff Attorney

Cecil Elvis Key, Jr.

Attorney at Law Offices of Cecil Key

1934 Old Gallows Road, Suite 350

Vienna, VA 22182


Court Documents



7 #1

Proposed Order


6 #1

Notice to Attorney






1 #5

Civil Cover Sheet

1 #4

Exhibit D

1 #3

Exhibit C

1 #2

Exhibit B

1 #1

Exhibit A

6 More Documents Available
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Docket Entries

  • 05/03/2021
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  • Docket(#8) ORDER granting #7 Motion for Extension of Time to File Response/Reply. It is hereby ORDERED that Frontpoint Security SHALL answer, plead, or otherwise respond to the Complaint no later than June 2, 2021. Signed by Magistrate Judge John F. Anderson on 05/03/2021. (wgar, ) (Entered: 05/03/2021)

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  • 04/30/2021
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  • Docket(#7) Consent MOTION for Extension of Time to File Response/Reply as to #1 Complaint by Aperture IP LLC. (Attachments: #1 Proposed Order)(Key, Cecil) (Entered: 04/30/2021)

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  • 04/07/2021
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  • Docket(#6) Summons Issued as to FrontPoint Security Solutions LLC. NOTICE TO ATTORNEY: Print out two Electronically issued summons and one copy of the attachments for each defendant to be served with the complaint. (Attachments: #1 Notice to Attorney)(choy, ) (Entered: 04/07/2021)

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  • 04/01/2021
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  • Docket(#5) Report on the filing or determination of an Trademark action. (choy, )(c/s on 04/01/2021) (Entered: 04/01/2021)

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  • 04/01/2021
  • DocketInitial Case Assignment to District Judge Claude M. Hilton and Magistrate Judge John F. Anderson. (choy, ) (Entered: 04/01/2021)

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  • 04/01/2021
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  • Docket(#4) Proposed Summons re #1 Complaint by Aperture IP LLC. (Key, Cecil) (Entered: 04/01/2021)

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  • 04/01/2021
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  • Docket(#3) NOTICE by Aperture IP LLC re #1 Complaint Report on Filing - Form AO120 (Key, Cecil) (Entered: 04/01/2021)

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  • 04/01/2021
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  • Docket(#2) NOTICE by Aperture IP LLC re #1 Complaint Corporate Disclosure Statement (Key, Cecil) (Entered: 04/01/2021)

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  • 04/01/2021
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  • Docket(#1) Complaint ( Filing fee $ 402, receipt number 0422-7701860.), filed by Aperture IP LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Civil Cover Sheet)(Key, Cecil) (Entered: 04/01/2021)

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