This case was last updated from PACER on 11/27/2021 at 08:00:36 (UTC).

KT Imaging USA, LLC v. Apple Inc.

Case Summary

On September 28, 2021, KT Imaging USA, LLC (“KTI” or “Plaintiff”), represented by Stafford Grigsby Helm Davis of The Stafford Davis Firm, PC, filed an intellectual property lawsuit against Apple Inc. (“Apple” or “Defendant”), seeking injunctive relief and damages along with pre-and post-judgement interest for the alleged infringement of various United States Patents owned by the plaintiff. This case was filed in the U.S. District Court in the Western District of Texas.

 

The plaintiff filed this complaint for the alleged infringement of U.S. Patent No. 7,196,322 (“the ’322 Patent”), entitled “Image Sensor Package”, U.S. Patent No. 7,511,261 (“the ’261 Patent”), entitled “Image Sensor Module Structure with Lens Holder Having Vertical Inner and Outer Sidewalls”, U.S. Patent No. 7,598,580 (“the ’580 Patent”), entitled “Image Sensor Module Package Structure with Supporting Element”, U.S. Patent No. 8,004,602 (“the ’602 Patent”), entitled “Image Sensor Structure and Integrated Lens Module Thereof” and U.S. Patent No. 8,314,481 (“the ’481 Patent”), entitled “Substrate Structure for an Image Sensor Package and Method for Manufacturing the Same” (collectively , “Patents-in-suit”) owned by the plaintiff.

 

In the complaint the plaintiff alleged that, “On information and belief, Apple has infringed the ’322 Patent pursuant to 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in the United States or importing into the United States the Accused Products and all other products with substantially similar imaging sensors. On information and belief, Apple has committed the foregoing infringing activities without a license.”

 

The plaintiff further alleged that, “On information and belief, Apple has infringed the ’261 Patent pursuant to 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in the United States, or importing into the United States the Accused Products and all other products with substantially similar imaging sensors. For example, on information and belief, Apple has infringed and continues to infringe at least claim 1 of the ’261 Patent by including an image sensor module structure in the Apple iPhone 6s product.”

 

The plaintiff also alleged that, “On information and belief, Apple has infringed the ’580 Patent pursuant to 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in the United States or importing into the United States the Accused Products and all other products with substantially similar imaging sensors. For example, on information and belief, Apple has infringed and continues to infringe at least claim 1 of the ’580 Patent by including an image sensor module package structure with a supporting element in the Apple iPad Mini 4 product.”

 

Similar allegations have been made by the plaintiff with respect to the other Patents-in-suit.

 

There are five claims for relief laid down by the plaintiff. All of the claims deal with the alleged infringement of the Patents-in-suit owned by the plaintiff.

 

In its prayer for relief the plaintiff has requested the court to permanently enjoin Apple from infringing the Patents-in-Suit. The plaintiff has also requested the court to enter a judgment that Apple has infringed the Patents-in-Suit. Further, the plaintiff requested the court for an award of compensatory damages adequate to compensate KTI for Apple’s infringement of the Patents-in-suit and an award of reasonable attorneys’ fees and expenses against Apple along with prejudgment and post-judgment interest.

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    6:21-CV-01002

  • Filing Date:

    09/28/2021

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent

Judge Details

Presiding Judge

Alan D Albright

 

Party Details

Plaintiff

KT Imaging USA, LLC

Defendant

Apple Inc.

Attorney/Law Firm Details

Plaintiff Attorneys

Stafford Grigsby Helm Davis

Attorney at The Stafford Davis Firm, PC

815 South Broadway Avenue

Tyler, TX 75701

Andrey Belenky

Attorney at Kheyfits Belenky LLP

80 Broad St., 5Th Floor

New York, NY 10004

Brandon Moore

Attorney at Kheyfits Belenky LLP

108 Wild Basin Road South, Suite 250

Austin, TX 78746

Catherine Bartles

Attorney at Stafford Davis Firm, PC

815 S Broadway Ave

Tyler, TX 75701

Dmitry Kheyfits

Attorney at Kheyfits Belenky LLP

108 Wild Basin Road

Austin, TX 78746

Hanna G. Cohen

Attorney at Kheyfits Belenky LLP

1140 Avenue Of The Americas, 9Th Floor

New York, NY 10036

Defendant Attorney

J. Stephen Ravel

Attorney at Kelly Hart & Hallman LLP

303 Colorado Street, Suite 2000

Austin, TX 78701

 

Court Documents

#9

(#9) NOTICE Regarding Agreed Extension to Respond to the Complaint by Apple Inc. re #1 Complaint,,,,,,,, (Ravel, J.) (Entered: 10/14/2021)

1 #102

Civil Cover Sheet

1 #93

Exhibit 91

1 #91

Exhibit 89

1 #90

Exhibit 88

1 #88

Exhibit 86

1 #84

Exhibit 82

1 #79

Exhibit 77

1 #74

Exhibit 72

1 #64

Exhibit 62

1 #59

Exhibit 57

1 #55

Exhibit 53

1 #31

Exhibit 29

1 #24

Exhibit 22

1 #22

Exhibit 20

1 #11

Exhibit 9

1 #8

Exhibit 6

1 #4

Exhibit 2

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Docket Entries

  • 10/14/2021
  • DocketReset Deadlines: Apple Inc. answer due 12/13/2021. (ir) (Entered: 10/14/2021)

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  • 10/14/2021
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  • Docket(#9) NOTICE Regarding Agreed Extension to Respond to the Complaint by Apple Inc. re #1 Complaint,,,,,,,, (Ravel, J.) (Entered: 10/14/2021)

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  • 10/14/2021
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  • Docket(#8) NOTICE of Attorney Appearance by J. Stephen Ravel on behalf of Apple Inc.. Attorney J. Stephen Ravel added to party Apple Inc.(pty:dft) (Ravel, J.) (Entered: 10/14/2021)

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  • 10/08/2021
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  • Docket(#7) Standing Order Regarding Order Governing Proceedings Patent Cases. Signed by Judge Alan D Albright. (Entered: 10/13/2021)

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  • 10/06/2021
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  • Docket(#6) NOTICE of Attorney Appearance by Catherine Bartles on behalf of KT Imaging USA, LLC (Bartles, Catherine) (Entered: 10/06/2021)

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  • 09/29/2021
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  • Docket(#5) Summons Issued as to Apple Inc.. (lad) (Entered: 09/29/2021)

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  • 09/29/2021
  • DocketAll parties shall comply with the Standing Orders located at https://www.txwd.uscourts.gov/judges-information/standing-orders/. (lad) (Entered: 09/29/2021)

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  • 09/28/2021
  • DocketCase assigned to Judge Alan D Albright. CM WILL NOW REFLECT THE JUDGE INITIALS AS PART OF THE CASE NUMBER. PLEASE APPEND THESE JUDGE INITIALS TO THE CASE NUMBER ON EACH DOCUMENT THAT YOU FILE IN THIS CASE. (lad) (Entered: 09/29/2021)

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  • 09/28/2021
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  • Docket(#4) RULE 7 DISCLOSURE STATEMENT filed by KT Imaging USA, LLC. (Davis, Stafford) (Entered: 09/28/2021)

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  • 09/28/2021
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  • Docket(#3) Notice of Filing of Patent/Trademark Form (AO 120). AO 120 forwarded to the Director of the U.S. Patent and Trademark Office. (Davis, Stafford) (Entered: 09/28/2021)

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  • 09/28/2021
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  • Docket(#2) REQUEST FOR ISSUANCE OF SUMMONS by KT Imaging USA, LLC. re Apple Inc. (Davis, Stafford) (Entered: 09/28/2021)

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  • 09/28/2021
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  • Docket(#1) COMPLAINT for Patent Infringement ( Filing fee $ 402 receipt number 0542-15275484), filed by KT Imaging USA, LLC. (Attachments: #1 Exhibit Attachment A, #2 Exhibit Attachment B, #3 Exhibit 1, #4 Exhibit 2, #5 Exhibit 3, #6 Exhibit 4, #7 Exhibit 5, #8 Exhibit 6, #9 Exhibit 7, #10 Exhibit 8, #11 Exhibit 9, #12 Exhibit 10, #13 Exhibit 11, #14 Exhibit 12, #15 Exhibit 13, #16 Exhibit 14, #17 Exhibit 15, #18 Exhibit 16, #19 Exhibit 17, #20 Exhibit 18, #21 Exhibit 19, #22 Exhibit 20, #23 Exhibit 21, #24 Exhibit 22, #25 Exhibit 23, #26 Exhibit 24, #27 Exhibit 25, #28 Exhibit 26, #29 Exhibit 27, #30 Exhibit 28, #31 Exhibit 29, #32 Exhibit 30, #33 Exhibit 31, #34 Exhibit 32, #35 Exhibit 33, #36 Exhibit 34, #37 Exhibit 35, #38 Exhibit 36, #39 Exhibit 37, #40 Exhibit 38, #41 Exhibit 39, #42 Exhibit 40, #43 Exhibit 41, #44 Exhibit 42, #45 Exhibit 43, #46 Exhibit 44, #47 Exhibit 45, #48 Exhibit 46, #49 Exhibit 47, #50 Exhibit 48, #51 Exhibit 49, #52 Exhibit 50, #53 Exhibit 51, #54 Exhibit 52, #55 Exhibit 53, #56 Exhibit 54, #57 Exhibit 55, #58 Exhibit 56, #59 Exhibit 57, #60 Exhibit 58, #61 Exhibit 59, #62 Exhibit 60, #63 Exhibit 61, #64 Exhibit 62, #65 Exhibit 63, #66 Exhibit 64, #67 Exhibit 65, #68 Exhibit 66, #69 Exhibit 67, #70 Exhibit 68, #71 Exhibit 69, #72 Exhibit 70, #73 Exhibit 71, #74 Exhibit 72, #75 Exhibit 73, #76 Exhibit 74, #77 Exhibit 75, #78 Exhibit 76, #79 Exhibit 77, #80 Exhibit 78, #81 Exhibit 79, #82 Exhibit 80, #83 Exhibit 81, #84 Exhibit 82, #85 Exhibit 83, #86 Exhibit 84, #87 Exhibit 85, #88 Exhibit 86, #89 Exhibit 87, #90 Exhibit 88, #91 Exhibit 89, #92 Exhibit 90, #93 Exhibit 91, #94 Exhibit 92, #95 Exhibit 93, #96 Exhibit 94, #97 Exhibit 95, #98 Exhibit 96, #99 Exhibit 97, #100 Exhibit 98, #101 Exhibit 99, #102 Civil Cover Sheet)(Davis, Stafford) (Attachment 102 replaced on 9/29/2021) (lad). (Entered: 09/28/2021)

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