This case was last updated from PACER on 09/29/2021 at 07:34:01 (UTC).

KT Imaging USA, LLC v. Microsoft Corporation

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 Microsoft Corporation (“Microsoft” or “Defendant”), seeking injunctive relief, compensatory damages, costs, expenses, pre-judgment and post-judgment interest, and other reliefs for alleged infringement of the United States Patents owned by the Plaintiff. This case was filed in the United States District Court in the Western District of Texas with Judge Alan D. Albright presiding.

 

This is an action for alleged Patent infringement by the Defendant of the United States Patent No. 6,590,269 entitled “Package Structure for a Photosensitive Chip” (“the ’269 Patent”), United States Patent No. 6,876,544 entitled “Image Sensor Module and Method for Manufacturing the Same” (“the ’544 Patent”), United States Patent No.  7,196,322 entitled “Image Sensor Package” (“the ’322 Patent”), United States Patent No. 8,004,602, entitled “Image Sensor Structure And Integrated Lens Module Thereof” (“the ’602 Patent”), United States Patent No. 8,314,481, entitled “Substrate Structure for an Image Sensor Package and Method for Manufacturing the Same” (“the ’481 Patent”) (collectively, “Patents-in-suit”).

 

In the complaint, the Plaintiff alleged that, “On information and belief, Microsoft has infringed the ’544 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.”

 

The Plaintiff also alleged that, “For example, on information and belief, Microsoft has infringed and continues to infringe at least claim 1 of the ’544 Patent by including an image sensor module to be mounted to a printed circuit board in the Microsoft Surface Go 2 product. See Exs. 1 and 2 (Microsoft Surface Go 2 main front facing image sensor). 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.”

 

Further, the Plaintiff alleged that, “On information and belief, Microsoft has induced infringement of the ’544 Patent pursuant to 35 U.S.C. § 271(b), by actively and knowingly inducing, directing, causing, and encouraging others, including, but not limited to, its partners, resellers, distributors, customers, and end users, to make, use, sell, and/or offer to sell in the United States, and/or import into the United States, the Accused Products by, among other things, providing the accused products and incorporated image sensor technology, specifications, instructions, manuals, advertisements, marketing materials, and technical assistance relating to the installation, set up, use, operation, and maintenance of said products.”

 

Similar allegations have been made by the Plaintiff with reference to the other Patents-in-suit.

 

There are five claims for relief laid down by the Plaintiff, one for the alleged infringement of each of the Patents-in-suit.

 

In the prayer for relief, the Plaintiff has requested the Court to pass an order for an award of permanent injunctive relief along with damages in no event less than a reasonable royalty as provided by 35 U.S.C. § 284 together with compensatory damages. Further, the Plaintiff requested the Court for pre-judgment and post-judgment interest and an award of attorneys’ fees and costs pursuant to 35 U.S.C. § 285 and further relief as the Court may deem just and proper. 

 

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Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    6:21-CV-01000

  • 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

Microsoft Corporation

Attorney/Law Firm Details

Plaintiff Attorney

Stafford Grigsby Helm Davis

Attorney at The Stafford Davis Firm, PC

815 South Broadway Avenue

Tyler, TX 75701

 

Court Documents

#5

(#5) Summons Issued as to Microsoft Corporation. (jc5) (Entered: 09/28/2021)

#3

(#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) (Main Document 3 replaced on 9/28/2021) (jc5). Replaced on 9/28/2021 due to document submission not flattened. (Entered: 09/28/2021)

1 #36

Exhibit 34

1 #33

Exhibit 31

1 #31

Exhibit 29

1 #30

Exhibit 28

1 #24

Exhibit 22

1 #22

Exhibit 20

1 #21

Exhibit 19

1 #17

Exhibit 15

1 #12

Exhibit 10

1 #10

Exhibit 8

1 #9

Exhibit 7

1 #6

Exhibit 4

1 #5

Exhibit 3

1 #2

Exhibit Attachment B

1 #1

Exhibit Attachment A

#1

(#1) COMPLAINT for Patent Infringement ( Filing fee $ 402 receipt number 0542-15274752), 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 Civil Cover Sheet)(Davis, Stafford) (Attachment 37 replaced on 9/28/2021) (jc5). Replaced on 9/28/2021 due to document submission not flattened. (Entered: 09/28/2021)

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Docket Entries

  • 09/28/2021
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  • Docket(#5) Summons Issued as to Microsoft Corporation. (jc5) (Entered: 09/28/2021)

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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. (jc5) (Entered: 09/28/2021)

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  • 09/28/2021
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  • DocketDocuments #1 Cover Sheet #2 Summons #3 AO 120 were not flattened. Please notice that all documents are required to be flattened upon filing. The US Clerk's Office will flatten any document needed prior but all parties MUST flatten documents going forward. Contact the Clerk's Office for any questions. (Entered: 09/28/2021)

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  • 09/28/2021
  • DocketAll parties shall flatten all documents before e-filing. All parties shall comply with the Standing Orders located at https://www.txwd.uscourts.gov/judges-information/standing-orders/ (jc5) (Entered: 09/28/2021)

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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) (Main Document 3 replaced on 9/28/2021) (jc5). Replaced on 9/28/2021 due to document submission not flattened. (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 Microsoft Corporation (Davis, Stafford) (Main Document 2 replaced on 9/28/2021) (jc5). Replaced on 9/28/2021 due to document submission not flattened. (Entered: 09/28/2021)

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  • 09/28/2021
  • View Court Documents
  • Docket(#1) COMPLAINT for Patent Infringement ( Filing fee $ 402 receipt number 0542-15274752), 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 Civil Cover Sheet)(Davis, Stafford) (Attachment 37 replaced on 9/28/2021) (jc5). Replaced on 9/28/2021 due to document submission not flattened. (Entered: 09/28/2021)

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