360Heros, Inc. v. GoPro, Inc.

CourtDistrict Court, D. Delaware
DecidedMay 22, 2020
Docket1:17-cv-01302
StatusUnknown

This text of 360Heros, Inc. v. GoPro, Inc. (360Heros, Inc. v. GoPro, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
360Heros, Inc. v. GoPro, Inc., (D. Del. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

360HEROS, INC., ) ) Plaintiff, ) ) v. ) Civil Action No. 17-1302-LPS-CJB ) GOPRO, INC., ) ) Defendant. )

REPORT AND RECOMMENDATION In this action filed by Plaintiff 360Heros, Inc. (“Plaintiff”) against Defendant GoPro, Inc. (“Defendant”), presently before the Court is the matter of claim construction. The Court recommends that the District Court adopt the constructions as set forth below. I. BACKGROUND AND STANDARD OF REVIEW The Court hereby incorporates by reference the summary of the background of this matter set out in its October 4, 2019 Report and Recommendation (“October 4 R&R”). (D.I. 138 at 1-2) It additionally incorporates by reference the legal principles regarding claim construction set out in the October 4 R&R. (Id. at 2-4) II. DISCUSSION The parties had claim construction disputes regarding seven terms or sets of terms (hereinafter, “terms”). The Court addressed three of these terms in the October 4 R&R and addressed two more in a Report and Recommendation issued on October 25, 2019. (D.I. 139) The remaining two terms are addressed below. A. “within” or “in” “a common spherical plane”

The next disputed term, “within” or “in” “a common spherical plane”, is found in claims 8, 20 and 31-33 of the asserted patent. Claim 8 reads as follows: 8. A holding assembly as recited in claim 1, including a plurality of camera receptacles disposed within a common spherical plane and at least one camera receptacle disposed above or below the common spherical plane.

('019 patent, col. 22:58-61 (emphasis added)) Further, claim 20 is for “[a] method as recited in claim 15, including the step of supporting a plurality of photographic cameras within a common spherical plane.” (Id., col. 23:43-45 (emphasis added)) Claim 31 is dependent on claim 30, and adds the limitation that, with regard to the claimed holding fixture, the “plurality of receptacles are disposed in a common spherical plane.” (Id., col. 24:41-43 (emphasis added)) Claims 32 and 33 further limit the holding fixture in claim 31 by providing that certain receptacles are disposed in certain ways relative to the “common spherical plane.” (Id., col. 24:44-46, 47-49) The parties’ proposed constructions are as follows: Term Plaintiff’s Proposed Defendant’s Proposed Construction Construction “within” or “in” “a common “[o]n a common plane The term is invalid due to spherical plane” bounded by a great circle of a indefiniteness. sphere”

(D.I. 74 at 18; D.I. 76 at 15) As Defendant contends that the term is indefinite, the Court first sets out the law as to definiteness and then will discuss the merits thereafter. Section 112 of the Patent Act requires that a patent claim “particularly point[] out and distinctly claim[] the subject matter which the inventor or a joint inventor regards as the invention.” 35 U.S.C. § 112(b). If it does not, the claim is indefinite and therefore invalid. Nautilus, Inc. v. Biosig Instruments, Inc., 572 U.S. 898, 902 (2014). The primary purpose of the definiteness requirement is to ensure that patent claims are written in such a way that they give notice to the public of what is claimed, thus enabling interested members of the public (e.g., competitors of the patent owner) to determine whether they infringe. All Dental Prodx, LLC v. 2 Advantage Dental Prods., Inc., 309 F.3d 774, 779-80 (Fed. Cir. 2002). Even so, “absolute precision is unattainable” and not required. Nautilus, 572 U.S. at 910. In the end, “a patent is invalid for indefiniteness if its claims, read in light of the specification delineating the patent, and the prosecution history, fail to inform, with reasonable certainty, those skilled in the art about the

scope of the invention.” Id. at 901. Definiteness is to be evaluated from the perspective of a person of skill in the art at the time the patent was filed. Id. at 908.1 The Court now turns to the merits. In doing so, it notes that the patent unfortunately never uses the term “common spherical plane” in the specification. Instead the term is found only in the claims. The patent does, however, frequently use the term “common plane” (sometimes referred to as “common [] horizonal [] plane”) a number of times, both in the claims and the specification. For example, claim 4 claims the holding assembly of claims 1 and 2, “wherein at least some of said camera receptacles are oriented about a common plane.” ('019 patent, col. 22:48-50 (emphasis added); see also id., col. 2:15-18 (the specification noting that in an

embodiment of the invention, a “plurality of camera receptacles can be disposed along the common plane as well as above and/or below the defined plane”); id., cols. 7:24-27, 8:55-57; 10:3-8, 10:53-55, 11:15-21, 12:6-12, 13:58-63, 16:4-11, 16:62-66)) The parties all agree on what a “common plane” or “common horizontal plane” is: “a horizonal plane[,]” (D.I. 74 at 18- 19), i.e., a plane parallel to the horizon. (Id.; see also Tr. at 111) And because “common

1 Like claim construction, definiteness is a question of law for the court. H-W Tech., L.C. v. Overstock.com, Inc., 758 F.3d 1329, 1332 (Fed. Cir. 2014). The United States Court of Appeals for the Federal Circuit has stated that “[a]ny fact critical to a holding on indefiniteness . . . must be proven by the challenger by clear and convincing evidence.” Intel Corp. v. VIA Techs., Inc., 319 F.3d 1357, 1366 (Fed. Cir. 2003); see also Tech. Licensing Corp. v. Videotek, Inc., 545 F.3d 1316, 1338 (Fed. Cir. 2008). 3 spherical plane” and “common plane” are both used in the claims, it is clear that the former must have a meaning that is at least slightly different from that of the latter. See Haemonetics Corp. v. Baxter Healthcare Corp., 607 F.3d 776, 781 (Fed. Cir. 2010) (“[W]e construe claims with an eye toward giving effect to all of their terms[.]”); see also (D.I. 74 at 19; Tr. at 119). Plaintiff's proposed construction (“on a common plane bounded by a great circle of a sphere”) is meant to get to that “something different.” In support of the proposed construction, Plaintiff points to Figures 3(a) to 3(d). Figure 3(a) is depicted below, for reference:

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3367 (Mera. = ZS 332 i rs ae nd —— > a NY 337 WEB © PP | 1-329 330 eS iN ) 32 336 WL) > 336 ae 5 334-& i 334

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(‘019 patent, FIG. 3(a)) Plaintiff notes that the specification describes Figures 3(a) to 3(d) as depicting “five (5) of the camera receptacles 324 extend[ing] along a common (horizontal) plane in a substantially circular or circumferential manner[,]” (019 patent, col. 10:53-55 (emphasis added)), such that the “camera receptacles 324 are maintained at an identical radial distance from the center of the holding assembly 300, thereby enabling a composite spherical field of

view for a plurality of cameras 380[,]” (id., col 10:61-65 (emphasis added)). Plaintiff then explains that this description of a “common spherical plane” is “equivalent” to its proposed construction. (D.I. 76 at 17; D.I. 85 at 16-17) Importantly, Plaintiff also cites to the declaration of its expert, Randall King, who avers that a person of ordinary skill in the art would understand

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360Heros, Inc. v. GoPro, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/360heros-inc-v-gopro-inc-ded-2020.