A complaint filed just before the Thanksgiving holiday in the Northern District of California implicates Motorola Mobility LLC, an indirectly and wholly-owned subsidiary of China’s Lenovo Group Ltd. According to the lawsuit, Taiwan’s Largan Precision Co Ltd. owns six patents related to “state-of-the-art optical lens assemblies” that Motorola purportedly infringes by making and selling various smartphones.
“Largan is a world leader in the research, development, design, and production of high-end imaging lenses, optical lens modules, and optoelectronic components,” the filing says. In addition, the company supplies lenses for an array of consumer electronics such as smartphones, computers, webcams, and scanners.
The asserted patents’ inventions relate to “compact optical lens assemblies supporting image capture with smaller pixel sizes and increased resolution, resulting in high image quality.” The plaintiff says that compared to conventional assemblies, its assemblies “have a reduced total track length,” resulting in a smaller size ideal for use in high-end, portable or handheld consumer electronics.
As for Motorola’s alleged infringement, the complaint points to the example of the Motorola One 5G Ace smartphone, which has a camera system made up of several assemblies, including ones for rear-facing main and rear-facing ultrawide cameras. According to the complaint, the 5G Ace incorporates lens assemblies that infringe at least one claim of each of the six patents.
In June 2021, Largan contacted Lenovo Group, to notify it of the alleged infringement. In August, Largan sent another communication to the defendant providing it with claim charts “detailing how the Main Lens and the Wide Lens meet the elements of certain claims.” Though Lenovo purportedly acknowledged the communication, it continued to sell infringing products.
As such, the plaintiff contends that the defendant has been on notice since receiving its June letter. The complaint states six claims for relief, one for each of the asserted patents.
The Taiwanese company seeks injunctive and declaratory relief, damages, including those for willful infringement, interest, and an award of its attorneys’ fees and costs. Largan is represented by Maschoff Brennan Gilmore & Israelsene PLLC.