On Thursday, plaintiff Flexiworld Technologies, Inc. filed a complaint in the Western District of Texas against Canon, Inc., and Canon Solutions America, Inc. (collectively Canon) alleging that Canon infringed the patents-in-suit through its wireless printers.
The patents-in-suit are United States Patent Nos. 9,036,181 (the ’181 patent); 10,140,071 (the ’071 patent); 10,481,846 (the ’846 patent); 10,642,576 (the ’576 patent); and 10,761,791 (the ’791 patent). According to the plaintiff, Canon “makes, uses, sells, offers to sell, and/or imports into the United States wireless printers (and a computer readable medium) that infringe at least one claim of one or more of the Patents-in-Suit, including but not limited to Canon’s imageClass and image Runner wireless printers (and Canon’s PRINT Business App)” (the Accused Instrumentalities).
For example, the ’071 patent is entitled “Printers, print controllers, printer software, or printer firmware for supporting wireless printing or printing over air.” The ’071 patent covers “(a) printing device supporting wireless printing of digital content…wherein the printing device uses the one or more wireless communication chips or chipsets to: wirelessly broadcast availability of the printing device for the one or more wireless information apparatuses to wirelessly discover the printing device for service; wirelessly transmit at least part of the output device profile, stored within the printing device, to the one or more wireless information apparatuses that have wirelessly discovered the printing device; and wirelessly receive…print data…”
Canon allegedly infringed at least claims 1-7 of the ’071 patent through its Accused Instrumentalities, including its Accused Wireless Printers. According to the claim chart, Canon purportedly infringed through the Accused Wireless Printers, including the Canon imageCLASS, which “supports wireless printing of digital content…using a wireless printing technology,” such as Apple AirPrint, Google Cloud Print, Canon PRINT Business App, and others. The Accused Instrumentalities allegedly incorporate the components mentioned in the ’071 patent.
Accordingly, the Accused device can “wirelessly broadcast( ) its availability to be wirelessly discovered by a wireless information apparatus (e.g. iOS/Android devices, etc.) for service (e.g. wireless printing, etc.)” it can allegedly connect with mobile devices wirelessly or through a LAN router to enable wireless printing in a network environment. Moreover, the plaintiff stated from this environment a user’s device is able to discover and detect the printer, which the user can select; after which, the user is able to wirelessly print from their device to the printer. This is purportedly accomplished when the printer wirelessly receives, “via the wireless communication chip (e.g. Wi-Fi module compatible with protocols within IEEE 802.11 wireless standards etc.) the print data” from the user’s devices, such as an iOS or Android device, to print.
Canon is accused of direct, indirect, and induced infringement. Flexiworld Technologies has sought a declaratory judgment in its favor; an award for damages, royalties, and costs; pre- and post-judgment interest; and other relief.
Flexiworld Technologies is represented by Nelson Bumgardner Albritton PC.