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Gesture Technology Partners LLC v. Motorola Mobility LLC

Docket 1:22-cv-03535, Illinois Northern District Court (July 7, 2022)
Honorable Lindsay C. Jenkins, presiding
Patent
DivisionChicago
FlagsAO279, PROTO, TERMED, WEISMAN
Cause15:1126 Patent Infringement
Case Type830 Patent
Tags830 Patent, 830 Patent
Patent
... 7933431 ...
500894650889285088938522798652490535297061536559753767965388059545404354597935491507552826355349215572251558127655944695616078562411757816475781650580867258287705845006585332758544915864334587817459044845926168593661059401265956417598235259998406008000600880060441836052132609845861080336148100616089962048526252598630176363017836342917634692963596476363160637347264424656453180650870965296176545670659781766634916750848676603667753616788336691197270159507084859709889174017837489863756447677562977804530
7933431
81890538194924855307986541988878949
Plaintiff Gesture Technology Partners LLC
Defendant Motorola Mobility LLC
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No. 157 MEMORANDUM Opinion and Order written by the Honorable Lindsay C. Jenkins on 9/24/2024

Document Gesture Technology Partners LLC v. Motorola Mobility LLC, 1:22-cv-03535, No. 157 (N.D.Ill. Sep. 24, 2024)
Citations to docket filings generally refer to the electronic pagination provided by CM/ECF, which may not be consistent with page numbers in the underlying documents.
A genuine issue of material fact exists if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986).
Summary judgment “is the ‘put up or shut up’ moment in a lawsuit, when a party must show what evidence it has that would convince a trier of fact to accept its version of events.” Wade v. Ramos, 26 F.4th 440, 446 (7th Cir. 2022) (quoting Schacht v. Wis. Dept’ of Corr., 175 F.3d 497, 504 (7th Cir. 1999)).
Intel Corp. v. Qualcomm Inc., 21 F.4th 801, 810 (Fed. Cir. 2021) (“It is highly disfavored to construe terms in a way that renders them void, meaningless, or superfluous.”) Therefore, for GTP to overcome Motorola’s non-infringement argument, it must put forth sufficient evidence for a reasonable jury to conclude the Module of the Accused Devices contains the components of a digital camera, and another, separate sensor that is capable of detecting gestures.
Davis v. Brouse McDowell, L.P.A., 596 F.3d 1355, 1364 (Fed. Cir. 2010) (“an expert’s naked conclusion is insufficient to survive summary judgment”); USC IP P’ship, L.P. v. Meta Platforms, Inc., 2023 WL 5606977, at *3 (Fed. Cir. 2023) (“conclusory expert opinion[s] do[] not present a genuine factual dispute to prevent summary judgment.”) Based on this record, no reasonable jury could conclude the Accused Devices contain a sensor that is separate from the digital camera.
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No. 154 REPLY by Motorola Mobility LLC to MOTION by Defendant Motorola Mobility LLC for summary judgment ...

Document Gesture Technology Partners LLC v. Motorola Mobility LLC, 1:22-cv-03535, No. 154 (N.D.Ill. Jul. 10, 2024)
Motion for Summary Judgment
While it is true that the CMOS electro-optical sensing array and the lens are separate components, this is irrelevant because they are both part of the digital cameras that GTP identifies in its Final Infringement Contentions.
Moreover, GTP’s citation to Motorola’s motion is to the “Legal Standard” section, which notes the universally-accepted proposition that under Alice Step 2, the addition of generic hardware cannot rescue an otherwise abstract idea from patent ineligibility.
The Thales court explained that the ’159 patent disclosed methods that “directly measure the gravitational field in the platform frame,” rather than using the flawed prior art approach of “measuring inertial changes with respect to the earth.” Id. at 1345.
The court further explained that the ’159 patent disclosed an “unconventional … combination of sensor placement” that had multiple advantages over the prior art, including “increas[ing] the accuracy with which inertial sensors measure the tracked object,” “requir[ing] fewer measured inputs (and fewer points of potential error),” the ability to “operate independently, without requiring other hardware on the moving platform,” and simpler installation since “the whole system is installed on the inside of the moving platform.” Id. at 1345, 1348.
In other words, other than the generic disclosure of “sensors,” there is nothing about Thales that is applicable to the instant case.5 Finally, GTP devotes over two pages to the Texas PNC case to rebut the Federal Circuit’s Yu decision.
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No. 137 MOTION by Defendant Motorola Mobility LLC for summary judgment Defendant Motorola Mobility ...

Document Gesture Technology Partners LLC v. Motorola Mobility LLC, 1:22-cv-03535, No. 137 (N.D.Ill. May. 22, 2024)
Motion for Summary Judgment
Defendant Motorola Mobility LLC (“Motorola”), by its attorneys, hereby moves for an Order granting summary judgment of non-infringement and invalidity of U.S. Patent No. 8,878,949 (the “’949 patent”).
In support hereof, Motorola relies upon the accompanying Memorandum of Points and Authorities and exhibits submitted herewith.
WHEREFORE, Defendant Motorola Mobility LLC respectfully requests that this Court enter an Order:
granting summary judgment of non-infringement of claim 4 of the ’949 patent; and
granting summary judgment of invalidity of claim 4 of the ’949 patent under 35
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No. 141 MEMORANDUM by Motorola Mobility LLC in support of motion for summary judgment 137 Defendant ...

Document Gesture Technology Partners LLC v. Motorola Mobility LLC, 1:22-cv-03535, No. 141 (N.D.Ill. May. 22, 2024)
Motion for Summary Judgment
Claim 4 simply recites the use of well- known, generic components—a housing, sensors, and a digital camera—to implement the underlying abstract idea of taking a photograph based on observable cues.
1610057067.2 Section 101 provides that “[w]homever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.” 35 U.S.C. § 101.
Thus, in light of the evidence in the case, Dr. Creusere’s detailed opinions, and Dr. Myler’s admissions, there is no genuine dispute that the electro-optical sensor of the Accused Devices that is engaging in the gesture determination is not “separate from” the digital camera that captures the resulting image.
Consistent with Yu, the Federal Circuit has frequently held that a concept that “can be performed in the human mind ... is merely an abstract idea and is not patent-eligible under § 101.” CyberSource Corp., 654 F.3d at 1372-73; see also MeridianLink, Inc., 839 F. App’x at 526; Erie Indemnity Co., 850 F.3d at 1327; Content Extraction & Transmission LLC, 776 F.3d at 1347; Symantec Corp., 838 F.3d at 1318.
Motorola’s position is again supported by Dr. Pryor, who testified that he did not invent any of the general-purpose components recited in claims 1 and 4, including portable devices (Ex. 7 at 37:11-13), electro-optical sensors (id. at 37:17-23), digital cameras (id. at 38:6-11), and processing units (id. at 39:20-40:6).
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No. 1 COMPLAINT For Patent Infringement filed by Gesture Technology Partners LLC; Jury Demand

Document Gesture Technology Partners LLC v. Motorola Mobility LLC, 1:22-cv-03535, No. 1 (N.D.Ill. Jul. 7, 2022)
Complaint
Gesture Technology Partners, LLC is a limited liability company filed under the laws of the State of Ohio, with its principal place of business at 2815 Joelle Drive, Toledo, OH 43617.
Defendant Motorola Mobility LLC is a Delaware limited liability company, with its principal place of business at 222 W. Merchandise Mart Plaza, Suite 1800, Chicago, Illinois 60654.
Motorola, an indirect subsidiary of Lenovo Group Limited, is involved in the development and sale of hardware and software relating to mobile products, such as smartphones.
The Accused Products have features including, but not limited to, at least the following: Auto Smile Capture, Shot Optimization, Smart Composition, Portrait Mode, Cutout, Live Filter, Best Shot, Google Lens Integration, AR Sticker, Electronic Image Stabilization, Face Beauty, Attentive Display, Group Selfie, Gesture Selfie, and facial recognition (the “Features”).
Thus, Motorola is liable to Plaintiff in an amount that adequately compensates it for such infringements, which by law cannot be less than a reasonable royalty, together with interest and costs as fixed by this Court under 35 U.S.C. § 284.
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