Sprintray Inc v. Shenzhen Anycubic Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SprintRay, Inc. (California)
  • Defendant: Shenzhen Anycubic Technology Co. Ltd. (China); Anycubic Innovation US Inc. (Delaware); Anycubic Technology (US) Ltd. (California)
  • Plaintiff’s Counsel: Potter Anderson & Corroon LLP
• Case Identification: 1:26-cv-00175, D. Del., 02/17/2026
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Anycubic Innovation US Inc. is a Delaware corporation, and Defendant Shenzhen Anycubic Technology Co. Ltd. is a foreign corporation, against which suit may be brought in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s resin-based 3D printers, including the Photon and Mono series, infringe four U.S. patents related to real-time process control, substrate assemblies, and separation force reduction in additive manufacturing.
• Technical Context: The lawsuit concerns stereolithography (SLA) 3D printing, a technology that builds objects layer-by-layer by curing liquid photopolymer resin, which is a key process for rapid prototyping and manufacturing in fields including dentistry.
• Key Procedural History: The complaint alleges that on January 20, 2026, approximately one month prior to filing suit, Plaintiff informed Kickstarter in writing that Defendant's Photon P1 Printer infringed the '316 Patent and requested its removal from the platform. This allegation may be used to support claims of pre-suit knowledge and willful infringement.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 8,845,316 - “Process and Device for Producing a Three-Dimensional Object”

• Patent Identification: U.S. Patent No. 8,845,316, "Process and Device for Producing a Three-Dimensional Object," issued September 30, 2014 (the "’316 Patent").

The Invention Explained

• Problem Addressed: The patent and complaint describe technical problems in resin-based 3D printing, such as unreliable layer formation and physical damage to the printed object that can occur during the "separation/peel" step, where a newly cured layer is detached from the bottom of the resin tank Compl. ¶16
• The Patented Solution: The invention proposes a device that uses real-time feedback to manage these forces Compl. ¶16 It incorporates a sensor to measure physical conditions like separation force, pressure, or strain in the "building region" where the object is formed, and a controller that receives a signal from the sensor and dynamically adjusts build parameters—such as the lift speed or distance—to optimize the separation process Compl. ¶¶16-17 '316 Patent, abstract
• Technical Importance: This approach introduces a dynamic feedback control loop to a process that often relies on static, pre-set parameters, addressing a core reliability issue in SLA printing Compl. ¶16

Key Claims at a Glance

• The complaint asserts at least Claim 1 of the '316 Patent Compl. ¶47
• The essential elements of independent Claim 1 include:
  • A device for supplying energy to a building region.
  • An object carrier for the object being produced and a provider for the solidifiable material.
  • A sensor arranged to measure and output a signal indicative of a separation force.
  • A controller configured to receive the signal from the sensor during the build process and to adjust at least one build parameter (such as the object carrier's distance from the building plane) based on that signal.

U.S. Patent No. 10,894,355 - “Resin Solidification Substrate and Assembly”

• Patent Identification: U.S. Patent No. 10,894,355, "Resin Solidification Substrate and Assembly," issued January 19, 2021 (the "’355 Patent").

The Invention Explained

• Problem Addressed: The patent addresses the technological challenge of reliably separating a newly solidified resin layer from the underlying substrate (typically the transparent bottom of the resin tank) without causing print failures, damaging the part, or creating excessive peel forces Compl. ¶20 '355 Patent, col. 1:26-44
• The Patented Solution: The invention is a multi-layer "solidification substrate assembly" Compl. ¶20 It comprises a rigid or semi-rigid translucent substrate (like an LCD screen) housed in a frame, which is then connected to a separate "film assembly" that also includes a frame and a film layer that contacts the resin '355 Patent, claim 1 This layered construction, which may also incorporate peeling members, is designed to manage and reduce separation forces '355 Patent, abstract Compl. ¶20
• Technical Importance: This patent focuses on the mechanical and structural design of the resin tank and solidification surface to improve the reliability of the layer separation process, a fundamental step in bottom-up SLA printing Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least Claim 1 of the '355 Patent Compl. ¶65
• The essential elements of independent Claim 1 include:
  • A multi-layer assembly comprising a rigid or semi-rigid solidification substrate assembly (itself comprising a frame and a translucent substrate).
  • A film assembly (itself comprising a frame and a film).
  • A connection between the solidification substrate assembly and the film assembly.

U.S. Patent No. 11,633,910 - “Resin Solidification Substrate and Assembly”

• Patent Identification: U.S. Patent No. 11,633,910, "Resin Solidification Substrate and Assembly," issued April 25, 2023 (the "’910 Patent").
• Technology Synopsis: The '910 Patent, sharing a specification with the '355 Patent, also claims a multi-layer system for 3D printing Compl. ¶84 It specifies a rigid or semi-rigid translucent solidification substrate and a separate film assembly, where the film is "adjacent to and in non-adhesive contact with" the substrate '910 Patent, claim 1 This configuration is intended to improve the mechanical detachment of cured resin layers and prevent excessive peel forces Compl. ¶23
• Asserted Claims: The complaint asserts at least Claim 1 Compl. ¶82
• Accused Features: The accused features include the printers' multi-layer assembly, which is alleged to comprise a translucent LCD substrate within a frame and a film assembly (the resin tank) that sits atop the substrate Compl. ¶¶85-86

U.S. Patent No. 11,679,555 - “Reservoir with Substrate and Assembly for Reducing Separation Forces in Three-Dimensional Printing”

• Patent Identification: U.S. Patent No. 11,679,555, "Reservoir with Substrate and Assembly for Reducing Separation Forces in Three-Dimensional Printing," issued June 20, 2023 (the "’555 Patent").
• Technology Synopsis: The '555 Patent claims a substrate assembly for a 3D printer reservoir that comprises a specific three-layer structure Compl. ¶100 This structure includes a first permeable film layer, a second layer below it, and a third permeable substrate disposed between the first and second layers '555 Patent, claim 1 The arrangement of these multiple layers, including at least one permeable substrate, is designed to reduce separation forces and increase print reliability Compl. ¶26
• Asserted Claims: The complaint asserts at least Claim 1 Compl. ¶98
• Accused Features: The complaint alleges that the P1 printer’s substrate assembly infringes by having a three-layer structure composed of a first permeable NFEP film, a second layer comprising the transparent LCD screen, and a third layer comprising a "wave release film" layered over the LCD screen Compl. ¶¶102-104

III. The Accused Instrumentality

• Product Identification: The primary accused products are the Anycubic Photon P1, Anycubic Photon Mono M7 Max, Anycubic Photon Mono M7 Pro, and Anycubic Photon Mono 4 3D printers Compl. ¶29 Compl. ¶39 The complaint also names related components such as the "Dual Kit" and replacement films Compl. ¶60
• Functionality and Market Context:
  • The accused products are resin-based 3D printers that use a light source at the base of the printer and an LCD panel as the solidification substrate to cure a photosensitive resin Compl. ¶29 Compl. ¶40
  • The complaint highlights specific features alleged to be infringing, including the "Dynamic Release 3.0" system in the P1 printer and the "Intelligent Release 2.0" system in the Mono M7 Max Compl. ¶51 Compl. ¶52 These systems are alleged to monitor layer separation forces in real time and dynamically adjust parameters like lift height and speed to improve print success Compl. ¶51 Compl. ¶52 The complaint provides a screenshot from Anycubic's marketing materials for the P1 printer that describes its "Dynamic Release 3.0" system monitoring real-time layer separation forces to modulate lift height and speed Compl. p. 19
  • The products were offered for sale in the United States through Defendant's website and a Kickstarter campaign that the complaint alleges raised over $1.5 million from more than 2,000 backers Compl. ¶30 Compl. ¶35 The complaint includes a screenshot from the concluded Kickstarter campaign page showing the funding total and a link to "Shop on Official Website" Compl. p. 10

IV. Analysis of Infringement Allegations

'316 Patent Infringement Allegations

'355 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: For the '355 and '910 Patents, a primary question may be whether a physically separate and user-removable resin tank that sits atop an LCD screen assembly is "connected to" the substrate assembly in the manner required by the claims. The interpretation of "connected" will be a central issue.
• Technical Questions: For the '316 Patent, the analysis will likely focus on the actual technical operation of the "Dynamic Release" and "Intelligent Release" systems. The dispute may turn on what evidence exists that these systems employ a "sensor" that directly measures "separation force" (as opposed to motor current or another proxy) and whether the controller's adjustment is truly "based on the received signal" in a closed-loop feedback system as claimed.

V. Key Claim Terms for Construction

'316 Patent - Claim 1

• The Term: "a sensor arranged to sense or measure and output a signal indicative of... a separation force"
• Context and Importance: This term is the core of the asserted claim, defining the feedback mechanism. The infringement case depends on whether the accused devices contain a "sensor" that performs this specific function. Practitioners may focus on this term because the complaint's allegations are functional (e.g., "monitors... layer separation force") Compl. ¶51, and the actual hardware implementation (e.g., a strain gauge, a motor encoder, a current sensor) will be scrutinized to see if it meets the claim's definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language recites a signal "indicative of" a separation force, which may support an argument that an indirect measurement (e.g., motor load) is sufficient. The specification discusses sensing conditions "selected from the group consisting of pressure and/or strain" '316 Patent, abstract, suggesting flexibility in the type of sensor.
  • Evidence for a Narrower Interpretation: The specification may describe specific embodiments that use a particular type of direct force or strain sensor (e.g., a strain gauge affixed to the object carrier or build plate), which could be used to argue for a more limited construction that excludes indirect measurements.

'355 Patent - Claim 1

• The Term: "the rigid or semi-rigid solidification substrate assembly is connected to the film assembly"
• Context and Importance: Infringement hinges on the nature of the relationship between the accused LCD screen assembly and the accused resin tank assembly. The complaint alleges connection via "latching or screwing" Compl. ¶69, but if the components are merely placed in proximity without a more integral bond, the meaning of "connected" will be dispositive.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "connected" is not explicitly defined, which may allow for a broad interpretation covering any form of physical joining or functional association that enables the assemblies to work together. The patent's focus is on the multi-layer structure, not necessarily a specific method of attachment.
  • Evidence for a Narrower Interpretation: The patent figures, such as FIG. 2A in the '355 Patent, depict a system where the substrate assembly and film assembly are part of a coordinated mechanical apparatus. A defendant may argue that "connected" implies a more permanent or integrated physical link than simply placing a removable tank on top of a screen.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement based on Defendant's instructions, marketing, and promotional activities, including directing social media influencers to use and post videos of the accused printers Compl. ¶59 Compl. ¶37 It alleges contributory infringement on the basis that the accused printers and replacement films are material components of the claimed inventions, are not staple articles of commerce, and have no substantial non-infringing use Compl. ¶60 Compl. ¶77
• Willful Infringement: Willfulness is alleged based on several grounds of knowledge. These include Defendant's alleged practice of monitoring competitors' patent-practicing products Compl. ¶45, Plaintiff's patent marking via its website Compl. ¶45, Plaintiff's pre-suit written notice to Kickstarter regarding the '316 Patent Compl. ¶44, and Defendant's receipt of the complaint itself Compl. ¶45

VII. Analyst’s Conclusion: Key Questions for the Case

• Evidentiary - Functional Operation: A central evidentiary question will be whether the accused printers' "Dynamic Release" and "Intelligent Release" features operate as claimed in the '316 Patent. This will require technical discovery into whether these systems use a "sensor" to generate a "signal indicative of a separation force" and a "controller" that uses this specific signal in real-time to "adjust" a build parameter, or if they rely on a different, non-infringing control logic.
• Claim Construction - Structural Relationship: A key legal question will concern the scope of terms like "connected to" ('355 Patent) and "non-adhesive contact" ('910 Patent). The case may turn on whether a system with a user-removable resin tank that rests atop an LCD screen assembly constitutes the integrated "multi-layer assembly" described in the patents, or if the claims require a more permanent physical integration.
• Claim Construction - Layer Mapping: For the '555 Patent, a critical issue will be mapping the structure of the accused P1 printer's components—allegedly an NFEP film, an LCD screen, and a "wave release film" Compl. ¶¶102-104—onto the specific three-layer structure of Claim 1. The analysis will focus on whether these components meet the claimed definitions and their required spatial and functional relationships, particularly the requirement of a "permeable substrate disposed between the first layer and the second layer."