Arashi Vision Inc v. SZ DJI Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Arashi Vision Inc. (d/b/a Insta360) (People's Republic of China)
  • Defendant: SZ DJI Technology Co., Ltd. (People's Republic of China); SZ DJI Osmo Technology Co., Ltd. (People's Republic of China); DJI Europe B.V. (Netherlands); and iFlight Technology Company Limited (Hong Kong SAR)
  • Plaintiff's Counsel: Bayes PLLC
• Case Identification: 2:26-cv-00466, E.D. Tex., 06/11/2026
• Venue Allegations: Venue is alleged on the basis that the defendants are foreign entities subject to venue in any judicial district and that they conduct substantial business in the Eastern District of Texas through the distribution and sale of the accused products.
• Core Dispute: Plaintiff alleges that Defendant's handheld-gimbal camera products, including the Osmo 360, infringe two patents related to digital video stabilization technology.
• Technical Context: The technology at issue involves methods for correcting image instability and distortion in videos captured by lightweight, handheld cameras, particularly those using rolling shutter sensors.
• Key Procedural History: The complaint alleges that Defendants had pre-suit knowledge of the asserted patents as of at least June 4, 2026, when Plaintiff sent a list of its patents to Defendant DJI, an allegation that may support a claim for willful infringement.

Case Timeline

Date	Event
2012-12-11	'045 Patent Priority Date
2015-01-01	Insta360 founded
2017-01-24	'045 Patent Issue Date
2018-03-16	'339 Patent Priority Date
2022-07-12	'339 Patent Issue Date
2026-06-04	Plaintiff allegedly provides notice of patents to Defendant DJI
2026-06-11	Complaint Filing Date

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

U.S. Patent No. 11,388,339 - Anti-Shake Method for Panoramic Video, and Portable Terminal (Issued Jul. 12, 2022)

The Invention Explained

• Problem Addressed: The patent addresses the "jelly effect," a form of image distortion that occurs in videos shot with CMOS-sensor cameras, particularly during high-speed movement Compl. ¶12 '339 Patent, col. 1:55-62 This effect is caused by the "rolling shutter," where the image is captured line by line rather than all at once, creating a time lag between the top and bottom of a single frame '339 Patent, col. 1:40-54
• The Patented Solution: The invention proposes to correct this distortion by precisely synchronizing two data streams in real time: the video data and motion data from the camera's gyroscope '339 Patent, abstract By obtaining a specific timestamp for each pixel (or pixel line) and matching it to a corresponding gyroscope timestamp, the method calculates the exact camera rotation at the moment that specific part of the image was captured. This allows for a highly accurate, pixel-by-pixel correction to create a smooth and stable final video '339 Patent, col. 2:6-23 '339 Patent, Fig. 1
• Technical Importance: This method provides a way to computationally remove rolling shutter artifacts, improving the quality of video from widely used and less expensive CMOS-based cameras without requiring mechanical stabilizers.

Key Claims at a Glance

• The complaint asserts independent claims 1 (method) and 7 (portable terminal) Compl. ¶32
• Essential elements of independent claim 1 include:
  • obtaining, in real time, a video frame, a fisheye image, a "timestamp of the pixel in the video frame," and a corresponding camera gyroscope timestamp;
  • synchronizing the pixel timestamp with the gyroscope timestamp and calculating a rotation matrix of the camera movement;
  • smoothing the camera movement and establishing a coordinate system of a smooth trajectory;
  • correcting the fisheye image distortion; and
  • rendering the fisheye image using "forward rendering" to generate a stable video.
• The complaint reserves the right to assert additional claims Compl. ¶35

U.S. Patent No. 9,554,045 - Systems and Methods for Digital Video Stabilization via Constraint-Based Rotation Smoothing (Issued Jan. 24, 2017)

The Invention Explained

• Problem Addressed: The patent addresses video instability caused by camera shake in lightweight devices like mobile phones '045 Patent, col. 1:26-34 A common side effect of digital stabilization is that rotating or shifting frames to counteract shake can create distracting black or empty regions at the edges of the video '045 Patent, col. 10:11-14
• The Patented Solution: The invention describes a method that uses gyroscope data to smooth out camera motion through a constrained optimization process '045 Patent, abstract The system is designed to "minimize a rate of rotation between successive input image frames" (to create a smooth path) while simultaneously "minimizing an amount of empty regions in the input image frames" (to avoid black borders) '045 Patent, col. 2:3-9 This dual-objective approach aims to produce a video that is both stable and maintains its full frame.
• Technical Importance: This approach provides a computationally defined method for achieving video stabilization that balances smoothness with the aesthetic and practical need to avoid cropping or showing empty pixels, a key trade-off in digital stabilization.

Key Claims at a Glance

• The complaint asserts independent claims 1 (method), 9 (system), and 13 (non-transitory computer storage medium) Compl. ¶41
• Essential elements of independent claim 1 include:
  • receiving input image frames from a video and camera orientation data from a gyroscope;
  • generating stabilized image frames based on the input frames and orientation data; and
  • smoothing the camera orientation data by "minimizing a rate of rotation between successive input image frames while minimizing an amount of empty regions" in the reoriented frames.
• The complaint reserves the right to assert additional claims Compl. ¶44

III. The Accused Instrumentality

• Product Identification: The accused products are identified as "DJI's Osmo 360 product and/or software applications compatible with the Osmo 360 product" and are generally categorized as "handheld-gimbal camera products" Compl. ¶1 Compl. ¶2
• Functionality and Market Context: The complaint alleges that the Accused Products are used for capturing video and are sold in the United States through DJI's website and various retailers Compl. ¶1 Compl. ¶24 While the complaint does not detail the specific functionality of the accused products, they are positioned in the same market as the Plaintiff's products. The complaint includes a screenshot from the Plaintiff's website asserting that Insta360 is the "world's leading 360 camera brand," which serves to establish the competitive landscape and the Plaintiff's market position Compl. p. 3

IV. Analysis of Infringement Allegations

The complaint alleges infringement but does not provide a detailed mapping of accused product features to claim limitations. The following chart summarizes the allegations based on the asserted claims and the general nature of the accused products.

'339 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
obtaining, in real time, an output video frame, a fisheye image..., a timestamp of the pixel..., and a corresponding camera gyroscope timestamp	The complaint alleges the accused Osmo 360 products, which capture panoramic video using internal sensors, necessarily perform this step during operation, but provides no specific details on the data obtained.	¶32	col. 7:30-44
synchronizing the timestamp of the pixel in the video frame with the corresponding camera gyroscope timestamp, and calculating a rotation matrix...	The complaint alleges the Accused Products' stabilization feature performs this function, without specifying the mechanism or granularity of the synchronization.	¶32	col. 7:45-53
smoothing the camera movement and establishing a coordinate system of a smooth trajectory	The complaint alleges the stabilization feature in the Accused Products performs this step to create a stable video output, without detailing the smoothing method.	¶32	col. 8:14-18
correcting the fisheye image distortion	The complaint alleges the Accused Products correct for lens distortion inherent in panoramic video capture, but does not describe the specific correction method.	¶32	col. 8:58-60
rendering the fisheye image by means of forward rendering to generate a stable video	The complaint alleges the Accused Products render a final stabilized video, but does not detail the rendering process.	¶32	col. 8:27-29

'045 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
receiving, by a computer system, input image frames associated with a video	The complaint alleges the Accused Products perform this step by capturing video, but provides no specific details.	¶41	col. 11:66-67
receiving, by the computer system, camera orientation data from a gyroscope	The complaint alleges the Accused Products use their internal gyroscopes to gather orientation data for stabilization, without specifying data format or frequency.	¶41	col. 12:1-2
generating, by the computer system, stabilized image frames...	The complaint alleges the Accused Products' stabilization feature generates a stable video output, without detailing the process.	¶41	col. 2:3-9
smoothing the camera orientation data... wherein the smoothing... comprises minimizing a rate of rotation... while minimizing an amount of empty regions...	The complaint alleges the Accused Products' stabilization feature performs this smoothing, but does not specify whether the underlying algorithm performs the claimed dual minimization.	¶41	col. 10:11-14

• Identified Points of Contention:
  • Technical Questions ('339 Patent): A central question will be the granularity of the data synchronization in the accused products. The claim requires synchronizing a "timestamp of the pixel" with gyroscope data. The case may turn on whether the accused DJI system operates at this fine-grained, pixel-level (or line-level) timing, or uses a coarser, frame-level synchronization that may not meet the claim limitation.
  • Scope Questions ('045 Patent): The infringement analysis will likely focus on the "smoothing" limitation, which is defined functionally as a dual-objective minimization. The key question is whether the accused products' stabilization algorithm performs this specific optimization ("minimizing a rate of rotation while minimizing an amount of empty regions"), or if it uses a different smoothing technique that achieves a similar result through a non-infringing method.

V. Key Claim Terms for Construction

• Term: "timestamp of the pixel" ('339 Patent, Claim 1)

  • Context and Importance: This term is critical because it defines the required level of precision for the patented method. The infringement analysis will depend on whether the accused products' stabilization system processes timing data at this specific granularity.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that this term does not require a unique timestamp for every individual pixel but could refer to the timestamp for the line or row in which the pixel is located, as the specification discusses the line-by-line readout of CMOS sensors '339 Patent, col. 1:43-46
    • Evidence for a Narrower Interpretation: The use of the singular "pixel" could support a literal construction requiring per-pixel timing data. The specification further details a formula for calculating the timestamp for a specific pixel "p(x,y)" based on its line number y, which reinforces a highly granular interpretation '339 Patent, col. 7:54-62

• Term: "minimizing a rate of rotation between successive input image frames while minimizing an amount of empty regions" ('045 Patent, Claim 1)

  • Context and Importance: This phrase defines the core of the '045 invention. Its construction will determine the scope of protection for the claimed optimization method. The dispute will center on what constitutes "minimizing" both objectives concurrently.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that any smoothing algorithm that takes both camera path smoothness and the avoidance of empty regions into account would meet this limitation, even if it does not use a formal, simultaneous optimization.
    • Evidence for a Narrower Interpretation: The specification describes implementing the smoothing via an "iterative algorithm based on gradient descent" on an "energy function" that includes terms for both rotation and a constraint function for empty regions '045 Patent, col. 9:47-49 '045 Patent, col. 11:57-64 This may support an argument that the claim requires a specific type of mathematical optimization that solves for both constraints simultaneously, rather than a more general balancing of the two goals.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendants design the Accused Products to infringe and encourage infringement by "promoting, advertising, and instructing customers" on the products' infringing uses Compl. ¶35 Compl. ¶44
• Willful Infringement: The complaint alleges that Defendants' infringement has been and is "willful, deliberate, and in disregard of Plaintiff's patent rights" Compl. ¶39 Compl. ¶48 This allegation is supported by the claim that Defendants received actual notice of the patents-in-suit no later than June 4, 2026, a week before the complaint was filed Compl. ¶3

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

This dispute between two major players in the 360-degree camera market will likely focus on the precise technical implementation of DJI's video stabilization technology compared to the specific methods claimed in Insta360's patents. The key questions for the court appear to be:

1. A question of technical implementation: Does DJI's stabilization technology for the Osmo 360 operate with the "pixel-level" timestamp synchronization required by the '339 Patent, or does it use a different, potentially non-infringing, data-handling method?
2. A question of functional scope: Does the smoothing algorithm in DJI's products perform the specific dual-objective "minimization" of both rotation rate and empty regions as claimed in the '045 Patent, or does it employ a functionally different approach to achieve a smooth, full-frame video?
3. An evidentiary question on willfulness: Did Defendants have pre-suit knowledge of the patents as alleged, and if so, did they act with objective recklessness regarding a high likelihood of infringement, which could expose them to enhanced damages?