DCT

2:26-cv-00467

Arashi Vision Inc v. SZ DJI Technology Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00467, E.D. Tex., 06/11/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants, as foreign entities, may be sued in any judicial district. It further alleges Defendants have committed acts of infringement in the Eastern District of Texas through direct online sales to consumers in the district, sales through authorized retailers with a physical presence in the district (such as a Best Buy in McKinney, Texas), and importation of accused products that are sold within the district.
  • Core Dispute: Plaintiff alleges that Defendant's camera gimbals, stabilized cameras, and related accessories infringe three U.S. patents related to camera stabilization control systems and location-sharing technology.
  • Technical Context: The lawsuit concerns technology for stabilizing cameras, such as those used in action sports and professional filmmaking, to counteract unwanted operator movement and provide smooth, intuitive control over the camera's pointing angle.
  • Key Procedural History: Plaintiff alleges that Defendant had pre-suit knowledge of two of the asserted patents since at least August 31, 2017, based on Defendant having cited those patents in Information Disclosure Statements (IDS) during the prosecution of its own patent applications. The complaint also mentions prior patent litigation between the same parties in the same judicial district.

Case Timeline

Date Event
2013-03-15 Priority Date for '161 Patent
2013-03-15 Priority Date for '090 Patent
2013-09-30 Priority Date for '910 Patent
2014-12-09 Issue Date for U.S. Patent No. 8,908,090
2015-01-20 Issue Date for U.S. Patent No. 8,938,161
2015-10-06 Issue Date for U.S. Patent No. 9,154,910
2017-08-31 Defendant allegedly cites '161 and '090 Patents in an IDS
2017-11-13 Defendant allegedly cites '161 and '090 Patents in a second IDS
2019-05-21 Defendant allegedly cites '161 and '090 Patents in a third IDS
2026-06-04 Plaintiff allegedly provides Defendant with written notice of infringement
2026-06-11 Complaint Filing Date

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

U.S. Patent No. 8,938,161 - "Method and System for Enabling Pointing Control of an Actively Stabilized Camera"

  • Issued: January 20, 2015

The Invention Explained

  • Problem Addressed: The patent describes issues with prior art active stabilization systems where preventing unintentional camera movement requires an operator to continuously hold a control input at a precise zero value, which is difficult in practice and can lead to poor quality video from inadvertent movements Compl. ¶29 '161 Patent, col. 19:48-55 Additionally, the high-precision gyroscopic sensors used in such systems were often large and expensive '161 Patent, col. 1:36-38
  • The Patented Solution: The invention proposes a threshold-gated control method for an actively stabilized camera. The system creates a "dead-band zone" or "threshold window" where small rotational movements of a steering member (like a gimbal handle) do not affect the camera's pointing angle Compl. ¶¶30-31 Only when the joint angle of the steering member's rotation exceeds this threshold does the system adjust the camera's pointing angle, allowing the operator to make intentional movements without needing to worry about minor, unintentional jitters '161 Patent, abstract '161 Patent, col. 20:9-21
  • Technical Importance: This approach aimed to provide a low-cost, lightweight stabilization system that could effectively remove unwanted movements while giving operators intuitive control over filming '161 Patent, col. 1:42-46

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 Compl. ¶48
  • Claim 1 of the '161 Patent requires, in essence:
    • A method for adjusting a pointing angle of a camera housed by an active stabilization system with a rotatable steering member.
    • Deriving a joint angle measurement of the steering member associated with a rotational movement.
    • Adjusting the pointing angle of the camera based on the derived joint angle measurement, in the direction of the rotational movement, if the joint angle measurement exceeds a threshold window.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,908,090 - "Method for Enabling Manual Adjustment of a Pointing Direction of an Actively Stabilized Camera"

  • Issued: December 9, 2014

The Invention Explained

  • Problem Addressed: In conventional actively stabilized systems, any attempt by an operator to physically force the camera to a new position results in the operator "fighting the stabilization process," which tries to return the camera to its last commanded angle Compl. ¶34 '090 Patent, col. 25:8-11 Changing the camera's pointing direction often required a second, remote operator, increasing complexity and equipment needs '090 Patent, col. 17:41-55
  • The Patented Solution: The patent describes a method where the system detects an "externally applied force" from the operator. Upon detection, it disables its own "angle-based control loop," allowing the operator to freely move the camera to a new position. Once the manual adjustment is complete (e.g., the force is no longer applied), the system measures the new pointing angle and re-enables the stabilization loop to hold the camera steady at that new angle Compl. ¶35 '090 Patent, abstract
  • Technical Importance: This invention allows a single operator to intuitively and manually override an active stabilization system to repoint the camera, without fighting against the stabilization motors.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 Compl. ¶61
  • Claim 1 of the '090 Patent requires, in essence:
    • A method for adjusting a camera's pointing direction in an active stabilization system that uses an angle-based control loop and a rate-based control loop.
    • Detecting an externally applied force.
    • Disabling the angle-based control loop upon detecting a manual adjustment condition.
    • Adjusting the pointing angle of the camera in the direction of the force.
    • Measuring the new pointing angle of the camera.
    • Re-enabling the angle-based control loop to stabilize the camera based on the newly measured pointing angle.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,154,910 - "Terminal Location Obtaining Method, Device, and System"

  • Issued: October 6, 2015

Technology Synopsis

The patent addresses the problem of inaccurate location data for devices that rely on IP addresses for positioning Compl. ¶39 The solution involves a "first terminal" (e.g., a camera with low-accuracy positioning) requesting location data from a "second terminal" (e.g., a paired GPS remote with high-accuracy positioning) and then using the second terminal's more accurate location as its own for location-based operations Compl. ¶40

Asserted Claims & Accused Features

  • Asserted Claims: The complaint asserts at least independent claim 1 Compl. ¶74
  • Accused Features: The complaint alleges that the DJI Osmo 360 camera (first terminal), when paired with the DJI GPS Remote Controller (second terminal), infringes by requesting and receiving location data from the remote, then using that data as its own, for example, by embedding the GPS coordinates into video file metadata Compl. ¶75 The complaint includes a screenshot from a retailer's website showing the DJI Osmo 360 Adventure Combo offered for sale Compl. p. 9

III. The Accused Instrumentality

Product Identification

  • The complaint accuses two main categories of DJI products: "Handheld Gimbal Products" and "Non-Gimbal Products" Compl. ¶¶43-45
    • The "Accused '161 Products" and "Accused '090 Products" are the Handheld Gimbal Products, which include numerous models such as the DJI Osmo Pocket series, DJI Ronin series, and DJI Osmo Mobile series Compl. ¶44 Compl. ¶46 The complaint provides a screenshot showing the DJI Ronin RS 5, an accused gimbal product, available for purchase at a Best Buy in the district Compl. p. 8
    • The "Accused '910 Products" are the Non-Gimbal Products, which include the DJI Osmo 360 and the DJI Osmo GPS Bluetooth Remote Compl. ¶45 Compl. ¶46

Functionality and Market Context

  • The Handheld Gimbal Products are described as actively stabilized camera systems that comprise a "steering member rotatable around one or more axes" Compl. ¶49 These products are alleged to allow users to control the camera's pointing angle through physical manipulation of the gimbal.
  • The Non-Gimbal Products are alleged to involve a camera (e.g., DJI Osmo 360) that pairs with a separate GPS remote controller. This combination allegedly performs a method where the camera obtains and uses the remote controller's location data for its own location-based functions, such as geotagging video files Compl. ¶75

IV. Analysis of Infringement Allegations

'161 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for adjusting a pointing angle of a camera housed by an active stabilization system configured to stabilize the camera in accordance with a commanded pointing angle, the system comprising a steering member rotatable around one or more of a pan axis, tilt axis, or roll axis of the system... The Accused '161 Products are actively stabilized camera systems with a steering member rotatable around one or more axes. ¶49 col. 18:40-52
deriving a joint angle measurement of the steering member associated with a rotational movement of the steering member... The Accused '161 Products derive a joint angle measurement of the steering member associated with its rotational movement. ¶49 col. 19:48-52
and adjusting the pointing angle of the camera, based on the derived joint angle measurement, in a direction of the rotational movement of the steering member, if the joint angle measurement exceeds a threshold window. The Accused '161 Products adjust the camera's pointing angle based on the derived joint angle measurement, in the direction of the rotational movement, when the measurement exceeds a threshold window. ¶49 col. 20:10-21

'090 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for adjusting a pointing direction of a camera housed by an active stabilization system, the active stabilization system executing a stabilization process to stabilize the pointing direction of the camera, the method comprising: detecting an externally applied force; The Accused '090 Products are camera systems housed by active stabilization systems that detect an externally applied force. ¶62 col. 27:1-5
disabling an angle-based control loop of the stabilization process upon detecting a manual adjustment condition... The Accused '090 Products disable the angle-based control loop upon detecting a manual adjustment condition. ¶62 col. 28:1-2
adjusting the pointing angle of the camera in a direction of the externally applied force; The Accused '090 Products adjust the pointing angle of the camera in a direction of the externally applied force. ¶62 col. 27:5-8
measuring a pointing angle of the camera; and The Accused '090 Products measure the pointing angle of the camera. ¶62 col. 27:21-25
re-enabling the angle-based control loop of the stabilization process to stabilize the pointing direction of the camera based on the measured pointing angle of the camera in response to detecting that the manual adjustment condition failed. The Accused '090 Products re-enable the angle-based control loop to stabilize the camera's pointing direction based on the measured pointing angle after the manual adjustment. ¶62 col. 27:25-30

Identified Points of Contention

  • Scope Questions: A central question for the '161 and '090 Patents may be whether the control logic in DJI's products performs the specific functions as claimed. For the '161 Patent, this raises the question of whether the accused products implement a "threshold window" that creates a dead-zone for operator input, as distinct from other forms of input filtering or smoothing. For the '090 Patent, the dispute may turn on whether DJI's products "disable an angle-based control loop" in the specific manner envisioned by the patent, or if they achieve manual override through a technically different, non-infringing mechanism.
  • Technical Questions: The infringement allegations in the complaint are stated at a high level of generality, referencing attached claim charts that were not provided with the complaint document. A key technical question will be what evidence demonstrates that the accused gimbals actually implement the claimed "threshold window" ('161 Patent) or "disable" a control loop upon detecting an "externally applied force" ('090 Patent). The complaint does not detail the specific software or hardware implementation in the accused products that allegedly performs these steps.

V. Key Claim Terms for Construction

'161 Patent

  • The Term: "threshold window"
  • Context and Importance: This term is the central feature of the asserted independent claim, defining the "dead-band zone" that distinguishes intentional operator movements from unintentional ones. The outcome of the infringement analysis may depend on whether the accused products' input processing method can be characterized as implementing a "threshold window."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent equates the term with a "dead-band zone" in a general sense, which could support an interpretation covering various forms of input filtering that create a region of reduced sensitivity around a zero-point '161 Patent, col. 20:9-11
    • Evidence for a Narrower Interpretation: The specification describes a specific implementation where if the measurement is within the window, the output is zero, and if it is outside, the output is the measurement reduced by the threshold value '161 Patent, col. 19:67-20:8 A defendant may argue this specific mathematical operation is required.

'090 Patent

  • The Term: "disabling an angle-based control loop"
  • Context and Importance: This term describes the core mechanism that allows an operator to manually override the active stabilization. Practitioners may focus on this term because the infringement question will likely turn on whether the accused products' method for allowing manual adjustment is technically equivalent to "disabling" the loop as taught in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 5 provides two alternative definitions for "disabling," including "activating a switch to cause the stabilization process to bypass the angle-based control loop" or "setting a commanded pointing angle to match a current pointing angle" '090 Patent, col. 31:1-6 This suggests the term is not limited to a single physical or software action.
    • Evidence for a Narrower Interpretation: The specification describes the result of disabling the loop as the camera becoming "free to move in response to the force exercised by the camera operator" '090 Patent, col. 23:58-60 A defendant may argue that if their system still provides some resistance or control during manual adjustment, the loop is not truly "disabled."

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement against DJI, stating that the company provides product manuals, user guides, tutorials, and in-app workflows that instruct and encourage end-users to operate the Accused Products in a manner that directly infringes the asserted patents (Compl. ¶¶51; Compl. ¶64; Compl. ¶77). It also alleges contributory infringement, asserting that DJI supplies gimbal systems, controllers, and firmware that are material parts of the inventions, are especially made for infringing use, and are not staple articles of commerce with substantial non-infringing uses Compl. ¶¶52-53 Compl. ¶¶65-66 Compl. ¶¶79-80

Willful Infringement

The complaint alleges willful infringement based on both pre-suit and post-suit knowledge. For the '161 and '090 Patents, it alleges pre-suit knowledge since at least August 31, 2017, due to DJI repeatedly citing these patents in its own patent prosecution filings Compl. ¶¶6-7 Compl. ¶54 Compl. ¶67 For all three patents, it alleges knowledge based on a written notice letter sent on June 4, 2026, and at a minimum, since the filing of the complaint itself Compl. ¶9 Compl. ¶54 Compl. ¶67 Compl. ¶81

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

  • A central issue for the '161 and '090 patents will be one of technical implementation: Does the control software in DJI's gimbals operate in a way that meets the specific functional requirements of the claims? For the '161 patent, this means determining if there is an actual "threshold window" creating a dead-zone, and for the '090 patent, if an "angle-based control loop" is truly "disabled" to permit manual override. The case may turn on expert testimony comparing the patent's described logic with the reverse-engineered functionality of DJI's products.
  • For the '910 patent, a key question will be one of definitional scope: Can the act of a camera receiving GPS coordinates from a remote accessory and embedding them into video metadata be construed as the camera "us[ing] the location information of the second terminal as the location information of the first terminal" as required by claim 1? The court will need to determine if this use constitutes the camera adopting the location as its own for a "location-based application operation."
  • A significant question for damages will be willfulness: The complaint alleges that DJI knew of the '161 and '090 patents for years because it cited them as relevant prior art during its own patent prosecution. This allegation, if proven, could make it difficult for DJI to argue it did not willfully infringe, potentially exposing it to enhanced damages. The key inquiry will be whether DJI formed a good-faith belief of non-infringement despite this knowledge.
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