IP Law Daily, PATENT—S.D. Cal.: Google obtains partial dismissal of digital photography patent infringement claims, (Jul 8, 2025)

By Kevin M. Finson, J.D.

Several patents concerning digital camera functionality were invalid for being directed at an abstract idea because they used generic computer technology to produce an enhanced image using several original images, a well-known photographic technique.

Google showed that several claims of patents asserted against its Pixel smartphone products were invalid, the U.S. District Court in San Diego has held. The asserted claims were directed to the abstract idea of image enhancement and they used generic computer technology to produce an enhanced image using several original images, which was a technique known to photographers for over a century (Clear Imaging Research LLC v. Google LLC, No. 3:25-cv-00221-GPC-BLM (S.D. Cal. July 7, 2025)).

Clear Imaging Research, LLC (CIR) was the owner of numerous patents related to digital photography which it asserted in an infringement action against Google, LLC (Google), alleging that the camera functionality of Google’s Pixel smartphone product infringed. Google moved to dismiss in part, arguing that four of the asserted patents, specifically U.S. Patents Nos. 9,013,587 (the ’587 patent”), 10,171,740 (the ’740 patent), 11,165,961 (the ’961 patent), and 11,457,149 (the ’149 Patent) (collectively, the Combined-Image Patents) were invalid for being directed to an abstract idea. The court applied the two-step Alice test.

Abstract idea. Google argued that each of the asserted patents was directed to the abstract idea of combining images to enhance each other, which was well-known and did not represent an improvement to digital camera functionality. CIR argued that this was an over-simplification of its claims, which were instead directed to a new technological solution for reducing unwanted blur in a photograph or video.

The court found that while the patents may have included specific technological improvements, the claim language was written far more broadly than any particular technological improvement and used instead results-oriented language which could cover any possible means of obtaining blur-free images by combining multiple images. This was an abstract idea.

Inventive concept. Under step two of the Alice test, the court found that the claims at issue merely recited the use of well-known and conventional digital camera components to perform their basic functions in carrying out the abstract idea. There was no inventive concept that could save the patentability of the claims.

Representativeness. CIR challenged Google’s argument on the basis that the representative claims chosen by Google for each of the four Combined Image Patents were not in fact representative. The court found that CIR failed to identify any material difference between Google’s chosen representative claims and the other asserted claims which would lead to a different result.

Finding that amendment would be futile, the court granted Google’s motion to dismiss without leave to amend.

The Case is No. 3:25-cv-00221-GPC-BLM.

Judge: Curiel, G.

Attorneys: Brett E. Cooper (BC Law Group, P.C.) for Clear Imaging Research LLC. Abigail A. Gardner (Perkins Coie LLP) for Google LLC.

Companies: Clear Imaging Research LLC; Google LLC

Cases: Patent TechnologyInternet CaliforniaNews