DCT
2:17-cv-09042
LuMee LLC v. Snap Light LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: LuMee LLC (Delaware)
- Defendant: Snap Light, LLC (d.b.a. SNAPLIGHT) (California); Hooshmand Harooni (California)
- Plaintiff’s Counsel: Workman Nydegger; Payne & Fears LLP
- Case Identification: 2:17-cv-09042, C.D. Cal., 12/15/2017
- Venue Allegations: Plaintiff LuMee asserts venue is proper because Defendant Harooni resides in the district and Defendant Snaplight engaged in actions giving rise to the controversy within the district, specifically by filing a prior lawsuit against LuMee's customers.
- Core Dispute: Plaintiff seeks a declaratory judgment that its "LuMee Two" and "LuMee Duo" illuminated smartphone cases do not infringe Defendant Harooni's patent for an integrated lighting accessory.
- Technical Context: The technology concerns smartphone cases with built-in lighting designed to improve the quality of photographs and videos taken with the phone's cameras.
- Key Procedural History: This action was filed in response to a prior lawsuit ("Customer Suit") initiated by Defendant Snaplight on July 31, 2017, in the same district. The Customer Suit accuses retailers of infringing the patent-in-suit by selling LuMee's products. The existence of this earlier suit provides the basis for the "actual case or controversy" required for this declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2012-01-20 | U.S. Patent No. 8,428,644 Priority Date (Filing Date) |
| 2013-04-23 | U.S. Patent No. 8,428,644 Issues |
| 2017-07-31 | Defendant Snaplight files "Customer Suit" against LuMee's retailers |
| 2017-12-15 | LuMee files Complaint for Declaratory Judgment |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,428,644 - "Integrated Lighting Accessory and Case for a Mobile Phone Device," Issued April 23, 2013
The Invention Explained
- Problem Addressed: The patent identifies an issue with then-existing mobile phone lighting, stating that built-in lights are often not "diffused sufficiently or not dispersed enough to be an appropriate lighting source for professional photography/videography purposes" (’644 Patent, col. 1:29-34).
- The Patented Solution: The invention is a protective smartphone case with an integrated "ring of LED lights" that provides an enhanced and diffused light source (’644 Patent, Abstract; col. 1:34-38). The case contains its own power source (a battery), and the individual LED lights are covered by a "frosted or softening lens" to create diffused illumination (’644 Patent, col. 1:34-36, 1:62-63). The design also contemplates a port for providing "programmability" to the lights, potentially via a software application on the phone (’644 Patent, col. 2:30-39).
- Technical Importance: The invention aims to provide amateur and professional users with a portable, integrated tool for creating higher-quality, more flatteringly lit images and videos directly from a mobile device.
Key Claims at a Glance
- The complaint seeks a declaration of non-infringement of "any claim" of the patent (Compl. ¶10). The patent contains one independent claim, Claim 1.
- Independent Claim 1 requires:
- An integrated case for a mobile phone device with an "integrated ring of Light Emitting Diode (LED) lights."
- Embedded electronic circuitry with a portable power source.
- The "ring of LED lights" mounted in a "recessed manner" and covered by a lens for "diffusion of the illumination."
- A separate or extended docking port for the phone, providing a replacement port and optionally a USB connection.
- An "additional port used to provide power and programmability to the LSD [sic] lights embedded in the case."
- The LED light ring providing a "diffused light source" for photography or videography.
III. The Accused Instrumentality
Product Identification
- The "LuMee Two" and "LuMee Duo" smartphone cases (Compl. ¶7).
Functionality and Market Context
- The LuMee Two is a smartphone case that provides illumination for the front-facing camera via "two parallel linear strips of LEDs on the left and right sides of the front of the smartphone case" (Compl. ¶16).
- The LuMee Duo provides similar front-facing illumination and adds "two parallel linear strips of LEDs on the left and right sides of the back of the smartphone case" for the rear-facing camera (Compl. ¶17).
- Both products include an integrated battery and a port on the bottom to recharge that battery (Compl. ¶19).
- The complaint alleges that these products are sold in the United States and are the subject of the "Customer Suit" filed by Defendant Snaplight against retailers Kimsaprincess Inc. and Urban Outfitters, Inc. (Compl. ¶¶7-9).
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint is for a declaratory judgment of non-infringement. The core of LuMee's position is that its products lack at least two specific elements required by the patent's independent claim.
’644 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality (per LuMee) | Complaint Citation | Patent Citation |
|---|---|---|---|
| an integrated ring of Light Emitting Diode (LED) lights | The products provide illumination via "two parallel linear strips of LEDs," which LuMee alleges is not a "ring." | ¶¶16, 17, 18, 23 | col. 4:10-14 |
| an additional port used to provide power and programmability to the...lights embedded in the case | The products include a port, but it is only for recharging the case's internal battery and does not provide "programmability" to the LEDs. | ¶¶19, 23 | col. 4:24-27 |
- Identified Points of Contention:
- Scope Questions: A central dispute will be the proper construction of the term "ring of...lights." The court will need to determine whether this term is limited to a continuous, circular, or annular arrangement (as depicted in the patent's figures, e.g., Fig. 5) or if it can be interpreted more broadly to encompass other arrangements that surround a central area, such as the two parallel strips on the accused products.
- Technical Questions: The meaning of "programmability" will be at issue. The complaint alleges the accused products' ports are only for recharging (Compl. ¶19). The patent specification suggests "programmability" involves control via a software application to create custom light patterns (’644 Patent, col. 2:30-39). The court will have to determine what level of control is required to meet this limitation and whether the accused products' functionality meets that standard.
V. Key Claim Terms for Construction
The Term: "ring of...lights"
- Context and Importance: This term is central to the dispute, as LuMee’s primary non-infringement argument is that its linear strips of lights are not a "ring" (Compl. ¶23). The case may turn on whether the court adopts a narrow, geometric definition or a broader, functional one.
- Intrinsic Evidence for a Broader Interpretation: The patent’s stated purpose is to provide dispersed and diffused illumination for photography (’644 Patent, col. 1:29-38). A party could argue that any light arrangement that substantially surrounds the camera's field of view to achieve this purpose, including two parallel strips, meets the functional goal of a "ring."
- Intrinsic Evidence for a Narrower Interpretation: The plain and ordinary meaning of "ring" suggests a circular or closed-loop shape. Every embodiment and figure in the patent that shows the lighting element depicts it as a continuous, four-sided, rectangular loop that encircles the phone's screen area (e.g., ’644 Patent, Fig. 5, element 501). The specification consistently and repeatedly uses the phrase "LED light ring" without reference to any other configuration.
The Term: "an additional port used to provide...programmability"
- Context and Importance: This is LuMee's second explicit basis for non-infringement (Compl. ¶23). The construction of "programmability" will determine whether a simple recharging port can satisfy the claim limitation. Practitioners may focus on this term because the patent appears to give it a specific technical meaning beyond simple power input.
- Intrinsic Evidence for a Broader Interpretation: The term "programmability" is not explicitly defined in the claims. A party might argue that any ability to control the lights beyond a simple on/off switch, such as dimming, could be considered a form of programmability, and that the port enables this.
- Intrinsic Evidence for a Narrower Interpretation: The specification provides significant context, describing "an associated software application running on the mobile device that will allow third parties to control the LED lights" and a "software developer's toolkit" (’644 Patent, col. 2:30-39). This suggests "programmability" requires a data connection for sophisticated software-based control, not merely the supply of power for recharging or simple hardware-based functions.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaration that "no user or re-seller" of the LuMee products infringes any claim of the '644 patent (Compl., Prayer for Relief ¶B). This addresses potential claims of indirect infringement (inducement or contributory) that were likely raised against retailers in the underlying "Customer Suit" (Compl. ¶9). However, the complaint's factual allegations focus on denying the elements of direct infringement.
- Willful Infringement: The complaint does not contain allegations related to willful infringement, as it is a declaratory judgment action filed by the accused infringer.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to hinge on two critical, dispositive questions of claim construction and infringement:
- A core issue will be one of definitional scope: Can the term "ring of...lights," which is described and depicted in the patent as a continuous loop, be construed to cover the "two parallel linear strips of LEDs" used in the accused LuMee products?
- A key question of functional capability will be whether the accused products' recharging port meets the claim requirement of "an additional port used to provide...programmability." This will depend on whether "programmability" is interpreted narrowly to mean sophisticated software control, as suggested by the patent's specification, or more broadly to include simpler functions.