DCT
2:18-cv-02690
D3 LED LLC v. Revolution Display LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: D3 LED, LLC (Delaware)
- Defendant: Revolution Display, LLC; Full Throttle Films, LLC; Video Equipment Rentals, LLC (all Delaware)
- Plaintiff’s Counsel: Enenstein Pham & Glass
- Case Identification: 2:18-cv-02690, C.D. Cal., 04/03/2018
- Venue Allegations: Venue is alleged to be proper based on Defendants residing in the district and committing acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendants’ "M8 Distribution Platform," a controller for modular LED displays, infringes a patent related to the automatic configuration and mapping of such displays.
- Technical Context: The technology addresses the configuration of large-scale, modular digital displays, where automatically determining the physical location of each module is critical for simplifying installation and maintenance.
- Key Procedural History: The complaint alleges that Plaintiff notified Defendants of infringement via a letter dated July 12, 2017. It further alleges that Defendants’ counsel reported that there was no infringement but refused to provide technical documentation or enter into a confidentiality agreement to support this assertion.
Case Timeline
| Date | Event |
|---|---|
| 2006-11-09 | '450 Patent Priority Date |
| 2011-05-24 | '450 Patent Issue Date |
| 2017-07-12 | Plaintiff's counsel allegedly sent pre-suit notice letter |
| 2018-04-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,948,450 - "Apparatus and Method for Allowing Display Modules to Communicate Information About Themselves to Other Display Modules in the Same Display Panel," Issued May 24, 2011
The Invention Explained
- Problem Addressed: The patent’s background section details the challenges of configuring large display panels composed of many individual modules. Prior art methods, such as specific cabling for each module, daisy-chaining, or manual address programming via switches, are described as labor-intensive, time-consuming, and highly susceptible to human error, particularly during installation and maintenance (’450 Patent, col. 1:31 - col. 2:32).
- The Patented Solution: The invention proposes a system where display modules can automatically determine their own location within a larger panel by communicating with their immediate neighbors. As described in the specification, each module is equipped with transmitters and receivers on its borders, allowing it to send its own unique identifier to, and receive identifiers from, adjacent modules (’450 Patent, Abstract; col. 3:1-11). This peer-to-peer exchange of information allows a main controller or software to construct a complete map of the display panel's layout without manual input (’450 Patent, col. 4:26-43).
- Technical Importance: This automated approach was designed to eliminate the tedious and error-prone manual steps required to configure large-scale displays, thereby reducing installation time and simplifying the process of replacing failed modules (’450 Patent, col. 2:46-54).
Key Claims at a Glance
- The complaint asserts infringement of the patent generally, without specifying claims (Compl. ¶15, ¶21). Independent claim 1 is the broadest apparatus claim and its elements are listed below.
- Independent Claim 1:
- A module-based display panel comprising a plurality of display modules, each with at least three borders.
- A transmitter, receiver, or transceiver located on each border that is adjacent to another display module.
- The transceivers are configured so a transmitter on one module is adjacent to a receiver on a neighboring module.
- Each display module has a unique identifier.
- The transmitters transmit the module's unique identifier to adjacent receivers (within a bandwidth of 10 Kbps or less).
- The receivers receive the unique identifier from adjacent modules.
- Each display module sends its own identifier and the identifiers of its neighbors to a main controller.
- The unique identifiers are used by the main controller to determine the location of the display module within the panel.
III. The Accused Instrumentality
Product Identification
- The "M8 Distribution Platform" ("Accused Device"), which the complaint identifies as an LED digital display module controller (Compl. ¶3, ¶21).
Functionality and Market Context
- The complaint alleges the Accused Device enables "automatic mapping" of LED display panels through the use of "intelligent sensors and software" (Compl. ¶3, ¶16). Marketing materials cited in the complaint state that when coupled with compatible panels, the "M8 system will auto-map the display" and "automatically integrate components as they are connected or replaced" (Compl. ¶16, ¶20). The complaint includes a screenshot from a product brochure that depicts the "AUTO MAPPING" feature. (Compl. ¶20). Plaintiff alleges on information and belief that this functionality is achieved by "utilizing adjacent receivers or transceivers mounted on individual display modules" (Compl. ¶3). The Defendants are positioned as "direct competitors" of the Plaintiff (Compl. ¶3).
IV. Analysis of Infringement Allegations
'450 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An apparatus for allowing display modules to communicate information about themselves to other display modules in the same display panel, comprising a module-based display panel... wherein each face comprises a plurality of display modules | The Accused Device is a controller for LED display panels composed of individual modules (Compl. ¶3). | ¶3, ¶21 | col. 1:49-57 |
| wherein a transmitter, receiver or transceiver is located on each border that is adjacent to another display module | Plaintiff alleges on information and belief that the accused system utilizes "adjacent receivers or transceivers mounted on individual display modules" to accomplish its functionality. | ¶3 | col. 3:30-34 |
| wherein each display module has a unique identifier | The complaint alleges the system uses "intelligent sensors" to identify and integrate components, suggesting each module has a distinguishable identity. | ¶16, ¶20 | col. 3:15-18 |
| wherein the transmitters or transceivers... transmit that display module's unique identifier to the adjacent receivers or transceivers | The complaint alleges modules communicate information about themselves to adjacent modules to enable "automatic mapping." | ¶2-3 | col. 3:4-8 |
| wherein each display module sends its own unique identifier and the unique identifiers of the adjacent display modules to a main controller | The M8 system is alleged to be a module controller that "auto-map[s] the display," which implies collection of module data for processing. | ¶3, ¶16, ¶20 | col. 11:11-15 |
| wherein the unique identifiers are used by the main controller to determine the location of the display module within a display panel | The Accused Device is alleged to perform "automatic mapping" and to "automatically integrate components," which is the function of determining module locations. | ¶3, ¶16, ¶20 | col. 11:15-19 |
- Identified Points of Contention:
- Technical Question: The complaint's core technical allegation—that the Accused Device works by using adjacent transceivers on display modules—is made on "information and belief" (Compl. ¶3). A central question for discovery will be to determine the actual mechanism by which the "M8 Distribution Platform" performs "automatic mapping." Does the evidence show it uses the specific neighbor-to-neighbor communication architecture claimed in the patent, or does it achieve this result through a different, non-infringing technology?
- Scope Questions: The claims require that information from the modules be sent to a "main controller" for location determination. The court may need to resolve whether the Defendants' "M8 Distribution Platform," described as a combination of "intelligent sensors and software" (Compl. ¶16), functions as the claimed "main controller," or if the location-determining logic is distributed in a way that falls outside the claim's architectural requirements.
V. Key Claim Terms for Construction
The Term: "unique identifier"
- Context and Importance: This term is fundamental to the invention's operation, as the ability to distinguish one module from another is a prerequisite for mapping. The infringement analysis will depend on whether the information exchanged between components in the accused system constitutes a "unique identifier" as contemplated by the patent.
- Intrinsic Evidence for a Broader Interpretation: The patent body refers more generally to "identifier information" being transmitted, which could support an argument that any data serving to uniquely distinguish a module for mapping purposes meets the limitation (’450 Patent, col. 3:15-18).
- Evidence for a Narrower Interpretation: The patent discloses a specific example in its communication packet structure, where the identifier is a "Module identifier" corresponding to a "Media Access Control address" (’450 Patent, Table 1; col. 14:17-18). This could be used to argue for a more constrained definition tied to specific hardware or network addresses.
The Term: "main controller"
- Context and Importance: Claim 1 recites a specific data flow where modules send identifiers to a "main controller," which in turn "determine[s] the location." Practitioners may focus on this term because the architecture of the accused system (a "Distribution Platform" with "software") may not map cleanly onto the hardware-centric "main controller" language of the claims.
- Intrinsic Evidence for a Broader Interpretation: The specification describes a system where a "main control module... in turn sends the data to the display panel's controller software," which then interprets the data (’450 Patent, col. 4:30-38). This suggests the "main controller" could be part of a larger system that includes software, supporting a broader construction.
- Evidence for a Narrower Interpretation: A party could argue that the term implies a singular, centralized hardware component that receives all identifier data directly, and that a distributed software-based system does not meet this limitation. The consistent use of "module" in the patent could be argued to support a hardware-based definition.
VI. Other Allegations
- Willful Infringement: The complaint alleges that infringement has been willful since at least July 12, 2017, the date of a pre-suit notice letter sent by Plaintiff's counsel (Compl. ¶24). The allegation is supported by the assertion that Defendants, after being notified, refused to provide technical information to substantiate their non-infringement position (Compl. ¶4). Notably, the complaint text identifies the patent in the letter as the "‘451 Patent," which appears to be a typographical error, as the '450 patent is the sole subject of the lawsuit (Compl. ¶24).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of evidentiary proof: The complaint's infringement theory is based on "information and belief" derived from marketing materials. The case will likely turn on whether discovery reveals that the accused "M8 Distribution Platform" achieves "automatic mapping" using the specific technical architecture recited in the patent—namely, modules communicating unique identifiers to adjacent modules—or if it employs a different, non-infringing method.
- The second key question will be one of architectural scope: Does the combination of "intelligent sensors and software" in the accused system constitute the "main controller" that "determine[s] the location" as required by the claims? The resolution may depend on whether the court construes "main controller" to encompass a distributed software platform or require a more centralized, hardware-based component.