DCT
2:21-cv-05876
Nicor Inc v. SourceBlue LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Nicor, Inc. (New Mexico)
- Defendant: SourceBlue, LLC (Delaware)
- Plaintiff’s Counsel: Loza & Loza, LLP
- Case Identification: 2:21-cv-05876, C.D. Cal., 03/01/2022
- Venue Allegations: Venue is based on Defendant's agreement to transfer a prior action from the District of Delaware to the Central District of California, and on allegations that Defendant regularly conducts business and has committed infringing acts within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Remote Driver Control Center (RDCC) lighting products, marketed under the Solidian® brand, infringe a patent related to centralized power supply and control systems.
- Technical Context: The technology concerns systems for providing unified power and control to large-scale lighting installations, such as those found in data centers and warehouses, to simplify complex wiring and management.
- Key Procedural History: The current action is a consolidation of a case originally filed by NICOR in Delaware on May 14, 2021, which was subsequently transferred by agreement of the parties. The complaint alleges that NICOR first provided Defendant with notice of the patent-in-suit on November 12, 2020. A related action, Infinilux v. Nicor, Inc., is also mentioned, through which NICOR allegedly discovered that Infinilux was the supplier of the Accused Product to SourceBlue.
Case Timeline
| Date | Event |
|---|---|
| 2017-10-25 | Earliest Priority Date for '427 Patent |
| 2018-03-22 | Spring 2018; NICOR alleges losing first contracts to SourceBlue |
| 2020-10-01 | Approx. October 2020; NAO5/6 contract awarded to SourceBlue |
| 2020-11-03 | '427 Patent Issued |
| 2020-11-12 | NICOR sent notice letter to Defendant regarding the '427 Patent |
| 2021-05-14 | NICOR filed original patent infringement action in Delaware |
| 2022-03-01 | NICOR's First Amended Complaint filed in C.D. Cal. |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,824,427 - "Method and System for Power Supply Control", issued November 3, 2020
The Invention Explained
- Problem Addressed: In typical large-scale lighting environments like warehouses, each light fixture requires its own dedicated power and control lines, resulting in complex wiring that is difficult to manage and service individually ('427 Patent, col. 1:40-48).
- The Patented Solution: The invention proposes a centralized power and control system housed within a single case. This system takes in mains AC power, converts it to low-voltage DC power using one or more power supplies, and distributes this power via a terminal block. A modular control system, which can interface with building automation protocols like BACnet/IP, converts high-level commands into a serial output (e.g., DALI) that is sent over the same cable as the DC power to control individual downstream applications like LED lights ('427 Patent, Abstract; col. 2:11-25; col. 8:1-col. 9:4). Figure 4 from the patent provides a schematic of the power supply and control system, illustrating the case (405), power supplies (415, 416), terminal block (435), and control modules (450, 455, 460, 465) (Compl., Ex. A, FIG. 4).
- Technical Importance: This architecture aims to reduce the "spider web of cabling" endemic to prior art systems by combining power and control signals into a single cable, thereby simplifying installation, centralizing management, and improving scalability for large industrial lighting applications ('427 Patent, col. 9:8-13).
Key Claims at a Glance
- The complaint asserts infringement of claims 1-7, with a focus on independent claim 1 (Compl. ¶ 31).
- The essential elements of independent claim 1 include:
- A distributed DC power output system comprising a case with a normal power side and an emergency power side, separated by a barrier.
- Separate AC power inputs for the normal and emergency sides.
- At least one normal power supply driver on the normal side and at least one emergency power supply driver on the emergency side.
- A first terminal block on the normal side to accept normal AC input and distribute normal DC power at constant current.
- A second terminal block on the emergency side to accept emergency AC input and distribute emergency DC power at constant current.
- A controller connected to the terminal block to control at least one application.
- A cable from the system that provides both control signals and DC power at constant current to the application.
- The complaint alleges infringement of dependent claims 2-7, which add limitations such as a surge protector and jacks for specific power operations ('427 Patent, col. 15:11-col. 16:29; Compl. ¶ 31).
III. The Accused Instrumentality
Product Identification
The Accused Product is Defendant's "Remote Driver Control Center ('RDCC') product, marketed under the Solidian® brand" (Compl. ¶ 10). The complaint alleges the product is acquired by Defendant from a third-party supplier, Infinilux (Compl. ¶ 13).
Functionality and Market Context
The complaint describes the Accused Product as a lighting system that was installed in Facebook data centers in place of NICOR's own system (Compl. ¶¶ 9-10). The core allegation is that the Accused Product was created by "intentionally cop[ying] NICOR's LCU product" (Compl. ¶ 14). The complaint alleges that Defendant's conduct, including supplying the Accused Product, led to NICOR losing multiple lighting contracts for Facebook data centers (Compl. ¶¶ 17-18).
IV. Analysis of Infringement Allegations
The complaint alleges that the Accused Product infringes each limitation of claims 1-7 of the ’427 Patent, either literally or under the doctrine of equivalents (Compl. ¶¶ 31-32). It incorporates by reference a claim chart (Exhibit 3) that was filed under seal and is not available for public review (Compl. ¶ 32). The infringement theory is predicated on the allegation that the Accused Product is a "copy" of NICOR's own commercial product, which embodies the patent (Compl. ¶ 14). Based on the complaint's narrative, the infringement allegations for the lead independent claim are summarized below.
'427 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a distributed DC power output system comprising: a case with a normal power side and an emergency power side; a barrier separating the normal power side and the emergency power side; | The complaint alleges the Accused Product is a lighting control system that was sold to replace Plaintiff's own patented system, suggesting it has a comparable physical architecture (Compl. ¶¶ 10, 14, 17). | ¶¶10, 14, 32 | col. 13:51-col. 14:4 |
| a normal mains AC power input...; a second mains AC power input...; at least one normal power supply driver...; at least one emergency power supply driver...; | The complaint broadly alleges the Accused Product meets every limitation of Claim 1, which would include the recited dual power input and driver configuration (Compl. ¶ 32). | ¶32 | col. 14:5-12 |
| a terminal block configured on the normal power side to...distribute normal DC power at constant current; a second terminal block...to...distribute emergency DC power at constant current; | The complaint alleges the Accused Product is a "Remote Driver Control Center" that infringes the claims, implying it performs the function of power conversion and distribution via terminal blocks as claimed (Compl. ¶¶ 10, 32). | ¶¶10, 32 | col. 14:13-25 |
| a controller connected to the terminal block wherein the controller controls at least one application; and a cable provided...wherein the system can provide control and the DC power at constant current, to the at least one application | The Accused Product is alleged to be a lighting control system for data centers, which by its nature provides control and power over cabling to lighting applications (Compl. ¶¶ 10, 17, 32). | ¶¶10, 17, 32 | col. 14:26-34 |
Identified Points of Contention
- Architectural Questions: A central dispute will likely be whether the Accused Product's physical architecture matches the specific claim requirement of a single case containing two distinct, barrier-separated sides for normal and emergency power, each with its own AC input, drivers, and terminal block. The complaint alleges that Defendant previously claimed its installation diagrams differed from the actual product, foreshadowing a dispute over the product's construction (Compl. ¶ 22).
- Technical Questions: The claim requires the terminal blocks to "distribute... DC power at constant current." The patent specification, however, describes the terminal block as providing "constant voltage" to downstream "pucks," which in turn provide constant current to the lights ('427 Patent, col. 8:55-58, col. 10:57-58). This raises the question of whether there is a contradiction between the claim language and the specification that could support a non-infringement argument.
V. Key Claim Terms for Construction
1. "controller"
- Context and Importance: Claim 1 requires "a controller connected to the terminal block wherein the controller controls at least one application." The definition is critical to determine what component in the accused system must perform this function. Practitioners may focus on this term because the specification describes multiple potential "controllers," including a centralized DALI control system (455), a room controller (980), and distributed "pucks" (505), creating ambiguity as to the term's scope ('427 Patent, col. 9:42-44, FIG. 5, FIG. 9).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discusses a "modular control system" and a "DALI control system 455" as components that receive high-level commands and interface with the overall system, suggesting the "controller" could be a centralized unit within the main case ('427 Patent, col. 8:22, col. 9:42-44).
- Evidence for a Narrower Interpretation: The specification also describes "pucks 505-508" which "are configured to send and receive control commands in DALI" and directly control the LED light bars ('427 Patent, col. 10:58-61). This could support an argument that the controlling function is performed by distributed units outside the main terminal block connection.
2. "distribute... DC power at constant current"
- Context and Importance: Claim 1 requires both the normal and emergency "terminal block[s]" to perform this function. This is a specific electrical engineering requirement, and its interpretation is fundamental to the infringement analysis. Practitioners may focus on this term because of a potential inconsistency between the claim language and the detailed description.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (as claimed): The plain language of the claim explicitly assigns the function of distributing constant current power to the terminal block itself ('427 Patent, col. 14:16-17, 14:23-24).
- Evidence for a Narrower Interpretation (as potentially disclaimed): The patent's detailed description states that the output from the terminal block is "held at a constant voltage" ('427 Patent, col. 8:55-58). It further explains that the distributed "pucks" are the components that "comprise a circuit configured to provide, among other things, a constant current supply to LED light bars" ('427 Patent, col. 10:56-58). This suggests the terminal block provides constant voltage, and a separate component provides constant current, which may raise questions of whether the claim is fully supported by the specification or if the inventors disclaimed a broader scope.
VI. Other Allegations
Indirect Infringement
The complaint alleges inducement of infringement, stating that Defendant provides "installation instructions, and other instruction materials" that actively induce its customers to use the Accused Product in an infringing manner (Compl. ¶ 33). It also alleges that Defendant has contributed to infringement by "instructing, directing, and/or requiring" third parties, such as its supplier Infinilux, to infringe the patent (Compl. ¶ 27).
Willful Infringement
Willfulness is alleged based on Defendant having actual knowledge of the ’427 Patent since at least November 12, 2020, when NICOR sent a notice letter (Compl. ¶¶ 21, 30, 37). The complaint further supports this allegation by claiming Defendant "intentionally copied NICOR's LCU product" (Compl. ¶ 14).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case will likely depend on the court's findings on two central issues:
- A core issue will be one of claim construction and technical contradiction: can the claim requirement that the "terminal block" distributes "constant current" be reconciled with the patent's own description, which appears to teach that the terminal block provides constant voltage and a separate "puck" provides the constant current? The outcome of this construction will be pivotal for the infringement analysis.
- A key evidentiary question will be one of architectural identity: does the accused RDCC product actually contain the specific, physically partitioned "normal power side" and "emergency power side" separated by a "barrier" as explicitly required by Claim 1? The plaintiff's ability to prove this precise structural correspondence will be critical to its case for literal infringement.