LMPG Inc v. KORRUS Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: LMPG Inc. (Canada)
  • Defendant: KORRUS, Inc. d/b/a Ecosense Lighting, Inc. (Delaware)
  • Plaintiff’s Counsel: Meylan Davitt Jain Arevian & Kim LLP; Burns & Levinson LLP
• Case Identification: 2:24-cv-00748, C.D. Cal., 01/26/2024
• Venue Allegations: Venue is asserted based on Defendant's principal place of business being located in Los Angeles, California, within the Central District of California.
• Core Dispute: Plaintiff alleges that Defendant’s lighting products featuring "Korrus Auto Sensing Technology" infringe a patent related to the automatic detection of and reconfiguration for different electronic dimming protocols.
• Technical Context: The technology addresses the challenge of interoperability in advanced lighting systems, where fixtures must be compatible with various control signals (dimming protocols) to function correctly.
• Key Procedural History: The asserted patent is a continuation of a prior application that issued as U.S. Patent No. 8,319,452. The complaint alleges that Plaintiff provided Defendant with notice of infringement via a letter dated January 9, 2024, approximately two weeks before filing the lawsuit.

Case Timeline

Date	Event
2012-01-05	Priority Date for U.S. Patent No. 8,643,304
2014-02-04	U.S. Patent No. 8,643,304 Issued
2024-01-09	Plaintiff sends pre-suit notice letter to Defendant
2024-01-26	Complaint Filed

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

U.S. Patent No. 8,643,304 - Dimming Protocol Detection For A Light Fixture

• Patent Identification: U.S. Patent No. 8,643,304, issued February 4, 2014 (the "’304 Patent").

The Invention Explained

• Problem Addressed: The patent's background section describes that LED light fixtures are typically configured to operate with only one specific dimming protocol (e.g., 0-10V, DALI). If an incompatible dimming signal is sent to the fixture, the fixture can be "damaged or destroyed," which complicates the installation process and increases costs (’304 Patent, col. 1:12-24).
• The Patented Solution: The invention is a system within a light fixture that automatically detects which dimming protocol is being used from a plurality of possible protocols. As described in the patent's summary and illustrated in Figure 1, the system uses a "dimming protocol detection module" to identify the incoming signal and a "light dimming control module" to reconfigure the fixture's operation to match the detected protocol, allowing a single fixture to work with multiple control systems without manual setup or risk of damage (’304 Patent, col. 1:52-62, Fig. 1).
• Technical Importance: This approach aims to increase the reliability and decrease the installation time and cost of advanced lighting systems by removing the need for installers to manually identify and match specific fixture types to corresponding dimming protocols (’304 Patent, col. 1:42-47).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶19).
• The essential elements of independent claim 1 are:
  • A system for controlling a plurality of light fixtures, comprising: a dimmer and a plurality of light fixtures.
  • Each light fixture comprising: a plurality of lights.
  • A dimming protocol detection module that automatically detects in real time at least one parameter of a dimming protocol from a plurality of protocols.
  • A light dimming control module that automatically reconfigures to match the detected dimming protocol to control the lights.
  • The dimming protocol detection module also automatically detects in real time a parameter of a second dimming protocol.
  • The light dimming control module reconfigures to match the second detected dimming protocol.
  • The light dimming control module automatically discontinues control of the lights based on the first detected protocol in real-time with the detection of the second dimming protocol.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused products are Defendant's "AURORA Products, including Defendant’s TROV products which incorporate their 'Korrus Auto Sensing Technology' feature ('KAST')" (Compl. ¶1, 17).

Functionality and Market Context

The complaint alleges the KAST feature provides "dimming protocol 'auto-sensing'" functionality (Compl. ¶12). Marketing materials cited in the complaint state that KAST "detects and controls the four major commercial dimming protocols (ELV, 0-10V, DALI and DMX)" and that it "auto-senses and self-configures to DALI, DMX, 0-10V and ELV" (Compl. ¶15, 17). The complaint provides a wiring diagram from the accused TROV-L60 product's installation instructions, showing connections for various control wire types including 0-10V, DALI, and DMX (Compl. p. 5).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in an "Exhibit B" that was not filed with the initial complaint (Compl. ¶19). The infringement theory is therefore drawn from the narrative allegations in the body of the complaint.

'304 Patent Infringement Allegations

The complaint alleges that the Accused Products, which incorporate the KAST feature, infringe at least claim 1 of the ’304 Patent (Compl. ¶19). The infringement theory appears to map the KAST feature directly onto the claimed modules. The complaint alleges that KAST's ability to "auto-sense and self-configure" to multiple protocols like DALI, DMX, and 0-10V meets the "dimming protocol detection module" and "light dimming control module" limitations (Compl. ¶16-17).

To satisfy the multi-protocol detection and switching elements of the claim, the complaint further alleges that the Accused Products "automatically detect a second dimmer protocol input signal after detecting a first dimmer protocol and reconfigure the control of the lights accordingly" (Compl. ¶18). For this element, the complaint cites a "Demo Kit Training Video" for the accused technology as evidentiary support (Compl. ¶18). This allegation appears to track the claim language requiring detection of a first protocol, then a second, and the subsequent discontinuation of control based on the first protocol in favor of the second.

• Identified Points of Contention:
  • Technical Questions: A primary factual question will be whether the accused KAST technology operates in the specific sequence mandated by claim 1. Specifically, what evidence demonstrates that upon detecting a second protocol, the system performs the affirmative step of "discontinu[ing] control ... based on the detected [first] dimming protocol in real-time with the detection of the second"? The complaint's reliance on a marketing video may be challenged as insufficient to prove this precise technical operation (Compl. ¶18).
  • Scope Questions: The claim requires detection and discontinuation "in real time." The precise meaning of this temporal limitation will be a central issue. The dispute may turn on whether the accused KAST system's switching speed and process meet the "real time" standard as defined by the patent's specification.

V. Key Claim Terms for Construction

• The Term: "automatically detects in real time"

  • Context and Importance: This phrase appears twice in claim 1 and is central to the invention's automated nature. The definition of "real time" will be critical for determining infringement, as it sets the standard for how quickly and seamlessly the system must identify and react to a new dimming protocol.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent frequently uses the term "automatic" to distinguish the invention from prior art requiring manual configuration, suggesting the term could be construed broadly to mean any detection that occurs without user intervention (’304 Patent, col. 3:10-14).
    • Evidence for a Narrower Interpretation: The specification states that the module detects protocol changes "in or near real-time with the receipt of the dimming input," which could support a narrower construction requiring detection that is nearly instantaneous upon receiving a signal (’304 Patent, col. 4:48-50).

• The Term: "dimming protocol detection module"

  • Context and Importance: Practitioners may focus on this term because the claims require a distinct "module" for detection and another for control. Whether the accused KAST technology has a structure that can be fairly characterized as separate "detection" and "control" modules, or if it is a single, undifferentiated system, will be a key question.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the modules in functional terms, and the functions could potentially be performed by integrated software routines on a single processor, supporting a broader definition not tied to a specific hardware structure (’304 Patent, col. 9:60-65).
    • Evidence for a Narrower Interpretation: The patent's figures, particularly Figure 1, depict the "Dimming Protocol Detection Module (132)" and "Dimming Protocol Control Module (134)" as distinct functional blocks, which could argue for a construction requiring separable components or processes (’304 Patent, Fig. 1).

VI. Other Allegations

• Indirect Infringement: The complaint includes language suggesting indirect infringement, stating Defendant infringes "directly, jointly, indirectly" and by "causing others to make, use, sell, and/or offer to sell" the Accused Products (Compl. ¶12-13). Allegations that Defendant provides installation instructions and training videos could be used to build a case for induced infringement (Compl. ¶17-18).
• Willful Infringement: The complaint alleges willful infringement based on Defendant's continued infringement after receiving a notice letter from Plaintiff on January 9, 2024 (Compl. ¶20-21). This allegation appears to be based on post-notice conduct.

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

1. A central issue will be one of operational sequence and timing: Does the accused KAST technology perform the specific, three-part sequence required by Claim 1—(1) operating on a first detected protocol, (2) detecting a second protocol, and (3) affirmatively "discontinuing" control based on the first protocol "in real-time with" the detection of the second? The case may depend on factual evidence of the accused system's internal logic.
2. The case will also involve a question of definitional scope: How should "in real time" be construed? Whether this term implies near-instantaneous, simultaneous action, as some language in the specification might suggest, or whether it allows for a short but perceptible lag in switching between protocols, will be a critical question for claim construction.
3. A key evidentiary question will be one of structural correspondence: Does the accused KAST technology, as implemented in hardware and software, contain structures that correspond to the claimed "dimming protocol detection module" and "light dimming control module," or does it operate as a monolithic system in a way that falls outside the claim's scope?