DCT
2:24-cv-04238
Seoul Viosys Co Ltd v. Feit Electric Co Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Seoul Viosys Co., Ltd. (Republic of Korea)
- Defendant: Feit Electric Co., Inc. (California)
- Plaintiff’s Counsel: Radulescu LLP; Ruttenberg IP Law
- Case Identification: 2:24-cv-04238, C.D. Cal., 05/21/2024
- Venue Allegations: Venue is based on Defendant Feit Electric Co., Inc.'s principal place of business being located within the Central District of California.
- Core Dispute: Plaintiff alleges that Defendant’s LED lighting products, including multicolor floodlights and filament-style bulbs, infringe six patents related to LED device structure, optical configuration, and light spectrum optimization for plant growth.
- Technical Context: The lawsuit involves foundational aspects of modern light-emitting diode (LED) technology, from the micro-architecture of the semiconductor chip to the macro-level design of multi-emitter modules for specialized applications.
- Key Procedural History: The complaint alleges that Plaintiff sent multiple pre-suit notice letters to Defendant and its distributor, Home Depot, beginning in July 2023. These letters allegedly identified infringing products and asserted patents, and in some cases included claim charts, but received no response. These allegations form the basis for the claim of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2007-10-29 | U.S. Patent No. 7,982,207 Priority Date |
| 2010-08-23 | U.S. Patent No. 9,269,871 Priority Date |
| 2010-11-18 | U.S. Patent No. 9,929,314 Priority Date |
| 2011-03-30 | U.S. Patent No. 9,837,387 Priority Date |
| 2011-03-30 | U.S. Patent No. 10,163,975 Priority Date |
| 2011-07-19 | U.S. Patent No. 7,982,207 Issues |
| 2016-02-23 | U.S. Patent No. 9,269,871 Issues |
| 2017-12-05 | U.S. Patent No. 9,837,387 Issues |
| 2018-03-27 | U.S. Patent No. 9,929,314 Issues |
| 2018-12-25 | U.S. Patent No. 10,163,975 Issues |
| 2020-03-10 | U.S. Patent No. 11,879,602 Priority Date |
| 2023-07-21 | Plaintiff sends warning letter to Home Depot concerning Feit products |
| 2023-11-08 | Plaintiff sends warning letter to Defendant's counsel |
| 2024-01-23 | U.S. Patent No. 11,879,602 Issues |
| 2024-01-23 | Plaintiff sends follow-up letter to Defendant |
| 2024-02-20 | Plaintiff sends follow-up letter with claim chart for '314 patent to Defendant |
| 2024-05-13 | Plaintiff sends final letter with claim charts for '602 and '871 patents to Defendant |
| 2024-05-21 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,879,602 - "Light Source Module for Plant Cultivation and Light Irradiation Device Including the Same"
The Invention Explained
- Problem Addressed: The patent addresses the limitation of conventional plant cultivation lights, which typically provide a narrow spectrum of light suitable only for photosynthesis, without promoting the synthesis of other beneficial substances (phytochemicals) within the plant (’602 Patent, col. 1:36-44).
- The Patented Solution: The invention proposes a light source module that combines multiple light emitters, each producing a different optical spectrum. By mixing the light from these different emitters, the module can generate a tailored white light spectrum with specific peak wavelengths designed to improve not only plant growth but also the production of phytochemicals (’602 Patent, Abstract; col. 2:54-64).
- Technical Importance: This technology represents a shift from generic growth lighting to precision horticulture, where the light spectrum is engineered to elicit specific, desirable biological responses in plants, thereby enhancing their nutritional or commercial value (’602 Patent, col. 2:1-10).
Key Claims at a Glance
- The complaint asserts exemplary independent claim 16 (Compl. ¶17).
- Essential elements of Claim 16 include:
- A substrate with a first, a second, and a third emitter disposed on it, each emitting light with a respective optical spectrum.
- At least two of the three optical spectrums are different.
- A series of specific relationships between the optical spectrums, including:
- The total number of peaks in the first spectrum is greater than in the third spectrum.
- The peak wavelength of the second spectrum is different from the peak wavelength of the third spectrum.
- The intensity of a peak in the 410 nm to 460 nm range of the first spectrum is different from the intensity of a peak in the same range of the second spectrum.
U.S. Patent No. 9,837,387 - "Light Emitting Apparatus"
The Invention Explained
- Problem Addressed: In LED devices that use a light-transmissive chip (e.g., grown on a sapphire substrate), a significant amount of light emitted from the bottom mounting surface can be blocked by the underlying circuit board or package, reducing overall efficiency (’387 Patent, col. 1:46-54).
- The Patented Solution: The invention mounts the LED chip on the top surface of a light-transmissive substrate and places a reflector over the chip. This reflector captures upward- and side-emitted light and redirects it downward through the transmissive substrate, which becomes the primary light-emitting surface. The solution also strategically places different wavelength converters (phosphors) both on the reflector and on the bottom of the substrate to efficiently produce light of a desired color (’387 Patent, Abstract; Fig. 1).
- Technical Importance: This "reverse emission" architecture is designed to maximize usable light output by capturing and redirecting photons that would otherwise be lost, thereby improving the luminous efficacy of the LED apparatus (’387 Patent, col. 2:56-62).
Key Claims at a Glance
- The complaint asserts exemplary independent claim 1 (Compl. ¶25).
- Essential elements of Claim 1 include:
- A light-transmissive substrate with a top and a bottom surface.
- A semiconductor light emitting device disposed on the top surface.
- A reflective part disposed over the device to reflect light toward the substrate.
- A first wavelength converter located between the substrate and the reflective part.
- A second wavelength converter disposed directly on the bottom surface of the substrate.
- A light-transmissive adhesive material between the device and the substrate.
- The reflective part is configured to reflect light that has been converted by the first wavelength converter.
U.S. Patent No. 10,163,975 - "Light Emitting Apparatus"
- Technology Synopsis: This patent, related to the ’387 Patent, discloses an LED apparatus designed for high-efficiency light extraction. It describes a structure with a semiconductor light emitting device on a transmissive substrate, a reflector positioned over the device to redirect light, and multiple wavelength converters. A key feature is the reflector comprising a "concave curved surface" to shape the reflected light (’975 Patent, Claim 1).
- Asserted Claims: Exemplary Claim 1 is asserted (Compl. ¶35).
- Accused Features: The complaint alleges that the internal structure of the filament in the EcoSmart #A19605CCTCA/WFIL/ECP bulb, including its substrate, LED chip, encapsulant, and phosphor coatings, infringes this patent (Compl. ¶¶36-39).
U.S. Patent No. 9,269,871 - "Light Emitting Diode"
- Technology Synopsis: This patent concerns the micro-architecture of an LED chip's electrode structure. It addresses the problem of light being absorbed by the electrode pad material, which reduces efficiency. The solution involves forming a "current shielding layer," such as a pad-type or dot-pattern reflector, directly under the electrode structure to block current flow in that area and reflect light away from the absorptive material (’871 Patent, col. 5:14-26).
- Asserted Claims: Exemplary Claim 7 is asserted (Compl. ¶43).
- Accused Features: The complaint alleges that the electrode structures within the LED chips of the EcoSmart #A19605CCTCA/WFIL/ECP bulb contain pad type and dot-pattern current shielding layers (Compl. ¶¶47-48).
U.S. Patent No. 9,929,314 - "Light Emitting Diode Chip Having Electrode Pad"
- Technology Synopsis: This patent discloses a specific design for an electrode on an LED chip to improve current spreading. It describes a "first electrode extension" which is structured to have alternating "first portions" that are in contact with the underlying semiconductor layer and "second portions" that are not in contact. This patterned contact is intended to distribute current more uniformly and improve light emission efficiency (’314 Patent, Claim 1).
- Asserted Claims: Exemplary Claim 1 is asserted (Compl. ¶52).
- Accused Features: The complaint uses microscope and FIB/SEM images to allege that the electrode extensions on the LED chips in the EcoSmart #A19605CCTCA/WFIL/ECP bulb have this structure of alternating contact and non-contact portions (Compl. ¶¶56-58).
U.S. Patent No. 7,982,207 - "Lighting Emitting Diode"
- Technology Synopsis: This patent addresses the problem of "current crowding" directly under an electrode pad, which leads to inefficient light emission. The invention creates an "opening" in the transparent electrode layer beneath the pad, exposing the underlying semiconductor layer. A "current blocking portion" (e.g., a distributed Bragg reflector) is placed in this opening, forcing the current to spread out into the transparent electrode layer rather than concentrating under the pad (’207 Patent, Abstract).
- Asserted Claims: Exemplary Claim 7 is asserted (Compl. ¶63).
- Accused Features: The complaint alleges, with supporting SEM images, that the LED chips in the EcoSmart #A19605CCTCA/WFIL/ECP bulb contain a transparent electrode layer with an opening, a current blocking portion in that opening, and an electrode pad arranged on the blocking portion (Compl. ¶¶66-67).
III. The Accused Instrumentality
Product Identification
The complaint names two categories of accused products:
- Feit #PAR38/RGBW/CA/AG(C)
- EcoSmart #A19605CCTCA/WFIL/ECP
Functionality and Market Context
- The Feit #PAR38/RGBW/CA/AG(C) is a PAR38-style floodlight bulb. The complaint alleges it functions as a multi-emitter light source, using a substrate populated with at least three different types of emitters to produce various colors and white light (Compl. ¶¶18-19). The annotated photograph provided in the complaint identifies a "First emitter," "Second emitter," and "Third emitter" on the device's substrate (Compl. ¶19). Such bulbs are common in consumer and commercial markets for adjustable and colored lighting.
- The EcoSmart #A19605CCTCA/WFIL/ECP is an LED bulb designed to mimic the appearance of a traditional incandescent filament bulb. It utilizes what the complaint describes as "chip-on-board type LED packages," which are the elongated yellow strips that function as the light-emitting "filaments" (Compl. ¶¶26, 36). These packages contain multiple microscopic LED chips, and the complaint's allegations focus on the detailed physical construction of these packages and the chips within them (Compl. ¶¶27-31, 37-39, 45-48, 53-59, 64-68).
IV. Analysis of Infringement Allegations
'602 Infringement Allegations
| Claim Element (from Independent Claim 16) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a substrate; | The accused Feit #PAR38 product includes a substrate upon which LED packages are disposed. | ¶18 | col. 12:1-2 |
| a first emitter disposed on the substrate and configured to emit a first light including a first optical spectrum; | The accused product includes a first emitter on the substrate configured to emit light with a first optical spectrum. | ¶19 | col. 12:3-5 |
| a second emitter disposed on the substrate and configured to emit a second light including a second optical spectrum; | The accused product includes a second emitter on the substrate configured to emit light with a second optical spectrum. | ¶19 | col. 12:6-8 |
| a third emitter disposed on the substrate and configured to emit a third light including a third optical spectrum, | The accused product includes a third emitter on the substrate configured to emit light with a third optical spectrum. | ¶19 | col. 12:9-11 |
| wherein at least two of the first, second, and third optical spectrums are different, | The complaint alleges the optical spectra are different. The provided graph shows the first and second spectra are different. | ¶21 | col. 12:13-14 |
| wherein a total number of peaks in the first optical spectrum is greater than the total of one or more peaks in the third optical spectrum, | The complaint alleges the first optical spectrum has more peaks than the third optical spectrum. | ¶20 | col. 12:17-19 |
| wherein a peak wavelength of the second optical spectrum is different from a peak wavelength of the third optical spectrum, | The complaint alleges the peak wavelength of the second optical spectrum differs from that of the third. | ¶20 | col. 12:20-22 |
| and wherein an intensity of a peak in a range from 410 nm to 460 nm of the first optical spectrum is different from an intensity of a peak in the range from 410 nm to 460 nm of the second optical spectrum. | The complaint provides a graph showing different peak intensities for the first and second emitters in the 410-460 nm range. The graph in paragraph 21 shows distinct spectral distributions for the first and second emitters (Compl. ¶21). | ¶21 | col. 12:23-27 |
'387 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a light-transmissive substrate comprising a top surface and a bottom surface; | The accused EcoSmart product allegedly includes a light-transmissive substrate with top and bottom surfaces within its filament package. | ¶27 | col. 8:12-14 |
| a semiconductor light emitting device disposed on the top surface of the light-transmissive substrate... | The accused product includes a semiconductor light emitting device on the top surface of the substrate. An annotated microscope image shows these labeled components (Compl. ¶9). | ¶27 | col. 8:15-18 |
| a reflective part disposed over the semiconductor light emitting device and configured to reflect light...toward the light-transmissive substrate; | The accused product allegedly has a reflective part over the device that reflects light toward the substrate. | ¶28 | col. 8:19-22 |
| a first wavelength converter disposed between the light-transmissive substrate and the reflective part... | The accused product allegedly includes a first wavelength converter between the substrate and reflective part. | ¶29 | col. 8:23-31 |
| a second wavelength converter disposed directly on the bottom surface of the light-transmissive substrate... | The accused product allegedly includes a second wavelength converter on the bottom surface of the substrate. | ¶30 | col. 8:32-38 |
| a light-transmissive adhesive material disposed between the semiconductor light emitting device and the light-transmissive substrate, | The accused product allegedly includes a light-transmissive adhesive material between the device and substrate. An SEM image shows this material (Compl. ¶11). | ¶31 | col. 8:39-41 |
| wherein the reflective part is configured to reflect the first portion of light converted by the first wavelength converter... | The complaint alleges the accused product is configured such that the reflective part reflects light converted by the first wavelength converter. | ¶31 | col. 8:42-46 |
Identified Points of Contention
- Scope Questions: For the ’387 and ’975 Patents, a key question may be whether the integrated structure of the accused filament package can be read on claims that describe discrete components like a "reflective part disposed over" the LED. The patents' figures depict a physically separate, spaced-apart reflector (’387 Patent, Fig. 1), whereas the complaint identifies a portion of the filament's encapsulant as the "reflective part" (Compl. ¶28). The interpretation of whether this integrated structure meets the claim limitation will be a central point of contention.
- Technical Questions: For the ’602 Patent, the infringement allegation rests on satisfying a complex set of seven distinct spectral criteria across three different emitters. A technical question will be what evidence demonstrates that the accused product's third emitter has spectral properties (number of peaks, peak wavelength) that satisfy the specific relationships required by the claim relative to the first and second emitters, as the provided graph only compares the first and second (Compl. ¶21). For the patents concerning LED chip architecture (’871, ’314, ’207), the analysis will depend on whether the microscopic structures identified in the complaint's SEM images (e.g., "dot-pattern current shielding layer" at Compl. ¶48) perform the specific functions required by the claims.
V. Key Claim Terms for Construction
The Term: "emitter" ('602 Patent, Claim 16)
Context and Importance
The term "emitter" (from ’602 Patent, Claim 16) is critical. Claim 16 requires three distinct emitters, each with a unique optical spectrum, and sets forth specific relationships between those spectra. The complaint identifies three physically different components on the accused product's circuit board as the "first," "second," and "third" emitters (Compl. ¶19). Practitioners may focus on this term because the definition will determine the unit of analysis; whether an "emitter" is the bare semiconductor die or an entire packaged LED component (which may itself contain phosphors and other elements) could be critical to the infringement analysis.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent specification uses the term "light source" interchangeably with "light source module" and states a light source "may include an emitter" and a wavelength conversion part (’602 Patent, col. 5:26-33). This may support construing "emitter" broadly to mean a complete LED package.
- Evidence for a Narrower Interpretation: The specification also frequently refers to the core light-generating component as a "light emitting diode" (’602 Patent, col. 5:31-33). This could support a narrower construction where "emitter" refers specifically to the semiconductor die itself, separate from any associated phosphors or packaging.
The Term: "reflective part disposed over the semiconductor light emitting device" ('387 Patent, Claim 1)
Context and Importance
This term is central to the infringement theory for the filament-style bulb. The patent's architecture relies on capturing upward-emitted light. The complaint identifies a portion of the filament's encapsulant as this "reflective part" (Compl. ¶28). Practitioners may focus on this term because the defense may argue that an integrated part of the encapsulant is not a "reflective part disposed over" the device in the manner taught by the patent, which depicts a separate, spaced-apart component.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claim language requires a "reflective part" that is "disposed over" the device and performs a function. It does not explicitly require the part to be physically separate or air-gapped. One could argue that any structure fulfilling the reflective function in that location meets the claim language.
- Evidence for a Narrower Interpretation: The specification consistently describes and depicts the "reflector 30" as a distinct component "disposed over the light-transmissive substrate 10 so as to be spaced apart from the top surface" (’387 Patent, col. 4:30-33; Fig. 1). This explicit teaching of a spaced-apart configuration could be used to argue for a narrower construction that excludes integrated encapsulants.
VI. Other Allegations
Willful Infringement
The complaint alleges willful infringement for all asserted patents. The basis for this allegation is a series of pre-suit communications starting on July 21, 2023, which allegedly put Defendant on notice of the infringement (Compl. ¶¶12-16). The complaint alleges that Plaintiff sent letters to Defendant's counsel and its distributor that identified specific patents and accused products, and that later communications included exemplary claim charts, but that Defendant provided no response (Compl. ¶¶13-16).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue for the five patents asserted against the filament bulb will be one of definitional scope: can claim terms describing discrete, assembled components (e.g., a "reflective part disposed over" an LED, or a "current blocking portion" within an "opening") be construed to read on the highly integrated, chip-on-board structures found in the accused filament package? The resolution will likely depend on whether the court views the accused design as a fundamentally different technology or merely a more compact implementation of the claimed inventions.
- A key evidentiary question for the patent asserted against the PAR38 bulb will be one of functional matching: what evidence will be presented to demonstrate that the three emitters in the accused product collectively satisfy all seven specific and relative spectral limitations recited in Claim 16? The outcome may depend on detailed optical testing and comparison against the precise numerical and relational constraints of the claim language.
- A third central question will concern willfulness: given the detailed allegations of repeated, unanswered pre-suit notice letters that included patent numbers, product names, and claim charts, the court will have to evaluate whether Defendant’s alleged inaction constituted objective recklessness sufficient to support a finding of willful infringement.