DCT
2:24-cv-07565
In 2 Developments LLC v. Globe Electric
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: IN 2 Developments LLC (Minnesota)
- Defendant: Globe Electric (Canada)
- Plaintiff’s Counsel: Perkowski Legal, PC; Daignault Iyer LLP
- Case Identification: 2:24-cv-07565, C.D. Cal., 09/05/2024
- Venue Allegations: Venue is asserted based on the defendant being a foreign corporation that allegedly transacts business and commits acts of patent infringement within the judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s vintage-style LED lightbulbs infringe two patents related to methods of constructing LED bulbs to mimic the appearance and form factor of traditional incandescent filament bulbs.
- Technical Context: The technology addresses the market challenge of replacing traditional incandescent bulbs by integrating energy-efficient LED components onto filament-like structures within a conventional glass bulb.
- Key Procedural History: The complaint notes that U.S. Patent No. 9,995,436 is a continuation of the application that resulted in U.S. Patent No. 9,702,510, indicating a close technological relationship between the two patents-in-suit. No other prior litigation or administrative proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2013-05-24 | Earliest Priority Date for the '510 and '436 Patents |
| 2017-07-11 | U.S. Patent No. 9,702,510 Issues |
| 2018-06-12 | U.S. Patent No. 9,995,436 Issues |
| 2024-09-05 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,702,510 - LED LIGHT BULB, Issued July 11, 2017
The Invention Explained
- Problem Addressed: The patent describes a market need for light bulbs that combine the energy efficiency and long lifespan of Light Emitting Diodes (LEDs) with the conventional designs of traditional bulbs to achieve broader consumer acceptance and application (Compl. ¶20). The specification notes that prior to the invention, traditional lighting had not fully capitalized on the benefits of LEDs (’510 Patent, col. 2:27-33).
- The Patented Solution: The invention is an LED light bulb constructed to resemble a traditional incandescent bulb. It features an Edison-style base, a glass bulb, and one or more internal structures that look like filaments. These "filaments" are substrates that support "light emitting diode channels" (’510 Patent, Abstract). To manage heat, a key challenge in LED design, the bulb is filled with an inert gas, such as argon, which uses convection to transfer heat away from the LED components and dissipate it through the glass bulb (’510 Patent, col. 6:2-9).
- Technical Importance: This design allows for a "drop-in" replacement for incandescent bulbs, using the same fixtures and providing a similar aesthetic, which was a significant factor in overcoming market resistance to new lighting technologies (Compl. ¶¶20-21).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶25).
- The key elements of Claim 1 include:
- An Edison style base.
- Light emitting diode circuitry coupled to the base.
- A conductive structure with proximal and distal contacts.
- A bulb sealed about the base that entirely encases the filament.
- A "substantially cylindrical elongated filament" supported by the conductive contacts.
- A "light emitting diode channel disposed within the filament."
- An inert gas disposed within the bulb.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 9,995,436 - LED LIGHT BULB, Issued June 12, 2018
The Invention Explained
- Problem Addressed: As a continuation of the '510 patent's application, the '436 Patent addresses the same problem of integrating the advantages of LED technology into a conventional light bulb form factor for better market adoption (Compl. ¶20; '436 Patent, col. 2:27-33).
- The Patented Solution: The solution is materially the same as that described in the '510 patent: an LED light bulb with an Edison base, a glass bulb enclosure, and internal, filament-like structures supporting LEDs, with an inert gas for thermal management (’436 Patent, Abstract; col. 6:2-9).
- Technical Importance: The technical importance is identical to that of the '510 patent, focusing on creating an aesthetically familiar, energy-efficient replacement for incandescent bulbs (Compl. ¶¶20-21).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶35).
- The key elements of Claim 1 are nearly identical to Claim 1 of the '510 patent, with two notable distinctions:
- It requires an "elongated filament," omitting the "substantially cylindrical" limitation found in the '510 patent.
- It requires a "light emitting diode disposed within the filament," replacing the term "light emitting diode channel" from the '510 patent.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The accused products are Globe Electric's "Vintage LED BULB – 60W replacement bulb" and other similar LED lightbulbs (collectively, the "Globe Electric Products") (Compl. ¶6).
Functionality and Market Context
The complaint alleges the accused products are LED lightbulbs designed to replicate the appearance of traditional incandescent bulbs (Compl. ¶26). They feature a standard threaded Edison-style base, a clear glass bulb, and multiple visible yellow strips inside the bulb that function as the light-emitting filaments (Compl. ¶29). The complaint asserts these products are sold throughout the United States, including in California (Compl. ¶6). The photograph in the complaint shows the accused product held in a hand, illustrating its conventional light bulb size and shape (Compl. ¶26, p. 5).
IV. Analysis of Infringement Allegations
'510 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an Edison style base | The accused product is alleged to have a standard threaded Edison-style base for use in conventional light sockets. A photograph shows the accused product with this base (Compl. ¶26, p. 5). | ¶26 | col. 4:10-11 |
| a bulb sealed about the base and extending above the base ... wherein the bulb entirely encases the elongated filament | The product is alleged to have a glass bulb sealed to the base that fully encloses the internal filament structures. A photograph with a red circle highlights this feature (Compl. ¶27, p. 6). | ¶¶27, 29 | col. 5:46-48 |
| a conductive structure including a first proximal contact that is proximate the base ... and a first distal contact that is distal from the base | The complaint alleges the product has a conductive structure that supports the filament, with contacts near the base (proximal) and at the tip of the filament (distal). | ¶28 | col. 21:26-31 |
| a substantially cylindrical elongated filament supported on a first proximate filament end by the first proximate contact; and supported on a first distal filament end by the first distal contact; the filament extending from the base into the bulb above the base | The product is alleged to contain multiple elongated filaments, which are yellow strips that extend from the base structure up into the glass bulb. A close-up photograph displays these filament structures (Compl. ¶29, p. 7). | ¶29 | col. 8:38-41 |
| a light emitting diode channel disposed within the filament, coupled to the light emitting diode circuitry, and extending into the bulb above the base | The complaint alleges an LED channel is disposed within the filament structure. A close-up photograph highlights the base of the filaments where they connect to circuitry (Compl. ¶30, p. 8). | ¶30 | col. 5:22-24 |
| an inert gas disposed within the bulb | The complaint does not provide specific evidence for this element but alleges on information and belief that the accused products contain an inert gas. | ¶23 | col. 6:64-7:1 |
'436 Patent Infringement Allegations
The allegations for infringement of the '436 patent are substantively identical to those for the '510 patent, using the same photographs and descriptions for each corresponding element (Compl. ¶¶36-41). The complaint provides a diagram of a filament manufacturing process, which it alleges is representative of the accused product's structure (Compl. ¶42, p. 14).
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an elongated filament supported on a first proximate filament end by the first proximate contact; and supported on a first distal filament end by the first distal contact; the filament extending from the base into the bulb above the base | The product is alleged to contain multiple elongated filaments. The allegations and supporting visuals are identical to those asserted for the '510 patent (Compl. ¶39, p. 12). | ¶39 | col. 7:12-16 |
| a light emitting diode channel disposed within the filament, coupled to the light emitting diode circuitry, and extending into the bulb above the base | The complaint alleges the product's filaments contain a light emitting diode. The allegations and supporting visuals are identical to those asserted for the '510 patent (Compl. ¶41, p. 14). | ¶41 | col. 5:22-24 |
Note: Other elements are omitted for brevity as the allegations are identical to the '510 patent analysis.
- Identified Points of Contention:
- Scope Questions: A central issue for the '510 patent may be whether the accused product's filaments, which appear in photographs as flat strips, meet the claim requirement of being "substantially cylindrical." A further question for both patents is whether mounting LEDs onto a substrate, as is common practice, constitutes a diode or channel being "disposed within the filament" as claimed.
- Technical Questions: The complaint alleges the presence of an inert gas but provides no direct evidence. The composition and internal structure of the accused filament will be a key factual question, requiring discovery and potentially expert analysis to determine if it aligns with the "LED channel" or "LED disposed within" limitations.
V. Key Claim Terms for Construction
The Term: "substantially cylindrical elongated filament" (from '510 patent, Claim 1)
- Context and Importance: This term is critical because the visual evidence in the complaint depicts the accused filaments as flat, rectangular strips (Compl. ¶29, p. 7). The infringement determination for the '510 patent may turn on whether a flat strip can be construed as "substantially cylindrical."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's overall goal is to mimic the aesthetic of a traditional bulb. A party could argue that "substantially" loosens the geometric requirement, and that any elongated shape creating a filament-like appearance falls within the scope. The specification also discloses multi-sided filaments (e.g., two-sided, three-sided) which are not perfectly cylindrical (’510 Patent, Figs. 6A-6E).
- Evidence for a Narrower Interpretation: The patent explicitly illustrates a "cylindrical filament" as a distinct embodiment (’510 Patent, Fig. 6F, col. 8:38-41). A party could argue that this specific disclosure, combined with the plain meaning of "cylindrical," limits the term to shapes with a generally circular cross-section, excluding flat strips.
The Term: "light emitting diode channel disposed within the filament" (from '510 patent, Claim 1)
- Context and Importance: This term defines the core inventive concept. Practitioners may focus on this term because the actual construction of LED filaments often involves mounting LED chips onto the surface of a substrate, not placing them "within" the substrate material itself. The infringement analysis will depend on whether "within the filament" means "fully enclosed by" or "integrated as a component of."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the filament as a "substrate" that "support[s]" the LED channel, which could suggest the channel is part of a larger filament assembly rather than being strictly inside the substrate material (’510 Patent, col. 7:3-8).
- Evidence for a Narrower Interpretation: The plain language "disposed within" suggests an internal or embedded relationship. The complaint itself uses a diagram showing "LED chip bonding" to a substrate, followed by a "Phosphor Coating" that encases the components, which a party could argue creates the "filament" that the channel is "within" (Compl. ¶32, Figure 1). The precise definition will likely be a significant point of dispute.
VI. Other Allegations
- Indirect Infringement: The complaint does not allege indirect infringement (inducement or contributory infringement).
- Willful Infringement: The complaint does not include factual allegations typically used to support a claim for willful infringement, such as alleging that the defendant had pre-suit knowledge of the patents-in-suit. The prayer for relief includes a general request for damages under 35 U.S.C. § 284, but the body of the complaint focuses exclusively on direct infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction and scope: can the term "substantially cylindrical ... filament," as required by the '510 patent, be interpreted to read on the accused product’s apparently flat, strip-like filaments? The outcome of this question could create divergent infringement results between the two asserted patents.
- A key factual and evidentiary question will be whether the accused product's structure, where LED chips are mounted on a substrate, satisfies the claim requirement of a "channel" or "diode" being "disposed within the filament," or if this represents a fundamental mismatch in technical operation.
- The case may also turn on the slight but significant differences in claim language between the two patents. A key question for the court will be whether dropping the "substantially cylindrical" requirement and changing "channel" to "diode" in the '436 patent is sufficient for its claims to cover the accused products even if the '510 patent claims do not.