AMP Plus Inc v. Nora Lighting Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: AMP Plus, Inc. d/b/a ELCO Lighting (California)
  • Defendant: Nora Lighting, Inc. (California)
  • Plaintiff’s Counsel: RUTTENBERG IP LAW, A PROFESSIONAL CORPORATION
• Case Identification: 2:24-cv-08460, C.D. Cal., 10/01/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in the district, maintains a regular and established place of business in the district, and has committed alleged acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s Pearl LED Retrofit Series of LED downlights infringes a patent related to the mechanical and thermal design of an integrated lighting module.
• Technical Context: The technology concerns the design of self-contained LED lighting modules intended to replace older bulbs in recessed lighting fixtures, a significant market segment in both commercial and residential lighting.
• Key Procedural History: The complaint details extensive pre-suit communications, beginning with a notice letter from Plaintiff to Defendant on September 10, 2021. In response to a request for clarification, Plaintiff provided a claim chart in November 2021. In February 2022, Defendant asserted the patent was invalid and threatened to file a petition for Post-Grant Review (PGR), but allegedly never did so. The patent-in-suit is subject to a terminal disclaimer.

Case Timeline

Date	Event
2019-06-03	’326 Patent Priority Date
2021-08-17	’326 Patent Issue Date
2021-09-10	Plaintiff provides first notice of infringement to Defendant
2021-11-11	Plaintiff sends cease-and-desist letter with claim chart
2022-02-21	Defendant threatens to file a Post-Grant Review (PGR)
2024-10-01	Complaint Filing Date

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

U.S. Patent No. 11,092,326 - "Integrated Lighting Module"

• Patent Identification: U.S. Patent No. 11,092,326, "Integrated Lighting Module," issued on August 17, 2021 (’326 Patent). (Compl. ¶6).

The Invention Explained

• Problem Addressed: The patent’s background section identifies a need for an integrated LED lighting module that can achieve high brightness (lumens output) through efficient heat dissipation, while remaining compact enough to fit within standardized, pre-existing trim sizes, such as MR16 formats. (’326 Patent, col. 1:45-54).
• The Patented Solution: The invention is a multi-component lighting module comprising a driver housing, an LED element, an optical reflector, a holder, and a distinctively shaped heat sink. The heat sink is described as having an upper, finned portion with a larger diameter and a lower, non-finned portion with a smaller diameter, allowing the module to maximize its heat-dissipating surface area while still fitting into a compact housing. (’326 Patent, Abstract; col. 6:31-46). Figure 11 shows an exploded view of these components, illustrating how the driver cap (101), heat sink (115), LED chip (701), optical reflector (703), and holder (125) assemble into a single unit.
• Technical Importance: This design attempts to resolve the inherent conflict between thermal management, which favors larger surface areas, and the physical constraints of retrofit lighting applications, which demand compatibility with small, standardized form factors. (’326 Patent, col. 1:45-54).

Key Claims at a Glance

• The complaint asserts independent claim 1 and reserves the right to assert other claims. (Compl. ¶¶8, 10).
• Independent Claim 1 of the ’326 Patent recites:
  • A "driver housing" with side walls and a top, configured to receive a power driver.
  • A "heat sink module" configured to receive the light emitting diode element, having an "upper portion" with a "larger exterior diameter" that is larger than a "smaller exterior diameter" of a "lower portion", with the driver housing attachable to the top of the heat sink.
  • A "light emitting diode element" configured to emit light.
  • An "optical reflector" that is "substantially conical in shape" for directing light.
  • A requirement that the light emitting diode element is disposed "above a top-hole" of the reflector and "underneath the heat sink module".
  • A "holder" with side-walls configured to receive a bottom region of the heat sink module.

III. The Accused Instrumentality

Product Identification

• The complaint names Defendant’s "Pearl LED Retrofit Series LED downlights," including specific model numbers NPR-4RC, NPR-4RG, NPR-4RNB, NPR-4RNDC, NPR-4RPH, NPR-4RPHA, NPR-4RSL, NPR-4SC, NPR-4SG, NPR-4SNB, NPR-4SNDC, NPR-4SNDSQ, and NPR-56RNDC (the “Infringing Products”). (Compl. ¶10).

Functionality and Market Context

• The complaint alleges the Infringing Products are "integrated lighting modules" that contain each of the structural components recited in claim 1 of the ’326 Patent. (Compl. ¶¶27-31). The complaint alleges that Defendant makes, uses, sells, offers to sell, and imports these products in the United States. (Compl. ¶10). The complaint does not provide sufficient detail for analysis of the accused products' commercial importance or market positioning beyond general allegations of sales.
  No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’326 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a driver housing that has first side walls, a first top that caps the first side walls; wherein the first side walls and the first top substantially surround a first volume of the driver housing, wherein the first volume is configured to receive a driver that is configured to provide electrical power to a light emitting diode element	The Infringing Products are alleged to comprise a driver housing with first side walls and a capped first top that substantially surround a volume configured to receive a driver for powering an LED element.	¶27	col. 4:26-35
a heat sink module that is configured for receiving the light emitting diode element...wherein the heat sink module has an upper portion that has a larger exterior diameter that is larger than a smaller exterior diameter of a lower portion of the heat sink module; wherein the lower portion transitions into the upper portion; wherein a first bottom portion of the driver housing is attachable to a second top...a top of the heat sink module	The Infringing Products are alleged to comprise a heat sink module for receiving and cooling an LED element. The heat sink allegedly has an upper portion with a larger exterior diameter than a smaller exterior diameter of its lower portion, and a top portion that is attachable to the driver housing.	¶28	col. 6:31-46
the light emitting diode element that is configured to emit light	The Infringing Products are alleged to comprise an LED element configured to emit light.	¶29	col. 5:11-16
at least one optical reflector that is substantially conical in shape configured for reflecting and directing at least some light from the light emitting diode element out of a second bottom...	The Infringing Products are alleged to comprise at least one optical reflector that is substantially conical in shape, configured for reflecting and directing light out of a second bottom.	¶30	col. 10:5-9
wherein the light emitting diode element is disposed above a top-hole of the at least one optical reflector and underneath the heat sink module, wherein the top-hole is located at a top of the optical reflector	The Infringing Products are alleged to have an LED element disposed above the top-hole of the optical reflector and underneath the heat sink module, with the top-hole located at the top of the optical reflector.	¶30	col. 11:11-16
a holder that has second side-walls that substantially surround a second volume, wherein the second volume is configured to receive at least a bottom region of the lower portion of the heat sink module; wherein the holder is open at both a third top and at a third bottom...	The Infringing Products are alleged to comprise a holder with side-walls that surround a second volume configured to receive a bottom region of the heat sink module, with the holder being open at its top and bottom.	¶31	col. 5:30-40

Identified Points of Contention

• Structural Questions: A primary factual dispute may concern the specific geometry of the accused products' heat sinks. The infringement case hinges on whether the products actually have an "upper portion that has a larger exterior diameter that is larger than a smaller exterior diameter of a lower portion." (Compl. ¶28). The complaint makes a conclusory allegation without providing measurements, diagrams, or other documentary evidence to substantiate this structural claim.
• Scope Questions: The claim uses the term "substantially conical" to describe the optical reflector. (Compl. ¶8). This raises the question of how much deviation from a perfect cone is permissible for an accused product to fall within the scope of the claim. Similarly, the term "substantially surround" appears in the description of the driver housing and holder, which could be another point of contention regarding the degree of enclosure required.

V. Key Claim Terms for Construction

• The Term: "an upper portion that has a larger exterior diameter that is larger than a smaller exterior diameter of a lower portion" [of the heat sink module]

• Context and Importance: This limitation defines the core structural characteristic of the heat sink, which the patent presents as key to achieving improved thermal performance while maintaining a compact form factor. Practitioners may focus on this term because the infringement analysis will likely depend on a comparison of physical measurements of the accused product against the definition of "upper portion," "lower portion," and the required diameter differential.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not impose any specific ratio or degree of difference between the diameters, suggesting any measurable difference where an upper section is wider than a lower section could suffice.
  • Evidence for a Narrower Interpretation: The specification includes figures showing a specific curved transition between the lower and upper portions. (’326 Patent, Fig. 2). A defendant may argue that the claims should be limited to a heat sink exhibiting such a transition. The specification also provides exemplary dimensions, noting a potential ratio of the heat sink top diameter to the holder diameter of approximately 1.21 to 1.22, which could be argued as context for what constitutes a "larger" diameter. (’326 Patent, col. 8:55-60).

• The Term: "substantially conical in shape"

• Context and Importance: This term defines the shape of the optical reflector. The meaning of "substantially" is a frequent subject of claim construction disputes. The outcome of the infringement analysis for this element depends on whether the accused reflector's geometry, which may not be a perfect cone, is close enough to be considered "substantially conical."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The use of "substantially" itself suggests the patentee did not intend to limit the claim to a mathematically perfect cone and envisioned some variation in shape.
  • Evidence for a Narrower Interpretation: The specification provides a more specific definition, stating that the reflector may be "substantially conical in space, but without a cone's point; instead, a cone's point might reside may be replaced with top-hole 1131." (’326 Patent, col. 10:7-10). This language could be used to argue that the term requires a specific truncated cone shape as depicted in the patent's figures (e.g., Fig. 11, item 703).

VI. Other Allegations

• Indirect Infringement: The complaint alleges both contributory and induced infringement. (Compl. ¶26). It supports the contributory infringement claim by alleging the accused products "embody a material part of the claimed invention," are "especially made and/or adapted" for infringement, and are not "staple articles or commodities of commerce suitable for substantially non-infringing uses." (Compl. ¶33). The inducement claim is based on the allegation that Defendant "knows that its actions induce actual infringement by its customers." (Compl. ¶34). The complaint does not, however, allege specific facts regarding how Defendant instructs or encourages its customers to infringe.
• Willful Infringement: The complaint alleges that Defendant’s infringement has been and continues to be willful. (Compl. ¶32). This allegation is supported by a detailed timeline of pre-suit communications, including Plaintiff's initial notice on September 10, 2021, and its provision of a claim chart in November 2021. (Compl. ¶¶11, 13). The complaint further notes that Defendant threatened to file a PGR petition in February 2022 but never did so, which Plaintiff may use to argue that Defendant was aware of the patent and its potential infringement but continued its conduct regardless. (Compl. ¶¶14-15).

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

• A central issue will be one of structural fact-finding: does the accused "Pearl LED Retrofit Series" physically embody the specific two-tiered heat sink geometry required by claim 1, where an upper portion has a demonstrably larger exterior diameter than a lower portion? The outcome will depend on evidence such as product teardowns and measurements, as the complaint's allegations are currently conclusory.
• The case may also turn on a question of claim scope: how broadly will the court construe the term "substantially conical"? The answer will determine whether the shape of the accused product's optical reflector falls within the bounds of the patent claim, particularly in light of the more detailed description of a truncated cone provided in the specification.
• A key question for damages will be willfulness: given the extensive pre-suit notice alleged in the complaint, including Defendant's own threat of a PGR proceeding that was never initiated, the court will have to determine whether Defendant's continued sales constitute willful infringement, which could expose it to enhanced damages.