DCT

2:24-cv-10883

Creeled Inc v. Adj Products LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-10883, C.D. Cal., 12/18/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant resides in the district and has allegedly committed acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s high-resolution LED video display panels infringe ten U.S. patents (eight utility and two design) related to the design, structure, and manufacturing of light-emitting diode (LED) packages and components.
  • Technical Context: The technology at issue concerns the micro-level packaging of LEDs, which are fundamental components for large-scale, high-resolution video displays used in commercial, entertainment, and architectural settings.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the asserted patents via a letter on July 12, 2024, followed by a letter containing claim charts detailing the alleged infringement on August 15, 2024, which forms the basis for the willfulness allegation.

Case Timeline

Date Event
2006-04-24 Priority Date (U.S. Patent Nos. 8,487,337 & 8,748,915)
2006-05-23 Priority Date (U.S. Patent No. 7,718,991)
2008-05-16 Priority Date (U.S. Patent No. 8,049,230)
2010-04-12 Priority Date (U.S. Patent No. 8,901,583)
2010-05-18 Issue Date (U.S. Patent No. 7,718,991)
2010-11-30 Priority Date (U.S. Patent No. 9,240,395)
2011-03-02 Priority Date (U.S. Patent No. 9,634,209) & Filing Date (U.S. Patent No. D684,545)
2011-11-01 Issue Date (U.S. Patent No. 8,049,230)
2011-11-24 Priority Date (U.S. Patent No. 9,054,257)
2013-06-18 Issue Date (U.S. Patent No. D684,545)
2013-07-16 Issue Date (U.S. Patent No. 8,487,337)
2014-05-06 Issue Date (U.S. Patent No. D704,358)
2014-06-10 Issue Date (U.S. Patent No. 8,748,915)
2014-12-02 Issue Date (U.S. Patent No. 8,901,583)
2015-06-09 Issue Date (U.S. Patent No. 9,054,257)
2016-01-19 Issue Date (U.S. Patent No. 9,240,395)
2017-04-25 Issue Date (U.S. Patent No. 9,634,209)
2024-07-12 Plaintiff alleges sending notice letter to Defendant
2024-08-15 Plaintiff alleges sending claim charts to Defendant
2024-12-18 Complaint Filing Date

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

U.S. Patent No. 8,049,230 - "Apparatus and System for Miniature Surface Mount Devices," issued November 1, 2011

The Invention Explained

  • Problem Addressed: The patent describes challenges in developing large-format LED displays, including perceptible loss of color fidelity at off-axis viewing angles, unwanted light reflection and glare from package materials, and the need for effective thermal management for densely packed surface mount devices (SMDs) (’230 Patent, col. 1:35-54).
  • The Patented Solution: The invention discloses a lead frame structure for an SMD that positions a linear array of LEDs (e.g., red, green, blue) on an electrically conductive chip carrier part, with separate connection parts for other electrical terminals. This entire lead frame is then at least partially encased in a black casing to reduce glare and improve contrast (’230 Patent, col. 2:1-13, Abstract). The vertical, linear arrangement of the LEDs is described as improving color fidelity over a wide range of viewing angles (’230 Patent, col. 2:52-54).
  • Technical Importance: This design provides an apparatus for creating compact, multi-color LED pixels with improved optical performance and thermal dissipation, a key enabler for high-resolution indoor video screens (’230 Patent, col. 1:25-30).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (a lead frame) and 19 (an LED display) (Compl. ¶26).
  • Independent Claim 1 (Lead Frame):
    • An electrically conductive LED chip carrier part with a surface carrying a linear array of LEDs adapted to produce a full range of colors.
    • Each LED has first and second electrical terminals, with the first terminal electrically and thermally coupled to the chip carrier surface.
    • Electrically conductive connection parts separate from the chip carrier part, each with a connection pad.
    • The second terminal of each LED is coupled to a corresponding connection pad.
    • A black casing at least partially encasing the lead frame.
  • Independent Claim 19 (LED Display):
    • A substrate carrying an array of SMDs arranged in columns and rows.
    • Each SMD comprises a dark casing.
    • Each SMD contains a vertically oriented, linear arrangement of LEDs adapted to produce a full range of colors to define one pixel.
    • Signal processing and LED drive circuitry to selectively energize the SMDs.

U.S. Patent No. 8,901,583 - "Surface Mount Device Thin Package," issued December 2, 2014

The Invention Explained

  • Problem Addressed: The patent notes that as LED packages for flat panel displays become thinner and have a lower profile, their structural integrity can be compromised. Specifically, conventional packages may deform or experience separation between the plastic casing and the metal lead frame during manufacturing, particularly during the high-temperature reflow soldering process (’583 Patent, col. 1:15-28).
  • The Patented Solution: The invention describes an emitter package designed for improved robustness. The solution involves a casing with a "step-wise gradation" where the bottom dimensions are greater than the top, creating a wider base. It also incorporates a lead frame with integral features, such as v-cuts or through-holes, that "cooperate with said casing to provide a rigid connection" by allowing the casing material to flow into and mechanically interlock with the lead frame (’583 Patent, Abstract; col. 3:4-7, col. 11:10-18).
  • Technical Importance: This approach addresses manufacturing and reliability challenges for the thin LED packages required for modern, low-profile flat panel displays, potentially improving manufacturing yields and long-term durability (’583 Patent, col. 2:15-22).

Key Claims at a Glance

  • The complaint asserts independent claim 38 (a light emitting device display) (Compl. ¶35).
  • Independent Claim 38 (Display):
    • A substrate carrying an array of emitter packages.
    • Each emitter package comprises:
      • A casing with a cavity of a depth ≤ 0.5 mm and a "stepwise gradation" making the bottom wider and longer than the top.
      • A lead frame integral to the casing, with features that cooperate with the casing for a rigid connection.
      • A plurality of LEDs in linear alignment on the lead frame.
    • Electrically connected drive circuitry to energize the array.

Multi-Patent Capsules

  • U.S. Patent No. 9,054,257 - "Water Resistant LED Devices..."

    • Technology Synopsis: Discloses an LED package designed for water resistance, comprising a first inner plastic portion holding the LED and a second surrounding plastic portion. The two portions have different optical properties and may interlock to create a robust seal (’257 Patent, Abstract).
    • Asserted Claims: Claim 1 (Compl. ¶22).
    • Accused Features: The package structure of the LEDs within the VS3IP Display (Compl. ¶44).

  • U.S. Patent No. 8,487,337 - "Side View Surface Mount LED"

    • Technology Synopsis: Describes a "side-looker" LED package where the rectangular LED chip is intentionally "rotationally misaligned" with respect to the rectangular package geometry. This misalignment is intended to improve color uniformity and light extraction efficiency by altering the emission pattern (’337 Patent, col. 8:20-27).
    • Asserted Claims: Claims 1, 7, and 8 (Compl. ¶22).
    • Accused Features: The rotational orientation of the LED chips within the packages of the VS3IP Display (Compl. ¶52-54).

  • U.S. Patent No. 8,748,915 - "Emitter Package with Angled or Vertical LED"

    • Technology Synopsis: Discloses an LED package where the LED chip is rotated within a reflective cup so that it is "out of alignment" with the cup's primary axes. This rotation is intended to create a smoother, more uniform far-field pattern and reduce the need for light-absorbing diffusers (’915 Patent, col. 5:5-11, Abstract).
    • Asserted Claims: Claim 1 (Compl. ¶22).
    • Accused Features: The rotational alignment of the LED chip relative to the reflective cup in the packages of the VS3IP Display (Compl. ¶62).

  • U.S. Patent No. 7,718,991 - "Lighting Device and Method of Making"

    • Technology Synopsis: Addresses optical degradation in LED packages caused by high-energy photons. The solution is a lighting device with an encapsulant region made of a silicone compound and a separate "supporting region" made of a different material (e.g., epoxy) that surrounds at least a portion of an electrode, enhancing reliability (’991 Patent, Abstract; col. 4:1-9).
    • Asserted Claims: Claim 1 (Compl. ¶22).
    • Accused Features: The material composition and structure of the encapsulant and support elements in the LED packages of the VS3IP Display (Compl. ¶70).

  • U.S. Patent No. 9,634,209 - "Miniature Surface Mount Device"

    • Technology Synopsis: Details a specific lead frame geometry for a miniature SMD, comprising an "L shaped electrically conductive chip carrier" and three separate connection parts arranged in a particular spatial relationship to optimize layout and connectivity in a compact footprint (’209 Patent, Abstract).
    • Asserted Claims: Claim 1 (Compl. ¶22).
    • Accused Features: The geometric shape and arrangement of the lead frame and connection parts within the LED packages of the VS3IP Display (Compl. ¶78).

  • U.S. Patent No. 9,240,395 - "Waterproof Surface Mount Device Package and Method"

    • Technology Synopsis: Aims to improve the structural integrity and waterproofing of an LED package by incorporating "v-cuts" in the lead frame that are shaped to receive the casing material. This creates a stronger mechanical interlock. The invention also calls for controlling the geometry (length, thickness, loop height) of the wire bonds for improved reliability (’395 Patent, Abstract).
    • Asserted Claims: Claim 1 (Compl. ¶22).
    • Accused Features: The lead frame structure and wire bond geometry within the LED packages of the VS3IP Display (Compl. ¶86).

  • U.S. Patent No. D684,545 - "Miniature Surface Mount Device"

    • Technology Synopsis: Claims the ornamental design for a miniature surface mount device, focusing on its visual appearance, including the shape of the casing, the layout of the internal components, and the configuration of the external leads.
    • Asserted Claims: The claimed design (Compl. ¶26).
    • Accused Features: The overall visual appearance of the LED packages within the VS3IP Display (Compl. ¶94).

  • U.S. Patent No. D704,358 - "High Brightness LED Package"

    • Technology Synopsis: Claims the ornamental design for a high brightness LED package, characterized by its particular proportions, surface features, and arrangement of visible internal elements.
    • Asserted Claims: The claimed design (Compl. ¶26).
    • Accused Features: The overall visual appearance of the LED packages within the VS3IP Display (Compl. ¶101).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is Defendant’s “VS3IP” high-resolution LED video display panel and the LED packages contained within it, identified as including at least the NH-Z1921RGBA-SF (Compl. ¶21, ¶22).

Functionality and Market Context

  • The VS3IP is a modular LED panel designed to be assembled into larger video screens (Compl. ¶21). The complaint provides an image from Defendant's website, which describes the product as having a 3.84mm pixel pitch, IP65/IP54 weather ratings for temporary outdoor use, and the ability to form curved displays (Compl. p. 6, Fig. 1). The complaint alleges these panels are made, used, and sold by Defendant, positioning them as commercially significant products in the video display market (Compl. ¶21). The image shows the VS3IP Display, which includes features such as IP65-rated rubber capped protective connections (Compl. p. 6, Fig. 1).

IV. Analysis of Infringement Allegations

U.S. Patent No. 8,049,230 Infringement Allegations

Claim Element (from Independent Claim 19) Alleged Infringing Functionality Complaint Citation Patent Citation
a substrate carrying an array of surface-mount devices (“SMDs”) arranged in vertical columns and horizontal rows The Infringing VS3IP Display is alleged to have a substrate that carries an array of SMDs in the specified arrangement. ¶28(i) col. 2:35-38
each of said SMDs comprise a dark casing The SMDs within the Infringing VS3IP Display are alleged to each have a dark casing. ¶28(ii) col. 2:39-40
each of said SMD’s contain a vertically oriented, linear arrangement of LEDs adapted to be energized to produce in combination a substantially full range of colors and to define one pixel of the display The SMDs within the Infringing VS3IP Display are alleged to contain LEDs arranged in a vertically oriented, linear fashion to produce a full color range for a single pixel. ¶28(iii) col. 2:40-46
signal processing and LED drive circuitry electrically connected to selectively energize the array of SMDs for producing visual images on the display The Infringing VS3IP Display is alleged to contain the necessary circuitry to control and power the SMD array to create images. ¶28(iv) col. 2:47-51

U.S. Patent No. 8,901,583 Infringement Allegations

Claim Element (from Independent Claim 38) Alleged Infringing Functionality Complaint Citation Patent Citation
a substrate carrying an array of emitter packages, each of said emitter packages comprising: The Infringing VS3IP Display is alleged to be a substrate carrying an array of emitter packages that have the following features. ¶36(i) col. 3:15-18
1. a casing comprising a cavity... wherein said cavity has a depth of less than or equal to 0.5 mm, wherein said casing comprises a stepwise gradation such that the length and width of the bottom of said casing are greater than the length and width of the top of said casing The emitter packages are alleged to have a casing with a cavity of the specified depth and a "stepwise gradation" where the base is wider than the top. ¶36(i)(1) col. 3:1-4
2. a lead frame integral to said casing, wherein said lead frame comprises features that cooperate with said casing to provide a rigid connection between said lead frame and said casing The emitter packages are alleged to have a lead frame that is integral to the casing and includes features that create a rigid, interlocking connection. ¶36(i)(2) col. 3:4-7
3. a plurality of LEDs arranged in linear alignment on said lead frame, said LEDs and portions of said lead frame exposed through said cavity The emitter packages are alleged to have multiple LEDs arranged in a line on the lead frame, visible through the casing's cavity. ¶36(i)(3) col. 3:8-12
electrically connected drive circuitry to selectively energize said array for producing visual images on said display The Infringing VS3IP Display is alleged to have the drive circuitry to power the array of emitter packages. ¶36(ii) col. 10:1-4

Identified Points of Contention

  • Scope Questions: For the ’230 Patent, a potential issue is the scope of "vertically oriented." The interpretation of this term will depend on the patent's specification and figures, and whether the orientation of LEDs in the accused product falls within that scope.
  • Technical Questions: For the ’583 Patent, the infringement analysis will raise factual questions regarding the physical structure of the accused LED packages. The case may turn on evidence of whether the accused packages possess the specific "stepwise gradation" and integral lead frame "features that cooperate" for a rigid connection as required by the claim. The claim's dimensional limitation ("depth of less than or equal to 0.5 mm") also presents a direct factual question for measurement and comparison.

V. Key Claim Terms for Construction

From the ’230 Patent

  • The Term: "vertically oriented, linear arrangement of LEDs" (Claim 19)
  • Context and Importance: This term defines the specific spatial configuration of the LEDs within each SMD, which the patent links directly to improved off-axis color fidelity. The infringement determination for Claim 19 will depend heavily on whether the arrangement in the accused SMDs meets this structural requirement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "vertically oriented" is not explicitly defined, which may support an interpretation that covers any arrangement more vertical than horizontal relative to the display substrate.
    • Evidence for a Narrower Interpretation: The specification repeatedly links this term to the specific embodiments shown, for example, where the linear array's direction is perpendicular to the side surfaces of the casing (’230 Patent, col. 4:23-30). Figures such as Fig. 1 show a distinct up-down linear orientation of three LEDs, which could be used to argue for a narrower construction limited to that specific alignment.

From the ’583 Patent

  • The Term: "stepwise gradation" (Claim 38)
  • Context and Importance: This structural feature of the casing is presented as a core element of the solution to the problem of package delamination and deformation. Whether the accused package infringes will depend on whether its casing profile can be characterized as having a "stepwise gradation."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term is not explicitly defined with a specific angle or number of steps, which could support a construction that reads on any non-uniform, tiered, or sloped transition from a wider base to a narrower top.
    • Evidence for a Narrower Interpretation: The patent’s detailed description refers to the feature in the context of a specific embodiment, explaining it as a "step-wise gradation such that the dimensions of the bottom of the casing are greater than the dimensions of the top" (’583 Patent, col. 3:2-4). Figures 11 and 12 depict a distinct, single step, which may support an argument that the term is limited to such a discrete transition rather than a continuous slope.

VI. Other Allegations

Indirect Infringement

  • The complaint focuses on direct infringement under 35 U.S.C. § 271(a) by alleging Defendant "makes, uses, offers to sell, and/or sells" the accused products (Compl. ¶21, ¶26). The complaint does not plead specific facts to support claims of induced or contributory infringement.

Willful Infringement

  • The complaint alleges willful infringement based on pre-suit knowledge. It specifically pleads that Defendant had notice of the Asserted Patents "since at least July 12, 2024, by virtue of a letter Cree LED sent to ADJ" and that Plaintiff subsequently sent "a follow-up letter attaching claim charts" on August 15, 2024 (Compl. ¶23).

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

  • A central issue will be one of structural correspondence: does the physical construction of the accused LED packages map onto the specific geometric and dimensional limitations required by the asserted claims, particularly the "stepwise gradation" of the '583 Patent and the interlocking plastic portions of the '257 Patent? This will likely be a fact-intensive inquiry driven by expert analysis of the accused products.
  • A key question will be one of configurational scope: can the arrangement of LEDs within the accused SMDs be construed as the "vertically oriented, linear arrangement" of the '230 Patent or the "rotationally misaligned" configurations of the '337 and '915 Patents? The outcome may depend on how the court construes these spatial and orientational claim terms.
  • Given the assertion of ten distinct patents, a broader strategic question is one of technological accumulation: can the accused product be shown to avoid every asserted patented feature, from structural integrity and waterproofing to specific component arrangements and ornamental designs, or does the comprehensive nature of the patent portfolio create a high barrier to a finding of non-infringement across all asserted claims?