DCT
2:25-cv-00764
Hisense USA Corp v. Polaris PowerLED Tech LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Hisense USA Corporation (Georgia)
- Defendant: Polaris PowerLED Technologies, LLC (California)
- Plaintiff’s Counsel: Leydig, Voit & Mayer, Ltd.
- Case Identification: 2:25-cv-00764, C.D. Cal., 09/11/2025
- Venue Allegations: Venue is alleged to be proper as Defendant Polaris PowerLED Technologies resides in the Central District of California.
- Core Dispute: Plaintiff seeks a declaratory judgment that its television products do not infringe two of Defendant’s patents related to circuits for controlling light-emitting diodes (LEDs).
- Technical Context: The dispute centers on power control and self-calibration circuitry for LED backlights, a core technology for optimizing power efficiency and performance in modern electronic displays like televisions.
- Key Procedural History: The complaint alleges this declaratory judgment action follows a January 17, 2025 demand letter from Polaris. This letter accused Hisense of infringing four patents, two of which (’148 and ’887 patents) were subsequently found to have invalid or cancelled claims in separate U.S. Patent and Trademark Office proceedings. Polaris has since provided Hisense with a covenant not to sue on those two patents, leaving the ’572 and ’810 patents as the subject of the current dispute. The complaint also notes a history of litigation between the parties and by Polaris against other electronics manufacturers.
Case Timeline
| Date | Event |
|---|---|
| 2008-03-11 | ’810 Patent Priority Date |
| 2008-06-24 | ’572 Patent Priority Date |
| 2012-11-20 | ’572 Patent Issue Date |
| 2013-11-12 | ’810 Patent Issue Date |
| 2020-01-21 | Polaris files prior lawsuit against Hisense |
| 2024-03 | USPTO determines reasonable likelihood of invalidity for '148 patent claims in IPR |
| 2024-03 | USPTO orders ex parte reexamination of '887 patent |
| 2024-09-25 | USPTO issues Office Action rejecting '887 patent claims |
| 2025-01-17 | Polaris sends demand letter to Hisense |
| 2025-02-25 | USPTO issues Final Written Decision invalidating '148 patent claims in IPR |
| 2025-03 | USPTO issues Final Office Action on '887 patent |
| 2025-06-13 | Polaris provides Hisense a covenant not to sue on the '148 and '887 patents |
| 2025-09-10 | USPTO issues Reexamination Certificate cancelling all '887 patent claims |
| 2025-09-11 | Hisense files First Amended Complaint for Declaratory Judgment |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,314,572 - "Apparatus and Methodology for Enhancing Efficiency of a Power Distribution System Having Power Factor Correction Capability by Using a Self-Calibrating Controller"
The Invention Explained
- Problem Addressed: The patent describes inefficiencies in conventional LED display backlights, where the drive voltage is often fixed at an unnecessarily high level to ensure operation under worst-case conditions, leading to wasted power (’572 Patent, col. 2:21-28). Additionally, converting AC power from a wall outlet to the necessary DC voltage for LEDs often requires multiple conversion stages, which reduces overall efficiency (’572 Patent, col. 2:45-51).
- The Patented Solution: The invention proposes a circuit where a programmable controller monitors the LED strings to determine the optimal drive voltage needed. It then generates a control signal indicative of this desired voltage. This signal is sent to a power supply that has integrated power factor correction (PFC) capability. The power supply uses the control signal and the incoming AC waveform to generate the precise DC drive voltage required, thereby improving efficiency and eliminating the need for a separate DC-to-DC scaling converter (’572 Patent, Abstract; col. 3:19-45).
- Technical Importance: This approach aims to create more power-efficient electronic displays by dynamically adjusting LED drive voltage and integrating power management functions to reduce energy waste and component count (’572 Patent, col. 1:16-24).
Key Claims at a Glance
- The complaint identifies independent claim 1 as asserted by Polaris (Compl. ¶24).
- The essential elements of claim 1 include:
- A detector coupled to one or more LED strings for detecting a measurable parameter.
- A programmable controller that receives information from the detector and adjusts controllable parameters until the measurable parameter meets a reference condition.
- As part of this adjustment, the controller determines a desired drive voltage level and generates a corresponding control signal.
- A power supply with power factor correction capability that receives the control signal and an AC voltage waveform as separate inputs and generates a drive voltage based on the control signal.
- The complaint does not explicitly reserve the right to assert dependent claims but seeks a declaration of non-infringement of "any claims" of the patent (Compl. ¶23).
U.S. Patent No. 8,581,810 - "Methods and Circuits for Self-Calibrating Controller"
The Invention Explained
- Problem Addressed: The patent notes that optimizing the efficiency of LED driver circuits requires controlling many parameters, such as temperature, current, and voltage, and conventional systems may not do so efficiently (’810 Patent, col. 1:10-19).
- The Patented Solution: The invention discloses a "programmable decentralized controller" that influences, but is not a necessary part of, the main power delivery loop (’810 Patent, col. 4:56-62). This controller monitors a parameter of the LEDs or their drivers, adjusts a controllable parameter until a "reference condition" is met, and then sets that parameter to operate at a value relative to the value where the condition was met. This allows the circuit to self-calibrate for optimal performance without interrupting the basic operation of the driver loop (’810 Patent, Abstract).
- Technical Importance: The use of a decentralized, non-essential controller for calibration provides a method for improving LED driver efficiency and adapting to changing conditions without adding complexity to the core power-delivery circuit (’810 Patent, col. 4:56-65).
Key Claims at a Glance
- The complaint identifies independent claim 1 as asserted by Polaris (Compl. ¶34).
- The essential elements of claim 1 include:
- One or more LED drivers configured to receive a drive voltage from a power supply.
- A programmable decentralized controller coupled to the power supply and one or more detectors that measure parameters of the LEDs or drivers.
- The controller is configured to control the power supply to set the drive voltage.
- The controller receives information from the detectors and adjusts a controllable parameter until a reference condition is met.
- The controller then sets the controllable parameter to operate at a value relative to the value at which the reference condition was met.
- The complaint seeks a declaration of non-infringement of "any claims" of the patent (Compl. ¶33).
III. The Accused Instrumentality
Product Identification
- The complaint identifies Hisense's U6 and U8 Series TVs, including specifically the 65U6N and 65U8K models, as the products accused by Polaris in its demand letter (Compl. ¶3).
Functionality and Market Context
- The complaint is for declaratory judgment of non-infringement and, as such, does not describe the functionality of the accused products in detail. Instead, it asserts what the products allegedly lack. Specifically, it alleges the products do not contain the "programmable controller" required by the ’572 Patent or the "programmable decentralized controller" required by the ’810 Patent (Compl. ¶¶25, 35). The complaint does not provide sufficient detail for further analysis of the accused instrumentality's specific functionality.
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
The complaint seeks a declaratory judgment of non-infringement. Its allegations focus on elements of the asserted claims that are purportedly absent from the accused products.
’572 Patent Non-Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| the programmable controller that: receives information from the detector... adjusts one or more controllable parameters... generates a control signal... | Hisense alleges that its products do not contain the claimed "programmable controller" of the claims of the ’572 patent. | ¶25 | col. 11:14-29 |
’810 Patent Non-Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a programmable decentralized controller coupled to the power supply and one or more detectors, wherein the one or more detectors are configured to detect one or more measurable parameters... | Hisense alleges its products do not contain "a programmable decentralized controller coupled to the power supply and one or more detectors" as required by the claims. | ¶35 | col. 6:53-59 |
- Identified Points of Contention:
- Scope Questions: The central dispute appears to turn on the proper construction of "programmable controller" in the ’572 Patent and "programmable decentralized controller" in the ’810 Patent. The complaint's lack of technical detail about the accused products suggests the initial conflict will be a legal one over the scope of these terms, followed by a factual analysis of whether the undisclosed circuitry in Hisense's products falls within that scope.
- Technical Questions: The complaint does not provide evidence regarding the technical operation of the accused products' controllers. A key question for discovery will be: what is the architecture and function of the control circuitry within the accused Hisense TVs, and how does it relate to the power supply and LED drivers?
V. Key Claim Terms for Construction
The Term: "programmable controller" (’572 Patent, Claim 1)
Context and Importance: Hisense's non-infringement defense for the ’572 patent hinges on this term, as it alleges its products do not contain such a controller (Compl. ¶25). The definition will determine whether the control circuitry in the accused products meets this limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests flexibility, stating the controller "can be programmable and may be implemented in analog, digital or some combination of these devices and in hardware, software, firmware, or some combination of these media" (’572 Patent, col. 6:55-61). This could support a broad, functional interpretation.
- Evidence for a Narrower Interpretation: An exemplary embodiment discloses that the controller "can comprise a digital-to-analog converter ("DAC") and a state machine" (’572 Patent, col. 6:52-54, Fig. 5). Polaris may argue that "programmable" implies the specific self-calibrating functions described in the patent, potentially narrowing the term's scope to controllers capable of such dynamic adjustments.
The Term: "programmable decentralized controller" (’810 Patent, Claim 1)
Context and Importance: This term is the foundation of Hisense’s non-infringement argument for the ’810 patent (Compl. ¶35). Practitioners may focus on this term because the word "decentralized" is explicitly defined in the specification, creating a potentially significant architectural limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: As with the '572 patent, the specification states the controller can be implemented in various forms of hardware or software, which may support a functionally broad reading of "programmable" (’810 Patent, col. 4:50-54).
- Evidence for a Narrower Interpretation: The specification provides a specific definition for "decentralized": "That is, the controller 42 is not a necessary part of the control loop of the power supply loop, but it can influence the power supply loop... the driver loop... can operate independently of the controller 42" (’810 Patent, col. 4:57-62). This language suggests a controller that is architecturally separate and non-essential for basic operation, which could exclude controllers that are integral to the main power management integrated circuit.
VI. Other Allegations
- Indirect Infringement: The complaint makes conclusory denials of induced and contributory infringement for both patents, based on the alleged absence of underlying direct infringement and a lack of specific intent (Compl. ¶¶ 27-28, 37-38). No specific facts are provided for analysis.
- Willful Infringement: Willful infringement is not alleged by Polaris in this proceeding. Hisense seeks a declaration that it has not willfully infringed in its prayer for relief but does not plead specific facts on this point (Compl., Prayer for Relief ¶B).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "programmable decentralized controller," which the ’810 patent specification defines as non-essential to the operation of the main driver loop, be construed to cover the integrated control circuitry found in modern televisions? The answer may depend on whether the court views this "decentralized" architecture as a strict structural limitation.
- The primary evidentiary question will be one of factual correspondence: once the key claim terms are construed by the court, what is the actual circuit architecture and functionality within the accused Hisense products? Discovery will be required to determine if that architecture includes components that meet the court's definition of a "programmable controller" (’572 patent) and, specifically, a "programmable decentralized controller" (’810 patent).