Signify Holding BV v. EEMA Industries Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Signify Holding B.V. (Netherlands) and Signify North America Corporation (Delaware)
  • Defendant: EEMA Industries Inc. d/b/a Liton Lighting (California)
  • Plaintiff’s Counsel: Bond, Schoeneck & King PLLC
• Case Identification: 2:25-cv-03928, C.D. Cal., 05/02/2025
• Venue Allegations: Venue is asserted based on Defendant's alleged commission of infringing acts within the Central District of California and its maintenance of a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s LED lighting products infringe seven U.S. patents related to configurable color temperature systems, thermal management for recessed fixtures, and power factor correction circuitry.
• Technical Context: The dispute centers on technologies for LED luminaires, a market segment focused on energy efficiency, longevity, and advanced features like user-selectable color temperatures.
• Key Procedural History: The complaint alleges that Defendant has been aware of Plaintiff’s patented technologies since at least 2018 and details a history of correspondence between the parties regarding the alleged infringement, which may form a basis for Plaintiff’s willfulness allegations.

Case Timeline

Date	Event
2004-03-15	’706 Patent Priority Date
2008-04-15	’706 Patent Issue Date
2011-12-06	’328 Patent Issue Date
2013-01-08	’479 Patent Issue Date
2013-01-08	’477 Patent Issue Date
2014-12-09	’602 Patent Issue Date
2016-02-19	’588 and ’682 Patents Priority Date
2018-11-19	Plaintiff’s first alleged correspondence to Defendant regarding infringement
2019-12-10	’682 Patent Issue Date
2022-08-09	’588 Patent Issue Date
2025-05-02	Complaint Filing Date

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

U.S. Patent No. 11,408,588 - “Configurable lighting system,” issued August 9, 2022

The Invention Explained

• Problem Addressed: The patent describes the problem of conventional light-emitting-diode (LED) luminaires having reduced flexibility because their light source is permanently attached, forcing distributors to stock a large inventory to accommodate user preferences for different color temperatures (U.S. Patent 11,408,588, col. 1:41-51).
• The Patented Solution: The invention is a luminaire with at least two distinct sets of LED light sources, each with a different color temperature. A user-accessible switch controls these LED sets, allowing the user to select the first color temperature, the second color temperature, or a third, intermediate color temperature created by "mixing" the light from both sets of LEDs (U.S. Patent 11,408,588, Abstract; col. 2:5-19). This allows a single product to offer multiple lighting options.
• Technical Importance: This approach provides field-configurability for a single lighting product, reducing inventory requirements for distributors and increasing flexibility for end-users (U.S. Patent 11,408,588, col. 2:1-4).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶26).
• Claim 1 requires:
  • A luminaire comprising a housing;
  • At least one switch disposed on the housing;
  • A first set of LED light sources with a first color temperature and a second set of LED light sources with a second color temperature;
  • The switch controls both sets of LEDs, and in a first configuration, produces a third color temperature (between the first and second) by mixing light from at least a portion of both sets.
• The complaint reserves the right to assert additional claims (Compl. ¶34).

U.S. Patent No. 10,506,682 - “Configurable lighting system,” issued December 10, 2019

The Invention Explained

• Problem Addressed: The patent addresses the need for a single luminaire that can be easily configured to provide different illumination properties, such as different lumen outputs or color temperatures, to adapt to various applications (U.S. Patent 10,506,682, col. 1:49-58).
• The Patented Solution: The invention is a luminaire with a control module containing a multi-position switch coupled to a plurality of resistive components. Each switch position corresponds to a specific resistance value, which in turn determines the current level supplied to the light source. This mechanism allows the light source's output (e.g., brightness or color) to be controlled by the physical position of the switch (U.S. Patent 10,506,682, Abstract; col. 8:10-24).
• Technical Importance: This design provides a simple, field-selectable electronic control mechanism for adjusting a luminaire's output without complex programming, using a straightforward switch-and-resistor architecture (U.S. Patent 10,506,682, col. 7:20-25).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶43).
• Claim 1 requires:
  • A luminaire comprising a control module;
  • The control module includes a multi-position switch and a plurality of resistive components coupled to the switch;
  • Each switch position corresponds to a resistance of the resistive components, which determines a current level;
  • A light source is coupled to the control module and emits output based on the received current level;
  • The switch and at least one resistive component are coupled to the light source, which illuminates regardless of the switch position.
• The complaint reserves the right to assert additional claims (Compl. ¶53).

Multi-Patent Capsules

• U.S. Patent No. 8,905,602

  • Patent Identification: U.S. Patent No. 8,905,602, “Thermal management for light emitting diode fixture,” issued December 9, 2014.
  • Technology Synopsis: The patent describes an LED downlight module designed for efficient thermal management and ease of maintenance. The invention features a heat sink, a housing coupled to the heat sink bottom, and a replaceable trim removably coupled to the housing.
  • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶62).
  • Accused Features: The complaint accuses Liton-branded downlight products with removable trims, such as the LREQLD402, of infringement (Compl. ¶62).

• U.S. Patent No. 8,348,479

  • Patent Identification: U.S. Patent No. 8,348,479, “Light emitting diode recessed light fixture,” issued January 8, 2013.
  • Technology Synopsis: This patent relates to a downlight module that uses at least two torsion springs on opposite sides for mounting the heat sink and LED package within a recessed light fixture.
  • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶80).
  • Accused Features: The complaint accuses Liton-branded downlight products with torsion springs on opposite side surfaces, such as the LRLD678 and LRALD4, of infringement (Compl. ¶80).

• U.S. Patent No. 8,348,477

  • Patent Identification: U.S. Patent No. 8,348,477, “Light emitting diode recessed light fixture,” issued January 8, 2013.
  • Technology Synopsis: The patent discloses a downlight module where an LED package is affixed to a substantially planar surface of a heat sink. The module is mounted using at least two torsion springs coupled to its exterior surface.
  • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶101).
  • Accused Features: The complaint accuses Liton-branded downlight products with torsion springs, such as the LRLD678 and LRALD4, of infringement (Compl. ¶101).

• U.S. Patent No. 8,070,328

  • Patent Identification: U.S. Patent No. 8,070,328, “LED downlight,” issued December 6, 2011.
  • Technology Synopsis: This patent describes an LED downlight fixture with a multi-piece reflector assembly. The assembly includes a first and second reflector and a diffuser positioned between them to define a light exit passageway.
  • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶123).
  • Accused Features: The complaint accuses Liton-branded products having a dual reflector arrangement, such as the LRELD442, of infringement (Compl. ¶123).

• U.S. Patent No. 7,358,706

  • Patent Identification: U.S. Patent No. 7,358,706, “Power factor correction control methods and apparatus,” issued April 15, 2008.
  • Technology Synopsis: The patent relates to a power factor correction apparatus that uses a switch controller to process signals representing AC line voltage, AC current, DC voltage output, and a predetermined desired power to control a switch and manage power delivery to a load.
  • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶139).
  • Accused Features: The complaint accuses Liton-branded products with power factor correction and external dimming terminals, such as the LHABLDQ4, of infringement (Compl. ¶139).

III. The Accused Instrumentality

Product Identification

• The complaint identifies several families of Liton-branded LED lighting products, referred to collectively as the Accused Products (Compl. ¶¶ 26, 43, 62, 80, 101, 123, 139). Representative models include the LCMPD12R, LREQLD402, LRLD678, LRALD4, LRELD442, and LHABLDQ4 (Compl. ¶¶ 27, 44, 63, 81, 102, 124, 140).

Functionality and Market Context

• The accused products are primarily LED luminaires and downlights intended for commercial and residential use. The complaint focuses on specific features alleged to infringe, including:
  • A "ColorSelect" switch that allows users to select from multiple color temperatures (e.g., 2700K to 5000K) by physically moving a switch on the product housing (Compl. ¶¶ 26, 31). The complaint provides a photograph of this switch on the product housing (Compl. ¶31, p. 10).
  • Internal control modules and LED arrays that implement the color selection functionality (Compl. ¶¶ 32, 47). A photograph displays two distinct sets of LEDs arranged on a circular board within the product (Compl. ¶32, p. 11). Another visual shows the internal control module circuitry (Compl. ¶47, p. 17).
  • Mechanical features such as removable trims for serviceability and torsion springs for mounting (Compl. ¶¶ 62, 80). The complaint includes a photograph showing a removable trim piece on a downlight module (Compl. ¶70, p. 26).
  • Optical systems using multi-piece reflectors and diffusers (Compl. ¶123).
  • Power control circuits that allegedly perform power factor correction (Compl. ¶139).

IV. Analysis of Infringement Allegations

U.S. Patent No. 11,408,588 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A luminaire comprising: a housing;	The accused LCMPD12R product is a luminaire with a physical housing.	¶29, ¶30	col. 6:40-41
at least one switch disposed on the housing;	The accused products have a "ColorSelect" switch on the exterior of the housing, allowing user selection of color temperature.	¶31	col. 6:42-43
wherein the housing includes: a first set of light emitting diode (LED) light sources each having a first color temperature and a second set of LED light sources each having a second color temperature;	The accused product’s internal circuit board contains two alternating sets of LEDs, alleged to correspond to different color temperatures.	¶32	col. 6:4-10
wherein each of the first set of LED light sources and second set of LED light sources are controlled by the at least one switch, wherein when the at least one switch is in a first configuration, the light emitted by the luminaire is a third color temperature ... produced by mixing light emitted by at least a portion of the first set ... and ... at least a portion of the second set...	The "ColorSelect" switch is alleged to control both sets of LEDs, and in certain positions, to power both sets simultaneously to produce an intermediate color temperature by mixing their light output.	¶33	col. 6:11-23

Identified Points of Contention

• Scope Questions: A central question may be the construction of the term "produced by mixing light." Does this term require a specific optical component designed to blend the light (e.g., a diffuser), or is the simultaneous emission of light from two proximate but distinct LED sets on a circuit board sufficient to meet this limitation as alleged?
• Technical Questions: What evidence does the complaint provide that the two visually distinct sets of LEDs in the accused product actually possess different "color temperatures" as required by the claim?

U.S. Patent No. 10,506,682 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A luminaire comprising: a control module comprising: at least one first switch that has multiple positions;	The accused product is a luminaire containing a control module, which includes the multi-position "ColorSelect" switch.	¶46, ¶47, ¶48	col. 7:27-31
and a plurality of resistive components coupled to the at least one first switch, wherein each position ... corresponds to a resistance ... wherein the resistance determines a current level...	The control module allegedly contains a switch board with multiple resistive components. The complaint provides a circuit diagram purporting to show that the switch position selects different resistive paths.	¶49	col. 8:13-20
and a light source coupled to the control module, wherein the light source emits an output based on the current level received from the control module,	The LED array is coupled to the control module and its light output is alleged to be determined by the current level set by the switch and resistor combination.	¶50	col. 8:20-24
wherein the light source illuminates when the power flows through the control module to the light source, regardless of the position of the at least one first switch.	The complaint alleges the product is designed such that the LEDs illuminate in any of the switch's operative positions.	¶52	col. 8:28-32

Identified Points of Contention

• Scope Questions: The interpretation of "control module" will be relevant. The patent describes this as a discrete module, and the parties may dispute whether the integrated circuitry of the accused product constitutes such a "module."
• Technical Questions: Does the complaint's provided circuit diagram (Compl. ¶49, p. 18) provide sufficient detail to establish that the "resistance determines a current level" as claimed, or will further evidence from discovery be required to demonstrate this specific electrical functionality?

V. Key Claim Terms for Construction

For the ’588 Patent

• The Term: "produced by mixing light"
• Context and Importance: The infringement theory hinges on whether the accused product's method of simultaneously activating two different-colored LED sets on a board constitutes "mixing light." If this term is construed to require a specific physical mixing element, such as a lens or diffuser, which is not explicitly alleged for this purpose, the infringement argument could be challenged.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify a required structure for mixing. One could argue that the plain and ordinary meaning encompasses any method that results in the combination of light from two sources, including simple co-location and simultaneous operation (U.S. Patent 11,408,588, col. 6:17-23).
  • Evidence for a Narrower Interpretation: The specification mentions that a lens can "mix and blend light" (U.S. Patent 11,408,588, col. 5:50-53), which may suggest that "mixing" implies the use of an optical component to achieve the effect, rather than just the result of simultaneous emission.

For the ’682 Patent

• The Term: "control module"
• Context and Importance: Practitioners may focus on this term because its physical and functional boundaries are critical. If "control module" is construed to require a physically distinct and separable unit, and the accused product's control circuitry is fully integrated into a single mainboard, there may be a dispute over whether the accused product contains the claimed element.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the control module in functional terms, stating it "controls the amount of power (e.g., current) that is delivered to the light sources" (U.S. Patent 10,506,682, col. 9:29-32). This functional description could support an interpretation that covers any collection of components performing that function, regardless of their physical integration.
  • Evidence for a Narrower Interpretation: The patent's figures and description often depict the "lumen control module" as a discrete block within a larger system diagram (e.g., U.S. Patent 10,506,682, Fig. 7A, item 704), which could support an argument that the inventors contemplated a physically distinct module.

VI. Other Allegations

Indirect Infringement

• The complaint alleges active inducement for all asserted patents, based on Defendant allegedly providing instructions, technical support, and marketing that encourage infringing use by customers (e.g., Compl. ¶¶ 36, 55). It also pleads contributory infringement, alleging the accused products and their components are not staple articles of commerce and are especially made for an infringing use (e.g., Compl. ¶¶ 37, 56).

Willful Infringement

• The complaint makes detailed allegations of willful infringement. It asserts that Defendant has been aware of Plaintiff's patented technologies since "at least 2018" and cites specific correspondence between the parties starting on November 19, 2018 (Compl. ¶19). The complaint further alleges specific dates on which Defendant received notice for each of the patents-in-suit (e.g., Compl. ¶¶ 35, 54, 72, 93, 115, 131, 161).

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

• A core issue will be one of claim construction: can the term “produced by mixing light” in the ’588 Patent be construed to cover the simultaneous operation of two adjacent LED sets on a circuit board, as alleged, or does it require a dedicated optical element for blending?
• A key evidentiary question will be one of functional proof: do the complaint's photographs and circuit diagrams provide sufficient technical evidence to demonstrate that the accused products perform the specific electrical functions required by the claims, such as the resistance-determines-current relationship of the ’682 Patent, or will discovery be needed to substantiate these operational claims?
• A central focus of the litigation will likely be willfulness: given the complaint's detailed allegations of a multi-year history of pre-suit notice and correspondence, a significant question for the court will be Defendant's state of mind and conduct after it was allegedly made aware of the patents-in-suit.