Pacem IP Holdings LLC v. Maxim Lighting Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Pacem IP Holdings LLC (Texas)
  • Defendant: Maxim Lighting International, Inc. (California)
  • Plaintiff’s Counsel: Insight, PLC; Cherry Johnson Siegmund James, PC
• Case Identification: 2:25-cv-09702, C.D. Cal., 10/10/2025
• Venue Allegations: Venue is alleged to be proper in the Central District of California because the Defendant resides in the district and has committed acts of infringement there, including through its regular and established place of business in the City of Industry, California.
• Core Dispute: Plaintiff alleges that Defendant’s LED light bulbs infringe four patents related to the design and thermal management of LED lamps, including technologies for gas cooling and for creating a filament-style appearance.
• Technical Context: The technology concerns LED-based replacements for traditional incandescent light bulbs, a market segment where replicating the classic form factor, light distribution, and appearance is commercially significant.
• Key Procedural History: The complaint alleges that the Defendant has had knowledge of the asserted patents and its infringement since "at least as early as the filing of the original Complaint," suggesting this action may be related to a prior-filed case or that the current complaint is an amended version, which may be relevant to allegations of willful infringement.

Case Timeline

Date	Event
2012-07-12	Earliest Priority Date for ’062, ’983, ’687, and RE48,489 Patents
2013-11-26	U.S. Patent No. 8,591,062 Issues
2014-06-17	U.S. Patent No. 8,752,983 Issues
2016-08-09	U.S. Patent No. 9,410,687 Issues
2021-03-30	U.S. Patent No. RE48,489 Issues
2025-10-10	Complaint Filing Date

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

U.S. Reissued Patent No. RE48,489 - "Gas cooled LED lamp"

The Invention Explained

• Problem Addressed: Traditional manufacturing processes for incandescent bulbs involve fusing a glass stem to the bulb’s enclosure, a step that generates high temperatures. Such heat can damage the sensitive electronic components of an LED assembly, making these traditional, efficient manufacturing techniques unsuitable for LED lamps (’983 Patent, col. 2:18-29).
• The Patented Solution: The invention describes an LED lamp constructed with a sealed, gas-filled enclosure that provides thermal coupling to cool the LED array. It further specifies an electrically insulating base made of a separate upper part connected to the enclosure and a separate lower part joined to the upper part, a design which may facilitate assembly without exposing the LED components to excessive heat (’983 Patent, Abstract; col. 2:56-65).
• Technical Importance: This approach allows for the use of established, high-volume manufacturing techniques for light bulbs while mitigating the risk of thermal damage to LED components, and also addresses the operational cooling needs of the LEDs.

Key Claims at a Glance

• The complaint asserts independent claim 11 (Compl. ¶31).
• Claim 11 requires:
  • A lamp comprising: an optically transmissive enclosure;
  • an LED array disposed in the enclosure, operable to emit light, and being thermally coupled to the enclosure; and
  • an electrically insulating base comprising an upper part connected to the enclosure and a separate lower part that is a separate component from, and joined to, the upper part, with an electrical connector on the lower part.
• The complaint reserves the right to assert additional claims (Compl. ¶31).

U.S. Patent No. 8,591,062 - "LED Lamp"

The Invention Explained

• Problem Addressed: Solid-state LED lamps often have a light pattern and appearance that differs significantly from traditional incandescent bulbs, which can be undesirable for consumers accustomed to the omnidirectional glow of a filament (’062 Patent, col. 2:44-48).
• The Patented Solution: The patent describes an LED lamp with a central support structure, or "tower," that extends from the base into the glass enclosure. A plurality of LEDs are arranged "in a band" around the periphery of this tower, facing outward. This configuration is designed to create a light source that "appears as a glowing filament" or a "centrally glowing area," mimicking the aesthetic of an incandescent bulb (’062 Patent, Abstract; col. 2:5-9).
• Technical Importance: This design directly addresses the aesthetic and functional challenge of making LED technology a form-fit replacement for incandescent bulbs, particularly in applications where the bulb itself is visible.

Key Claims at a Glance

• The complaint asserts independent claim 7 (Compl. ¶43).
• Claim 7 requires:
  • A lamp comprising: an optically transmissive enclosure;
  • a base with an Edison screw;
  • an LED assembly connected to the base and extending into the enclosure;
  • the LED assembly having a plurality of LEDs energized by an electrical path from the base; and
  • the LED assembly arranged with LEDs disposed about a longitudinal axis "in a band" and facing outward to create a source of light that "visibly appears as a centrally glowing area."
• The complaint reserves the right to assert additional claims (Compl. ¶43).

U.S. Patent No. 9,410,687 - "LED lamp with filament style LED assembly"

• Technology Synopsis: This technology, similar to that of the ’062 Patent, is directed at an LED lamp designed to emulate a traditional filament bulb. The invention describes a tower extending from the base that supports an LED assembly, with the LEDs arranged around the tower's periphery to create a light source that "appears as a glowing filament" (’687 Patent, Abstract).
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶57).
• Accused Features: The complaint alleges that the internal structure of products like the Maxim B11 4W E12 Bulb, specifically its use of a central tower to support an array of outwardly facing LEDs, infringes the ’687 Patent (Compl. ¶60).

U.S. Patent No. 8,752,983 - "Gas cooled LED lamp"

• Technology Synopsis: This invention discloses an LED lamp cooled by a gas contained within the lamp's enclosure. The design involves an LED array on a submount that is thermally coupled to a heat sink structure, which in turn transfers heat to the surrounding gas for dissipation (’983 Patent, Abstract). The ’489 Patent is a reissue of a patent that is a divisional of the application that led to the ’983 patent.
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶69).
• Accused Features: The complaint accuses products like the Maxim E26 6W ST58 2700K Bulb of infringing by allegedly incorporating a gas-filled enclosure for thermal coupling, a submount made of thermally conductive material, and a heat sink structure to transmit heat from the LED array to the gas (Compl. ¶¶70-73).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are various LED light bulbs sold by Defendant Maxim Lighting International, Inc., including but not limited to the B11 4W E12 Bulb, E26 6W ST58 2700K Bulb, 7W A19 Frosted 3000K Bulb, and others (Compl. ¶2).

Functionality and Market Context

• The complaint describes the Accused Products as LED-based light bulbs designed as replacements for conventional incandescent bulbs (Compl. ¶¶32, 44, 58). Based on the photographic evidence provided, these products feature optically transmissive glass enclosures, standard Edison screw bases, and internal LED assemblies configured to resemble traditional filaments (Compl. Fig. 1A-1, 1B-1, 1C-1, 1D-1). The complaint alleges that these products are marketed, sold, and distributed throughout the United States (Compl. ¶2). A teardown photograph of an accused product's base suggests a multi-component construction (Compl. Fig. 1A-4). The complaint also presents evidence, via a screenshot of a gas detector, that at least some accused products contain helium gas within the enclosure to facilitate thermal management (Compl. Fig. 1A-3; Fig. 1D-6).

IV. Analysis of Infringement Allegations

RE48,489 Infringement Allegations

Claim Element (from Independent Claim 11)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A lamp comprising: an optically transmissive enclosure;	The Maxim A19 3000K Bulb has an optically transmissive glass enclosure.	¶32	col. 2:56-57
an LED array disposed in the optically transmissive enclosure to be operable to emit light when energized through an electrical connection, the LED array being thermally coupled to the enclosure; and	The bulb contains an LED array that emits light when energized. It is alleged to be thermally coupled to the enclosure via helium gas, as shown in a photograph of a gas detector reading.	¶33	col. 2:57-61
an electrically insulating base comprising an upper part that is connected to the enclosure and a separate lower part that is a separate component from the upper part and that is joined to the upper part and an electrical connector connected to the lower part that forms part of the electrical connection to the LED assembly.	The bulb's base is alleged to be electrically insulating and constructed from a separate upper part joined to a separate lower part, with an electrical connector. A dissection photograph is provided to illustrate this structure.	¶34	col. 2:61-65

Identified Points of Contention

• Scope Questions: A central question may be the construction of "thermally coupled to the enclosure." The complaint's theory rests on thermal transfer via a fill gas (Compl. ¶33). A defendant may argue this term requires a more direct, solid-state conductive pathway, though the specification of the related ’983 patent provides explicit support for gas-based thermal coupling (’983 Patent, Abstract).
• Technical Questions: The infringement allegation for the base structure relies on a dissected photograph (Compl. Fig. 1A-4). The analysis will depend on whether the actual construction of the accused base meets the claim's specific structural requirements of an "electrically insulating base" with a "separate lower part that is a separate component."

8,591,062 Infringement Allegations

Claim Element (from Independent Claim 7)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A lamp comprising: an optically transmissive enclosure;	The Maxim E26 T30 4W Clear Bulb is a lamp with an optically transmissive enclosure.	¶44	col. 2:10-11
a base comprising an Edison screw adapted to engage an Edison socket;	The bulb includes a base with a standard Edison screw for use in Edison sockets.	¶45	col. 2:10-11
an LED assembly connected to the base and extending into the optically transmissive enclosure,	The bulb contains an LED assembly that is connected to the base and extends into the enclosure, as depicted in a provided photograph.	¶46	col. 2:11-13
the LED assembly comprising a plurality of LEDs operable to emit light when energized through an electrical path from the base,	The LED assembly includes multiple LEDs that emit light when powered through the base.	¶47	col. 2:13-15
the LED assembly is arranged such that the plurality of LEDs are disposed about a longitudinal axis of the lamp in a band and face outwardly toward the enclosure to create a source of the light that visibly appears as a centrally glowing area.	The LEDs are arranged in a spiral formation around a central axis and face outward, which allegedly creates the appearance of a centrally glowing area. Several photographs illustrate this configuration.	¶48	col. 2:15-19

Identified Points of Contention

• Scope Questions: The claim requires the LEDs to be "disposed about a longitudinal axis of the lamp in a band." The accused product shows a helical or spiral arrangement of LEDs (Compl. Fig. 1B-8). A key dispute may be whether a "spiral" falls within the scope of the term "band."
• Technical Questions: Infringement will likely turn on the construction of the phrase "visibly appears as a centrally glowing area." This limitation relates to visual appearance, making it inherently subjective and a likely focus of dispute regarding both its definiteness and whether the accused products create such an appearance.

V. Key Claim Terms for Construction

• The Term: "visibly appears as a centrally glowing area" (from ’062 Patent, Claim 7)

• Context and Importance: This term is the central aesthetic and functional limitation of claim 7 of the ’062 patent. Its construction is critical because the infringement analysis depends on whether the visual effect produced by the accused spiral-filament bulbs meets this definition. Practitioners may focus on this term because its subjective nature makes it a primary candidate for disputes over both claim scope and definiteness.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification repeatedly frames the invention's goal as mimicking a traditional incandescent filament, stating the arrangement creates a "source of the light that appears as a glowing filament" (’062 Patent, Abstract; col. 2:8-9). This purpose-driven language may support a construction that covers any arrangement achieving this general visual effect.
  • Evidence for a Narrower Interpretation: The Abstract and a disclosed embodiment link this appearance to a specific structure where LEDs are "disposed about the periphery of the tower in a band" (’062 Patent, Abstract). A defendant may argue that the term must be limited to the appearance created by such a "band," potentially excluding other filament-like configurations.

• The Term: "band" (from ’062 Patent, Claim 7)

• Context and Importance: The claim requires the LEDs to be arranged "in a band." The complaint's evidence shows accused products with LEDs in a helical or spiral arrangement (Compl. Fig. 1B-9). The viability of the infringement claim depends on whether a spiral can be construed as a "band."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not explicitly define "band." A broad interpretation could argue that the term refers to any continuous or semi-continuous grouping of LEDs that encircles the longitudinal axis, which would encompass a spiral. The specification's focus is on the resulting "glowing area," not the precise geometry of the LED arrangement.
  • Evidence for a Narrower Interpretation: A defendant could argue for the plain and ordinary meaning of "band" as a ring or strip that is not helical. The patent figures (e.g., '062 Patent, Fig. 16) depict discrete, stacked rings of LEDs (151, 153), which may support an interpretation that a "band" is a non-spiral, circumferential arrangement.

• The Term: "thermally coupled to the enclosure" (from RE48,489 Patent, Claim 11)

• Context and Importance: Plaintiff's infringement theory relies on this coupling being achieved through a thermally conductive gas fill within the bulb (Compl. ¶33). Defendant may challenge this, arguing the term requires a solid conductive path. The case may hinge on whether gas-based thermal transfer meets this limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification of the parent ’983 patent, from which the reissued patent derives, explicitly states in its Abstract: "A gas is contained in the enclosure to provide thermal coupling to the LED array." This provides strong intrinsic support that the inventors contemplated and disclosed gas as a means for thermal coupling.
  • Evidence for a Narrower Interpretation: A defendant might point to embodiments in the specification that depict physical heat sinks and argue that "thermally coupled" implies a solid-state structure. This argument, however, appears weaker given the explicit contrary language in the abstract of the related patent.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendant sells the Accused Products with the intent that end-users will operate them in an infringing manner and encourages third parties to manufacture the infringing LED packages (Compl. ¶¶36, 50, 62, 74). Contributory infringement is based on allegations that Defendant purchases and incorporates LED packages that it knows are material to practicing the inventions and have no substantial non-infringing use (Compl. ¶¶37, 51, 63, 75).
• Willful Infringement: The complaint alleges that Defendant has had knowledge of the Patents-in-Suit and its infringement since "at least as early as the filing of the original Complaint" and has continued its infringing activities despite this knowledge (Compl. ¶¶35, 49, 61, 73). This forms the basis for a claim of post-filing willfulness.

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

• A core issue will be one of definitional scope: can the term "band," as used in the context of LED arrangement in the ’062 patent, be construed to cover the helical or spiral filament structure of the accused products? The outcome of this construction will be pivotal to the infringement analysis for that patent.
• A second primary question will be one of aesthetic interpretation: how will the court construe the subjective limitation "visibly appears as a centrally glowing area"? This will involve determining whether the term is sufficiently definite and, if so, what visual characteristics an accused product must exhibit to meet it.
• A key technical question will be one of claim construction: does the term "thermally coupled to the enclosure" require a solid-state conductive pathway, or can it be satisfied by thermal transfer through a conductive gas fill as alleged by the Plaintiff? While intrinsic evidence appears to support the plaintiff's position, this remains a central technical question for the court to resolve.