DCT

2:25-cv-09704

Pacem IP Holdings LLC v. Sunco Lighting Inc

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-09704, C.D. Cal., 10/10/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant is a California corporation that resides in the district, maintains a regular and established place of business in Valencia, CA, and has committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s LED light bulbs infringe five patents related to the design of filament-style LED lamps, including technologies for thermal management using inert gases and for tuning light quality.
  • Technical Context: The technology at issue involves LED light bulbs designed to aesthetically and functionally replace traditional incandescent filament bulbs, a significant segment of the market for energy-efficient lighting.
  • Key Procedural History: The complaint repeatedly alleges Defendant’s knowledge of infringement dates to "at least as early as the filing of the original Complaint." This language suggests the current filing may be an amended complaint or that there is a prior litigation history between the parties, which could be relevant to the allegations of willful infringement.

Case Timeline

Date Event
2010-06-04 ’559 Patent Priority Date
2012-07-12 ’062, ’983, ’687, ’489 Priority Date
2013-11-26 ’062 Patent Issue Date
2014-04-01 ’559 Patent Issue Date
2014-06-17 ’983 Patent Issue Date
2016-08-09 ’687 Patent Issue Date
2021-03-30 ’489 Reissue Patent Issue Date
2025-10-10 Complaint Filing Date

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

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

  • Patent Identification: U.S. Reissue Patent No. RE48,489, "Gas cooled LED lamp," issued March 30, 2021.

The Invention Explained

  • Problem Addressed: The patent describes that traditional manufacturing processes for incandescent bulbs, such as fusing a glass stem to the enclosure, generate heat that can damage the sensitive components of LED lamps, making such designs unsuitable for LED-based lighting. (RE48,489 Patent, col. 2:12-24).
  • The Patented Solution: The invention discloses an LED lamp with a gas, such as helium, contained within the sealed glass enclosure. This gas provides thermal coupling between the LED array and the enclosure, allowing heat to dissipate without requiring the bulky external heat sinks common to many LED bulb designs and enabling structures that more closely resemble traditional incandescent bulbs. (RE48,489 Patent, Abstract; col. 2:48-52).
  • Technical Importance: This gas-cooling approach was a key enabler for the commercial production of filament-style LED bulbs that mimic the appearance and form factor of classic incandescent bulbs.

Key Claims at a Glance

  • The complaint asserts independent claim 11. (Compl. ¶35).
  • 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.
    • An electrically insulating base with an upper part connected to the enclosure and a separate lower part joined to the upper part.
    • An electrical connector connected to the lower part that forms part of the electrical connection to the LED assembly.
  • Plaintiff reserves the right to assert other claims. (Compl. ¶35).

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

  • Patent Identification: U.S. Patent No. 8,591,062, "LED Lamp," issued November 26, 2013.

The Invention Explained

  • Problem Addressed: The patent background notes the desire to create solid-state replacement lamps for traditional incandescent bulbs that replicate their desirable light patterns and appearance, which is challenging with conventional LED placement and heat sink designs. (’062 Patent, col. 9:43-52).
  • The Patented Solution: The invention describes an arrangement where multiple LEDs are disposed around the periphery of a central tower within the bulb enclosure. The LEDs are configured to face outwardly, creating a light source that "appears as a glowing filament," thereby mimicking the aesthetic of a traditional incandescent bulb. (’062 Patent, Abstract; col. 2:1-9).
  • Technical Importance: This structural arrangement directly addresses the market demand for LED replacement bulbs that are not only energy-efficient but also aesthetically indistinguishable from the incandescent bulbs they are designed to replace.

Key Claims at a Glance

  • The complaint asserts independent claim 7. (Compl. ¶47).
  • Claim 7 requires:
    • A lamp with 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 comprising a plurality of LEDs energized through an electrical path from the base.
    • The LED assembly arranged such that the LEDs are disposed about a longitudinal axis in a band and face outwardly to create a source of light that "visibly appears as a centrally glowing area."
  • Plaintiff reserves the right to assert other claims. (Compl. ¶47).

Multi-Patent Capsule: U.S. Patent No. 8,684,559 - “Solid state light source emitting warm light with high CRI”

  • Patent Identification: U.S. Patent No. 8,684,559, “Solid state light source emitting warm light with high CRI,” issued April 1, 2014.
  • Technology Synopsis: This patent addresses the technical challenge of altering the color characteristics of an LED light source. The invention describes using a filter arranged to pass light from an LED source, which changes the light's color temperature (e.g., making it "warmer") while maintaining "substantially the same" high Color Rendering Index (CRI), a measure of color accuracy. (’559 Patent, Abstract).
  • Asserted Claims: The complaint asserts independent claim 1. (Compl. ¶61).
  • Accused Features: The complaint alleges that the Sunco A19 2200K Amber Bulb uses a filter to modify the light from its LED source in an infringing manner. (Compl. ¶62-63).

Multi-Patent Capsule: U.S. Patent No. 8,752,983 - “Gas cooled LED lamp”

  • Patent Identification: U.S. Patent No. 8,752,983, “Gas cooled LED lamp,” issued June 17, 2014.
  • Technology Synopsis: This patent, which is the original patent that was reissued as the ’489 Patent, discloses an LED lamp cooled by a gas contained within the bulb's enclosure. The gas provides a medium for thermal coupling, transferring heat from the LED array to a heat sink structure to be dissipated, enabling designs that mimic traditional bulbs without large external heat sinks. (’983 Patent, Abstract).
  • Asserted Claims: The complaint asserts independent claim 1. (Compl. ¶84).
  • Accused Features: The complaint alleges that various Sunco bulbs, including the ST64 4000K Bulb, contain a gas (such as helium) and a heat sink structure that provides thermal coupling to the LED array in a manner that infringes the patent. (Compl. ¶85-89).

Multi-Patent Capsule: U.S. Patent No. 9,410,687 - “LED lamp with filament style LED assembly”

  • Patent Identification: U.S. Patent No. 9,410,687, “LED lamp with filament style LED assembly,” issued August 9, 2016.
  • Technology Synopsis: This patent describes the mechanical and optical arrangement of an LED lamp designed to look like a traditional filament bulb. It discloses a central "tower" extending from the base that supports an LED assembly, with the LEDs disposed about the tower's periphery and facing outward to "create a source of the light that appears as a glowing filament." (’687 Patent, Abstract).
  • Asserted Claims: The complaint asserts independent claim 1. (Compl. ¶72).
  • Accused Features: The complaint alleges that the Sunco ST64 4000K Bulb includes a tower supporting an outward-facing LED assembly arranged to create the appearance of a glowing filament. (Compl. ¶75).

III. The Accused Instrumentality

Product Identification

  • The accused products include the Sunco CA11 5W 2000K Bulb, Sunco A19 2200K Amber Bulb, Sunco ST64 4000K Bulb, Sunco A19 9W 3000K Clear Bulb, and other substantially similar products. (Compl. ¶2).

Functionality and Market Context

  • The complaint describes the accused products as commercial LED light bulbs marketed and sold throughout the United States. (Compl. ¶2, ¶9). The infringement allegations focus on their internal construction, including the use of filament-style LED arrays, internal gases for cooling, and filters for modifying light properties. (Compl. ¶36-38, ¶62-63). The complaint provides visual evidence, including a photograph of a handheld gas detector allegedly measuring helium inside an accused bulb, to support its technical allegations. This image shows a detector reading "He 43.6" within the disassembled bulb. (Compl. ¶37, Fig. 1A-3). Another set of visuals purports to show spectrometer readings of an accused amber bulb, measuring its Color Rendering Index (CRI) with and without a filter. (Compl. ¶63, Fig. 1C-6, Fig. 1C-5 (labeled as CRI with filter)).

IV. Analysis of Infringement Allegations

RE48,489 Patent Infringement Allegations

Claim Element (from Independent Claim 11) Alleged Infringing Functionality Complaint Citation Patent Citation
A lamp comprising: an optically transmissive enclosure The Sunco ST64 4000K Bulb is a lamp that includes a glass, optically transmissive enclosure. ¶36 col. 46:35-37
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 The accused bulb has an LED array inside the enclosure. The complaint alleges the array is thermally coupled to the enclosure via helium gas contained within the bulb, evidenced by a gas detector reading. ¶37 col. 46:37-41; col. 2:48-52
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 The accused bulb's base is alleged to be electrically insulating and composed of a distinct upper part connected to the enclosure and a separate lower part joined to it. ¶38 col. 46:42-47
and an electrical connector connected to the lower part that forms part of the electrical connection to the LED assembly. The accused bulb has an electrical connector as part of its base that connects to the LED assembly. ¶38 col. 46:47-50
  • Identified Points of Contention:
    • Scope Question: A primary issue may be the construction of "thermally coupled to the enclosure." The allegation relies on coupling via an intermediary gas rather than direct physical contact. The dispute will likely focus on whether the claim language, interpreted in light of the specification, permits such an indirect thermal pathway to satisfy the limitation.
    • Technical Question: The complaint provides a photograph of a gas detector as evidence of helium. (Compl. ¶37, Fig. 1A-3). A factual dispute may arise concerning the accuracy and methodology of this measurement and what level of thermal conductivity this gas provides, and whether that level is sufficient to meet the "thermally coupled" requirement.

8,591,062 Patent Infringement Allegations

Claim Element (from Independent Claim 7) Alleged Infringing Functionality Complaint Citation Patent Citation
A lamp comprising: an optically transmissive enclosure The Sunco ST64 4000K Bulb has a glass, optically transmissive enclosure. ¶48 col. 41:1-2
a base comprising an Edison screw adapted to engage an Edison socket The accused bulb includes a standard Edison screw base. A complaint photograph shows the bulb's base being inserted into a socket. (Compl. ¶49, Fig. 1B-3). ¶49 col. 41:3-4
an LED assembly connected to the base and extending into the optically transmissive enclosure The accused bulb contains an LED assembly mounted on an internal structure that extends from the base into the glass enclosure. ¶50 col. 41:5-7
the LED assembly comprising a plurality of LEDs operable to emit light when energized through an electrical path from the base The LED assembly contains multiple LEDs that are energized by an electrical path originating from the base. ¶51 col. 41:8-10
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... The LEDs are arranged on vertical filaments positioned around the bulb's central axis, facing outward toward the glass enclosure. ¶52 col. 41:11-14
to create a source of the light that visibly appears as a centrally glowing area. When illuminated, the arrangement of outward-facing LEDs is alleged to create the appearance of a glowing area in the center of the bulb. ¶52 col. 41:14-16
  • Identified Points of Contention:
    • Scope Question: The claim limitation "visibly appears as a centrally glowing area" is qualitative and dependent on visual perception. A significant legal question will be how the court construes this term—whether it requires a specific resemblance to a traditional filament, or if any central light source suffices.
    • Technical Question: A factual dispute may center on whether the light output of the accused product, as it operates, actually "appears" as a "centrally glowing area" to an ordinary observer. Evidence for this element may go beyond simple photographs and could involve consumer surveys or expert testimony on optics and human perception.

V. Key Claim Terms for Construction

For the ’489 Patent

  • The Term: "thermally coupled to the enclosure" (Claim 11)
  • Context and Importance: This term is critical because the infringement theory hinges on thermal coupling occurring via a gas contained within the enclosure, not through direct solid-to-solid contact. The definition will determine whether the complaint's core technical allegation can meet the claim language.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification of the original patent (’983) repeatedly describes the invention's use of gas for thermal management. For example, it states, "A gas is contained in the enclosure to provide thermal coupling to the LED array." (’983 Patent, Abstract). An argument may be made that one of ordinary skill in the art would understand "thermally coupled" in this context to include coupling via a conductive gas.
    • Evidence for a Narrower Interpretation: An argument for a narrower construction might focus on embodiments where a heat sink structure makes physical contact with other components. For example, the specification describes a heat sink structure that is "thermally coupled to the LED assembly for transmitting heat from the LED array to the gas." (’983 Patent, col. 46:38-41). This could be used to argue that "thermally coupled" implies a more direct conductive pathway than merely being surrounded by the same volume of gas as the enclosure.

For the ’062 Patent

  • The Term: "visibly appears as a centrally glowing area" (Claim 7)
  • Context and Importance: Practitioners may focus on this term because its subjective nature makes it a prime candidate for dispute. The entire aesthetic purpose of the invention is captured in this phrase, and its scope will determine whether the accused product's appearance infringes.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification uses similar, slightly different phrases, such as creating a light source that "appears as a glowing filament" or "appears as a glow of a filament." (’062 Patent, Abstract; col. 2:17-18). A party could argue that these phrases do not require an exact replica of an incandescent filament but rather a generally centralized, elongated light source.
    • Evidence for a Narrower Interpretation: The patent's consistent reference to the appearance of a "filament" could be used to argue for a narrower construction requiring a distinct, thin, linear, or wire-like appearance, as opposed to a more diffuse or voluminous "glowing area." The figures showing the LEDs mounted on distinct vertical substrates may support this interpretation. (’062 Patent, Fig. 2).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is alleged based on Defendant selling the accused products "with the intention that they will use" them in an infringing manner. (Compl. ¶40, ¶54, ¶65, ¶77, ¶91). Contributory infringement is alleged based on Defendant purchasing and incorporating "LED packages and components that it knows are material to the practicing of the claimed inventions and have no substantial non-infringing use." (Compl. ¶41, ¶55, ¶66, ¶78, ¶92).
  • Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the patents-in-suit and the alleged infringement "at least as early as the filing of the original Complaint." (Compl. ¶39, ¶53, ¶64, ¶76, ¶90). This allegation establishes a basis for post-suit willfulness and suggests a potential basis for pre-suit willfulness depending on the nature and timing of the "original Complaint." The complaint also pleads that the infringement is "exceptional" to support a claim for attorneys' fees under 35 U.S.C. § 285. (Compl. ¶42, ¶56, ¶67, ¶79, ¶93).

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

  • A core issue will be one of technical and definitional scope: can the term "thermally coupled," as used in the gas-cooling patents, be met by an indirect thermal path through a contained gas, or does it require a more direct, solid-state connection? The answer will depend on claim construction informed by the patent's description of how the gas functions.
  • A second central question will be one of qualitative assessment: how will the court define and test the appearance-based limitation that the lamp "visibly appears as a centrally glowing area"? This may require the court to move beyond purely technical specifications and consider evidence related to visual perception and consumer expectations.
  • A key evidentiary question will be one of functional proof: does the accused amber bulb’s alleged "filter" perform the specific function required by Claim 1 of the ’559 Patent—namely, altering color temperature while keeping the CRI "substantially the same"? The outcome will likely depend on the credibility and interpretation of competing technical measurements, such as the spectrometer data presented in the complaint.