DCT

2:25-cv-10995

Parmida LLC v. Obert Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-10995, C.D. Cal., 11/17/2025
  • Venue Allegations: Venue is alleged to be proper in the Central District of California because Defendant Obert, Inc. resides in the district, maintains a regular and established place of business there, and a substantial part of the events giving rise to the claims occurred in the district.
  • Core Dispute: Plaintiff seeks a declaratory judgment that Defendant’s patent related to the construction of LED tube lamps is invalid and not infringed by Plaintiff's products, which have been the subject of infringement complaints filed by Defendants on Amazon.com.
  • Technical Context: The technology pertains to the internal mechanical and electrical structure of LED tube lamps, a widely adopted, energy-efficient replacement for traditional fluorescent lighting in commercial and residential settings.
  • Key Procedural History: The complaint alleges that the patent-in-suit is a continuation of a parent patent (U.S. Patent No. 10,295,125) that was the subject of a prior lawsuit and a petition for Inter Partes Review (IPR). The U.S. Patent and Trademark Office instituted the IPR, indicating a reasonable likelihood that the challenged claims were unpatentable. Shortly after institution, Defendants settled the underlying litigation and filed a joint motion to terminate the IPR before a final written decision on validity was issued. Plaintiff alleges this history suggests the patent-in-suit is invalid.

Case Timeline

Date Event
2014-09-28 '197 Patent - Earliest Priority Date
2019-05-21 U.S. Patent No. 10,295,125 ('125 Patent) Issues
2020-06-02 U.S. Patent No. 10,670,197 ('197 Patent) Issues
2022-05-24 Defendants file lawsuit based on the '125 Patent
2022-12-14 IPR Petition filed against the '125 Patent
2023-08-16 USPTO grants institution of IPR on the '125 Patent
2023-10-11 Court dismisses lawsuit involving the '125 Patent following settlement
2023-10-13 Joint motion to terminate IPR on the '125 Patent is filed
2025-06-01 Defendants file infringement complaints on Amazon against Plaintiff (approx. date)
2025-11-17 Complaint for Declaratory Judgment is filed

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

U.S. Patent No. 10,670,197 - "LED tube lamp"

  • Issued: June 2, 2020 (’197 Patent)

The Invention Explained

  • Problem Addressed: The patent background describes a problem with existing LED tube lamps where the internal wiring can be easily damaged or broken during manufacturing, transportation, or use, potentially disabling the lamp (’197 Patent, col. 2:1-4).
  • The Patented Solution: The invention proposes a specific structural arrangement for an LED tube lamp to improve durability. It comprises an LED light strip situated inside a lamp tube, where the strip is divided into a "mounting region" for the LEDs and a "connecting region" for soldering pads that connect to the power supply. A "protective layer" is disposed over the light strip, featuring separate openings to accommodate the LED light sources and the soldering pads (’197 Patent, Abstract; Fig. 2). This configuration aims to provide a more robust and manufacturable assembly.
  • Technical Importance: This design addresses manufacturing and reliability challenges in the high-volume market for LED tube lamps, which are intended as direct replacements for less durable and less efficient fluorescent tubes.

Key Claims at a Glance

  • The complaint states that Defendants have asserted claims 1-2 of the ’197 Patent against Plaintiff through Amazon's complaint system (Compl. ¶25).
  • Independent Claim 1 of the ’197 Patent includes the following essential elements:
    • An illuminating region comprising at least a portion of a lamp tube;
    • Two non-illuminating regions, each coupled to an end of the illuminating region and comprising an end cap;
    • A power supply module disposed in one or two of the non-illuminating regions;
    • An LED light strip disposed in the tube, comprising a mounting region (disposed in the illuminating region) and a connecting region (disposed in one of the non-illuminating regions);
    • The mounting region is attached to an inner circumferential surface of the lamp tube;
    • A plurality of LED light sources mounted on the mounting region;
    • At least two soldering pads arranged on the connecting region for connection to the power supply module;
    • A protective layer disposed on the surface of the LED light strip;
    • The protective layer comprises a plurality of first openings for the LED light sources and at least two second openings for the soldering pads.
  • The complaint also seeks a declaratory judgment of non-infringement for claims 3-66 but does not allege that Defendants have asserted these specific claims (Compl. ¶38).

III. The Accused Instrumentality

Product Identification

Plaintiff’s "ecommerce retailer of LED lighting products," specifically its "tube lamp products" sold on Amazon.com (Compl. ¶4).

Functionality and Market Context

The accused instrumentalities are LED tube lamps designed as replacements for conventional fluorescent tube lights (Compl. ¶4). The complaint alleges that these products are sold on Amazon.com, which represents over 90% of Plaintiff's total sales, and that Defendants' infringement complaints have caused the delisting of approximately twenty-five of these products, resulting in a significant decrease in revenue (Compl. ¶¶4, 44). The complaint does not provide sufficient detail for analysis of the specific technical construction of Plaintiff's tube lamp products.

IV. Analysis of Infringement Allegations

The complaint, as an action for declaratory judgment initiated by the accused infringer, does not contain a claim chart from the patent holder or detailed factual allegations mapping claim elements to the accused products. Plaintiff makes a general assertion that its products do not infringe the ’197 Patent because they lack required elements or their equivalents (Compl. ¶¶38-39).

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions: An analysis of infringement may raise questions regarding the scope of the claimed regions. For example, a point of contention could be whether the accused products' internal structure contains distinct "illuminating" and "non-illuminating" regions that correspond to the claimed arrangement, where the LED mounting area and power connection area are physically separated as required by the claim language.
  • Technical Questions: A key technical question will likely concern the "protective layer" limitation. Analysis may focus on whether the accused products utilize a structure that meets the claim's definition of a "protective layer disposed on a surface of the LED light strip" that also contains two distinct sets of openings—"first openings" for the LEDs and "second openings" for the soldering pads. The specific construction and function of any layer covering the LED strip in the accused products will be a central point of comparison.

V. Key Claim Terms for Construction

"illuminating region" and "non-illuminating regions"

  • Context and Importance: Claim 1 spatially organizes the lamp's internal components by placing the "mounting region" (with LEDs) inside the "illuminating region" and the "connecting region" (with soldering pads) inside a "non-illuminating region." The construction of these terms will define the required physical separation and arrangement of components, which may be a critical factor in the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide an explicit definition. A party could argue that the terms should be given their plain and ordinary meaning, where the "illuminating region" is simply the light-transmissive portion of the lamp tube and the "non-illuminating regions" are the opaque end portions containing the end caps.
    • Evidence for a Narrower Interpretation: A party could argue that the claim language itself provides a structural definition, stating that a "non-illuminating region" comprises an end cap coupled to a respective end of the illuminating region (’197 Patent, cl. 1). This could be interpreted to limit the "non-illuminating region" to the physical boundary of the end cap assembly itself.

"protective layer"

  • Context and Importance: This is a key structural element of claim 1, which requires the layer to be disposed on the LED light strip and feature two distinct types of openings. Practitioners may focus on this term because its construction will determine whether common manufacturing features, such as a standard solder mask on a printed circuit board, meet the limitation, or if a more specific, separate layer is required.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification refers to the layer having openings "to accommodate" the light sources and soldering pads, which could support an interpretation where any layer that serves a protective purpose and has openings for these components qualifies (’197 Patent, col. 2:58-62).
    • Evidence for a Narrower Interpretation: The claim recites a "protective layer disposed on a surface of the LED light strip," which could be argued to require a distinct layer applied onto the strip, rather than an integral part of the light strip's substrate itself, such as a conventional solder mask. The Abstract also describes this as a separate component in the assembly (’197 Patent, Abstract).

VI. Other Allegations

This section is not applicable as the complaint is for declaratory judgment and does not contain allegations of indirect or willful infringement against the Plaintiff.

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

  • A primary issue for the court will be one of invalidity: given the prior institution of an inter partes review against the parent ’125 patent, a central question is whether the prior art that formed the basis of that proceeding will be found to render the allegedly similar claims of the asserted ’197 patent obvious under 35 U.S.C. § 103.
  • A second key question will be one of structural correspondence: assuming the patent is deemed valid, the infringement analysis will likely turn on whether the Plaintiff's products contain the specific, multi-part structural arrangement required by Claim 1, including the precise spatial relationship between the "illuminating/non-illuminating regions" and the "mounting/connecting regions," as well as the presence of a "protective layer" with two distinct types of openings.