Pacem IP Holdings LLC v. Globe Electric Co USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Pacem IP Holdings LLC (Texas)
  • Defendant: Globe Electric Company (U.S.A.), Inc. (Delaware)
  • Plaintiff’s Counsel: Cherry Johnson Siegmund James PLLC
• Case Identification: 2:26-cv-00943, C.D. Cal., 01/29/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the Central District of California, specifically in San Bernardino.
• Core Dispute: Plaintiff alleges that Defendant’s vintage-style LED filament light bulbs infringe six patents related to the structural design, thermal management, light quality, and aesthetic appearance of LED lamps.
• Technical Context: The technology concerns the design of modern LED light bulbs to mimic the visual appearance and performance characteristics of traditional incandescent filament bulbs, a significant segment of the consumer lighting market.
• Key Procedural History: The complaint references a prior "original Complaint," indicating the current filing is likely an amended complaint and establishing a date for Defendant's alleged knowledge of the asserted patents.

Case Timeline

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

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

The Invention Explained

• Problem Addressed: The patent addresses the challenge of manufacturing LED bulbs that resemble traditional incandescent bulbs, noting that the heat-intensive process of fusing a glass stem to the bulb's enclosure can damage the heat-sensitive LED components RE48,489 Patent, col. 2:17-25
• The Patented Solution: The invention proposes a gas-cooled LED lamp constructed with a multi-part base. This base comprises a separate upper part connected to the glass enclosure and a separate lower part containing the electrical connector, which are joined together during assembly. This design facilitates thermal management through a gas within the enclosure while avoiding high-heat manufacturing steps that could damage the LED array RE48,489 Patent, Abstract; col. 2:54-61
• Technical Importance: This design approach allows for the production of LED lamps that mimic the classic form factor of incandescent bulbs by using assembly methods compatible with sensitive electronic components RE48,489 Patent, col. 2:5-10

Key Claims at a Glance

• The complaint asserts independent claim 11 Compl. ¶39
• The essential elements of claim 11 are:
  • A lamp comprising: an optically transmissive enclosure;
  • An LED array disposed in the enclosure, operable to emit light, and thermally coupled to the enclosure; and
  • An electrically insulating base comprising an upper part connected to the enclosure, a separate lower part that is a separate component from the upper part, and an electrical connector joined to the lower part.
• Plaintiff reserves the right to assert additional claims Compl. ¶39

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

The Invention Explained

• Problem Addressed: The patent seeks to solve the aesthetic challenge of making an LED lamp that replicates the visual appearance of a traditional incandescent bulb with a "glowing filament" ('062 Patent, col. 1:49-54).
• The Patented Solution: The invention describes an LED assembly mounted on a central tower or support structure. A plurality of LEDs are arranged in a "band" around the lamp's longitudinal axis and are configured to face outwardly toward the enclosure. This specific spatial arrangement creates a light source that "visibly appears as a centrally glowing area," mimicking the look of a conventional filament '062 Patent, Abstract; col. 2:5-9
• Technical Importance: This architecture provided a technical pathway for creating omnidirectional LED lamps that successfully reproduced the popular aesthetics of traditional filament bulbs, which was a significant factor for consumer market acceptance '062 Patent, col. 2:10-14

Key Claims at a Glance

• The complaint asserts independent claim 7 Compl. ¶51
• The essential elements of claim 7 are:
  • A lamp with an optically transmissive enclosure and an Edison screw base.
  • An LED assembly connected to the base and extending into the enclosure.
  • The LED assembly has a plurality of LEDs operable to emit light.
  • The 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."
• Plaintiff reserves the right to assert additional claims Compl. ¶51

U.S. Patent No. 8,684,559 - "Solid state light source emitting warm light with high CRI"

• Technology Synopsis: The patent describes a method for creating warm-colored light with a high Color Rendering Index (CRI). It discloses using a filter that alters the color temperature of light from an LED source to be warmer, while ensuring the CRI remains substantially the same after filtering.
• Asserted Claims: Independent claim 1 is asserted Compl. ¶65
• Accused Features: The complaint alleges that the accused bulbs use a filter (such as the tinted glass enclosure) to modify the emission spectrum of an internal LED light source, resulting in a different color temperature but a substantially similar CRI Compl. ¶67

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

• Technology Synopsis: The patent discloses an LED lamp with a central tower that extends from the base to support an LED assembly. The LEDs are specifically arranged about the periphery of this tower in a band at the optical center of the enclosure, facing outward to create the appearance of a "glowing filament."
• Asserted Claims: Independent claim 1 is asserted Compl. ¶76
• Accused Features: The infringement allegation targets the internal structure of the accused bulbs, specifically the use of a tower to support LED filaments that are arranged to face outwardly and mimic the appearance of a traditional glowing filament Compl. ¶79

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

• Technology Synopsis: The technology relates to cooling an LED lamp using a gas contained within the sealed enclosure. The invention describes a heat sink structure thermally coupled to the LED array, which transmits heat from the LEDs to the gas; the gas then transfers the heat to the lamp's enclosure.
• Asserted Claims: Independent claim 1 is asserted Compl. ¶88
• Accused Features: The complaint alleges the accused bulbs contain a gas (identified as helium) that provides thermal coupling between the LED array and the enclosure. The infringement theory also points to the bulb’s internal submount and heat sink structure, which allegedly transfer heat from the LEDs to the gas Compl. ¶¶ 92-93

U.S. Patent No. 10,260,683 - "Solid-state lamp with LED filaments having different CCT's"

• Technology Synopsis: The patent describes an LED lamp capable of changing its Correlated Color Temperature (CCT) as it is dimmed, mimicking the "warming" effect of a dimmed incandescent bulb. This is achieved by using at least two types of LED filaments with different CCTs and a controller that adjusts their relative output during dimming.
• Asserted Claims: Independent claim 1 is asserted Compl. ¶102
• Accused Features: The infringement allegation targets the accused "Smart Filament Bulb," which allegedly contains at least two different types of LED filaments and a controller that changes the combined CCT of the emitted light when the lamp is dimmed Compl. ¶¶ 105-106

III. The Accused Instrumentality

Product Identification

• The accused products are the Globe Electric ST19 Vintage Bulb, Globe Electric G25 Smart Filament Bulb, Globe Electric B11 Vintage Bulb, and other substantially similar products Compl. ¶2

Functionality and Market Context

• The accused products are LED light bulbs designed to replicate the aesthetic of vintage-style incandescent "Edison" bulbs, featuring visible structures intended to look like filaments within a glass enclosure Compl. ¶¶ 38, 50 The complaint alleges these are commercial products sold throughout the United States Compl. ¶¶ 2, 9 The "G25 Smart Filament Bulb" is specifically alleged to possess functionality that changes its light color temperature when dimmed Compl. ¶106 The complaint includes a screenshot from a mobile application allegedly controlling the G25 bulb, showing a user interface for adjusting color temperature Compl. Fig. 1F-4; ¶105

IV. Analysis of Infringement Allegations

RE48,489 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be the construction of "separate lower part that is a separate component from the upper part." The analysis will likely focus on whether the accused product's base is manufactured from two distinct pieces that are subsequently joined, or if it is an integrated component with functionally distinct sections.
  • Technical Questions: The allegation that the LED array is "thermally coupled to the enclosure" via helium gas raises an evidentiary question. The complaint's evidence is a photograph of a handheld meter (Compl. Fig. 1A-3), and the reliability and context of this measurement may be a point of dispute.

8,591,062 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The infringement analysis may turn on the construction of subjective, appearance-based terms such as "visibly appears as a centrally glowing area." The parties may dispute whether the aesthetic effect produced by the accused products falls within the scope of this limitation as defined by the patent.
  • Technical Questions: Whether the specific arrangement of the accused product's multiple distinct filaments constitutes a single "band" as required by the claim raises a question of technical interpretation.

V. Key Claim Terms for Construction

RE48,489, Claim 11

• The Term: "separate lower part that is a a separate component from the upper part"
• Context and Importance: The infringement reading of this claim hinges on the physical construction of the accused bulb's base. Practitioners may focus on this term because if the base is found to be a single, integrally formed piece rather than an assembly of two distinct components, the infringement allegation could fail. The complaint's photographic evidence suggests two pieces Compl. Fig. 1A-5
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's abstract describes the base functionally, suggesting that any two-part construction that achieves the goal of separating the enclosure connection from the electrical connection might suffice.
  • Evidence for a Narrower Interpretation: The explicit language "separate component" suggests a requirement for two physically distinct and independently manufactured pieces that are later joined. Figures in the original patent (U.S. 8,752,983, of which RE48,489 is a reissue) depict a clear assembly of two separate parts.

'062 Patent, Claim 7

• The Term: "visibly appears as a centrally glowing area"
• Context and Importance: This term is functional and defines the required visual appearance of the lamp. Its construction will be critical because infringement depends on a subjective assessment of the lamp's aesthetic output. A defendant could argue its product creates a different visual impression (e.g., multiple distinct glowing lines rather than a single "area").
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's background explains the invention aims to mimic the "glow of a filament" from a traditional bulb '062 Patent, col. 1:49-54 This context may support a construction covering any arrangement that generally achieves this filament-like aesthetic.
  • Evidence for a Narrower Interpretation: The claim links this appearance to a specific structure: LEDs "disposed about a longitudinal axis... in a band." The abstract further specifies LEDs disposed "about the periphery of the tower." This language may support a narrower construction requiring a specific cylindrical or banded light source, rather than just any collection of glowing lines.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on allegations that Defendant sells the accused products with the intent that customers will use them in an infringing manner (e.g., Compl. ¶¶ 44, 58, 69). Contributory infringement is based on allegations that Defendant purchases and incorporates specific LED packages that are a material part of the patented inventions and have no substantial non-infringing use (e.g., Compl. ¶¶ 45, 59, 70).
• Willful Infringement: Willfulness is alleged for all patents based on Defendant's alleged knowledge of the patents "at least as early as the filing of the original Complaint" (e.g., Compl. ¶¶ 43, 57, 68). The complaint also asserts that the infringement is "exceptional," seeking an award of attorneys' fees under 35 U.S.C. § 285 (e.g., Compl. ¶¶ 46, 60, 71).

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

• A core issue will be one of definitional scope: can claim terms rooted in aesthetics, such as "visibly appears as a centrally glowing area" ('062 Patent) or creating a light source that "appears as a glowing filament" ('687 Patent), be construed to read on the specific visual presentation of Defendant's multi-filament LED bulbs?
• A second central issue will be one of structural interpretation: does the accused product's base consist of "separate components" that are joined during manufacturing, as required by Claim 11 of the RE48,489 patent, or is it an integrally molded unit that may not meet this limitation?
• A key evidentiary question will be one of technical verification: can Plaintiff substantiate its allegations regarding the non-visible features of the accused products, such as the presence and function of helium gas for thermal coupling ('983 Patent) and the operation of a specific controller for color-tuning-while-dimming ('683 Patent)?