DCT
5:25-cv-00209
In 2 Developments LLC v. Globe Electric Co USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: In 2 Developments LLC (Minnesota)
- Defendant: Globe Electric Co (USA.), Inc. (Delaware)
- Plaintiff’s Counsel: PERKOWSKI LEGAL, PC; Daignault Iyer LLP
- Case Identification: 5:25-cv-00209, C.D. Cal., 01/25/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district and has committed the alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s vintage-style LED filament light bulbs infringe patents related to the structural design and composition of such bulbs, including the use of an elongated filament supporting LEDs within a gas-filled glass bulb.
- Technical Context: The technology concerns LED light bulbs designed to replicate the aesthetic of traditional incandescent Edison bulbs, a significant segment of the decorative and consumer lighting market.
- Key Procedural History: The complaint notes that U.S. Patent No. 9,995,436 is a continuation of the application that issued as U.S. Patent No. 9,702,510, indicating the patents share a common specification and priority claim. No other procedural history is mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2013-05-24 | Earliest Priority Date ('510 & '436 Patents) |
| 2017-07-11 | U.S. Patent No. 9,702,510 Issues |
| 2018-06-12 | U.S. Patent No. 9,995,436 Issues |
| 2025-01-25 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,702,510 - "LED LIGHT BULB" (Issued Jul. 11, 2017)
The Invention Explained
- Problem Addressed: The complaint asserts that prior lighting solutions did not fully integrate the efficiency and longevity benefits of LED technology into designs that were familiar and broadly acceptable to consumers, creating a need for improved LED bulb designs (Compl. ¶21).
- The Patented Solution: The invention is an LED light bulb constructed to resemble a traditional incandescent bulb, featuring an Edison-style base, a sealed glass bulb, and one or more internal elongated filaments that support light-emitting diodes ('510 Patent, Abstract). To manage heat and improve longevity, the bulb is filled with an inert gas, which allows for higher lumen output at a low operating temperature by facilitating convective heat transfer away from the LED components ('510 Patent, col. 6:1-21).
- Technical Importance: The described structure allows for the creation of LED bulbs that aesthetically and functionally replace traditional incandescent bulbs, combining modern energy efficiency with a vintage appearance (Compl. ¶21).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶26).
- Claim 1 recites a light bulb comprising:
- an Edison style base;
- light emitting diode circuitry coupled to the base;
- a conductive structure with proximal and distal contacts;
- a bulb sealed about the base;
- a substantially cylindrical elongated filament supported by the conductive structure and fully encased by the bulb;
- a light emitting diode channel disposed within the filament; and
- an inert gas disposed within the bulb.
U.S. Patent No. 9,995,436 - "LED LIGHT BULB" (Issued Jun. 12, 2018)
The Invention Explained
- Problem Addressed: As a continuation of the '510 patent application, the '436 patent addresses the same technical problem: combining the benefits of LED technology with the conventional form factor of an incandescent bulb (Compl. ¶¶ 21-22).
- The Patented Solution: The '436 patent describes the same fundamental invention as the '510 patent: an LED light bulb with an Edison base, internal LED filaments, and an inert gas fill to manage heat and prolong life ('436 Patent, Abstract; Compl. ¶24). The two patents share a nearly identical specification.
- Technical Importance: This technology enables the production of energy-efficient, long-lasting decorative light bulbs that are direct replacements for less efficient incandescent versions (Compl. ¶21).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶37).
- Claim 1 recites a light bulb comprising:
- an Edison style base;
- light emitting diode circuitry coupled to the base;
- a conductive structure with proximal and distal contacts;
- a bulb sealed about the base;
- an elongated filament (note: not "substantially cylindrical") supported by the conductive structure and fully encased by the bulb;
- a light emitting diode disposed within the filament (note: "diode" singular, not "channel"); and
- an inert gas disposed within the bulb.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are "Globe Electric Products," specifically including its "7.5W (60W Equivalent) Vintage Edison E26 LED bulbs" and other bulbs alleged to have a similar design and construction (Compl. ¶3).
Functionality and Market Context
- The complaint alleges these products are LED filament light bulbs that feature an Edison-style screw base, a transparent glass bulb, and internal structures that emulate the appearance of incandescent filaments (Compl. ¶¶ 27, 30). A photograph provided in the complaint shows the internal electronic components at the base of the bulb, which allegedly constitute the claimed "light emitting diode circuitry" (Compl. ¶28). The complaint asserts these products are sold and distributed in California and generate substantial revenue (Compl. ¶8).
IV. Analysis of Infringement Allegations
'510 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an Edison style base | The accused products are alleged to have an Edison style base. A photograph shows a bulb with a standard screw-in base (Compl. p. 5). | ¶27 | col. 4:10-12 |
| light emitting diode circuitry coupled to the base | The products allegedly contain light emitting diode circuitry coupled to the base. A close-up photograph displays electronic components within the base (Compl. p. 5). | ¶28 | col. 4:22-24 |
| a substantially cylindrical elongated filament supported on a first proximate filament end by the first proximate contact and supported on a first distal filament end by the first distal contact... | The products are alleged to have an elongated filament structure supported by contacts. A photograph shows the internal filament assembly connected to conductive posts (Compl. p. 7). | ¶31 | col. 6:58-62 |
| ...wherein the bulb entirely encases the elongated filament | The bulb is alleged to encase the filament. A photograph shows the glass bulb sealed around the base and enclosing the internal components (Compl. p. 8). | ¶31 | col. 9:43-51 |
| a light emitting diode channel disposed within the filament... | The products are alleged to have an LED channel within the filament. A photograph highlights the filament structures where the LEDs are located (Compl. p. 8). | ¶32 | col. 6:22-24 |
| an inert gas disposed within the bulb | The products are alleged to contain an inert gas. This allegation is supported by a diagram from a third-party website generally describing how LED filament bulbs are made (Compl. p. 9). | ¶33 | col. 6:1-4 |
- Identified Points of Contention:
- Scope Question: Does the term "substantially cylindrical" read on the accused product's filaments, which appear in photographs to be flat strips rather than cylindrical rods? (Compl. p. 8).
- Technical Question: What evidence does the complaint provide that the accused product contains an "inert gas"? The pleading relies on a generic diagram from a third-party website, not on any specific testing or documentation of the accused product itself (Compl. ¶33).
- Scope Question: The infringement reading of "a light emitting diode channel disposed within the filament" raises the question of whether LEDs mounted on a substrate (as is common) meets this limitation, or if the claim requires the LEDs to be fully embedded or encased inside the filament material.
'436 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an Edison style base | The accused products are alleged to have an Edison style base, as shown in a photograph (Compl. p. 10). | ¶38 | col. 19:20-21 |
| an elongated filament supported on a first proximate filament end by the first proximate contact and supported on a first distal filament end by the first distal contact... | The products allegedly have an elongated filament. A photograph shows the internal filament structure connected to support wires (Compl. p. 12). | ¶42 | col. 19:35-43 |
| a light emitting diode disposed within the filament, coupled to the light emitting diode circuitry... | The products are alleged to have a light emitting diode within the filament. This is supported by a photograph of the internal filaments and a third-party diagram of LED filament manufacturing (Compl. p. 14). | ¶43 | col. 19:44-48 |
| an inert gas disposed within the bulb | The products are alleged to contain an inert gas, supported by a diagram from a third-party website showing "Gas" as a component in a generic LED filament bulb (Compl. p. 15). | ¶44 | col. 19:49-50 |
- Identified Points of Contention:
- Scope Question: By asserting claim 1 of the '436 patent, which omits the "substantially cylindrical" limitation, Plaintiff appears to be presenting an alternative infringement theory that may more directly read on the flat-strip design of the accused product.
- Technical Question: As with the '510 patent, the allegation of an "inert gas" is supported only by general, third-party information, raising an evidentiary question regarding the specific composition of the accused product (Compl. ¶44).
V. Key Claim Terms for Construction
The Term: "substantially cylindrical elongated filament" ('510 Patent, Claim 1)
- Context and Importance: The construction of this term is critical because the accused products appear to use flat, strip-like filaments. The viability of the infringement claim under the '510 patent may depend on whether "substantially cylindrical" is interpreted broadly enough to cover a non-circular cross-section.
- Intrinsic Evidence for a Broader Interpretation: The specification discloses multiple filament embodiments with polygonal cross-sections, such as two-sided (FIG. 6A), three-sided (FIG. 6B), and four-sided (FIG. 6C) filaments, not just the "cylindrical filament" of FIG. 6F ('510 Patent, col. 7:3-40). Plaintiff may argue these examples show "cylindrical" is merely a preferred embodiment, not a strict limitation on the overall invention.
- Intrinsic Evidence for a Narrower Interpretation: Defendant may argue that the patentee explicitly chose the words "substantially cylindrical" in claim 1 to distinguish it from other possible shapes, and that the other figures represent different, unclaimed embodiments. The explicit depiction of a "cylindrical filament" in FIG. 6F could be used to argue for a more literal, shape-specific meaning ('510 Patent, col. 7:37-40).
The Term: "disposed within the filament" ('510 and '436 Patents, Claim 1)
- Context and Importance: Practitioners may focus on this term because the common method of manufacturing these products involves mounting LED dies onto a substrate. The dispute will likely center on whether "on" is equivalent to "within."
- Intrinsic Evidence for a Broader Interpretation: The specification describes that "filaments in one embodiment may be formed on a filament substrate" and that "light emitting diode strips may be coupled to the filament substrate" ('510 Patent, col. 6:58-62; col. 7:7-8). This language could suggest that the "filament" is the entire composite structure (substrate plus LEDs), meaning the LEDs are necessarily "within" the composite.
- Intrinsic Evidence for a Narrower Interpretation: Defendant may argue that the "filament" is the underlying substrate (e.g., the glass or ceramic strip) and the LEDs are mounted on its surface, not within its structure. The patent's description of a protective layer or coating being added over the LEDs could be interpreted as covering something that is on a surface, not enclosed within a volume ('510 Patent, col. 5:22-26).
VI. Other Allegations
The complaint does not allege indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "substantially cylindrical... filament" from the '510 patent be construed to cover the accused product's apparently flat, strip-like filaments? The concurrent assertion of the '436 patent, which omits this language, suggests this is a recognized and central point of dispute.
- A second key question will concern the meaning of "disposed within the filament." The case may turn on whether this requires the LED components to be physically embedded inside a substrate material, or if it can be interpreted to include LEDs mounted on the surface of a substrate that itself forms the filament.
- A primary evidentiary question will be whether Plaintiff can produce evidence, beyond the generic third-party materials cited in the complaint, to prove that the accused Globe Electric products actually contain the "inert gas" required by the asserted claims of both patents.