DCT
5:25-cv-00950
Lime Green Lighting LLC v. Brilliant NextGen Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lime Green Lighting, LLC (Michigan)
- Defendant: Brilliant NextGen, Inc. (Delaware)
- Plaintiff’s Counsel: Banie & Ishimoto LLP
- Case Identification: 5:25-cv-00950, N.D. Cal., 06/25/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of California because Defendant maintains a regular and established place of business within the district.
- Core Dispute: Plaintiff alleges that Defendant’s BRILLIANT SMART HOME SYSTEM infringes patents related to self-adaptive lighting control systems that use local sensors and remote servers to generate and execute lighting schedules.
- Technical Context: The technology at issue resides in the smart home and Internet of Things (IoT) sector, specifically focusing on automated lighting systems that learn from environmental conditions and user behavior to anticipate lighting needs.
- Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and that its predecessor has granted settlement licenses in prior litigations. Plaintiff contends these licenses do not trigger marking requirements under 35 U.S.C. § 287(a) because infringement was not admitted. Willful infringement is alleged based on notice letters reportedly sent to Defendant in August 2020.
Case Timeline
| Date | Event |
|---|---|
| 2014-09-12 | Earliest Priority Date for '874 and '798 Patents |
| 2017-07-04 | U.S. Patent No. 9,699,874 Issues |
| 2020-08-13 | Alleged date of notice letters establishing pre-suit knowledge |
| 2020-10-06 | U.S. Patent No. 10,798,798 Issues |
| 2025-06-25 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,699,874 - "System, Method, and Apparatus For Self-Adaptive Scheduled Lighting Control"
The Invention Explained
- Problem Addressed: The patent describes a limitation in prior art lighting systems, including early "smart" bulbs, which still required manual user intervention to adjust lighting conditions rather than anticipating a user's desires and acting independently (’874 Patent, col. 1:45-54).
- The Patented Solution: The invention proposes a lighting control device (e.g., a smart switch) that obtains data from local environmental sensors and user input devices. This data is transmitted to an external server, which generates a "new lighting operating schedule" based on an analysis of the data. The local device then obtains this new schedule from the server and executes it, thereby creating a self-adaptive system (’874 Patent, col. 2:1-13, 36-52).
- Technical Importance: This approach represents a shift from reactive smart home control (user commands action) to a more predictive model where the system learns and adapts lighting automatically based on aggregated data (’874 Patent, col. 1:50-54).
Key Claims at a Glance
- The complaint asserts claims 1-20 of the ’874 Patent (Compl. ¶13). Independent claim 1 is representative and recites the core elements of the system:
- A microcontroller, memory with executable instructions, a wireless transceiver, a dimmer, a powered lighting output, an environmental sensor, and an input device.
- The microcontroller is configured to perform a method comprising:
- obtaining environmental data from the sensor;
- obtaining input data from the input device;
- transmitting the environmental and input data to an external server;
- obtaining from the server a lighting operating schedule based on that data; and
- executing the lighting operating schedule.
- The complaint does not specifically identify which dependent claims it intends to assert beyond a general allegation covering claims 1-20 (Compl. ¶13).
U.S. Patent No. 10,798,798 - "System, Method, And Apparatus For Self-Adaptive Scheduled Lighting Control"
The Invention Explained
- Problem Addressed: The ’798 Patent addresses the same technical problem as the parent ’874 Patent: the need for a lighting system that adapts automatically without requiring constant manual intervention (’798 Patent, col. 1:49-59).
- The Patented Solution: The solution is also a system involving a local control device communicating with a remote server to generate and execute adaptive schedules. However, the claims of the ’798 Patent add a specific "interrupt operation." When a user makes a manual change, the system is claimed to suspend the current schedule, implement the user's change, and then resume the schedule, effectively allowing temporary user overrides without abandoning the automated schedule (’798 Patent, col. 12:2-17; Fig. 7).
- Technical Importance: This refinement provides a method for reconciling automated schedules with immediate user intent, a common challenge in autonomous control systems (’798 Patent, col. 9:11-18).
Key Claims at a Glance
- The complaint asserts claims 1-20 of the ’798 Patent (Compl. ¶19). Independent claim 1 is representative and recites a system for controlling smart bulbs, comprising:
- A microcontroller and memory with executable instructions.
- A method performed by the microcontroller, including:
- obtaining environmental data and input data;
- transmitting the data to a remote server;
- obtaining a lighting operating schedule from the server;
- executing the schedule by controlling smart bulbs; and
- executing an "interrupt operation" by suspending the schedule based on user input, implementing the user change, and resuming the schedule.
- The complaint generally alleges infringement of claims 1-20 without specifying particular dependent claims (Compl. ¶19).
III. The Accused Instrumentality
Product Identification
The BRILLIANT SMART HOME SYSTEM (Compl. ¶15).
Functionality and Market Context
The complaint alleges that the accused product is a smart home system used for lighting control (Compl. ¶15, ¶24). It further alleges that Defendant provides instructions on its website and in manuals for using the system (Compl. ¶14, ¶20). The complaint does not provide sufficient detail for analysis of the specific technical architecture or operational features of the BRILLIANT SMART HOME SYSTEM, instead referring to external exhibits that were not provided with the pleading (Compl. ¶12, ¶18). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint does not contain specific factual allegations mapping elements of the accused product to the patent claims. Instead, it states that support for the allegations is found in appended tables (Exhibits B and D), which were not included with the filed complaint (Compl. ¶12, ¶18). The following summary is based on the asserted claims and the general nature of the accused product as a smart home lighting system.
’874 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| obtaining environmental data from at least one environmental sensor | The BRILLIANT SMART HOME SYSTEM is alleged to include environmental sensors that gather data from the surrounding environment. | ¶12-15 | col. 2:1-5 |
| obtaining input data from at least one input device | The system allegedly obtains user input, for example, through a physical switch or a software application. | ¶12-15 | col. 2:5-7 |
| transmitting the environmental data and the input data to an external server | The system is alleged to transmit the collected sensor and user data to a remote server for processing. | ¶12-15 | col. 2:7-9 |
| obtaining, from the external server, a lighting operating schedule based on the environmental data and the input data | The system allegedly receives a set of lighting instructions or a schedule from the remote server that is based on the previously transmitted data. | ¶12-15 | col. 2:9-11 |
| executing the lighting operating schedule | The system allegedly controls connected lights according to the schedule received from the server. | ¶12-15 | col. 2:11-13 |
’798 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| obtaining from the remote server a lighting operating schedule | The BRILLIANT SMART HOME SYSTEM is alleged to receive a lighting schedule from a remote server. | ¶18-21 | col. 11:55-58 |
| executing the lighting operating schedule from the remote server by controlling one or more smart bulbs | The system allegedly uses the received schedule to control smart light bulbs. | ¶18-21 | col. 11:59-62 |
| executing an interrupt operation by: suspending execution...implementing the user change...resuming execution | The system is alleged to perform an operation where a manual user change temporarily overrides the automated schedule. The complaint lacks specific facts on how this is performed. | ¶18-21 | col. 12:2-17 |
Identified Points of Contention
- Evidentiary Questions: The complaint’s primary reliance on un-filed exhibits raises the question of whether its factual allegations are sufficient on their own. The analysis of infringement will depend entirely on evidence developed during discovery that demonstrates the specific architecture and functionality of the accused system.
- Scope Questions: A central dispute may revolve around whether the accused system’s cloud-based functionality constitutes a "remote server" that "generat[es] a new lighting operating schedule" based on weighted user and environmental data, as described in the patent specifications (’874 Patent, col. 2:40-44).
- Technical Questions (’798 Patent): A key technical question will be whether the accused system, when a user manually adjusts a setting, performs the specific three-step "interrupt operation" (suspend, implement, resume) as required by Claim 1 of the ’798 Patent. The complaint provides no specific facts on this point.
V. Key Claim Terms for Construction
The Term: "remote server" (’874 Patent, Cl. 1; ’798 Patent, Cl. 1)
- Context and Importance: The definition of this term is fundamental. The infringement case depends on showing that the accused system uses an external server that performs the functions required by the claims, rather than having all logic reside locally on the device.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims require only that the server be "remote" and be the source from which the schedule is obtained, suggesting any external server could satisfy the limitation (e.g., ’798 Patent, col. 11:55-58).
- Evidence for a Narrower Interpretation: The specification describes the server as performing specific analytical functions, such as "weighting the obtained environmental data and input data" and "generating a new lighting operating schedule based on a preexisting lighting operating schedule" (’874 Patent, col. 2:39-44). This may support a narrower construction requiring the server to perform these specific generation and analysis steps.
The Term: "interrupt operation" (’798 Patent, Cl. 1)
- Context and Importance: This term defines a key feature of the ’798 Patent. Infringement will require showing that the accused system performs the specific sequence of actions recited in the claim when a user manually overrides an automated setting.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term is not explicitly defined in the specification, which could suggest it should be given its plain and ordinary meaning to one skilled in the art.
- Evidence for a Narrower Interpretation: The claim itself provides a precise, multi-step definition: "suspending execution," "implementing the user change," and "resuming execution" (’798 Patent, col. 12:4-17). This explicit recitation within the claim body provides strong evidence for a narrow construction that requires all three steps to be performed in the manner described. The process is also illustrated in a flowchart (Fig. 7).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement and contributory infringement, asserting that Defendant encourages its customers to infringe by providing instructions on its website and in product manuals on how to use the accused lighting control systems (Compl. ¶13-14, ¶19-20).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported pre-suit knowledge of the patents-in-suit, stemming from notice letters Plaintiff claims to have sent on or around August 13, 2020 (Compl. ¶29).
VII. Analyst’s Conclusion: Key Questions for the Case
- A threshold procedural question will concern the sufficiency of the pleadings. Because the complaint's infringement allegations rely almost entirely on external exhibits that were not provided, the initial phases of litigation may focus on whether the complaint provides sufficient factual matter to state a plausible claim for relief.
- A core issue will be one of definitional scope. The viability of the infringement claims will likely depend on whether the court construes key terms like "remote server" and "lighting operating schedule" broadly to cover general cloud-based lighting control, or narrowly to require the specific data-weighting and schedule-generation functions detailed in the patent specifications.
- For the ’798 Patent, a key technical question will be one of functional equivalence. Does the accused system's response to a user's manual adjustment perform the specific, three-part "interrupt operation" required by Claim 1, or is there a fundamental mismatch in its technical operation that places it outside the scope of the claims?