BridgeComm LLC v. Ollny Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: BridgeComm LLC (Texas)
  • Defendant: Ollny Inc. (Colorado)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-01365, D. Colo., 04/30/2025
• Venue Allegations: Venue is alleged to be proper in the District of Colorado because the Defendant has an established place of business in the district, has allegedly committed acts of patent infringement there, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s variable-effect lighting products infringe patents related to controlling the color output of multi-colored LED systems.
• Technical Context: The technology concerns electronic control systems for decorative lighting, such as Christmas lights, that create variable color effects by precisely managing power delivery to light-emitting diodes (LEDs).
• Key Procedural History: The U.S. Patent No. 8,390,206 is a continuation of the application that resulted in U.S. Patent No. 8,203,275. No other significant procedural events are mentioned in the complaint.

Case Timeline

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

U.S. Patent No. 8,203,275 - “Variable-effect lighting system”

The Invention Explained

• Problem Addressed: The patent describes a need for a "relatively simple variable-effect lighting system which allows for greater variation in the range of colour displays" than was previously available, noting that prior art systems were often complex or limited in their ability to produce intricate color displays (’275 Patent, col. 2:6-8).
• The Patented Solution: The invention is a lighting system where multiple multi-colored lamps (e.g., pairs of back-to-back LEDs of different colors) are connected in series to an AC power source (’275 Patent, col. 3:51-63). A microcontroller varies the color output by adjusting the "conduction interval" for each colored illuminating element during each half-cycle of the AC power, thereby creating smooth transitions between colors (’275 Patent, col. 2:21-24, Fig. 1a). The system is also configured to stop the color variation based on a user command and store the setting (’275 Patent, Abstract).
• Technical Importance: This approach allows for complex, dynamic color-changing effects in lighting strings (like decorative holiday lights) using a simple series circuit, which avoids more complex wiring and power distribution schemes (’275 Patent, col. 3:4-7).

Key Claims at a Glance

• The complaint asserts "exemplary claims" without specifying claim numbers (Compl. ¶12). Independent claim 1 is representative.
• Independent Claim 1: A variable-effect lighting system comprising:
  • A lamp assembly with a plurality of multi-colored lamps connected in series with an AC voltage source.
  • Each lamp has a first and second illuminating element for producing two different colors.
  • A lamp controller that varies the color by varying the "conduction interval" of each illuminating element according to a predetermined pattern.
  • The controller is configured to "terminate the variation upon activation of a user-operable input to the controller."
  • The controller includes non-volatile memory and is configured to retain a "datum associated with the conduction interval" when the user activates the input, and to use that retained setting upon re-application of power.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,390,206 - “Variable-effect lighting system”

The Invention Explained

• Problem Addressed: The patent addresses the same general problem as the ’275 Patent: the need for a simple yet versatile variable-effect lighting system (’206 Patent, col. 2:6-10). It also implicitly addresses the problem of inconsistent performance if the AC power frequency deviates from its expected value (’206 Patent, col. 11:56-12:15).
• The Patented Solution: The system is structurally similar to that described in the ’275 Patent, using series-connected, multi-colored lamps on an AC source (’206 Patent, Fig. 1a). The key feature highlighted in the asserted claims is the controller's ability to "control the current draw of each said illuminating element" and "adjust the current draw in accordance with the frequency of the voltage source" (’206 Patent, Abstract). This is achieved by measuring the time between zero-crossings of the AC waveform to determine the actual frequency and then calculating the appropriate conduction intervals based on that measurement (’206 Patent, col. 12:1-12).
• Technical Importance: By adjusting to the actual AC frequency, the system can maintain consistent and predictable color-changing patterns even if the power source frequency is unstable or different from a standard value (e.g., 50 Hz vs. 60 Hz), ensuring synchronized effects (’206 Patent, col. 12:62-66).

Key Claims at a Glance

• The complaint asserts "exemplary claims" without specifying claim numbers (Compl. ¶21). Independent claim 1 is representative.
• Independent Claim 1: A variable-effect lighting system comprising:
  • A lamp assembly with a plurality of multi-colored lamps connected in series with an AC voltage source having a frequency.
  • Each lamp has a first and second illuminating element for producing two different colors.
  • A lamp controller coupled to the assembly for "controlling a current draw of each said illuminating element."
  • The controller is configured to "adjust the current draw in accordance with the voltage frequency."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint refers generally to "Exemplary Defendant Products" identified in charts incorporated by reference as Exhibits 3 and 4 (Compl. ¶¶12, 17, 21). The specific product names or models are not identified in the body of the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context, as these details are presumably contained within the unprovided exhibits (Compl. ¶¶18, 27). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement but incorporates the specific comparisons into Exhibits 3 and 4, which were not filed with the public complaint (Compl. ¶¶18, 27). Therefore, a detailed claim chart summary cannot be constructed from the provided documents.

• Identified Points of Contention:
  • ’275 Patent: A central question may be whether the accused products contain a controller that performs the specific functions of (1) "terminat[ing] the variation" of the light effect upon a user command and (2) retaining a "datum associated with the conduction interval" in non-volatile memory to restore that specific state after a power cycle, as required by claim 1. The dispute may focus on whether a simple on/off or mode-select function in the accused products meets these specific limitations.
  • ’206 Patent: The infringement analysis for the ’206 Patent will likely focus on the claim limitation requiring the controller to "adjust the current draw in accordance with the voltage frequency." A technical question for the court will be whether the accused products' controller actually measures the AC line frequency and adjusts its timing calculations accordingly, or if it merely operates on a fixed, assumed frequency (e.g., 60 Hz). Evidence of the accused controller's specific algorithm will be critical.

V. Key Claim Terms for Construction

• For the ’275 Patent:

  • The Term: "terminate the variation upon activation of a user-operable input"
  • Context and Importance: This term is central to the user-interaction feature of claim 1. Its construction will determine what kind of user control mechanism infringes. Practitioners may focus on this term because it distinguishes the claimed invention from a system that simply cycles through patterns without a "pause" or "set" function.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain meaning of "terminate" could arguably cover any user action that stops the changing color pattern, even if it resets to a default state.
    • Evidence for a Narrower Interpretation: The specification describes this feature as enabling a user to "fix or set the colour or intensity produced by the lamp assembly as desired" and keeping the conduction angles "steady" (’275 Patent, col. 15:16-19, col. 15:7). This language, especially when read in concert with the non-volatile memory limitation, suggests that "terminate" means to pause on the current color/intensity and hold it.

• For the ’206 Patent:

  • The Term: "adjust the current draw in accordance with the voltage frequency"
  • Context and Importance: This is the core functional limitation of independent claim 1 of the ’206 Patent. The case may turn on whether the accused products perform this specific type of environmental adaptation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that any system whose timing is inherently tied to the AC frequency (e.g., by using zero-crossings as a timing reference) is "in accordance with" the frequency, even if no explicit measurement or calculation occurs.
    • Evidence for a Narrower Interpretation: The specification provides a specific method for implementing this feature: "measures the period of time between instances of zero voltage crossings of the AC source voltage, and uses the calculated period to calculate the line frequency" to "accurately track the actual conduction interval" (’206 Patent, col. 11:66-12:6). This suggests "adjust... in accordance with" requires an active process of measurement and calculation to correct for frequency variations, not merely using the frequency as a clock source.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" both the ’275 and ’206 Patents (Compl. ¶¶15, 24).
• Willful Infringement: The complaint alleges knowledge of the patents and infringement "at least since being served by this Complaint" (Compl. ¶¶16, 25). This forms the basis for a claim of post-filing willful infringement.

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

1. A core issue for the ’275 Patent will be one of functional specificity: Do the accused products’ user controls merely select a pre-set mode, or do they perform the claimed function of "terminating" an active color variation to "set" a specific, arbitrary state and retain it in memory as described in the patent?

2. A key evidentiary question for the ’206 Patent will be one of operational capability: Does the controller in the accused products contain the specific logic to measure the AC power frequency and "adjust" its timing calculations "in accordance with" that measurement, or does it operate on a fixed-timing assumption, rendering it insensitive to frequency variations?

3. Given the complaint’s reliance on unprovided exhibits for its infringement contentions, a preliminary question will be whether the allegations in the complaint body alone are sufficient to meet federal pleading standards, or if the details in the exhibits are necessary to state a plausible claim for relief.