DCT
3:17-cv-00792
Light Sources Inc v. First Light Tech Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Light Sources, Inc. (Connecticut)
- Defendant: First Light Technologies, Inc. (Vermont)
- Plaintiff’s Counsel: Cantor Colburn LLP
- Case Identification: 3:17-cv-00792, D. Conn., 05/15/2017
- Venue Allegations: Venue is alleged to be proper in the District of Connecticut because the Defendant transacts business and/or has committed acts of infringement within the judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s replacement ultraviolet (UV) lamps infringe a patent directed to a specific lamp base design that ensures a secure and properly oriented electrical connection.
- Technical Context: The technology concerns the mechanical and electrical interface for high-intensity lamps, such as those used in water purification systems, where a reliable connection is critical for both consistent performance and operational safety.
- Key Procedural History: The complaint does not reference any prior litigation between the parties, proceedings before the Patent Trial and Appeal Board, or prior licensing history concerning the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2006-02-27 | '505 Patent Priority Date |
| 2009-10-20 | '505 Patent Issue Date |
| 2017-05-15 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,604,505, “Ultraviolet Lamp for Use in Water Purifiers,” issued October 20, 2009
The Invention Explained
- Problem Addressed: The patent addresses problems with prior art electrical connectors for UV lamps used in environments like water purifiers. In such applications, vibration can cause conventional "slide into place" connectors to become loose, leading to intermittent lamp operation and potentially incomplete water disinfection. Furthermore, the patent notes a need for systems that prevent the use of improperly matched lamps (e.g., wrong wattage) for safety reasons. (’505 Patent, col. 3:18-28, 3:45-48).
- The Patented Solution: The invention is a lamp base with a specific physical geometry designed for a secure, keyed connection with a corresponding socket. The base includes two distinct "step portions" on opposite sides, creating a central recess. Each step portion has a "raised face" from which an upper electrical pin connector extends. Additional lower pin connectors are located on the main end surface. This multi-level, asymmetric structure is intended to ensure a stable, properly aligned, and uniquely matched coupling. (’505 Patent, Abstract; Fig. 47).
- Technical Importance: This design approach aims to enhance the reliability and safety of replaceable UV lamps by creating a more robust physical and electrical interface that resists disconnection from vibration and helps ensure only compatible lamps are installed. (’505 Patent, col. 3:49-57).
Key Claims at a Glance
- The complaint asserts at least independent claim 1. The essential elements of claim 1 are:
- A lamp base for a lamp bulb, designed to couple with a socket.
- A cylindrical body with an end surface.
- A first step portion and a second step portion, each having a flat face perpendicular to the end surface and a raised face perpendicular to the flat face.
- A first upper pin connector on the raised face of the first step portion, extending perpendicular to the first step portion.
- A second upper pin connector on the raised face of the second step portion, extending perpendicular to the first step portion.
- A first and second lower pin connector on the end surface, extending perpendicular to it.
- The first and second step portions are arranged on opposite sides of the base to define a central recess between them.
III. The Accused Instrumentality
- Product Identification: The complaint identifies the accused instrumentalities as the "21000810-UV Replacement UV Lamp 254NM" and the "RL-210HO-UV Replacement UV Lamp 254NM," collectively referred to as the "UV Replacement Lamps" (Compl. ¶9).
- Functionality and Market Context: The accused instrumentalities are replacement UV lamps marketed for use in water purification systems (Compl. ¶9). The complaint alleges these lamps incorporate a specific base structure that includes a cylindrical body, first and second step portions with associated flat and raised faces, four electrical pin connectors, and a central recess formed between the step portions (Compl. ¶10). The complaint further alleges these products are offered for sale and sold within the judicial district and elsewhere through online retailers (Compl. ¶11). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’505 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a lamp base to be fitted on an end of a lamp bulb and designed to couple with a socket... | The UV Replacement Lamps consist of a lamp base to be fitted on an end of a lamp bulb and designed to couple with a socket. | ¶10 | col. 11:35-37 |
| a cylindrical body having an end surface; | The lamp bases comprise a cylindrical body having an end surface. | ¶10 | col. 11:38-39 |
| a first step portion and a second step portion, each comprising a flat face extending perpendicular to the end surface, and a raised face that is perpendicular to the flat face; | The lamps have a first step portion and a second step portion, each comprising a flat face extending perpendicular to the end surface, and they further have a raised face that is perpendicular to the flat face. | ¶10 | col. 11:40-43 |
| a first upper pin connector provided on the raised face of the first step portion and extending perpendicular to the first step portion; | The lamps have a first upper pin connector provided on the raised face of the first step portion and extending perpendicular to the first step portion. | ¶10 | col. 11:44-47 |
| a second upper pin connector provided on the raised face of the second step portion and extending perpendicular to the first step portion; | The lamps have a second upper pin connector provided on the raised face of the second step portion and extending perpendicular to the first step portion. | ¶10 | col. 11:48-51 |
| a first and second lower pin connector provided on the end surface and extending perpendicular to the end surface; | The lamps have a first and second lower pin connector provided on the end surface and extending perpendicular to the end surface. | ¶10 | col. 11:52-54 |
| wherein the first step portion and the second step portion arranged on opposite sides of the lamp base so as to define a central recess... | The first step portion and the second step portion are arranged on opposite sides of the lamp base so as to define a central recess between the first step portion and the second step portion. | ¶10 | col. 11:55-59 |
- Identified Points of Contention:
- Scope Question: A primary issue for claim construction may arise from the language requiring the "second upper pin connector" to extend "perpendicular to the first step portion." A literal reading of this limitation appears unusual from a mechanical design standpoint and inconsistent with the parallel structure for the first pin. This raises the question of whether this is a definitive limitation or a potential scrivener's error that the patentee might argue should be interpreted as "second step portion."
- Technical Question: The complaint provides a conclusory mapping of the accused products to the claim language. A central factual dispute will likely be whether the physical structures of the accused lamps actually meet the specific geometric and relational limitations of claim 1 (e.g., the precise configuration of the "flat face" and "raised face," and the required perpendicularity of the various components).
V. Key Claim Terms for Construction
The Term: "a first step portion and a second step portion, each comprising a flat face ... and a raised face that is perpendicular to the flat face"
- Context and Importance: The definition of this compound term is critical, as the entire keyed structure of the patented base depends on this specific geometry. Infringement will depend on whether the defendant's lamp base has a structure that can be properly characterized as having both a "flat face" and a "raised face" with the claimed perpendicular relationship.
- Evidence for a Broader Interpretation: A party seeking a broader construction may argue that any structure that creates two distinct levels on the base, where one is elevated relative to the other, meets the "step" limitation, without being confined to a specific shape.
- Evidence for a Narrower Interpretation: A party seeking a narrower construction may point to the specific embodiments in the patent, such as Figure 48, which shows distinct, planar "flat faces" (220b, 222b) and "raised faces" (220c, 222c). An argument could be made that the term should be limited to the geometric configurations expressly disclosed.
The Term: "extending perpendicular to the first step portion" (as applied to the second upper pin connector)
- Context and Importance: Practitioners may focus on this term because its literal interpretation is technically ambiguous and potentially dispositive of infringement. The construction of this phrase will determine the scope of a key structural limitation of the claim.
- Evidence for a Broader Interpretation (or Correction): A party might argue this is a clear drafting error, pointing to the parallel language for the first pin connector ("extending perpendicular to the first step portion") and the description in the specification that shows the second pin (214) extending from the second step portion. They may argue the term should be construed to mean "extending perpendicular to the second step portion" to give effect to the invention's clear intent. (’505 Patent, col. 8:63-65).
- Evidence for a Narrower Interpretation (Literal Reading): A party could argue for a strict, literal interpretation, requiring the second pin to be geometrically perpendicular to a plane defined by the first step portion. If the accused device does not meet this literal requirement, it would not infringe, regardless of whether the language appears to be an error.
VI. Other Allegations
- Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement. The allegations focus exclusively on direct infringement through acts of making, using, selling, and importing the accused lamps (Compl. ¶9, 14).
- Willful Infringement: The complaint alleges that the defendant's infringement "has been and continues to be knowing, willful, and objectively reckless" (Compl. ¶15). The pleading does not allege any facts indicating pre-suit knowledge, suggesting the willfulness claim is based on notice provided by the filing of the lawsuit itself.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction: can the phrase "extending perpendicular to the first step portion", as it applies to the second pin connector, be interpreted as a scrivener's error that the court may effectively correct, or must it be read literally as a potentially fatal-to-infringement limitation?
- A key evidentiary question will be one of structural correspondence: will the plaintiff be able to demonstrate, with sufficient factual evidence, that the physical geometry of the accused lamp bases precisely matches the multi-part definitions of the claimed "step portion" and the specific perpendicular relationships between its various surfaces and connectors?