Ultravision Tech LLC v. ANC Sports Enterprises LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ultravision Technologies, LLC (Delaware)
  • Defendant: ANC Sports Enterprises, L.L.C. (Delaware)
  • Plaintiff’s Counsel: Bayard, P.A.; Brown Rudnick LLP
• Case Identification: 1:18-cv-01031, D. Del., 07/12/2018
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation and is therefore incorporated in the District.
• Core Dispute: Plaintiff alleges that Defendant’s modular LED display panels infringe patents related to the design and construction of waterproof, cabinet-less, modular display panels.
• Technical Context: The technology concerns modular LED panels for large-scale outdoor displays, aiming to replace older, heavier, and more costly cabinet-based systems with a lighter, weatherproof, and more integrated design.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history concerning the patents-in-suit.

Case Timeline

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

U.S. Patent No. 9,349,306 - "Modular Display Panel"

The Invention Explained

• Problem Addressed: The complaint states that prior to the invention, outdoor LED displays were not waterproof and required placement in heavy, sealed cabinets that needed expensive fans or air conditioning systems to prevent overheating (Compl. ¶4). These displays were also not modular, requiring costly bespoke designs and specialized maintenance (Compl. ¶5).
• The Patented Solution: The invention is a self-contained, modular LED display panel designed to be lightweight, waterproof, and assembled into larger displays without requiring a protective outer cabinet (Compl. ¶6). Each panel is described as being hermetically sealed and passively cooled, directly exposed to the environment (’306 Patent, col. 2:5-9). The panel comprises a casing with a recess holding a printed circuit board (PCB), a plurality of LEDs, a driver circuit, a power supply, and a "framework of louvers" over the PCB to protect the LEDs (’306 Patent, Abstract).
• Technical Importance: The complaint alleges this cabinet-less, modular approach "dramatically lowered the customer's total cost of installation and total cost of operation" and "immediately made prior cabinet-based designs obsolete" (Compl. ¶¶6, 9).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶24).
• Claim 1 of the ’306 Patent recites the following essential elements:
  • A casing having a recess, attachment points for multi-panel assembly, and an outer surface that is part of the modular display panel's outer surface
  • A printed circuit board disposed in the recess
  • A plurality of LEDs attached to a front side of the printed circuit board
  • A driver circuit attached to the printed circuit board
  • A power supply unit for powering the LEDs
  • A framework of louvers disposed over the printed circuit board and between rows of the LEDs
  • The modular display panel is sealed to be waterproof
• The complaint alleges infringement of "one or more claims" (Compl. ¶24).

U.S. Patent No. 9,916,782 - "Modular Display Panel"

The Invention Explained

• Problem Addressed: The technology addresses the same problems of cost, weight, weatherproofing, and modularity in large-scale LED displays as the ’306 Patent (Compl. ¶¶3-5).
• The Patented Solution: This patent describes a modular display panel focused on thermal management in a cabinet-less design. The solution comprises a "shell with a first thermally conductive material" and a "second thermally conductive material...disposed between the power supply unit and an outer back side of the panel" (’782 Patent, Abstract). This configuration facilitates passive cooling by conducting heat away from the internal electronics, such as the power supply, to the exterior of the sealed unit (’782 Patent, col. 5:1-7).
• Technical Importance: The technical approach aims to solve the heat dissipation problem inherent in sealed electronic displays without resorting to the costly and heavy fans or air conditioning units used in prior cabinet-based systems (Compl. ¶4).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶38).
• Claim 1 of the ’782 Patent recites the following essential elements:
  • A shell comprising a first thermally conductive material, where the sidewalls of the shell comprise plastic
  • A printed circuit board disposed in the shell
  • A plurality of LEDs attached to a first side of the printed circuit board
  • A driver circuit disposed in the shell and coupled to the LEDs from a second side of the printed circuit board
  • A power supply unit for powering the LEDs, with the printed circuit board disposed between the power supply and the LEDs
  • A second thermally conductive material disposed between the power supply unit and an outer back side of the panel
  • A protective structure disposed over the first side of the printed circuit board
  • The modular display panel is sealed to be waterproof
• The complaint alleges infringement of "one or more claims" (Compl. ¶38).

III. The Accused Instrumentality

Product Identification

• The accused products are identified as "modular LED displays, originally manufactured by manufacturers such as Yaham, then relabeled under the Mitsubishi trade name and ultimately sold by Defendant ANC" (Compl. ¶24, ¶38). The complaint specifically shows an image of a "Yaham product, the D0" (Compl. p. 7).

Functionality and Market Context

• The complaint alleges the accused products are modular, waterproof display panels that embody the features of the patented inventions (Compl. ¶¶25-29, ¶¶39-45). The complaint provides an image showing a front and side view of an accused panel, displaying its modular housing and front LED array (Compl. p. 8). A nearly identical image is provided in the count for the ’782 patent (Compl. p. 10). The complaint alleges that Defendant is among the companies that have "recently entered the market by offering for sale and selling products that infringe the Patents-in-Suit" and are "copying this modular, waterproof design" (Compl. ¶9, ¶11).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,349,306 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the accused product's front-facing protective grid constitutes a "framework of louvers" as that term is used in the patent. The interpretation of this term could be pivotal, depending on whether it is construed broadly to cover any grid structure or narrowly to require specific shading characteristics described in the specification's embodiments.
  • Evidentiary Questions: The complaint's allegations are made "upon information and belief." A key point of contention will be the evidence Plaintiff provides to demonstrate that the accused products, manufactured by a third party (Yaham), contain each claimed element arranged in the required manner.

U.S. Patent No. 9,916,782 Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: The infringement analysis for this patent will likely focus on the materials and construction related to thermal management. Key questions may include: What specific components in the accused product constitute the "first thermally conductive material" and the "second thermally conductive material"? Does the accused product contain two distinct thermally conductive materials arranged in the specific configuration recited in the claim, particularly with one situated between the power supply and the outer back side of the panel?
  • Evidentiary Questions: As with the ’306 Patent, the conclusory allegations made "upon information and belief" raise the question of what factual evidence will be presented to substantiate the internal construction and material composition of the accused products.

V. Key Claim Terms for Construction

• The Term: "framework of louvers" (’306 Patent, claim 1)
• Context and Importance: This structural element is a key differentiator recited in claim 1 of the ’306 Patent. The outcome of the infringement analysis for this patent may depend on whether the accused product’s front protective structure falls within the court’s construction of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language requires the framework be "disposed over the printed circuit board" and "between rows of the LEDs," which could be read to encompass any grid-like structure in that location (’306 Patent, col. 30:22-24). The abstract also uses this general description (’306 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The specification describes embodiments where the louvers "block or minimize light from directly striking the LEDs...from certain angles" and may be configured to "completely shade each pixel" when a light source is at a specific position, suggesting a functional purpose beyond mere protection (’306 Patent, col. 7:8-16). This could support a narrower construction requiring a structure designed for light-shading.
• The Term: "a second thermally conductive material disposed between the power supply unit and an outer back side of the panel" (’782 Patent, claim 1)
• Context and Importance: This term is central to the thermal management solution claimed in the ’782 Patent. Proving infringement will require identifying a distinct component in the accused product that meets this structural and locational limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is broad, potentially covering any material that conducts heat and is placed in the specified location. The specification provides aluminum as just one example of a thermally conductive material (’782 Patent, col. 7:42-44).
  • Evidence for a Narrower Interpretation: Figure 2C of the patent depicts a distinct layer labeled "THERMALLY CONDUCTIVE MATERIAL" (226) situated between the "POWER SUPPLY" (224) and the "BACK OF HOUSING" (220). This illustration of a separate component could support a narrower construction that excludes, for example, a design where the thermally conductive housing itself is the only element behind the power supply.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement for both patents. The basis for this allegation is that Defendant knowingly induces customers and end-users to infringe by "supplying these products to end users for use in an infringing manner" (Compl. ¶32, ¶48).
• Willful Infringement: The complaint does not use the term "willful," but it alleges that Defendant has knowledge of infringement "at least as of the date of this Complaint" (Compl. ¶32, ¶48), which may form a basis for alleging post-suit willful infringement. The prayer for relief requests enhanced damages pursuant to 35 U.S.C. § 284 and a declaration that the case is exceptional under 35 U.S.C. § 285 (Compl. p. 13, ¶c-d).

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

The dispute appears to center on highly specific aspects of modular LED panel construction. The case will likely turn on the following key questions:

• A core issue will be one of claim scope and construction: For the ’306 patent, can the term "framework of louvers," which is described in the specification with a light-shading function, be construed to cover the accused product's general protective grid?
• A second core issue will be one of factual evidence: For the ’782 patent, does the accused product, as manufactured by a third party, contain both a "first" and a distinct "second" thermally conductive material arranged in the precise configuration relative to the power supply and shell as required by the claim? The conclusory nature of the complaint suggests this will be a central battleground in discovery.
• A final question will be one of intent: What evidence, beyond the filing of the complaint itself, can Plaintiff produce to demonstrate that Defendant possessed the specific intent required to support the allegations of induced infringement?