Launchip LLC v. Houzz Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Launchip LLC (Texas)
  • Defendant: Houzz Inc. (Delaware)
  • Plaintiff’s Counsel: O'KELLY & ERNEST, LLC
• Case Identification: 1:20-cv-00287, D. Del., 02/26/2020
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation and is therefore deemed a resident of the district.
• Core Dispute: Plaintiff alleges that Defendant’s dual-color LED light string infringes patents related to methods for electronically controlling variable color effects in lighting systems.
• Technical Context: The technology at issue concerns electronic controllers for multi-color light-emitting diode (LED) strings, a product category common in the decorative and festive lighting market.
• Key Procedural History: The '206 Patent is a continuation of the application that resulted in the '275 Patent. The complaint contains a notable inconsistency, identifying the plaintiff as "Launchip LLC" in the caption and parties section, but as "Encoditech LLC" in the prayer for relief.

Case Timeline

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

U.S. Patent No. 8,203,275 - "Variable-Effect Lighting System"

• Patent Identification: U.S. Patent No. 8,203,275, "Variable-Effect Lighting System", issued June 19, 2012.

The Invention Explained

• Problem Addressed: The patent's background section describes a need for a "relatively simple variable-effect lighting system which allows for greater variation in the range of colour displays" than was available from prior art systems, which were often either too basic or overly complex ('275 Patent, col. 2:6-8).
• The Patented Solution: The invention covers a lighting system where multiple multi-color lamps are connected in series to an AC power source. A lamp controller varies the displayed color by adjusting the "conduction interval" of different illuminating elements within the lamps. Claim 11, specifically, describes a controller that performs this variation in response to an "external digital signal input," which also allows the controller to adjust the speed of the color change ('275 Patent, Abstract; col. 29:46-30:11).
• Technical Importance: This patented approach enables sophisticated, externally-driven control over decorative light strings, potentially allowing synchronization with external systems like those used for stage or architectural lighting ('275 Patent, col. 29:46-30:11).

Key Claims at a Glance

• The complaint asserts independent claim 11 (Compl. ¶10).
• The essential elements of independent claim 11 are:
  • A lamp assembly with a plurality of multi-colored lamps connected in series with an AC voltage source, where each lamp has at least a first and a second illuminating element for producing different colors.
  • A lamp controller that varies the color produced by the lamps by varying a conduction interval of each illuminating element "according to an external digital signal input to the lamp controller."
  • The lamp controller is also configured to "adjust a speed of the colour variation based on the external signal input."

U.S. Patent No. 8,390,206 - "Variable-Effect Lighting System"

• Patent Identification: U.S. Patent No. 8,390,206, "Variable-Effect Lighting System", issued March 5, 2013.

The Invention Explained

• Problem Addressed: The patent addresses the problem that lighting controllers with fixed timing assumptions will produce "unpredictable results" and incorrect colors if the frequency of the AC voltage source differs from the expected value (e.g., 50 Hz vs. 60 Hz) ('206 Patent, col. 14:56-col. 15:24).
• The Patented Solution: The invention is a controller that self-calibrates by actively measuring the frequency of the AC voltage source and then "adjust[s] the current draw" of the light-emitting elements "in accordance with the voltage frequency." This ensures consistent and predictable color effects regardless of fluctuations in the power source frequency ('206 Patent, Abstract; col. 15:26-col. 16:16).
• Technical Importance: This method of self-calibration based on the actual power line frequency makes the lighting system's effects more robust and reliable across different electrical grids or under variable power conditions ('206 Patent, col. 15:26-col. 16:16).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶15).
• The essential elements of independent claim 1 are:
  • A lamp assembly with a plurality of multi-colored lamps connected in series with an AC voltage source, where the source has a frequency and each lamp has at least a first and second illuminating element.
  • 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."

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is the product identified as "ls21-801-70" and described as the "70 Bulb Dual Color LED Light String Starter Set - 9 Function" (Compl. ¶10, ¶15).

Functionality and Market Context

• The complaint alleges the product is a "variable-effect lighting system" (Compl. ¶10, ¶15). The product's descriptive name suggests it is a string of 70 LED bulbs capable of producing at least two colors and featuring nine pre-set operational modes or functions. The complaint does not provide further detail for analysis of the product's technical operation or its market position. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim chart exhibits, but these exhibits were not included with the complaint document. The following analysis is based on the narrative allegations.

'275 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Question: A primary evidentiary question is whether the Accused Product's controller operates "according to an external digital signal input." The complaint provides no facts to support this allegation, and the product's name ("9 Function") may suggest a self-contained unit with pre-programmed modes rather than one controlled by an external signal.
  • Scope Question: The infringement analysis may turn on the construction of "external digital signal input." A key question will be whether this term requires a data communications protocol (e.g., DMX) or if it could be interpreted to cover a user's interaction with a function-selection button on the product itself.

'206 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Question: The central dispute will likely focus on whether the Accused Product's controller performs the core inventive function of the '206 Patent. The complaint does not provide any evidence that the product actually measures the AC "voltage frequency" and "adjust[s] the current draw" in response to that measurement.

V. Key Claim Terms for Construction

• Term from '275 Patent: "external digital signal input"

  • Context and Importance: This term is dispositive for infringement of asserted claim 11. Practitioners may focus on this term because the Accused Product's name ("9 Function") suggests it uses internal, pre-set modes, raising the question of whether it receives any "external" input as required by the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not define the term or limit it to a specific protocol in the text of claim 11 itself, which a plaintiff may argue allows it to encompass any digital signal originating outside the controller's main processing chip.
    • Evidence for a Narrower Interpretation: The specification distinguishes between a "user-operable input" (e.g., a switch) in other claims and the "external signal input" of claim 11, suggesting they are different things ('275 Patent, col. 27:51-54 vs. col. 30:6-8). A defendant may argue this context implies a formal data signal, not a simple user switch.

• Term from '206 Patent: "adjust the current draw in accordance with the voltage frequency"

  • Context and Importance: This phrase captures the essence of the '206 Patent's claimed invention. Infringement hinges on proving the Accused Product performs this specific self-calibration function.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language does not specify the method of adjustment. A plaintiff could argue that any circuit design that inherently compensates for frequency changes, even indirectly, meets this limitation.
    • Evidence for a Narrower Interpretation: The specification describes a specific implementation where the controller measures the time between zero-crossings of the AC signal to calculate the frequency and then uses that value to correct the timing of the control signals ('206 Patent, col. 15:26-col. 16:16). A defendant will likely argue that the claim should be limited to this disclosed mechanism.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of indirect or induced infringement.
• Willful Infringement: The complaint does not contain allegations of willful infringement.

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

This case appears to present several fundamental questions of proof and claim scope. The resolution of the dispute may turn on the following issues:

1. A core issue for the '275 Patent will be one of definitional scope: can the claim term "external digital signal input" be construed to read on the function-selection mechanism of a self-contained decorative light string, or does it require a more sophisticated data input from a separate device?
2. A key evidentiary question for the '206 Patent will be one of functional proof: what evidence will Plaintiff be able to marshal to demonstrate that the Accused Product performs the specific technical function of measuring the AC power frequency and adjusting its operation "in accordance" with that measurement?
3. A threshold issue for the entire case may be pleading sufficiency: given the absence of the referenced claim chart exhibits and the lack of specific factual allegations mapping product features to claim elements, a court may have to determine if the complaint's conclusory allegations of infringement meet the plausibility standard required to proceed.