Launchip LLC v. CTC Triangle USA Ec LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Launchip LLC (Texas)
  • Defendant: CTC Triangle (USA) EC LLC (Delaware) and CTC Triangle (USA) LLC (Washington)
  • Plaintiff’s Counsel: Chong Law Firm PA; Sand, Sebolt & Wernow Co., LPA
• Case Identification: 1:22-cv-00995, D. Del., 07/28/2022
• Venue Allegations: Plaintiff alleges venue is proper because Defendants have committed acts of patent infringement in the District of Delaware and have an established place of business in the district, either directly or through a related entity under common control.
• Core Dispute: Plaintiff alleges that Defendant’s variable-effect lighting products infringe two patents related to methods for controlling multi-color light strings powered by an AC voltage source.
• Technical Context: The technology concerns programmable decorative lighting systems, such as LED Christmas lights, that can produce a variety of color-changing effects and respond to user or external inputs.
• Key Procedural History: U.S. Patent No. 8,390,206 is a continuation of the application that resulted in U.S. Patent No. 8,203,275, and both patents share a common specification. The complaint does not mention any prior litigation, licensing history, or administrative proceedings related to the patents-in-suit.

Case Timeline

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

U.S. Patent No. 8,203,275, “Variable-effect lighting system,” issued June 19, 2012.

The Invention Explained

• Problem Addressed: The patent describes prior art variable-effect lighting systems as being either too limited in the range of producible color displays or reliant on complex and costly control units ('275 Patent, col. 1:12-2:10). The goal was to create a "relatively simple" system capable of generating a greater variation of color effects ('275 Patent, col. 2:7-10).
• The Patented Solution: The invention is a lighting system, such as a string of decorative lights, comprising multiple multi-colored lamps (e.g., back-to-back red and green LEDs) connected in series to an AC power source ('275 Patent, col. 3:50-65). A lamp controller is configured to vary the color output by adjusting the "conduction interval"—the amount of time each color element is turned on during an AC cycle—based on a predetermined pattern or an external signal ('275 Patent, Abstract; Fig. 1a). This allows for smooth transitions between colors like red, amber, and green ('275 Patent, col. 5:1-3).
• Technical Importance: The technology provides a cost-effective method for creating dynamic, programmable color effects in mass-market lighting products by precisely controlling power delivery from a standard AC source.

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 11 (Compl. ¶19).
• Essential elements of Claim 11 include:
  • A lamp assembly with a plurality of multi-colored lamps connected in series with an AC voltage source.
  • Each lamp having a first illuminating element (first color) and a second illuminating element (second color).
  • A lamp controller that varies the color by changing the conduction interval of each illuminating element "according to an external digital signal input to the lamp controller."
  • The controller is also "configured to adjust a speed of the colour variation based on the external signal input."
• The complaint alleges infringement of "one or more claims," reserving the right to assert additional claims (Compl. ¶19).

U.S. Patent No. 8,390,206, “Variable-effect lighting system,” issued March 5, 2013.

The Invention Explained

• Problem Addressed: As a continuation of the '275 patent's application, this patent addresses the same general problem of creating simple, variable-effect lighting systems ('206 Patent, col. 1:21-2:10). It further addresses the technical challenge of inconsistent performance caused by real-world fluctuations in the frequency of the AC power source, which could disrupt the timing of color effects ('206 Patent, col. 11:46-12:10).
• The Patented Solution: The solution is a lamp controller that actively adapts to changes in the power supply. The controller is configured to measure the period between zero-crossings of the AC voltage waveform to calculate the actual line frequency ('206 Patent, col. 11:28-34). It then uses this measurement to "adjust the current draw" of the light-emitting elements, ensuring that the intended color patterns are produced accurately despite variations in the source frequency ('206 Patent, Abstract).
• Technical Importance: This invention introduces a self-correction mechanism into lighting controllers, making them more robust and reliable by enabling them to maintain consistent visual effects even when supplied with an unstable AC power source.

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶30).
• Essential elements of Claim 1 include:
  • A lamp assembly with a plurality of multi-colored lamps connected in series with an AC voltage source that has a frequency.
  • Each lamp having a first and second illuminating element for producing two different colors.
  • A lamp controller for controlling a current draw of each illuminating element.
  • The controller is "configured to adjust the current draw in accordance with the voltage frequency."
• The complaint alleges infringement of "one or more claims," reserving the right to assert additional claims (Compl. ¶30).

III. The Accused Instrumentality

Product Identification

• The "Noma Advanced Constant Lit: RL-08" lighting product is identified as an exemplary accused product (Compl. ¶15).

Functionality and Market Context

• The complaint describes the accused product as a "variable effect lighting system" (Compl. ¶15). It does not provide any specific technical details regarding the product's components, control mechanisms, or operational modes. No allegations are made regarding the product's commercial importance or market position.
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits 3 and 4) that were not provided with the publicly filed document (Compl. ¶16, ¶17). The infringement allegations are therefore summarized based on the complaint's narrative.

• ’275 Patent Infringement Allegations: The complaint alleges that the Accused Products directly infringe at least Claim 11 of the '275 patent (Compl. ¶19). It asserts that, as detailed in the missing Exhibit 3, the Accused Products "practice the technology claimed" and "satisfy all elements" of the asserted claims (Compl. ¶26). The complaint does not provide a specific, element-by-element breakdown of its infringement theory in its narrative section.

• ’206 Patent Infringement Allegations: The complaint alleges that the Accused Products directly infringe at least Claim 1 of the ’206 patent (Compl. ¶30). It states that the missing Exhibit 4 contains charts demonstrating that the Accused Products "practice the technology claimed" by the patent and "satisfy all elements" of the asserted claims (Compl. ¶36). The complaint's narrative does not contain a detailed, element-by-element infringement analysis.

• Identified Points of Contention:

  • Scope Questions ('275 Patent): A central dispute for the '275 patent will likely concern the claim term "external digital signal input." The case raises the question of what type of interface meets this limitation. The court may need to determine if a simple user-operated button or proprietary remote control signal, for example, qualifies as an "external digital signal input" in the context of the patent, or if the term requires a more complex data input like a DMX signal.
  • Technical Questions ('206 Patent): For the ’206 patent, the core technical question is whether the accused product’s controller performs the specific function of being "configured to adjust the current draw in accordance with the voltage frequency." The complaint provides no evidence on this point. A key dispute will be whether the accused controller merely synchronizes its timing to the AC line's zero-crossings (a common technique) or if it actively measures the line frequency and makes corresponding adjustments to its output, as the claim appears to require.

V. Key Claim Terms for Construction

• The Term: "external digital signal input" ('275 Patent, Claim 11)

  • Context and Importance: This term's construction is critical for the '275 patent. A narrow construction (e.g., requiring a standardized data protocol) could allow the defendant to design around the claim, while a broad construction (e.g., covering any non-analog user input) would make infringement easier to allege. Practitioners may focus on this term because it distinguishes the claimed invention from systems with only a simple, pre-programmed cycle-selection button.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification does not define the term or limit it to a specific protocol in the main embodiments, which may support a broader construction covering any form of digital command.
    • Evidence for a Narrower Interpretation: The specification elsewhere discloses the use of a "DMX signal" to control lighting effects ('275 Patent, col. 25:39-42). A party could argue this context suggests "external digital signal" was intended to mean a data-rich communications signal, not a simple command from a switch or button.

• The Term: "adjust the current draw in accordance with the voltage frequency" ('206 Patent, Claim 1)

  • Context and Importance: This phrase captures the asserted novelty of the ’206 patent. The infringement analysis will depend entirely on whether the accused product performs this specific, active adaptation. The dispute will be factual and technical: does the accused controller simply run on a fixed timer synchronized to the power line, or does it contain the logic to measure frequency and actively "adjust" its behavior in response?
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that any controller that uses the AC line's zero crossings for timing is inherently operating "in accordance with the voltage frequency," suggesting a broader scope.
    • Evidence for a Narrower Interpretation: The specification describes a specific process: "measures the period of time between instances of zero voltage crossings ... and uses the calculated period to calculate the line frequency" in order to "accurately track the actual conduction interval" ('206 Patent, col. 11:28-12:4). This language suggests a narrow construction requiring an explicit measurement and calculation loop, not just passive synchronization.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for both patents. The inducement claim is based on allegations that Defendants distribute "product literature and website materials" that instruct customers on how to use the products in an infringing manner (Compl. ¶23-24, ¶33-34). The contributory infringement claim alleges the products are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶25, ¶35).
• Willful Infringement: The complaint does not use the term "willful," but it alleges that service of the complaint provides "actual knowledge" of infringement and that Defendants' infringing activities have continued despite this knowledge (Compl. ¶22-23, ¶32-33). This forms a basis for post-filing willfulness. The prayer for relief seeks enhanced damages and attorneys' fees, which are remedies associated with findings of willful infringement or exceptional case status (Compl. ¶F.i).

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

1. A core issue will be one of claim construction: can the term "external digital signal input" in the '275 patent be interpreted to cover the specific control interface of the accused "Noma" product, or is the product's functionality outside the scope of the claim language as properly construed?
2. A key evidentiary question will be one of technical operation: does the accused product's controller perform the specific function of measuring the AC "voltage frequency" and actively "adjusting" its output as required by the '206 patent, or does it use a simpler timing mechanism that does not meet this limitation? Proving this will likely require detailed technical evidence from reverse engineering.
3. A central procedural question will be the sufficiency of the infringement contentions. Given the highly generic allegations in the complaint, the case's viability will depend on the specific evidence and theories articulated in the (currently unavailable) claim charts and developed during discovery.