DCT

1:23-cv-00381

Cedar Lane Tech Inc v. Hubbell Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-00381, D. Del., 04/04/2023
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in Delaware, has an established place of business in the District, and has committed alleged acts of infringement in the District.
  • Core Dispute: Plaintiff alleges that Defendant’s lighting products infringe a patent related to lighting devices with multiple power sources and distinct operational modes for normal and emergency use.
  • Technical Context: The technology concerns lighting fixtures, such as LED-based bulbs, designed to provide continuous illumination, often for safety or egress, even during a primary power failure by switching to a secondary power source.
  • Key Procedural History: The patent-in-suit is a continuation of a prior application that has since issued as a patent. The patent's term is subject to a terminal disclaimer, which may limit its expiration date to that of the parent patent.

Case Timeline

Date Event
2006-03-13 ’159 Patent Priority Date (via application 11/374,545)
2007-05-14 ’159 Patent Application Filing Date
2008-06-24 ’159 Patent Issue Date
2023-04-03 Complaint Dated
2023-04-04 Complaint Filing Date

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

U.S. Patent No. 7,391,159 - Lighting device with multiple power sources and multiple modes of operation, issued June 24, 2008

The Invention Explained

  • Problem Addressed: The patent addresses the problem that conventional lighting devices cease to function during a power failure, which can be "problematic in many situations where continued lighting may be desired" for safety or emergency purposes (’159 Patent, col. 2:21-30).
  • The Patented Solution: The invention is a self-contained lighting device, such as a light bulb, that includes both a primary connection to a main power source (e.g., AC power) and a secondary, internal power source like a battery (’159 Patent, col. 4:51-57, col. 3:25-28). A controller within the device manages two distinct modes of operation: a "normal operation" mode powered by the main source and a "backup operation" mode powered by the battery when the main power is lost (’159 Patent, Fig. 3). This allows the device to provide illumination, potentially at a reduced level or for a limited time, during a power outage (’159 Patent, col. 7:1-9).
  • Technical Importance: The invention describes consolidating emergency backup lighting functionality, which was often handled by separate, dedicated systems, into a standard form-factor lighting device (e.g., a screw-in bulb) that can be retrofitted into existing fixtures (’159 Patent, col. 4:60-65).

Key Claims at a Glance

  • The complaint alleges infringement of "one or more claims" without specifying them (Compl. ¶11). Claim 1 is the first independent claim of the patent.
  • Essential elements of Independent Claim 1 include:
    • A number of light sources mounted on a common printed circuit board (PCB).
    • A controller for distributing power from a main power source and a secondary battery power source.
    • Power distribution occurs according to a "first mode" (non-emergency) and a "second mode" (emergency).
    • A battery for powering the light sources in the second mode.
    • A housing defining a common enclosure for the components.
  • The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of the patent's claims (Compl. ¶11).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" but does not name specific products (Compl. ¶11).
  • Functionality and Market Context: The complaint does not provide any technical description of the accused products' features or functions. Instead, it states that claim charts comparing the patent claims to the "Exemplary Defendant Products" are included in an Exhibit 2 (Compl. ¶16). This exhibit was not filed with the complaint. The complaint alleges that Defendant makes, uses, sells, and imports these products and that its employees internally test and use them (Compl. ¶11-12).

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or detailed infringement allegations in its body. It incorporates by reference an external "Exhibit 2," which was not publicly filed with the complaint, alleging that this exhibit contains charts demonstrating infringement (Compl. ¶16-17). The narrative theory is that the "Exemplary Defendant Products practice the technology claimed by the ’159 Patent" and "satisfy all elements of the Exemplary ’159 Patent Claims" (Compl. ¶16). Without access to the referenced exhibit, a detailed element-by-element analysis is not possible.

  • Identified Points of Contention:
    • Scope Questions: A central question will be whether the accused products' operations map onto the "first mode" and "second mode" as defined in the claims. For instance, does an accused product's low-power state or battery-saving feature constitute the claimed "second mode of operation being associated with emergency illumination"? (’159 Patent, col. 9:64-67).
    • Technical Questions: The complaint provides no evidence regarding how the accused products technically operate. A key question for the court will be whether the internal circuitry of the accused products includes a "controller" that performs the specific functions required by the claims, such as selectively distributing power from two different sources based on distinct operational modes (’159 Patent, col. 9:57-67).

V. Key Claim Terms for Construction

  • The Term: "first mode of operation being associated with non-emergency illumination" and "second mode of operation being associated with emergency illumination" (from Claim 1)
  • Context and Importance: This pair of terms is the functional core of the invention. The infringement analysis will depend entirely on whether the accused products are found to operate in two distinct modes that correspond to these claim definitions. Practitioners may focus on whether "emergency illumination" requires a specific trigger (e.g., a power outage, an external signal) or if any operation on battery power qualifies.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the modes are primarily distinguished by the power source. The patent states that the controller "may switch from the first mode to the second mode and operate according to DC power levels if AC power is lost," linking the modes directly to the availability of main power (’159 Patent, col. 5:53-57). This could support a reading where any operation on battery power after AC power loss constitutes the "second mode."
    • Evidence for a Narrower Interpretation: The claim language itself links the modes to purpose ("non-emergency" vs. "emergency"). The specification elaborates on triggers for the "backup mode," including not just power loss but also receipt of an "emergency alert message" (’159 Patent, col. 7:31-34). This could support a narrower construction requiring a specific "emergency" condition beyond simple battery operation for the second mode to be invoked.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells the accused products to customers and distributes "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶14-15).
  • Willful Infringement: The complaint alleges that service of the complaint itself "constitutes actual knowledge of infringement" and that despite this knowledge, Defendant continues its allegedly infringing activities (Compl. ¶13-14). This forms the basis for an allegation of post-suit willful infringement.

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

No probative visual evidence provided in complaint.

  • A primary issue will be one of technical proof: given the complaint's lack of detail, Plaintiff will need to produce evidence from the unprovided Exhibit 2 or through discovery to demonstrate how the internal components and software of the accused products meet the specific functional limitations of the patent's claims, particularly the "controller" element.
  • The case will also turn on a question of definitional scope: can the terms "first mode" (non-emergency) and "second mode" (emergency) be construed to read on the standard operational and battery-backup functionalities of Defendant's products? The outcome will likely depend on whether "emergency illumination" is interpreted merely as operation on battery power or if it requires a more specific emergency-related trigger.