DCT

1:23-cv-00767

Signify North America Corp v. Current Lighting Solutions LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-00767, D. Del., 07/14/2023
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a limited liability company organized under the laws of Delaware, has designated an agent for service of process in the district, conducts regular business in the district through distributors, and has previously been subject to venue in the district in other patent litigation.
  • Core Dispute: Plaintiff alleges that Defendant’s LED lighting products, including luminaires and replacement bulbs, infringe six patents related to foundational LED technologies such as power factor correction, driver circuitry, thermal management, and optical design.
  • Technical Context: The lawsuit concerns the technology of solid-state lighting, a market where light-emitting diodes (LEDs) have largely replaced traditional light sources due to their efficiency, longevity, and design flexibility.
  • Key Procedural History: The complaint alleges that Defendant had actual notice of its alleged infringement of the various patents-in-suit on dates ranging from June 2018 to September 2022. It also notes that Defendant filed a declaratory judgment action in the District of Massachusetts on June 22, 2023, concerning several of the same patents, which may indicate Defendant's awareness of the dispute prior to the filing of this complaint.

Case Timeline

Date Event
2002-12-19 Priority Date: U.S. Patent No. 7,262,559
2004-01-28 Priority Date: U.S. Patent No. 7,654,703
2004-03-15 Priority Date: U.S. Patent No. 7,358,706
2004-09-20 Priority Date: U.S. Patent No. 7,670,038
2007-08-28 Issue Date: U.S. Patent No. 7,262,559
2008-04-15 Issue Date: U.S. Patent No. 7,358,706
2010-02-02 Issue Date: U.S. Patent No. 7,654,703
2010-03-02 Issue Date: U.S. Patent No. 7,670,038
2011-05-02 Priority Date: U.S. Patent No. 9,249,965
2012-04-24 Priority Date: U.S. Patent No. 8,629,631
2014-01-14 Issue Date: U.S. Patent No. 8,629,631
2016-02-02 Issue Date: U.S. Patent No. 9,249,965
2018-06-22 Defendant allegedly received notice of ’559, ’703, and ’038 Patents
2021-07-30 Defendant allegedly received notice of ’631 and ’965 Patents
2022-09-12 Defendant allegedly received notice of ’706 Patent
2023-06-22 Defendant filed declaratory judgment action in D. Mass.
2023-07-14 Complaint Filing Date

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

U.S. Patent No. 7,358,706 - “Power Factor Correction Control Methods and Apparatus”

The Invention Explained

  • Problem Addressed: Conventional power factor correction (PFC) circuits, which are used to improve the efficiency of power supplies, often have a limited response time. This can compromise stability when the power demanded by a load—such as a dimmable LED light—changes rapidly (e.g., "load full off to load full on, or vice versa") (’706 Patent, col. 10:52-65).
  • The Patented Solution: The invention proposes improving control loop response by "feeding-forward" information about the anticipated load condition (’706 Patent, Abstract). Instead of relying solely on feedback signals (like output voltage), the PFC controller is configured to process a signal representing the "predetermined desired power" for the load. This allows the controller to proactively adjust for load changes, resulting in a more stable and efficient power supply (’706 Patent, col. 1:13-21, col. 15:53-60).
  • Technical Importance: This feed-forward control method allows for the design of smaller, more cost-effective, and more stable power supplies for devices with dynamic power requirements.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶39, 41).
  • The essential elements of claim 1 are:
    • A power factor correction apparatus comprising at least one first switch and at least one switch controller.
    • The switch controller is configured to control the switch based on a predetermined desired power to be provided to a load.
    • The switch controller is configured to process four signals: (1) a first signal representing AC line voltage, (2) a second signal representing actual AC current drawn, (3) a third signal representing a DC voltage output, and (4) a fourth signal representing the predetermined desired power.
    • The controller processes these signals to generate a switch control signal to control the switch.
  • The complaint reserves the right to assert additional claims (Compl. ¶48).

U.S. Patent No. 7,262,559 - “LEDS driver”

The Invention Explained

  • Problem Addressed: LEDs are sensitive to variations in voltage and current; small changes can lead to unacceptable variations in brightness or even "catastrophic failure" (’559 Patent, col. 1:21-34). Power supplies must precisely regulate the current, particularly during initial power-on, to prevent damaging current spikes (’559 Patent, col. 1:35-41).
  • The Patented Solution: The patent describes an LED power supply with a control switch that is "operable to clamp a peak of the LED current during an initial loading stage of the LED light source" (’559 Patent, col. 2:44-48). This clamping function acts as a protective measure to prevent current overshoots when the light is first turned on or connected, thereby protecting the LEDs from electrical damage (’559 Patent, Abstract).
  • Technical Importance: This protective start-up feature improves the long-term reliability of LED lighting systems by mitigating a common failure mode associated with electrical stress.

Key Claims at a Glance

  • The complaint asserts independent claim 10 (Compl. ¶58, 60).
  • The essential elements of claim 10 are:
    • A power supply for an LED light source comprising a power converter, an LED control switch, and a current sensor.
    • The power converter provides a regulated power including an LED current and voltage.
    • The LED control switch controls the flow of LED current.
    • The current sensor senses the LED current and includes a differential amplifier and a "means for adjusting a gain of said differential amplifier."
    • The LED control switch is further operable to "clamp a peak of the LED current during an initial loading stage."
  • The complaint reserves the right to assert additional claims (Compl. ¶65).

Multi-Patent Capsules

U.S. Patent No. 8,629,631 - “Method and System for Improving Start-Up Time of a Light Emitting Diode (LED) Driver at Reduced Input Voltage”

  • Technology Synopsis: The patent addresses slow start-up times for LED drivers, particularly when operating at low input voltages (e.g., when connected to a dimmer). The solution is a "quick start circuit" with a constant current source that rapidly charges the controller's power supply capacitor, replacing the traditional, slower "trickle charge" path (’631 Patent, Abstract).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶75, 77).
  • Accused Features: The complaint accuses the LED Evolve Security Light E2SA of infringement, mapping the claimed elements to specific components in the product's power supply circuitry (Compl. ¶24, 78-86).

U.S. Patent No. 7,654,703 - “Directly Viewable Luminaire”

  • Technology Synopsis: The patent addresses thermal management in LED luminaires. It describes a housing with two thermally separate internal compartments: one for the heat-producing LEDs and another for the heat-producing electronic driver components (’703 Patent, col. 15:15-32). This separation prevents the heat from one set of components from adversely affecting the other, improving overall performance and reliability.
  • Asserted Claims: Independent claim 17 is asserted (Compl. ¶97, 99).
  • Accused Features: The complaint accuses the Evolve LED Area Light EALS, alleging its housing contains separate, thermally isolated compartments for the LEDs and the electronic driver, with a base cover acting as a heat sink (Compl. ¶25, 101-107).

U.S. Patent No. 9,249,965 - “Lighting Device”

  • Technology Synopsis: The patent describes a lighting device designed for improved cooling. The invention features a light source heat sink and a driver heat sink that are physically separated by an "air gap to provide thermal decoupling" (’965 Patent, Abstract). This air gap is part of a cooling channel that allows ambient air to flow between the heat sinks, actively cooling both the light source and the driver.
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶118, 120).
  • Accused Features: The GE LED HID Replacement light is accused of infringing. The complaint alleges the product has separate, thermally coupled heat sinks for its LEDs and driver, separated by an air gap that forms a cooling channel (Compl. ¶26, 121-129).

U.S. Patent No. 7,670,038 - “LED Collimator Element with an Asymmetrical Collimator”

  • Technology Synopsis: The patent addresses the need to create specific, non-uniform light distributions, such as the sharp cut-off required for vehicle headlights. The invention uses an asymmetrically designed collimator that directs light to create a defined light intensity pattern, where intensity decreases with distance from a primary face of the collimator (’038 Patent, Abstract).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶138, 140).
  • Accused Features: The Evolve LED Area Light EALS is accused of containing an LED and an asymmetrical collimator that allegedly produces the claimed non-uniform light intensity distribution (Compl. ¶27, 141-144).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies several distinct product lines accused of infringing different patents:
    • Lumination Recessed LED Luminaire RPL22 (’706 Patent) (Compl. ¶22, 39)
    • Evolve LED Area Light EANB (’559 Patent) (Compl. ¶23, 58)
    • LED Evolve Security Light E2SA (’631 Patent) (Compl. ¶24, 75)
    • Evolve LED Area Light EALS (’703 and ’038 Patents) (Compl. ¶25, 27, 97, 138)
    • GE LED HID Replacement light, model 93986445 (’965 Patent) (Compl. ¶26, 118)

Functionality and Market Context

  • The accused products are commercial and industrial LED lighting fixtures, including recessed luminaires, outdoor area and security lights, and high-intensity discharge (HID) replacement bulbs (Compl. ¶22-27). The complaint alleges these products are sold online and through brick-and-mortar distributors throughout the United States (Compl. ¶20). An image provided in the complaint shows the label for the "UltraMax Programmable LED Driver" used in the Evolve LED Area Light EANB (Compl. p. 20). The complaint further provides an annotated photograph of the GE LED HID Replacement light, highlighting the light source and the spatially separated driver unit (Compl. ¶123).

IV. Analysis of Infringement Allegations

7,358,706 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A power factor correction apparatus, comprising: at least one first switch; and at least one switch controller to control the at least one first switch based at least on a predetermined desired power to be provided to a load... The Lumination Recessed LED Luminaire RPL22 includes a driver with a switch (Q1) and a switch controller (ON Semiconductor NCL30186) that performs power factor correction. ¶42 col. 15:53-60
wherein the at least one switch controller is configured to process: a first signal representing an AC line voltage... The controller is configured to process a signal from the terminals labeled "AC MAINS INPUT." ¶43 col. 15:61-63
a second signal representing an actual AC current drawn by the power factor correction apparatus; The controller is configured to process a signal representing the AC current drawn from the "AC MAINS INPUT." ¶44 col. 15:64-66
a third signal representing a DC voltage output by the power factor correction apparatus; and The controller is configured to process a signal representing the voltage labeled "+LED." ¶45 col. 16:1-3
a fourth signal representing the predetermined desired power to be provided to the load, The controller is configured to process a signal from the input terminals labeled "DIMMING CONTROL INPUT TERMINAL BLOCK." ¶46 col. 16:4-6
so as to generate a first switch control signal to control the at least one first switch. The controller generates a signal to control the switch labeled AOTF8N80 Q1, based in part on the dimming control input. ¶47 col. 16:7-9

Identified Points of Contention

  • Scope Questions: A central question may be whether the "DIMMING CONTROL INPUT" signal (Compl. ¶46) qualifies as a "signal representing the predetermined desired power to be provided to the load" as required by the claim. The analysis may explore whether a dimming signal, which typically sets a relative brightness level, conveys the specific "desired power" information contemplated by the patent.
  • Technical Questions: What evidence does the complaint provide that the accused controller "processes" all four specified input signals to generate its output? The court will need to determine if the controller's operation, as alleged, matches the functional requirements of the claim.

7,262,559 Infringement Allegations

Claim Element (from Independent Claim 10) Alleged Infringing Functionality Complaint Citation Patent Citation
a power converter operable to provide a regulated power including a LED current and a LED voltage; The "UltraMax Programmable LED Driver" is operable to provide regulated power, including LED current and voltage, at the "LED OUTPUT WIRE LEADS." ¶61 col. 2:20-23
an LED control switch operable to control a flow of the LED current through the LED light source; The circuitry includes components labeled "L6599AD," "IPA65R660CFD Q101," and/or "IPA65R660CFD Q102" which allegedly act as a control switch. ¶62 col. 2:29-31
a current sensor operable to sense the LED current...said current sensor including an differential amplifier, and means for adjusting a gain of said differential amplifier, The circuitry allegedly includes a "T104 TRANSFORMER," "U602B LM2904," and resistors "R606" and "R608" that function as the claimed current sensor. ¶63 col. 2:58-62
wherein said LED control switch is further operable to clamp a peak of the LED current during an initial loading stage of the LED light source. The "L6599AD" component includes a "soft-start" functionality that allegedly clamps the peak current by progressively increasing power during start-up. ¶64 col. 2:44-48

Identified Points of Contention

  • Scope Questions: The dispute may center on whether the alleged "soft-start" functionality (Compl. ¶64) meets the claim limitation of being "operable to clamp a peak" of the current. A "clamp" typically implies setting a hard maximum limit, which raises the question of whether a gradual ramp-up function falls within the scope of that term.
  • Technical Questions: Does the accused product include a "means for adjusting a gain of said differential amplifier"? This is a means-plus-function limitation, and its scope will be defined by the corresponding structures disclosed in the ’559 Patent's specification. The analysis will compare the accused resistors (Compl. ¶63) to the structures disclosed in the patent.

V. Key Claim Terms for Construction

  • The Term: "a fourth signal representing the predetermined desired power to be provided to the load" (from ’706 Patent, Claim 1)

  • Context and Importance: This term is critical because the plaintiff's infringement theory equates it with a signal from a dimming control input (Compl. ¶46). The viability of the infringement claim for the ’706 patent may depend on whether a standard dimming signal can be construed as a signal representing "desired power."

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent's general description focuses on improving control loop response to changes in load power (’706 Patent, Abstract). Parties may argue that a dimming signal directly dictates the power the load should consume, fitting the plain meaning of "desired power."
    • Evidence for a Narrower Interpretation: The specification discusses a processor that "may be programmed with information relating to a desired power" and provides this information to the PFC apparatus (’706 Patent, col. 11:45-55). This may suggest the "signal" is a specific data value (e.g., in watts) generated by a processor, rather than a simpler analog or PWM dimming input.

  • The Term: "operable to clamp a peak of the LED current" (from ’559 Patent, Claim 10)

  • Context and Importance: The complaint alleges that a "soft-start" functionality in the accused product satisfies this limitation (Compl. ¶64). Practitioners may focus on this term because "clamping" and "soft-start" can describe technically distinct circuit behaviors.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent states the purpose of this feature is to "protect the LED light source from electrical damage" during initial loading (’559 Patent, col. 2:45-48). An interpretation focused on this purpose could encompass any function, including soft-start, that prevents damaging current spikes at startup.
    • Evidence for a Narrower Interpretation: The term "clamp" in electronics commonly refers to a circuit that prevents a signal from exceeding a defined level. The specification uses the term "clamps" without defining it in a special way (’559 Patent, Abstract), suggesting it should be given its ordinary meaning in the art, which may be narrower than the "soft-start" function of merely ramping up current gradually.

VI. Other Allegations

  • Indirect Infringement: For each patent-in-suit, the complaint alleges both active inducement and contributory infringement. The inducement allegations are based on Defendant marketing and selling the accused products with instructions and support that allegedly encourage infringing use (e.g., ’706 Patent, Compl. ¶51). The contributory infringement allegations state that the accused products and their internal components are not staple articles of commerce and are especially made for use in an infringing manner (e.g., ’706 Patent, Compl. ¶52).
  • Willful Infringement: The complaint alleges willful infringement for all asserted patents. This allegation is based on claims that Defendant received actual written notice of its infringement from Plaintiff on specific dates—June 22, 2018; July 30, 2021; and September 12, 2022—and continued its allegedly infringing activities despite this knowledge (Compl. ¶28-31, 34). The complaint also cites Defendant's filing of a declaratory judgment action as further evidence of its knowledge of the patents (Compl. ¶50).

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

  • A core issue will be one of definitional scope: can key claim terms, rooted in specific electronics concepts, be construed to cover the different but functionally related technologies found in the accused products? This question is central to whether a "dimming signal" is a signal for "desired power" (’706 patent) and whether a "soft-start" circuit performs the function of "clamping a peak" (’559 patent).
  • A second key issue will be one of structural and thermal equivalence: for the patents related to physical design (’703 and ’965), the case will likely turn on a factual analysis of whether the accused luminaires' internal compartments, heat sinks, and air gaps are arranged to provide the specific thermal separation, decoupling, and cooling channel configurations required by the claims.
  • Finally, a significant question will be one of intent: given the detailed allegations of pre-suit notice, should infringement be found, the court will need to assess whether Defendant's conduct after receiving notice was objectively reckless, which would support a finding of willful infringement and potential enhanced damages.