DCT
1:25-cv-00141
AGS Lighting Management LLC v. Jesco Lighting Group LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: AGS Lighting Management LLC (Texas)
- Defendant: Jesco Lighting Group, LLC (Delaware)
- Plaintiff’s Counsel: Shaw Keller LLP
- Case Identification: 1:25-cv-00141, D. Del., 02/04/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware entity and has allegedly committed acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s LIN product line of modular, connectable linear lighting fixtures infringes a patent related to controlling color temperature and brightness in such fixtures.
- Technical Context: The technology concerns modular LED lighting systems that allow for on-site adjustment of both light color (temperature) and brightness (luminance), and the ability to connect different lengths of fixtures while maintaining uniform light output.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement via a letter dated October 31, 2023, a fact which may be used to support allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2020-06-18 | ’302 Patent Priority Date |
| 2023-09-05 | ’302 Patent Issue Date |
| 2023-10-31 | Date of alleged pre-suit notice letter to Defendant |
| 2025-02-04 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,751,302 - "Controlling Color Temperature and Luminance in Linear LED Fixtures" (issued Sep. 5, 2023)
The Invention Explained
- Problem Addressed: The patent and complaint describe the logistical and manufacturing challenges of prior art linear LED lighting, which required manufacturers to produce and stock a large number of distinct product variations for every combination of length, color temperature, and brightness a customer might require (Compl. ¶14; ’302 Patent, col. 4:13-36). A further problem was ensuring that when different length fixtures were connected, they produced a uniform light output (Compl. ¶16).
- The Patented Solution: The invention is a modular linear LED lighting apparatus featuring at least two sets of LEDs, each with a different color temperature (e.g., one "warm" 3000K string and one "cool" 4000K string) ('302 Patent, col. 8:5-11). A switch assembly allows a user to select which set of LEDs receives power, or to blend power between them to create intermediate color temperatures ('302 Patent, col. 8:31-52). A separate switch controls a driver circuit to adjust the amount of current, thereby controlling the overall brightness ('302 Patent, col. 5:14-25). The patent also describes scaling the number of LEDs and the driver circuit's power output in proportion to the module's length, allowing different-sized modules to be connected together while maintaining consistent light properties ('302 Patent, col. 5:31-54). Figure 2 of the patent illustrates the core electrical assembly, showing the driver circuit (20), switch assembly (22), and separate LED arrays (16) for different color temperatures (Compl. ¶21; '302 Patent, Fig. 2).
- Technical Importance: This approach allows for the mass production of standardized, field-configurable modules, reducing inventory costs for manufacturers and providing greater flexibility for installers (Compl. ¶15, ¶20).
Key Claims at a Glance
- The complaint asserts independent claims 1, 10, and 18 (Compl. ¶28).
- Independent Claim 1 recites a linear LED lighting apparatus comprising:
- An array of LEDs of a "first length."
- The array includes a "first plurality of LEDs" with a "first color temperature" and a "second plurality of LEDs" with a different "second color temperature."
- A "driver circuit" that can output a "plurality of currents."
- A "switch assembly" with a "first switch" to cause the driver to output a current, and a "second switch" to couple that current to the first, second, or both pluralities of LEDs.
- The apparatus is "configured to electrically couple to an additional" apparatus of a "second length different than the first length by a scale factor."
- The coupled apparatus is configured to produce light matching the first or second color temperature.
- The complaint reserves the right to assert additional claims (Compl. ¶30).
III. The Accused Instrumentality
Product Identification
The Accused Jesco Products are identified as the Jesco LIN Product line, including the LIN SLIM lighting fixtures (Compl. ¶1, ¶23).
Functionality and Market Context
The complaint describes the accused products as modular linear lighting fixtures available in various fixed lengths (e.g., 2, 4, 6, and 8 feet) that can be connected to form continuous runs of up to 80 feet (Compl. ¶24, ¶28). The fixtures allegedly feature an "on-board selectable Color Temperature setting of 3000K/3500K/4000K" and a "7-level Wattage Selector" to adjust lumen output (Compl. ¶25). A photograph from Jesco's marketing materials shows the 'on-board Color Temperature and Light Output Selector' with distinct switches for CCT and wattage output (Compl. p. 11). These features are marketed for applications requiring high-quality, uniform light, such as retail showrooms, galleries, and offices (Compl. ¶24).
IV. Analysis of Infringement Allegations
’302 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an array of light emitting diodes (LEDs) having a first length | The Jesco LIN SLIM fixture has an array of LEDs and is sold in fixed lengths, such as 24 1/2 inches. A screenshot from a Jesco promotional video illustrates the availability of the accused product in various standard lengths, such as 2, 4, 6, and 8 feet. | ¶28; p. 9 | col. 6:24-28 |
| a first plurality of LEDs configured to produce a first light having a first color temperature... | The accused product has a selectable 3000K color temperature setting, which is alleged to correspond to a first plurality of LEDs. A photograph from Jesco's documentation shows the internal linear array of LEDs. | ¶28; p. 10 | col. 8:5-8 |
| a second plurality of LEDs configured to produce a second light having a second color temperature different from the first color temperature... | The accused product has a selectable 4000K color temperature setting. It is alleged that intermediate temperatures are produced by blending the output of the 3000K and 4000K LEDs. | ¶28; p. 10 | col. 8:8-11 |
| a driver circuit configured to output a plurality of currents | The accused product's "7-level Wattage Selector" is alleged to adjust light output, which requires the driver circuit to provide different currents. | ¶28; p. 10 | col. 6:55-63 |
| a switch assembly configured to couple to the driver circuit, wherein the switch assembly comprises: a first switch configured to cause the driver circuit to output one of the plurality of currents; a second switch configured to cause the one of the plurality of currents to couple to the first plurality of LEDs, the second plurality of LEDs, or both | The accused product includes an "on-board Color Temperature and Light Output Selector." The complaint alleges this functions as the claimed switch assembly, with the wattage selector being the "first switch" and the CCT selector being the "second switch." | ¶28; p. 11 | col. 8:12-24 |
| wherein the linear LED lighting apparatus is configured to electrically couple to an additional linear LED lighting apparatus having a second length different than the first length by a scale factor | The accused products are marketed as connectable into long, linear runs using different lengths. The complaint alleges that connecting, for example, a 2-foot and 8-foot fixture is based on a scale factor of 4. A screenshot from a Jesco video shows a user connecting two modules using a keyed electrical connector. | ¶28; p. 14 | col. 9:35-45 |
Identified Points of Contention
- Scope Questions: A central question will be the interpretation of "by a scale factor." The patent describes manufacturing modules with proportionally scaled components (e.g., an 8-foot fixture has twice the LEDs and a driver with twice the power output of a 4-foot fixture) ('302 Patent, col. 5:31-54). It is an open question whether the accused system's ability to connect different-length modules relies on this specific proportional design, or if it is merely the connection of independent units whose settings are manually matched by an installer.
- Technical Questions: What evidence demonstrates that the accused system maintains uniform luminance when different length sections are connected, as the patent teaches? The complaint alleges the functionality but does not provide detailed evidence on how the accused products' driver circuits coordinate or scale their output when interconnected. The mapping of the accused product's physical CCT and wattage switches onto the functionally-defined "first switch" and "second switch" of the claim may also be a point of dispute.
V. Key Claim Terms for Construction
- The Term: "scale factor"
- Context and Importance: This term appears in the final, and potentially most distinguishing, limitation of claim 1. The infringement analysis for interconnecting different-length modules hinges on its meaning. Practitioners may focus on this term because it appears to link the physical act of connecting modules to the underlying design principle of proportional scaling that the patent emphasizes as a solution to the prior art's uniformity problems.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification illustrates connecting a 4-foot fixture and an 8-foot fixture to create a 12-foot run ('302 Patent, Fig. 4, col. 10:25-33). Plaintiff may argue that "scale factor" should be broadly construed to encompass any system designed to allow modules of different, proportional lengths (e.g., 2 ft, 4 ft, 8 ft) to be connected to achieve a uniform appearance, without requiring a specific method of electronic auto-configuration.
- Evidence for a Narrower Interpretation: The specification repeatedly explains the concept of scaling the components themselves: "the driver circuit of the 8-ft linear LED light fixture module may output twice the amount of current that the driver circuit of the 4-ft linear LED light fixture module may output" ('302 Patent, col. 5:43-47). Defendant may argue that "scale factor" requires this specific design principle—where the component specifications (LED count, driver output) are scaled in proportion to fixture length during manufacturing—and is not met by simply connecting two independent fixtures.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement under 35 U.S.C. § 271(b), stating that Jesco's marketing materials, videos, and installation guides instruct customers on how to use the accused features (e.g., adjusting color and brightness) and connect modules in an infringing manner (Compl. ¶30).
- Willful Infringement: The complaint alleges that Jesco had pre-suit knowledge of the ’302 Patent and its infringement since at least October 31, 2023, via a notice letter from Plaintiff's counsel. This alleged knowledge forms the basis for the willfulness claim (Compl. ¶33).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "scale factor," which the patent specification links to the proportional design of internal components, be construed to cover the accused system where installers may simply connect different-sized modules and manually match their settings?
- A key evidentiary question will be one of technical implementation: what evidence will show that the accused system, when different length modules are interconnected, achieves uniform light output through the specific scaled-component approach taught by the patent, as opposed to relying on an installer to manually coordinate the independent settings of each module?