DCT
1:25-cv-01085
BridgeComm LLC v. Hampton Products Intl Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BridgeComm LLC (TX)
- Defendant: Hampton Products International Corporation (DE)
- Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
- Case Identification: 1:25-cv-01085, D. Del., 08/28/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation and has committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s variable-effect lighting products infringe two patents related to methods for controlling multi-colored lamps connected to an AC power source.
- Technical Context: The technology at issue involves electronic controllers for decorative lighting systems, such as holiday light strings, that create dynamic color-changing effects.
- Key Procedural History: The complaint notes that U.S. Patent No. 8,390,206 is a continuation of the application that resulted in U.S. Patent No. 8,203,275, indicating a shared specification and an early priority date for the core technology. No other procedural events are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2005-08-16 | Priority Date for '275 and '206 Patents |
| 2012-06-19 | U.S. Patent No. 8,203,275 Issues |
| 2013-03-05 | U.S. Patent No. 8,390,206 Issues |
| 2025-08-28 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,203,275, “Variable-effect lighting system” (Issued Jun. 19, 2012)
The Invention Explained
- Problem Addressed: The patent’s background section describes prior art lighting systems as being limited in the variety of color displays they could produce or requiring complex and costly control units to achieve intricate effects (’275 Patent, col. 2:6-9).
- The Patented Solution: The invention proposes a simplified lighting system where multiple multi-colored lamps (e.g., containing red and green LEDs) are connected in series to a standard AC power source (’275 Patent, col. 3:60-65). A lamp controller then creates color-changing effects by varying the "conduction interval," or the amount of time each colored element is lit during an AC cycle, according to predetermined patterns (’275 Patent, Abstract). The system also includes a feature where a user can operate an input (e.g., a button) to stop the pattern and retain the currently displayed color in non-volatile memory, so the selection is remembered even after the device is powered off (’275 Patent, col. 27:52-65).
- Technical Importance: This design allows for sophisticated, user-selectable lighting effects in products like decorative light strings using a relatively simple and cost-effective series circuit architecture (’275 Patent, col. 3:56-60).
Key Claims at a Glance
- The complaint asserts infringement of one or more claims, including exemplary claims identified in an attached exhibit (Compl. ¶12). Claim 1 is the first independent claim.
- Independent Claim 1 requires:
- A lamp assembly with multiple multi-colored lamps connected in series with an AC voltage source.
- A lamp controller that varies the color by changing the conduction interval of different illuminating elements according to a pattern.
- The controller is configured to "terminate the variation" when a user activates an input.
- The controller includes non-volatile memory to retain a "datum associated with the conduction interval" when the user terminates the variation.
- The controller is configured to use this retained datum to set the color upon "re-application of power."
- The complaint does not explicitly reserve the right to assert dependent claims, but this is standard practice.
U.S. Patent No. 8,390,206, “Variable-effect lighting system” (Issued Mar. 5, 2013)
The Invention Explained
- Problem Addressed: The patent addresses a problem inherent in AC-powered lighting controllers: real-world AC power sources may not have a perfectly stable frequency (’206 Patent, col. 11:56-60). Controllers that assume a fixed frequency (e.g., 60 Hz) can produce unpredictable or flawed visual effects if the actual line frequency deviates, as the controller's timing will become unsynchronized with the AC power cycle (’206 Patent, col. 12:1-14).
- The Patented Solution: The invention is a lighting system with a controller that actively adapts to the power source. It is configured to "adjust the current draw" of the illuminating elements "in accordance with the voltage frequency" (’206 Patent, Abstract; col. 2:42-45). The shared patent specification describes an algorithm that measures the time between zero-crossings of the AC voltage to calculate the actual line frequency and then uses that measurement to accurately control the lighting elements (’275 Patent, col. 15:27-34).
- Technical Importance: This solution provides for a more robust and reliable lighting system that produces consistent visual effects even when connected to AC power sources with fluctuating frequencies (’206 Patent, col. 12:26-34).
Key Claims at a Glance
- The complaint asserts infringement of one or more claims, including exemplary claims identified in an attached exhibit (Compl. ¶21). Claim 1 is the sole independent claim.
- Independent Claim 1 requires:
- A lamp assembly with multiple multi-colored lamps connected in series with an AC voltage source that has a frequency.
- A lamp controller for controlling the current draw of each illuminating element.
- The controller is configured to "adjust the current draw in accordance with the voltage frequency."
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The complaint refers to "Exemplary Defendant Products" that are identified in claim chart Exhibits 3 and 4, which were not available for this analysis (Compl. ¶12, ¶17, ¶21, ¶26).
Functionality and Market Context
Based on the allegations, the accused products are variable-effect, multi-colored lighting systems. The complaint alleges these products "practice the technology claimed by the '275 Patent" and the "'206 Patent" (Compl. ¶17, ¶26). This implies the products feature a controller that generates dynamic color patterns. The complaint does not provide specific details on the products' functionality, operation, or market position beyond these general allegations. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint references, but does not include, claim chart exhibits detailing its infringement theories (Compl. ¶18, ¶27). The narrative alleges that the "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶17, ¶26). A summary of the core infringement allegations, as inferred from the asserted independent claims and the complaint's general statements, is presented below.
’275 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a lamp assembly comprising a plurality of multi-coloured lamps in series with an AC voltage source... | The complaint alleges the accused products are lighting strings with multiple multi-colored lamps powered by an AC source. | ¶12, ¶17 | col. 3:49-55 |
| a lamp controller coupled to the lamp assembly for varying the colour produced by the lamps by varying a conduction interval... | The complaint alleges the accused products contain a controller that creates color-changing effects by modulating power to the lamps. | ¶12, ¶17 | col. 2:20-23 |
| the controller being configured to terminate the variation upon activation of a user-operable input... | The complaint's allegations suggest the accused products include a user input, such as a button, to stop a color-changing pattern. | ¶12, ¶17 | col. 2:23-25 |
| wherein the lamp controller includes a non-volatile memory and is configured to retain... a datum associated with the conduction interval... upon the activation of the user-operable input... | The complaint alleges the accused products practice the claimed technology, which includes remembering a user-selected color setting. | ¶12, ¶17 | col. 27:52-59 |
| the lamp controller being further configured to set the conduction interval... in accordance with the retained datum upon re-application of power... | The complaint's allegations suggest that when unplugged and plugged back in, the accused products return to the last user-selected color. | ¶12, ¶17 | col. 27:61-65 |
’206 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a lamp assembly comprising a plurality of multi-coloured lamps in series with an AC voltage source... the voltage source having a frequency... | The complaint alleges the accused products are lighting strings that connect to a standard AC power outlet. | ¶21, ¶26 | col. 3:60-63 |
| a lamp controller coupled to the lamp assembly for controlling a current draw of each said illuminating element... | The complaint alleges the accused products contain a controller that manages the flow of current to the lamps' illuminating elements. | ¶21, ¶26 | col. 2:40-42 |
| the controller being configured to adjust the current draw in accordance with the voltage frequency. | The complaint's allegations imply the accused product controllers measure the AC line frequency and use that data to adjust control timing for stable operation. | ¶21, ¶26 | col. 2:42-45 |
Identified Points of Contention
- Scope Questions: A central question for the ’206 Patent may be whether the accused products' controllers perform an active "adjust[ment]... in accordance with the voltage frequency." A defendant could argue its controller merely operates at the line frequency without performing the measurement and adjustment function required by the claim.
- Technical Questions: For the ’275 Patent, a key factual dispute may be whether the accused products contain non-volatile memory and perform the claimed function of retaining a user-selected state after a full power cycle. For the ’206 Patent, the complaint provides no evidence of how the accused controller operates, raising the question of what proof Plaintiff will offer to show the device performs the technically specific frequency-adjustment function.
V. Key Claim Terms for Construction
The Term: "terminate the variation" (from ’275 Patent, Claim 1)
- Context and Importance: This term is central to the user-interaction feature of the ’275 Patent. Its construction will determine whether simply pausing a color-changing pattern infringes, or if the user must be able to affirmatively select and lock in a specific, static color.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain meaning of "terminate" suggests simply causing the color-changing pattern to stop.
- Evidence for a Narrower Interpretation: The specification describes using the input to "fix or set the colour or intensity produced by the lamp assembly as desired" (’275 Patent, col. 16:17-19), which may support a narrower construction requiring the selection of a stable, final state.
The Term: "adjust the current draw in accordance with the voltage frequency" (from ’206 Patent, Claim 1)
- Context and Importance: This is the core technical limitation of the ’206 Patent. Infringement will hinge on whether this term requires an active, measurement-based adjustment or if it can be read to cover any system whose operation is passively dependent on the line frequency.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that any controller whose output timing is based on the AC cycle inherently operates "in accordance with" the frequency.
- Evidence for a Narrower Interpretation: The specification discloses an algorithm that "measures the period of time between instances of zero voltage crossings of the AC source voltage, and uses the calculated period to calculate the line frequency" to control the lamps (’275 Patent, col. 15:27-32). This disclosure of an active measurement and calculation process may support a narrower construction requiring more than passive synchronization.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for both patents, stating that Defendant distributes "product literature and website materials inducing end users" to operate the accused products in an infringing manner (Compl. ¶15, ¶24).
- Willful Infringement: The complaint alleges knowledge of infringement "at least since being served by this Complaint" and that Defendant's continued activities constitute willful infringement (Compl. ¶15-16, ¶24-25).
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to center on specific, advanced features within otherwise common consumer lighting products. The key questions for the court will likely involve both technical evidence and claim scope.
- A core evidentiary question will be one of technical capability: Does discovery show that the accused products' controllers actually perform the specific functions claimed—namely, the non-volatile memory "terminate and retain" feature of the ’275 patent and, most critically, the active frequency measurement and adjustment of the ’206 patent?
- A dispositive legal issue will be one of definitional scope: Will the court construe "adjust... in accordance with the voltage frequency" narrowly, to require the active measurement process described in the specification, or more broadly? The viability of the ’206 patent claim will likely depend on this construction.
- A final question concerns infringement evidence: Given the bare-bones allegations, a key challenge for the plaintiff will be to develop sufficient evidence, likely through reverse engineering or technical discovery, to prove that the accused products' internal operations meet the specific limitations of the asserted claims.