BridgeComm LLC v. OSRAM Sylvania Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: BridgeComm LLC (Texas)
  • Defendant: Osram Sylvania Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01118, D. Del., 09/09/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware, has an established place of business in the district, and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s variable-effect lighting products infringe patents related to systems and methods for controlling multi-colored lamps.
• Technical Context: The technology at issue involves electronic control systems for multi-colored light-emitting diodes (LEDs), enabling dynamic color changes and effects for decorative, festive, or advertising displays.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings (e.g., IPRs) 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: Prior art variable-effect lighting systems were either limited in the range of color displays they could produce or required complex and costly control units to achieve intricate effects (’275 Patent, col. 1:36-2:10).
• The Patented Solution: The invention describes a lighting system where multiple multi-colored lamps (e.g., bi-color LEDs) are connected in series with an AC voltage source. A lamp controller varies the "conduction interval"—the duration each illuminating element is active during an AC cycle—to control the color produced by the lamps. The system allows a user to select a color display and "freeze" it by activating a user-operable input (’275 Patent, Abstract; col. 3:30-4:15). This design aims to create a simple yet versatile system for generating a wide variety of color effects (’275 Patent, col. 3:49-58).
• Technical Importance: This approach allows for sophisticated, dynamic color control over a string of lights using a relatively simple controller that operates directly from an AC power source without requiring complex transformers or data transmission protocols for each individual lamp (’275 Patent, col. 3:62-66).

Key Claims at a Glance

• Independent Claim Asserted: The complaint asserts infringement of "one or more claims" without specifying them (Compl. ¶12). Claim 1 is the sole independent claim.
• Claim 1 Elements:
  • A lamp assembly with a plurality of multi-colored lamps in series with an AC voltage source.
  • Each lamp comprises a first illuminating element for a first color and a second element for a second color.
  • A lamp controller coupled to the assembly for varying the color by varying a "conduction interval" of each illuminating element according to a predetermined pattern.
  • The controller is configured to "terminate the variation upon activation of a user-operable input to the controller."

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 application leading to the '275 Patent, the '206 Patent addresses the same limitations in prior art lighting systems, but adds a focus on maintaining consistent performance when the AC power source frequency fluctuates (’206 Patent, col. 1:21-2:10, col. 11:55-12:24).
• The Patented Solution: The invention provides a lighting system with a controller that adjusts its operation based on the measured frequency of the AC voltage source. By measuring the time between zero-crossings of the AC waveform, the controller can calculate the precise line frequency and adjust the timing of the conduction intervals accordingly, preventing unpredictable visual displays that could result from frequency variations (’206 Patent, Abstract; col. 11:55-12:41).
• Technical Importance: This feature is designed to ensure that the lighting effects remain stable and predictable, even when powered by AC sources with inconsistent frequencies, which may vary between different countries or power grids (’206 Patent, col. 11:55-12:41).

Key Claims at a Glance

• Independent Claim Asserted: The complaint asserts infringement of "one or more claims" without specifying them (Compl. ¶21). Claim 1 is a representative independent claim.
• Claim 1 Elements:
  • A lamp assembly with a plurality of multi-colored lamps in series with an AC voltage source having a frequency.
  • Each lamp comprises a first illuminating element for a first color and a second element for a second color.
  • A lamp controller coupled to the assembly for controlling a "current draw" of each illuminating element.
  • The controller is configured to "adjust the current draw in accordance with the voltage frequency."

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" that are identified in claim charts attached as exhibits (Compl. ¶12, ¶21). However, these exhibits were not provided with the complaint. Therefore, the specific accused products are not identified in the available document.

Functionality and Market Context

The complaint does not describe the specific functionality of the accused products beyond conclusory allegations that they practice the technology claimed by the patents-in-suit (Compl. ¶17, ¶26). It alleges that Defendant makes, uses, sells, and imports these products in the United States (Compl. ¶12, ¶21).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibit 3 for the ’275 Patent and Exhibit 4 for the ’206 Patent) that are not provided (Compl. ¶17, ¶26). The complaint alleges that these charts compare the "Exemplary Patent Claims to the Exemplary Defendant Products" and demonstrate that the products "satisfy all elements" of the asserted claims (Compl. ¶17, ¶26). Lacking these exhibits, a detailed element-by-element analysis is not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent claims and the general nature of the dispute, several technical and legal questions may become central to the infringement analysis:

• For the ’275 Patent:

  • Scope Question: A key issue may be how the accused products implement a "user-operable input" to "terminate the variation" of the lighting effect. The analysis will question whether a general power switch or a multi-function button on the accused products meets this specific claim limitation as described in the patent.
  • Technical Question: What evidence does the complaint provide that the accused products control color by varying the "conduction interval" of different colored LEDs in relation to an AC waveform, as opposed to using alternative methods like pulse-width modulation (PWM) with a DC power supply?

• For the ’206 Patent:

  • Scope Question: The central dispute may revolve around the claim limitation "adjust the current draw in accordance with the voltage frequency." The analysis will question whether the accused products perform an active measurement of the AC line frequency and dynamically adjust their timing, or if they operate based on a fixed, assumed frequency (e.g., 60 Hz).
  • Technical Question: Does the complaint offer evidence showing that the accused products contain circuitry capable of detecting zero-crossings of the AC voltage source to calculate its frequency, as contemplated by the patent's specification?

V. Key Claim Terms for Construction

U.S. Patent No. 8,203,275

• The Term: "terminate the variation upon activation of a user-operable input" (Claim 1)
• Context and Importance: This term is critical because it defines a specific user interaction: freezing a dynamic color-changing pattern. Infringement will depend on whether the accused products offer this "stop-action" functionality, rather than simply cycling through preset modes or turning off.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A defendant might argue the term covers any user input that stops the lighting effect, including a power switch. The claim language itself does not specify the type of input beyond being "user-operable."
  • Evidence for a Narrower Interpretation: The specification describes an algorithm where a user can "fix or set the colour or intensity produced by the lamp assembly as desired, by simply depressing the user-operable switch 24 when the lamp controller has produced the desired colour or intensity," which then resumes the variation upon a second press (’275 Patent, col. 12:42-53). This suggests a specific "pause-and-resume" function, not just turning the device off.

U.S. Patent No. 8,390,206

• The Term: "adjust the current draw in accordance with the voltage frequency" (Claim 1)
• Context and Importance: This is the core technical distinction of the ’206 patent. The case may turn on whether the accused products perform a passive, one-time configuration for a given frequency or an active, ongoing adjustment as required by the claim. Practitioners may focus on whether "in accordance with" requires a dynamic, responsive relationship.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff could argue that any system designed to work properly at a specific AC frequency (e.g., 60 Hz) inherently has its current draw controlled "in accordance with" that frequency, even if it cannot adapt to other frequencies.
  • Evidence for a Narrower Interpretation: The specification explicitly describes a process of measuring the "period of time between instances of zero voltage crossings of the AC source voltage" and using the "calculated period to calculate the line frequency" to "accurately track the actual conduction interval" (’206 Patent, col. 11:30-36). This language strongly supports a definition requiring active measurement and adaptation.

VI. Other Allegations

• Indirect Infringement: Plaintiff alleges induced infringement for both patents. The complaint asserts that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶15, ¶24).
• Willful Infringement: The complaint does not use the term "willful." However, it alleges that service of the complaint provides Defendant with "actual knowledge" of infringement and that Defendant continues to infringe despite this knowledge (Compl. ¶14-15, ¶23-24). These allegations form a basis for potential claims of post-suit willful infringement.

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

Given the limited factual detail in the complaint, the litigation will likely focus on discoveries related to the precise operation of the accused products. The central questions for the court can be framed as:

1. A core issue will be one of functional operation: Do the accused Osram Sylvania products achieve variable color effects by controlling the "conduction interval" of LEDs relative to an AC power cycle, as claimed in the ’275 Patent, or do they employ a different, non-infringing control architecture?
2. A second key issue will be one of technical capability: Does the controller in the accused products actively measure the AC line frequency and "adjust" its operation "in accordance with" that measurement, as required by the ’206 Patent, or is it a simpler system designed to operate at a fixed, nominal frequency?
3. An evidentiary question will be one of inducement: Assuming direct infringement is found, do Defendant's user manuals and marketing materials contain instructions that actively encourage users to perform the specific patented methods, such as terminating a color variation to set a desired color?