DCT

1:25-cv-01119

BridgeComm LLC v. Acuity Inc

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01119, D. Del., 09/09/2025
  • Venue Allegations: Venue is alleged to be proper as Defendant is a Delaware corporation and has an established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s variable-effect lighting systems infringe patents related to methods for controlling multi-colored lamps powered by an AC voltage source.
  • Technical Context: The technology concerns electronic control systems for creating a wide variety of color-changing and intensity-varying effects in lighting products, a field relevant to decorative, festive, and architectural illumination.
  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history concerning the patents-in-suit. U.S. Patent No. 8,390,206 is a continuation of the application that issued as U.S. Patent No. 8,203,275, indicating a close technological relationship between the two asserted patents.

**Case Timeline**

Date Event
2005-08-16 Priority Date for U.S. Patent Nos. 8,203,275 and 8,390,206
2012-06-19 U.S. Patent No. 8,203,275 Issues
2013-03-05 U.S. Patent No. 8,390,206 Issues
2025-09-09 Complaint Filed

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: The patent’s background section describes prior art variable-color lighting systems as having limitations in the range of achievable color displays or requiring complex and specialized control units, particularly when attempting to create intricate color patterns from a standard AC power source (’275 Patent, col. 1:20-col. 2:10).
  • The Patented Solution: The invention proposes a simplified lighting system where multiple multi-colored lamps (e.g., bi-color LEDs) are connected in series with each other and directly to an AC voltage source. A lamp controller varies the color output by adjusting the “conduction interval”—the duration each color-emitting element is active during a cycle of the AC power—according to a predetermined pattern. The system also includes a user-operable input that allows a user to terminate the color variation, effectively freezing a desired color (’275 Patent, Abstract; col. 3:57-col. 4:3). The series arrangement is noted as eliminating the need for a step-down transformer, simplifying the overall circuit design (’275 Patent, col. 3:63-66).
  • Technical Importance: This approach aimed to provide a more cost-effective and versatile method for generating a wide range of dynamic color effects in products like decorative light strings, using a standard AC wall outlet as the power source (’275 Patent, col. 2:6-10).

Key Claims at a Glance

  • The complaint does not specify which claims are asserted, referring generally to “one or more claims” (Compl. ¶12). Claim 1 is the first independent claim.
  • Essential Elements of Claim 1:
    • A lamp assembly with multiple multi-colored lamps connected in series with an AC voltage source.
    • Each lamp has a first illuminating element for a first color and a second illuminating element for a second color.
    • A lamp controller coupled to the assembly.
    • The controller is configured to vary the color by varying a “conduction interval” of each illuminating element according to a pattern.
    • The controller is also configured to terminate this variation upon activation of a “user-operable input.”
  • The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" (Compl. ¶12).

U.S. Patent No. 8,390,206 - *“Variable-effect lighting system”*

  • Issued: March 5, 2013

The Invention Explained

  • Problem Addressed: The control algorithms in lighting systems that rely on the timing of an AC power cycle can produce unpredictable and incorrect colors if the frequency of the AC source deviates from the expected standard (e.g., 60 Hz in the U.S. vs. 50 Hz in other regions). This is because timing calculations for controlling the lamps become inaccurate (’206 Patent, col. 11:55-col. 12:24).
  • The Patented Solution: The invention adds a layer of intelligence to the lamp controller. The controller is configured to measure the actual frequency of the AC voltage source, for instance by timing the interval between zero-crossings of the AC waveform. It then uses this measured frequency to "adjust the current draw" for the illuminating elements, ensuring that the control algorithm remains synchronized and the intended color effects are produced accurately, regardless of variations in the power grid’s frequency (’206 Patent, Abstract; col. 12:25-40).
  • Technical Importance: This innovation makes the variable-effect lighting system more robust and reliable, allowing it to function correctly across different international power standards without modification (’206 Patent, col. 12:25-40).

Key Claims at a Glance

  • The complaint does not specify which claims are asserted (Compl. ¶21). Claim 1 is the first independent claim.
  • Essential Elements of Claim 1:
    • A lamp assembly with multiple multi-colored lamps connected in series with an AC voltage source that has a frequency.
    • Each lamp has first and second illuminating elements for producing different colors.
    • A lamp controller coupled to the assembly 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 alleges infringement of "one or more claims" of the ’206 Patent (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products or services by name. It refers to them generally as “Exemplary Defendant Products” (Compl. ¶12, ¶21).

Functionality and Market Context

The complaint alleges infringement through charts incorporated by reference as Exhibits 3 and 4, which were not filed with the complaint (Compl. ¶17-18, ¶26-27). As a result, the complaint does not provide sufficient detail for analysis of the functionality or market context of the accused instrumentalities.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations for both the ’275 and ’206 patents are made entirely by reference to claim chart exhibits that were not included with the filed complaint (Compl. ¶18, ¶27). The complaint asserts that these charts demonstrate that the "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶17, ¶26). Without these exhibits, a detailed element-by-element analysis of the infringement allegations is not possible from the provided documents.

No probative visual evidence provided in complaint.

Identified Points of Contention

  • For the ’275 Patent: A central point of contention may be the interpretation of “conduction interval.” The dispute could focus on whether the accused products’ method for controlling lamp brightness and color (which might, for example, use modern digital techniques like Pulse Width Modulation) falls within the scope of this term as it is used in the patent, which describes an analog-style phase control timed to an AC waveform (’275 Patent, col. 6:9-12). Another question may be whether a feature allowing a user to select a static color on an accused device meets the claim limitation of "terminat[ing] the variation upon activation of a user-operable input."
  • For the ’206 Patent: The primary technical question will be whether the accused products’ control circuitry performs the specific function claimed: actively measuring the AC “voltage frequency” and responsively “adjust[ing] the current draw” based on that measurement. A potential defense could argue that the accused products use a frequency-agnostic power supply or a different form of power regulation that does not perform the claimed adjustment, thereby creating a mismatch in technical operation.

V. Key Claim Terms for Construction

For the ’275 Patent

  • The Term: "conduction interval"
  • Context and Importance: This term is the mechanism by which the patented invention controls color. The scope of this term will be critical in determining whether the specific electronic control methods used in the accused products infringe. Practitioners may focus on whether this term is limited to the analog phase-control techniques disclosed or also covers digital duty-cycle modulation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the effect of varying the term functionally, stating that as the conduction interval for one LED decreases and the other increases, "the colour of light emanating from the bicoloured lamps . . . will gradually change" (’275 Patent, col. 6:18-24). This functional description could support an interpretation covering any technique that modulates the "on" time of the LEDs to blend colors.
    • Evidence for a Narrower Interpretation: The detailed operational description explains a specific implementation where a microcontroller "delays a predetermined period" after a zero-crossing of the AC wave before issuing a pulse to a bidirectional switch (’275 Patent, col. 6:9-12). This could support an argument that "conduction interval" is tied specifically to this method of phase-angle control relative to an AC sine wave.

For the ’206 Patent

  • The Term: "adjust the current draw in accordance with the voltage frequency"
  • Context and Importance: This limitation appears to be the novel contribution of the ’206 patent over the parent ’275 patent. Infringement of the ’206 patent claims will likely hinge entirely on whether the accused products perform this specific adaptive function.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is functional and does not specify how the adjustment must be made, which may support a reading on any system that alters its power consumption in response to a change in AC frequency to maintain performance.
    • Evidence for a Narrower Interpretation: The specification provides a detailed method for achieving this function, wherein the controller "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" in order to "accurately track the actual conduction interval" (’206 Patent, col. 12:29-35). This detailed disclosure may be used to argue that the claim is limited to systems that explicitly measure frequency via zero-crossings and use it to correct timing, rather than other forms of adaptive power regulation.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that the Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" the patents-in-suit (Compl. ¶15, ¶24).

Willful Infringement

While the complaint does not use the term "willful," it lays a foundation for such a claim based on post-filing conduct. It alleges that the service of the complaint "constitutes actual knowledge of infringement" and that despite this knowledge, the Defendant "continues to make, use, test, sell, offer for sale, market, and/or import" the infringing products (Compl. ¶14-15, ¶23-24).

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

  1. A threshold evidentiary question will be the identification of the "Exemplary Defendant Products." As the complaint lacks any specific product identification or technical description, discovery will be required to establish the basic facts of what technology is being accused and how it operates before any substantive infringement analysis can occur.
  2. A core issue will be one of technical and definitional scope: Does the control circuitry in the accused products function by varying a "conduction interval" tied to an AC waveform, as claimed in the ’275 patent? Further, does that circuitry perform the specific adaptive function of measuring the "voltage frequency" and "adjust[ing] the current draw" accordingly, as required by the claims of the ’206 patent, or is there a fundamental mismatch in technical operation?
  3. A central question of claim construction will be whether the terms "conduction interval" and "adjust... in accordance with the voltage frequency" are limited to the specific phase-angle control and zero-crossing detection methods described in the specifications, or if they can be construed more broadly to cover other modern digital control and power regulation techniques.