Luminatronics LLC v. Semiconductor Components Industries LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Luminatronics LLC (Delaware)
  • Defendant: Semiconductor Components Industries, LLC (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01477, D. Del., 12/08/2025
• 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, has committed acts of patent infringement in the District, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s unidentified products infringe a patent related to electronic circuits for driving Light Emitting Diodes (LEDs).
• Technical Context: The technology concerns power conversion circuits designed to improve the efficiency and power factor of LED lighting systems when powered by a standard alternating current (AC) source.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 9,807,836 - "Light emitting diode light structures"

• Patent Identification: U.S. Patent No. 9,807,836, "Light emitting diode light structures," issued October 31, 2017.

The Invention Explained

• Problem Addressed: When driving a string of LEDs directly from a rectified AC power source, the LEDs only conduct current and produce light during the high-voltage peaks of the AC cycle. This results in a low power factor, where the current draw is not aligned with the voltage supply, and can cause undesirable flicker in the light output ('836 Patent, col. 1:46-59; col. 2:54-65).
• The Patented Solution: The invention proposes a circuit that dynamically shortens the string of active LEDs during the lower-voltage portions of the AC cycle. Control circuitry monitors the rectified voltage and, when it falls below a set threshold, activates a switch that bypasses a segment of the LED string ('836 Patent, Abstract). This allows the remaining, smaller group of LEDs to activate at a lower voltage, enabling them to draw current and emit light for a larger portion of the AC cycle. This approach is intended to improve the overall power factor and increase the average light output ('836 Patent, col. 7:55 - col. 8:8; Fig. 6).
• Technical Importance: This circuit design aims to improve the electrical efficiency of AC-driven LED lights using relatively simple electronics, avoiding more complex and costly power conversion methods while addressing the inherent non-linear behavior of LEDs ('836 Patent, col. 2:54-62).

Key Claims at a Glance

• The complaint asserts "one or more claims" but does not specify which ones (Compl. ¶11). Independent claim 1 is representative of the core invention.
• Essential elements of Independent Claim 1:
  • A bridge rectifier configured to be powered by an alternating current power source and to produce a rectified output.
  • Control circuitry coupled to the bridge rectifier, configured to produce a shunt signal when the rectified output is less than a threshold voltage.
  • A series connected Light Emitting Diode (LED) string coupled directly to the bridge rectifier, having a first group of LEDs and a second group of LEDs.
  • A switch coupled to a first side of the second group of LEDs and controlled by the shunt signal to deactivate the second group of LEDs.
• The complaint does not explicitly reserve the right to assert dependent claims, but its general allegation for "one or more claims" may be interpreted to include them (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products by name. It refers to "Exemplary Defendant Products" that are allegedly identified in charts incorporated as Exhibit 2 (Compl. ¶11). This exhibit was not provided with the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It alleges generally that Defendant makes, uses, sells, and imports infringing products (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, "charts comparing the Exemplary '836 Patent Claims to the Exemplary Defendant Products" as Exhibit 2 (Compl. ¶16). It alleges that these charts demonstrate that the accused products "satisfy all elements of the Exemplary '836 Patent Claims" (Compl. ¶16). Without the specific products or the claim charts, a substantive analysis of the infringement theory is not possible based on the complaint alone. The narrative allegations are conclusory and lack specific factual support linking any particular product feature to a claim element.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

Based on the language of independent claim 1 of the ’836 Patent, the following terms may be central to the dispute.

Term for Construction: "deactivate the second group of LEDs"

• Context and Importance: This term defines the core function of the claimed invention. The interpretation of "deactivate" will determine what specific technical operations in an accused product fall within the claim's scope. Practitioners may focus on this term because the patent's preferred embodiments show a specific method of deactivation—shunting current around the LEDs—and a dispute may arise over whether other methods of turning LEDs off are covered.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain meaning of "deactivate" could encompass any method of rendering the LEDs non-operational or turning them off. The claim language does not explicitly limit the term to shunting or bypassing.
  • Evidence for a Narrower Interpretation: The specification consistently describes the switch's function as creating a bypass. For example, it states the switch "couples across the second group of LEDs" and is "connected in shunt across the second group of LEDs" (’836 Patent, col. 7:29-31, 50-52). The claim requires the switch to be controlled by a "shunt signal," which may further tie the meaning of "deactivate" to the specific act of shunting (’836 Patent, col. 22:15-16).

Term for Construction: "threshold voltage"

• Context and Importance: The value of this "threshold voltage" dictates when the claimed switching action occurs. Its definition is critical for determining infringement, as it defines the operational trigger for the patented functionality.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim term itself does not specify how the threshold is determined, leaving open the possibility that it could be a fixed, predetermined voltage.
  • Evidence for a Narrower Interpretation: The specification describes the control circuitry as a "ratio metric series resistor string configured to sense a proportion of the rectified output" (’836 Patent, col. 7:40-43). It further explains the threshold voltage is "equal to a portion of the peak voltage, e.g., 100%, 90%, 80%, 70%, 60%, etc." (’836 Patent, col. 7:58-60). This suggests the "threshold voltage" is not an absolute value but is dynamically related to the input voltage.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, stating that since the filing of the complaint, Defendant has "knowingly, and intentionally continued to induce infringement" by selling products to customers for infringing uses (Compl. ¶15). It also alleges that Defendant distributes "product literature and website materials inducing end users" to use its products in an infringing manner, referencing materials in the unattached Exhibit 2 (Compl. ¶14).

Willful Infringement

• Willfulness allegations are predicated on post-suit knowledge. The complaint alleges that service of the complaint and its attached claim charts "constitutes actual knowledge of infringement" and that Defendant's continued activities thereafter are willful (Compl. ¶13-14). Plaintiff requests a declaration that the case is "exceptional" under 35 U.S.C. § 285 (Compl. ¶ E.i.).

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

• A central evidentiary question will be one of factual specificity: The complaint makes conclusory infringement allegations while relying on an unattached exhibit. A threshold issue will be whether Plaintiff can produce sufficient factual evidence to connect the specific technical operation of any identified accused product to the limitations of the asserted patent claims.
• A core issue will be one of claim scope: The case will likely turn on the construction of the term "deactivate." The key question for the court will be whether this term is limited to the shunting/bypassing mechanism heavily featured in the patent’s specification, or if it can be construed more broadly to cover other electronic methods of switching off a segment of LEDs.
• A further question of technical operation will concern the "threshold voltage." The dispute may focus on whether the accused products, if they perform a similar function, trigger it based on a proportional sensing of the input voltage as described in the patent's embodiments, or use a different triggering logic that falls outside a potentially narrowed claim construction.