1:25-cv-01566
Semisilicon Technology Corp v. inMusic LLC
I. Executive Summary and Procedural Information
Parties & Counsel:
- Plaintiff: Semisilicon Technology Corp. (Taiwan)
- Defendant: inMusic, LLC (Delaware)
- Plaintiff’s Counsel: McCarter & English, LLP; Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
Case Identification: 1:25-cv-01566, D. Del., 12/29/2025
Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant, inMusic, LLC, is a Delaware corporation.
Core Dispute: Plaintiff alleges that Defendant’s ION Audio-branded products incorporating multi-color LED lighting features infringe a patent related to integrated LED package structures.
Technical Context: The technology concerns the design and packaging of light-emitting diodes (LEDs) that integrate control circuitry, enabling individual digital control and simplified assembly into complex lighting arrays.
Key Procedural History: The patent-in-suit survived a reexamination proceeding, with a certificate issued on December 13, 2024, confirming the patentability of the original claims asserted in this case. The complaint also alleges that Plaintiff provided Defendant with notice of infringement on May 15, 2025, and that subsequent negotiations failed to resolve the dispute, which may form the basis for a willfulness claim.
**Case Timeline**
| Date | Event |
|---|---|
| 2008-05-28 | ’988 Patent Priority Date |
| 2012-02-28 | ’988 Patent Issue Date |
| 2024-12-13 | ’988 Patent Reexamination Certificate Issued |
| 2025-05-15 | Plaintiff allegedly provided Defendant with notice of infringement |
| 2025-10-02 | Defendant allegedly provided limited sales information |
| 2025-10-30 | Plaintiff allegedly requested complete sales information |
| 2025-11-03 | Defendant allegedly refused to cooperate further |
| 2025-12-29 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 8,124,988, “Light emitting diode lamp package structure and assembly thereof,” issued February 28, 2012.
The Invention Explained
- Problem Addressed: The patent’s background section describes prior art LED lamp packages as lacking integrated data input and output pins. This limitation complicates the design of controllers for lamp strings, as the control logic must be external, and the complexity increases with the number of LEDs in the string (ʼ988 Patent, col. 1:41-50).
- The Patented Solution: The invention integrates a control circuit (IC) directly into the same package as a plurality of LEDs (e.g., red, green, blue). This integrated package features dedicated conductors for power (Vdd, Vss), data input (Din), and data output (Dout), all encapsulated in a single body (ʼ988 Patent, Abstract; col. 4:26-31). This architecture allows individual LED lamps to receive control data, adjust their illumination state, and pass control data to the next lamp in a series, simplifying the overall design of complex lighting systems (ʼ988 Patent, Fig. 1).
- Technical Importance: This approach transforms a simple light-emitting component into an individually addressable "smart" pixel, facilitating the creation of sophisticated, large-scale, and dynamically controlled lighting displays and effects with simplified wiring (ʼ988 Patent, col. 1:56-62).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶11).
- The essential elements of independent claim 1 include:
- A plurality of light emitting diodes (LEDs) with a common electrode end.
- A control integrated circuit (IC) with data input/output and positive/negative power-in electrodes, electrically connected to the LEDs to control their illumination based on external data.
- A set of four distinct conductors (first, second, third, fourth) connected to specific points:
- First conductor (positive DC voltage pad) connected to the common electrode of the LEDs and the positive power-in electrode of the IC.
- Second conductor connected to the data input electrode of the IC.
- Third conductor connected to the data output electrode of the IC.
- Fourth conductor (negative DC voltage pad) connected to the negative power-in electrode of the IC.
- A package body that encapsulates the LEDs, the IC, and the conductors, leaving a portion of each of the four conductors exposed to the outside.
- The complaint does not explicitly reserve the right to assert dependent claims, but states infringement of "one or more claims" (Compl. ¶10).
III. The Accused Instrumentality
Product Identification
The complaint identifies the "ION Audio Uber Boom Ultra" as a primary infringing product and lists dozens of other ION Audio-branded products with similar LED features (Compl. ¶¶12, 23).
Functionality and Market Context
The accused Uber Boom Ultra is a portable Bluetooth speaker that "features multi-colored LED lighting that moves and changes in response to the beat of the music" (Compl. ¶12). The complaint alleges that this product, and others sold under the ION Audio brand, incorporates an "LED lamp package structure" that infringes the ’988 Patent (Compl. ¶13). An annotated teardown photograph of the accused product's LED component is provided to illustrate its internal structure (Compl. p. 6). The complaint alleges these products are marketed and sold throughout the United States (Compl. ¶8).
IV. Analysis of Infringement Allegations
’988 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a plurality of light emitting diodes, each light emitting diode having two electrode ends and one of the electrode ends being a common electrode end | The accused product includes multiple LEDs (annotated as red, green, and blue) inside a package body, with one electrode end identified as a common connection to a positive power terminal ("V+") (Compl. p. 7). | ¶¶14-15 | col. 8:27-30 |
| a control integrated circuit, having a data input electrode, a data output electrode, a positive power-in electrode, and a negative power-in electrode, and electrically connected to the light emitting diodes, wherein the control integrated circuit receives external control data...to control the illumination state... | The accused product contains a control IC with electrodes for data input, data output, and power. This IC is alleged to receive external control data to control the illumination of the LEDs (Compl. p. 8). | ¶¶16-18 | col. 8:30-38 |
| a first conductor, a second conductor, a third conductor, and a fourth conductor, the first conductor being a positive direct current ("DC") voltage pad and connected to the common electrode...and the positive power-in electrode...the second...connected to the data input electrode, the third...connected to the data output electrode, the fourth...being a negative DC voltage pad... | The accused product's LED package allegedly has four external pads: a positive DC voltage pad (V+), a data input pad (DI), a data output pad (DO), and a negative DC voltage pad (V-), connected as required by the claim (Compl. p. 11). | ¶¶20-21 | col. 8:39-48 |
| a package body encapsulating the light emitting diodes, the control integrated circuit and the conductors, a portion of the first conductor, the second conductor, the third conductor, and the fourth conductor being exposed outside the package body. | The accused LED component has a package body, allegedly formed of white and transparent glue, which encapsulates the internal components while leaving the four external conductor pads exposed for connection (Compl. p. 12). | ¶22 | col. 8:49-54 |
- Identified Points of Contention:
- Scope Questions: The case may involve a dispute over the definition of "conductor." The complaint alleges that the flat surface-mount pads on the accused device meet this limitation (Compl. p. 11). The defense could argue that the term, in the context of the patent, implies a more substantial structure than a simple pad on a printed circuit board.
- Technical Questions: The complaint provides oscilloscope waveforms as evidence that the accused IC controls the LEDs using 8-bit digital signals for each color (Compl. p. 9). A key technical question for the court will be whether this evidence is sufficient to prove that the accused IC performs the specific function of receiving "external control data" and using it to "control the illumination state of each light emitting diode" as claimed.
V. Key Claim Terms for Construction
The Term: "conductor" (specifically, the "first conductor," "second conductor," etc.)
Context and Importance: The claim requires a specific arrangement and connection of four "conductors" that are partially encapsulated and partially exposed. The physical structure that satisfies this term is central to the infringement analysis. Practitioners may focus on this term because the accused device uses surface-mount pads, and the defendant may argue these do not meet the structural requirements of a "conductor" as described in the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification repeatedly refers to these elements as "conductivity supports" and "pads," suggesting the term is not limited to a specific shape like a wire or pin (ʼ988 Patent, Abstract; col. 2:5-13). Claim 1 itself refers to the first conductor as a "positive DC voltage pad."
- Evidence for a Narrower Interpretation: Many figures in the patent depict the "conductivity supports" as distinct physical legs or pins extending from the package body, which could be argued to limit the term to such structures (ʼ988 Patent, Figs. 2A, 5, 6A).
The Term: "control integrated circuit"
Context and Importance: This term defines the "brains" of the invention. The infringement case depends on showing the accused device's chip performs all the functions recited for the claimed "control integrated circuit," including receiving external data and controlling each LED.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the function of the IC in general terms: it "receives external control data via the Din, and controls the luminosity or flashing of LED 11 according to said control data, and outputs the control data via the Dout" (ʼ988 Patent, col. 4:26-30). This functional description could be read to cover any IC that performs these actions.
- Evidence for a Narrower Interpretation: The defense might argue that the term requires an IC with the specific architecture shown in the patent's block diagram (Fig. 1) or one that is distinct from the LEDs themselves, rather than a monolithic chip-on-board solution. The claim, however, recites the element primarily by its functional connections and capabilities.
VI. Other Allegations
- Indirect Infringement: The complaint makes a blanket allegation of infringement under 35 U.S.C. § 271(b) and (c) but does not plead specific facts to support the knowledge and intent elements required for induced or contributory infringement, such as referencing user manuals that instruct infringing use (Compl. ¶10).
- Willful Infringement: The complaint alleges that Plaintiff provided Defendant with actual notice of infringement of the ’988 Patent on May 15, 2025 (Compl. ¶25). It further alleges that after this notice, Defendant continued to sell the accused products and failed to negotiate in good faith, which forms the basis for the allegation that the infringement was willful and egregious (Compl. ¶¶25, 27).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Will the term "conductor," as used in Claim 1, be construed broadly enough to read on the flat, surface-mount electrical pads of the accused LED component, or will it be limited to the more pin-like structures depicted in some of the patent’s embodiments?
- A key evidentiary question will be one of functional proof: Can the Plaintiff demonstrate, through technical evidence like the provided oscilloscope waveforms and any subsequent analysis, that the accused "control integrated circuit" performs every claimed function, particularly receiving external data to independently control the illumination state of each individual LED within the package?
- The allegation of willfulness will depend on the factual record developed around the pre-suit notice provided in May 2025. The court will examine the nature of the notice and the subsequent conduct of the Defendant to determine if the alleged continued infringement was objectively reckless.