DCT

6:25-cv-00037

SemiLED Innovations LLC v. Green Creative LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-00037, M.D. Fla., 01/09/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Middle District of Florida because Defendants have committed acts of infringement and maintain regular and established places of business in the district, specifically citing a shared business address in Sanford, Florida.
  • Core Dispute: Plaintiff alleges that Defendants’ residential and commercial LED lighting products infringe four patents related to the structural design, thermal management, and electrical configuration of LED packages and modules.
  • Technical Context: The patents concern fundamental aspects of LED component design, aiming to improve slimness, heat dissipation, and current distribution, which are critical factors for the performance, longevity, and efficiency of modern lighting fixtures.
  • Key Procedural History: The complaint does not allege any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit. The complaint does note that Defendants GC and ILP merged under a parent company, ILLUMUS, and have combined operations.

Case Timeline

Date Event
2004-07-01 ’454 Patent Priority Date
2006-10-31 ’454 Patent Issue Date
2007-12-03 ’196 and ’942 Patents Priority Date
2010-01-07 ’971 Patent Priority Date
2012-11-13 ’971 Patent Issue Date
2015-02-24 ’196 Patent Issue Date
2016-12-27 ’942 Patent Issue Date
2025-01-09 Complaint Filing Date

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

U.S. Patent No. 8,963,196 - "Slim LED package"

  • Patent Identification: U.S. Patent No. 8,963,196, titled "Slim LED package," issued on February 24, 2015 (Compl. ¶16).

The Invention Explained

  • Problem Addressed: The patent’s background section identifies several problems with prior art LED packages, including excessive thickness that made fabricating thin packages difficult, and a "yellowing phenomenon" in the encapsulation material caused by heat, which degraded luminescence and lifetime (’196 Patent, col. 1:50-57). Previous solutions, such as adding a heat dissipation slug, were said to complicate the manufacturing process (Compl. ¶21).
  • The Patented Solution: The invention proposes a slimmer LED package design where the LED chip is mounted in a "chip mounting recess" formed by reducing the thickness of a region on a lead frame (’196 Patent, col. 2:62-66). This design allows the thickness of the LED chip to partially overlap with the thickness of the lead frame, reducing the overall package height (Compl. ¶22). Additionally, the design allegedly increases the bottom-exposed area of the lead frame, which improves thermal dissipation efficiency (Compl. ¶23; ’196 Patent, col. 3:1-5).
  • Technical Importance: This approach aimed to enable the creation of thinner, more thermally efficient LED packages, which is a critical factor for integrating high-power LEDs into compact and aesthetically demanding lighting applications (Compl. ¶23).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2 and 8 (Compl. ¶48).
  • Independent Claim 1 recites the following essential elements:
    • A light emitting diode (LED) package, comprising:
    • a first lead frame and a second lead frame separated from each other;
    • an LED Chip disposed on the first lead frame and electrically connected to the first lead frame and the second lead frame;
    • a wire connecting the LED chip to the second lead frame;
    • wherein opposing sides of the first lead frame and the second lead frame face each other in a slanted state to the other sides of the lead frame.
  • The complaint reserves the right to modify its infringement contentions based on discovery (Compl. ¶48).

U.S. Patent No. 9,530,942 - "Slim LED Package"

  • Patent Identification: U.S. Patent No. 9,530,942, titled "Slim LED Package," issued on December 27, 2016 (Compl. ¶24).

The Invention Explained

  • Problem Addressed: Similar to the ’196 Patent, the ’942 Patent addresses the problems of excessive thickness in prior art lead frame type LED packages and the "yellowing phenomenon" of encapsulation material that reduces performance and lifetime (’942 Patent, col. 1:57-62; Compl. ¶29).
  • The Patented Solution: The patent describes a solution that improves thermal dissipation and reduces package thickness. It discloses a lead frame with a larger exposed bottom area to improve heat transfer and a "chip mounting recess" that allows the LED chip's thickness to overlap with the lead frame's thickness, thereby creating a slimmer profile (’942 Patent, col. 3:1-11; Compl. ¶30). The claims focus on specific structural features of the lead frames, such as grooves on their lower surfaces.
  • Technical Importance: This design sought to improve the mechanical and thermal properties of slim LED packages, enhancing both manufacturability and long-term reliability in lighting products (Compl. ¶31).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claim 3 (Compl. ¶61).
  • Independent Claim 1 recites the following essential elements:
    • A light emitting diode (LED) package, comprising;
    • a first lead frame and a second lead frame separated from each other;
    • an LED Chip disposed on the first lead frame and electrically connected with the second lead frame;
    • a resin covering at least portions of surfaces of the first and second lead frames, wherein;
    • at least one of the first and second lead frames comprises a first edge facing the other lead frame and a second side opposite the first side;
    • the first lead frame comprising a first groove disposed on a lower surface thereof, and the second lead frame comprises a second groove disposed on the lower surface thereof;
    • each of the first and second grooves is open only on the lower surfaces of the first and second lead frames, respectively; and;
    • a depth of the first groove is equal to a depth of the second groove.
  • The complaint reserves the right to modify its infringement contentions based on discovery (Compl. ¶61).

U.S. Patent No. 8,309,971 - "Light emitting diode having electrode pads"

  • Patent Identification: U.S. Patent No. 8,309,971, titled "Light emitting diode having electrode pads," issued November 13, 2012 (Compl. ¶32).
  • Technology Synopsis: The patent addresses inefficient current distribution within the semiconductor layers of large, high-output LEDs (Compl. ¶¶36-37). Prior solutions using transparent electrode layers were limited by light absorption. The invention provides novel electrode pad and extension structures that are spaced apart from the semiconductor layer to enhance current spreading across the LED, thereby improving luminous efficacy (Compl. ¶38).
  • Asserted Claims: The complaint asserts claim 1 (Compl. ¶76).
  • Accused Features: The complaint accuses the internal light-emitting diodes within the Green Creative A19 9W product of infringing the ’971 Patent, providing annotated scanning electron microscope (SEM) images, such as Figure 3B-9, to illustrate the allegedly infringing electrode pad and extension structures (Compl. ¶¶76-77, 84).

U.S. Patent No. 7,128,454 - "Light emitting diode module for automobile headlights and automobile headlight having the same"

  • Patent Identification: U.S. Patent No. 7,128,454, titled "Light emitting diode module for automobile headlights and automobile headlight having the same," issued October 31, 2006 (Compl. ¶39).
  • Technology Synopsis: The patent addresses the need for LED modules with integrated protection from heat and moisture, which were shortcomings in the prior art as LEDs replaced traditional halogen lamps (Compl. ¶44). The invention discloses an LED module with a combined waterproof structure and a heat-radiating structure, designed to prevent the "permeation of external moisture while efficiently radiating heat to the outside" (Compl. ¶45).
  • Asserted Claims: The complaint asserts claims 1 and 15 (Compl. ¶90).
  • Accused Features: The complaint accuses the Green Creative INNOFIT 8” Commercial Downlight of infringing the ’454 Patent by allegedly incorporating the claimed module structure. Figure 4B-6 from the complaint shows the product's "modular body" and "through hole," features which are alleged to meet claim limitations (Compl. ¶¶91, 93).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Defendants’ residential and commercial LED lighting products, including the Green Creative A19 9W, Green Creative INNOFIT 8" Commercial Downlight, ILP RB4 Round High Bay, and ILP Slim Wall Pack (Compl. ¶2).

Functionality and Market Context

  • The complaint alleges these products are lighting fixtures that incorporate infringing LED packages and modules at their core (Compl. ¶¶49, 62, 77, 91). The infringement allegations focus on the micro-level structural components of these internal LEDs. The complaint provides extensive visual evidence, including photographs of the fully assembled products alongside annotated, magnified images of their internal lead frames, LED chips, and wiring (Compl. pp. 13-22, 24-35). For example, Figure 1A-3 shows the ILP RB4 Round High Bay product, while Figure 1A-4 shows a close-up of the LED component within it (Compl. ¶49). Defendants are alleged to market, distribute, and sell these products throughout the United States (Compl. ¶¶2, 11).

IV. Analysis of Infringement Allegations

'8,963,196 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first lead frame and a second lead frame separated from each other The accused products contain two distinct lead frames with a physical separation between them, as shown in annotated photographs. Figure 1B-1 provides a magnified, cross-sectional view of an accused LED package, explicitly labeling the "First Lead Frame," "Second Lead Frame," and the "Separation between lead frames." ¶50 col. 4:42-57
an LED Chip disposed on the first lead frame and electrically connected to the first lead frame and the second lead frame The accused products' LED chip is mounted on the first lead frame and has electrical connections to both lead frames. ¶51 col. 4:45-50
a wire connecting the LED chip to the second lead frame A bonding wire is used to create the electrical connection between the LED chip and the second lead frame. Figure 1B-10 presents an annotated photograph showing the "LED Chip," the "Second lead frame," and the "Wire" connecting them. ¶52 col. 4:63-65
wherein opposing sides of the first lead frame and the second lead frame face each other in a slanted state to the other sides of the lead frame The internal-facing sides of the lead frames in the accused products are angled. The complaint's Figure 1B-13 provides a close-up photograph with arrows indicating the "Opposing Sides" have a slanted geometry. ¶53 col. 6:15-24

Identified Points of Contention

  • Scope Questions: The infringement analysis may focus on the construction of "slanted state." A central question will be whether this term requires a specific angle, a particular manufacturing method, or the functional purpose of dispersing force on the encapsulation material, as described in the patent’s specification (’196 Patent, col. 6:29-37).
  • Technical Questions: The complaint provides photographic evidence purporting to show the slanted structure (Compl. ¶53). The technical question for the fact-finder will be whether the accused structures, as manufactured, actually possess sides that are in a "slanted state" relative to other sides of the lead frame, as required by the claim.

'9,530,942 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a resin covering at least portions of surfaces of the first and second lead frames The accused products' lead frames are covered by a resin material. Figure 2B-7 is a photograph annotated to show the "Resin covering portion of the first and second lead frames." ¶65 col. 3:17-19
the first lead frame comprising a first groove disposed on a lower surface thereof, and the second lead frame comprises a second groove disposed on the lower surface thereof The undersides of both lead frames in the accused products contain grooves. The complaint’s Figure 2B-16 provides a photograph annotated to show the "First Groove" and "Second Groove" on the respective lead frames. ¶67 col. 4:56-61
each of the first and second grooves is open only on the lower surfaces of the first and second lead frames, respectively The grooves are depicted as being open only on the bottom surfaces of the lead frames. ¶68 col. 4:56-61
a depth of the first groove is equal to a depth of the second groove The complaint alleges that the grooves in the accused products have equal depths. ¶69 col. 2:67-3:4

Identified Points of Contention

  • Scope Questions: A primary dispute may arise over the term "equal." The question for the court will be whether "equal" requires strict mathematical identity or if it can be construed to mean "substantially equal," thereby accommodating for normal manufacturing tolerances.
  • Technical Questions: A factual question will be whether the grooves in the accused products actually have equal depths. This may require expert testimony and analysis of physical samples to determine if the products meet this precise dimensional limitation.

V. Key Claim Terms for Construction

’196 Patent

The Term

  • "slanted state"

Context and Importance

  • This term defines the core structural innovation of claim 1, describing the orientation of the lead frames. The scope of this term is critical, as it dictates the specific geometry required for an LED package to infringe. Practitioners may focus on this term because the complaint’s evidence relies on visual interpretation of photographs, which may be contested.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The claim language itself does not specify a numerical angle or range, merely requiring a "slanted state." This suggests any non-perpendicular or non-parallel orientation could fall within the claim's scope.
  • Evidence for a Narrower Interpretation: The specification links this structure to a specific function: "the slant parts 125, 145 disperse the force diagonally, thereby preventing the encapsulation material from being broken" and helping to "more rigidly hold the encapsulation material" (’196 Patent, col. 6:29-37). A defendant may argue that the term should be limited to structures that achieve this stated functional advantage.

’942 Patent

The Term

  • "a depth of the first groove is equal to a depth of the second groove"

Context and Importance

  • This limitation imposes a specific and measurable dimensional relationship between two separate features of the LED package. Infringement of the claim depends entirely on whether this condition of equality is met in the accused products.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification describes the presence of grooves to increase bonding force but does not emphasize or explain any technical reason for why their depths must be equal (’942 Patent, col. 4:56-64). A plaintiff could argue that, absent a specific technical reason for strict equality, the term should be interpreted to encompass minor, unintentional variations inherent in manufacturing.
  • Evidence for a Narrower Interpretation: The plain meaning of "equal" implies exact correspondence. A defendant will likely argue that the patentee chose this precise term and should be held to it, meaning any measurable difference in depth would place a product outside the claim's scope.

VI. Other Allegations

Indirect Infringement

  • The complaint includes conclusory allegations of indirect infringement for all four patents-in-suit (Compl. ¶¶ 47, 60, 75, 89). However, the complaint does not provide sufficient detail for analysis of the factual basis for these claims, as it does not plead specific facts demonstrating knowledge of the patents or intent to encourage infringement by others.

Willful Infringement

  • The complaint does not explicitly allege willful infringement. It does, however, request for each patent that the case be found "exceptional" under 35 U.S.C. § 285, which would entitle the plaintiff to an award of attorneys' fees (Compl. ¶¶ 56, 71, 85, 97). The complaint does not plead facts typically associated with willfulness, such as pre-suit knowledge of the patents or egregious infringement conduct.

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

The resolution of this case will likely depend on the court’s interpretation of key claim terms and the factual evidence presented regarding the accused products' precise structures. The central questions raised by the complaint are:

  1. A core issue will be one of definitional scope: How will the term "slanted state" in the ’196 patent be construed? Will its meaning be determined by the geometric orientation shown in photographs, or will it be functionally limited to structures that provide the force-dispersing benefits described in the patent’s specification?

  2. A key evidentiary question will be one of dimensional precision: Does the ’942 patent’s requirement that two groove depths be "equal" demand strict mathematical identity, or does it permit minor variations common in mass manufacturing? This determination will be critical to the infringement analysis for that patent.

  3. A broader strategic question involves the relationship between the patents: The plaintiff has asserted four patents with overlapping subject matter against the same product line. This raises the question of how the distinct infringement theories—from the general module structure of the ’454 patent to the specific lead frame geometry of the ’196 and ’942 patents—will interact and whether infringement of one patent necessarily implies infringement of another.