BridgeComm LLC v. Cree Lighting USA LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: BridgeComm LLC (TX)
  • Defendant: Cree Lighting USA LLC (IL)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-04764, N.D. Ill., 04/30/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant 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 variable-effect lighting systems infringe patents related to controlling the color and display patterns of multi-colored lamps, particularly those powered by an AC source.
• Technical Context: The patents relate to the control of decorative and festive lighting systems, such as LED light strings, to produce dynamic color-changing effects.
• Key Procedural History: The U.S. Patent No. 8,390,206 is a continuation of the application that resulted in U.S. Patent No. 8,203,275. No other prior litigation, licensing, or administrative proceedings are mentioned in the complaint.

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: The patent describes a need for a "relatively simple variable-effect lighting system which allows for greater variation in the range of colour displays" than was available from prior art systems, which were often complex or limited in their display capabilities ('275 Patent, col. 2:6-9).
• The Patented Solution: The invention uses a plurality of multi-colored lamps (e.g., bi-color LEDs) connected in series with an AC voltage source ('275 Patent, col. 2:17-20). A lamp controller varies the color output by adjusting the "conduction interval" for each illuminating element within the lamps according to a "predetermined pattern" ('275 Patent, col. 2:21-23). A key feature is a user-operable input that can stop the color-changing variation and a non-volatile memory that stores the setting, allowing the system to resume the selected display even after being powered off and on again ('275 Patent, col. 27:51-61).
• Technical Importance: This approach aimed to provide sophisticated, user-selectable lighting effects in a cost-effective manner suitable for consumer products like decorative light strings, without requiring complex control hardware for each lamp. (Compl. ¶8; ’275 Patent, col. 3:56-59).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring only to "Exemplary '275 Patent Claims" identified in an unprovided exhibit (Compl. ¶12). Independent claim 1 is representative.
• Independent Claim 1: A variable-effect lighting system comprising:
  • A lamp assembly with multiple multi-colored lamps connected in series with an AC voltage source.
  • Each lamp has at least a first and a second illuminating element for producing different colors.
  • A lamp controller that varies the color by varying a "conduction interval" of each illuminating element according to a "predetermined pattern."
  • The controller is configured to "terminate the variation" when a user-operable input is activated.
  • The controller includes a non-volatile memory to retain a "datum associated with the conduction interval" upon user activation.
  • The controller is configured to use the retained datum to set the display upon "re-application of power."
• The complaint reserves the right to assert other claims, which may include dependent claims (Compl. ¶12).

U.S. Patent No. 8,390,206 - “Variable-effect lighting system,” issued March 5, 2013

The Invention Explained

• Problem Addressed: The patent, a continuation of the '275 patent's application, addresses a specific problem: lighting controllers that assume a fixed AC power frequency (e.g., 60 Hz) will produce unpredictable or incorrect visual effects if used on a power grid with a different frequency (e.g., 50 Hz), because the timing of the control signals will be mismatched with the AC waveform ('206 Patent, col. 11:1-24).
• The Patented Solution: The invention proposes a controller that actively adapts to the power source. The controller measures the time between zero-crossings of the AC voltage to determine the actual line frequency ('206 Patent, col. 11:25-34). It then uses this measured frequency to "adjust the current draw" for the illuminating elements, ensuring that the intended color-changing patterns are displayed correctly and reliably regardless of the input power frequency ('206 Patent, Abstract; col. 12:1-7).
• Technical Importance: This solution provides for self-synchronizing and robust operation of lighting effects, making a single product design compatible with different international power standards without modification. ('206 Patent, col. 11:25-34).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring only to "Exemplary '206 Patent Claims" identified in an unprovided exhibit (Compl. ¶21). Independent claim 1 is representative.
• Independent Claim 1: A variable-effect lighting system comprising:
  • A lamp assembly with multiple multi-colored lamps connected in series with an AC voltage source having a frequency.
  • Each lamp has at least a first and a second illuminating element.
  • A lamp controller for "controlling a current draw" of each illuminating element.
  • The controller is configured to "adjust the current draw in accordance with the voltage frequency."
• The complaint reserves the right to assert other claims, which may include dependent claims (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products or services by name. It refers generally to "Exemplary Defendant Products" that are identified in claim chart exhibits incorporated by reference but not attached to the pleading (Compl. ¶12, ¶17, ¶21).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market context. The allegations are limited to the assertion that these unidentified products "practice the technology claimed" by the patents-in-suit (Compl. ¶17, ¶26).

IV. Analysis of Infringement Allegations

The complaint’s substantive infringement allegations for both the ’275 and ’206 patents are presented by incorporating external exhibits by reference (Exhibits 3 and 4), which are not included with the filed complaint (Compl. ¶18, ¶27). The pleading states these exhibits contain "charts comparing the Exemplary Patent Claims to the Exemplary Defendant Products" (Compl. ¶17, ¶26). Without these exhibits, a detailed analysis of the infringement theory is not possible based on the complaint alone. No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Questions: The central issue for the initial phase of the case will be identifying the specific accused products and the evidence supporting the allegation that they meet each limitation of the asserted claims. The complaint's reliance on unprovided exhibits leaves all specific factual mappings unsupported in the pleading itself.
  • Technical Questions (’206 Patent): A potential point of contention for the ’206 Patent will be whether the accused products perform the specific function of measuring the AC voltage frequency and adjusting their operation "in accordance with" that measured frequency, as required by its claims ('206 Patent, col. 22:10-13). The infringement analysis may hinge on whether the accused products contain circuitry and logic for this adaptive timing function, or if they operate on a fixed-timing basis.
  • Technical Questions (’275 Patent): For the ’275 Patent, a key question may be whether the accused products include a "non-volatile memory" used to store and recall a user-selected lighting state after a power cycle, as recited in claim 1 ('275 Patent, col. 27:51-61).

V. Key Claim Terms for Construction

For the ’275 Patent:

• The Term: "predetermined pattern"
• Context and Importance: This term is central to how the controller varies the color of the lights. Its definition will determine whether a simple, repeating sequence qualifies, or if a more complex or selectable set of patterns is required. Practitioners may focus on this term to dispute whether the accused products' operation, which may be a simple fade, constitutes a "pattern" as envisioned by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification lists several examples of "Preferred colour displays," including "continuous slow colour change between red, amber and green," suggesting a simple, continuous transition could be a "pattern" ('275 Patent, col. 5:1-3).
  • Evidence for a Narrower Interpretation: The specification also describes a user-operable switch for selecting among multiple patterns and discusses programming the microcontroller with a "number of conduction angle patterns," which could suggest that a "pattern" implies one of several pre-programmed, selectable, and potentially complex sequences, not just a single, fixed mode of operation ('275 Patent, col. 4:35-39, col. 5:25-30).

For the ’206 Patent:

• The Term: "adjust the current draw in accordance with the voltage frequency"
• Context and Importance: This limitation is the core of the invention claimed in the ’206 patent. The infringement case will likely depend entirely on whether the accused products perform this specific adaptive function. The construction will clarify the degree of "adjustment" and "accordance" required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify how the adjustment must be made, potentially leaving room for any method that results in an output that changes in response to frequency.
  • Evidence for a Narrower Interpretation: The specification provides a detailed technical implementation: 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" to then adjust the timing ('206 Patent, col. 11:25-34). A court may be persuaded to limit the claim to this or a similar method of actively measuring and responding to frequency, as opposed to a system that might passively behave differently at different frequencies.

VI. Other Allegations

• Indirect Infringement: Plaintiff alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users... to use its products in the customary and intended manner that infringes" the patents (Compl. ¶15, ¶24). The complaint references Exhibits 3 and 4 for evidence of these materials, but the exhibits are not provided.
• Willful Infringement: The complaint alleges knowledge of infringement based on the service of the complaint itself (Compl. ¶14, ¶23). The claims for induced and continued direct infringement are explicitly based on post-suit conduct: "At least since being served by this Complaint..." (Compl. ¶16, ¶25).

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

1. Evidentiary Foundation: The most immediate question is what specific products are accused and what evidence Plaintiff possesses to map their functionality onto the claims. The complaint’s exclusive reliance on unprovided exhibits for all substantive infringement allegations raises the question of whether the pleading meets the plausibility standards required by federal court rules.

2. Claim Scope and Technical Function: A central technical issue, particularly for the ’206 patent, will be one of functional operation: do the accused products merely operate on an AC frequency, or do they perform the specific, adaptive function of measuring the "voltage frequency" and "adjust[ing] the current draw" in response, as claimed?

3. Definitional Boundaries: A key legal issue will be one of claim construction: can the term "predetermined pattern" in the ’275 patent be construed to cover the specific color-changing routines of the accused products? Similarly, the definition of "adjust... in accordance with the voltage frequency" in the ’206 patent will be dispositive for the infringement analysis of that patent.