DCT

1:25-cv-07388

Semisilicon Technology Corp v. Chanzhou Jutai Electronic Co

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I. Executive Summary and Procedural Information

Case Timeline

Date Event
2014-10-22 Earliest Priority Date for U.S. Patent No. 10,187,935
2017-03-10 Earliest Priority Date for U.S. Patent No. 9,939,117
2018-04-10 U.S. Patent No. 9,939,117 Issues
2019-01-22 U.S. Patent No. 10,187,935 Issues
2024-12-XX Plaintiff allegedly provides defendants with notice of infringement
2025-07-01 Complaint Filed

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

U.S. Patent No. 10,187,935 - "Light Emitting Diode Lamp with Burnable Function and Light Emitting Diode Lamp String with Burnable Function"

  • Patent Identification: U.S. Patent No. 10,187,935, “Light Emitting Diode Lamp with Burnable Function and Light Emitting Diode Lamp String with Burnable Function,” issued January 22, 2019.

The Invention Explained

  • Problem Addressed: The patent’s background section describes the inefficiency of conventional LED manufacturing, where a unique local address must be permanently "burned" into each LED's control chip before the chip is assembled into a lamp. This practice is described as creating logistical challenges for warehouse management and increasing the risk of assembly errors. (’935 Patent, col. 2:4-15).
  • The Patented Solution: The invention is an LED driving apparatus designed to have its local address programmed after it has been manufactured and assembled. The apparatus receives a special "burn start signal" and "burn address data" through its electrical contacts, which it then stores internally as its permanent "local address data." During normal operation, it receives signals containing both lighting instructions and a target address, and will only light up if the target address matches its stored local address. (’935 Patent, col. 2:25-48; Fig. 1).
  • Technical Importance: This post-manufacturing addressing capability could allow for more flexible and efficient assembly of complex, multi-LED lighting systems. (’935 Patent, col. 2:38-40).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶19).
  • Essential Elements of Claim 1:
    • At least one light emitting diode.
    • A light emitting diode driving apparatus with a "burnable function" comprising a first and second contact.
    • The apparatus is configured to receive a "burn start signal" and "burn address data" sent through the first contact.
    • The apparatus is configured to "burn the burn address data as a local address data" into itself after receiving the burn start signal.
    • The apparatus later receives a "first signal" (a plurality of pulse signals) comprising "lighting data" and "address data".
    • The apparatus is configured to compare the received "address data" with its stored "local address data".
    • The apparatus is configured to drive the light emitting diode based on the "lighting data" if the address data matches the local address data.
  • The complaint reserves the right to assert other claims. (Compl. ¶19).

U.S. Patent No. 9,939,117 - "Light Emitting Diode System With Light Signals Carried Via Power Lines"

  • Patent Identification: U.S. Patent No. 9,939,117, “Light Emitting Diode System With Light Signals Carried Via Power Lines,” issued April 10, 2018.

The Invention Explained

  • Problem Addressed: The patent identifies the added cost and complexity of arranging separate signal generation circuits to send control signals to LEDs over the same power lines that supply them with electricity. (’117 Patent, col. 1:26-31).
  • The Patented Solution: The invention discloses a system that eliminates the need for a separate signal circuit by using a "control unit" to directly modulate the power supplied to the entire LED string. The "control unit" drives a "signal voltage unit" (e.g., a transistor) to "continuously and repeatedly" adjust the voltage on the power line to a "predetermined voltage," thereby creating a series of pulse waves. These voltage pulses form the "light signal," which each individual LED unit on the string can then decode to determine how it should light up. (’117 Patent, col. 1:44-62, Fig. 1).
  • Technical Importance: This approach simplifies the control hardware by integrating the signaling function directly into the power delivery system, potentially reducing manufacturing costs. (’117 Patent, col. 2:58-62).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶32).
  • Essential Elements of Claim 1:
    • A light emitting diode lamp string comprising a plurality of light emitting diode units that receive power through power lines.
    • A "signal voltage unit" electrically connected to the lamp string.
    • A "control unit" electrically connected to the signal voltage unit.
    • The control unit is configured to drive the signal voltage unit to "adjust a voltage" of the lamp string "continuously and repeatedly" so the voltage is a "predetermined voltage".
    • This adjustment forms a "light signal" comprising a plurality of "pulse waves".
    • Each light emitting diode unit is configured to perform a "conversion and a decoding" of the light signal to obtain a "lighting mode".
    • Each unit is configured to light based on the obtained lighting mode.
  • The complaint reserves the right to assert other claims. (Compl. ¶33).

III. The Accused Instrumentality

Product Identification

  • The accused products are decorative LED light strings, including the "YIQU Color Changing Smart Christmas Lights" (ASIN B0D7MCYJ9H) and the "BHCLIGHT Smart DIY Color Changing Christmas Lights" (ASIN B0D7PTZGTB), among others. (Compl. ¶17, ¶21, ¶34).

Functionality and Market Context

  • The accused products are described as LED lamp strings that can be controlled to display various colors and patterns. (Compl. ¶21, ¶35). They operate in a "corded electric mode" via a power adapter and are controlled by a controller unit. (Compl. ¶23, ¶35).
  • The complaint alleges that defendant Jutai manufactures the products, which are then sold by the other defendants on Amazon, with Jutai identifying itself as a "preferred brand for Amazon e-commerce." (Compl. ¶13-14, ¶17).
  • The core of the infringement allegations rests on the functionality of the products' internal electronics, specifically the LED driving IC within each lamp and the main controller that sends signals to the string. (Compl. ¶23, ¶36). The complaint includes an annotated photograph of the YIQU product's components, identifying the "LIGHT EMITTING DIODE LAMP STRING" and its controller. (Compl. ¶21, pg. 6).

IV. Analysis of Infringement Allegations

’935 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a light emitting diode driving apparatus with the burnable function... The accused YIQU product contains an LED lamp with an LED driving IC. (Compl. ¶23). The complaint presents an "Exemplary optical microscope magnification of the poly layer of the LED driving IC" to support its allegations. (Compl. ¶23, pg. 9). ¶23 col. 2:25-28
receives a burn start signal sent through the first contact and a burn address data sent through the first contact; the light emitting diode driving apparatus is configured to burn the burn address data as a local address data into the light emitting diode driving apparatus after the light emitting diode driving apparatus receives the burn start signal The LED driving IC is alleged to incorporate "a plurality of address-recording fuses for the execution of the burnable function." (Compl. ¶23). The complaint alleges the LED control IC records burn address data by "blowing one or more specific fuses." (Compl. ¶25). This is supported by an annotated micrograph showing "Address recording fuses" and areas labeled "Blown fuse." (Compl. ¶25, pg. 10). ¶25 col. 2:31-38
a first signal is a plurality of pulse signals, and comprises a lighting data and an address data... configured to compare the address data with the local address data... and then... drive the light emitting diode... based on the lighting data if the address data is the same with the local address data The controller is alleged to transmit a series of pulse signals containing address and lighting data. (Compl. ¶26). An oscilloscope waveform is provided to show these pulse signals, which allegedly control the LEDs to light up when their local address matches the transmitted address. (Compl. ¶26, pg. 11). ¶26 col. 2:38-48
  • Identified Points of Contention:
    • Technical Question: The complaint's evidence for the "burn" function relies on static images of a reverse-engineered IC showing "blown fuses." A key question will be whether Plaintiff can produce evidence that this "burning" occurs post-manufacturing via a distinct "burn start signal," as this capability is central to the problem the patent claims to solve.
    • Scope Question: The patent describes the "burn start signal" as, for example, a voltage "greater than a working voltage" of the apparatus (’935 Patent, col. 6:40-44). The infringement analysis may turn on whether the signal used to program the accused devices meets the specific definition of a "burn start signal" as construed by the court.

’117 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a signal voltage unit electrically connected to the light emitting diode lamp string; and a control unit electrically connected to the signal voltage unit The controller of the BHCLIGHT product is alleged to include a "control unit" (identified as a PHY6252 IC) and a "signal voltage unit" (identified as an N-type MOSFET switch). (Compl. ¶36). The complaint provides an annotated photograph of the controller's circuit board and a corresponding circuit diagram to illustrate this connection. (Compl. ¶36, pg. 17). ¶36 col. 1:41-44
the control unit is configured to drive the signal voltage unit to adjust a voltage of the light emitting diode lamp string continuously and repeatedly so the voltage of the light emitting diode lamp string is a predetermined voltage, to form the light signal comprising a plurality of pulse waves The control IC is alleged to "continuously and repeatedly" drive the MOSFET switch to toggle its status, adjusting the voltage supplied to the LED string between 30V and 0V. (Compl. ¶37). This toggling allegedly generates a "plus wave pattern to form the light signal." (Compl. ¶37). An oscilloscope measurement is provided, showing the voltage waveform (yellow) at the lamp string terminals. (Compl. ¶37, pg. 18). ¶37 col. 1:44-53
each of the light emitting diode units is configured to perform a conversion and a decoding for the light signal to obtain a lighting mode... and then... is configured to light based on the lighting mode Each LED lamp in the string is alleged to process the received pulse wave signal, convert it into digital signals (e.g., 0 or 1) based on pulse width, and decode these signals to obtain the lighting mode (e.g., red, blue, or green). (Compl. ¶38). An oscilloscope photo shows the voltage of a single lamp (blue waveform) as it receives the signal. (Compl. ¶38, pg. 19). ¶38 col. 1:53-62
  • Identified Points of Contention:
    • Scope Question: A dispute may arise over the term "predetermined voltage". The claim requires adjusting the lamp string voltage to a predetermined voltage. The complaint alleges a toggle between 30V and 0V. Defendants may argue that the term, in light of the specification (which discusses a drop from 110V to 60V), implies a specific, non-zero level, raising the question of whether toggling to 0V meets the limitation.
    • Technical Question: The complaint asserts that each LED unit "converts each received pulse wave... into a representation of a digital signal, such as 0 or 1, based on its respective pulse width" (Compl. ¶38). The functional evidence for this specific decoding mechanism within the individual LEDs will be a critical part of the infringement case.

V. Key Claim Terms for Construction

For the ’935 Patent:

  • The Term: "burn start signal"
  • Context and Importance: This signal is the specific trigger that allows the LED driving apparatus to enter its programming mode. The existence and nature of this signal distinguish the invention from systems that are programmed at the time of wafer fabrication. Proving that the accused system uses a signal that meets this definition is crucial for the infringement case.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim itself does not define the signal's characteristics, merely its function: enabling the apparatus to "receive" and "burn" address data. A party could argue this covers any distinct input that initiates the programming sequence.
    • Evidence for a Narrower Interpretation: The specification provides a specific example: "The burn start signal 314 is, for example, a voltage greater than a working voltage of the light emitting diode driving apparatus 10." (’935 Patent, col. 6:40-42). A party could argue this language limits the term to an over-voltage condition, rather than any command signal.

For the ’117 Patent:

  • The Term: "predetermined voltage"
  • Context and Importance: This term defines the target voltage level that the control unit causes the power line to drop to in order to create a pulse. The definition will determine whether the accused product's alleged operation (toggling between 30V and 0V) falls within the claim scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself is broad, suggesting any voltage level that is set or decided in advance. Plaintiff may argue that 0V is a valid "predetermined voltage" used to create the low state of the pulse. The claim requires adjusting the voltage to a predetermined level, which can be read to include 0V.
    • Evidence for a Narrower Interpretation: The specification provides an example where the voltage is "decreased as 60 volts" from a normal 110 volts. (’117 Patent, col. 5:11-13). A party could argue that this context suggests the "predetermined voltage" is a specific, non-zero operational voltage, not merely an "off" state (0V).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement and contributory infringement, asserting that Defendants offer for sale and sell products with knowledge of the patents and with the intent that their customers will infringe by using the products as intended. (Compl. ¶19, ¶32). The basis for knowledge includes the alleged pre-suit notice. (Compl. ¶28, ¶40).
  • Willful Infringement: Willfulness is alleged based on Defendants' purported knowledge of the patents-in-suit since at least December 2024 via a notice of infringement, and awareness of a prior lawsuit in the Northern District of California involving the same plaintiff. (Compl. ¶28-29, ¶40-41).

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

This case appears to center on highly technical questions of how the accused LED control systems function at the microelectronic and electrical signal level. The resolution will likely depend on the answers to two central questions:

  1. A core issue will be one of evidentiary proof: Can Plaintiff demonstrate that the accused LED driver ICs, which show physical evidence of "blown fuses," are in fact programmed post-assembly using a distinct "burn start signal" as required by the '935 patent, or were they addressed using a conventional pre-manufacturing process?
  2. A key legal question will be one of definitional scope: Can the '117 patent's term "predetermined voltage" be construed to cover the accused product's alleged practice of toggling the power line to 0V, or does the patent's context limit the term to a specific, non-zero voltage level, creating a mismatch in technical operation?