DCT

1:23-cv-11398

Current Lighting Solutions LLC v. Signify Holding BV

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-11398, D. Mass., 06/22/2023
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Massachusetts because both Defendants maintain a regular and established place of business in Burlington, Massachusetts, from which licensing and enforcement activities related to the patents-in-suit are conducted.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its LED lighting fixtures and drivers do not infringe eighteen patents owned by Defendants related to LED system architecture, thermal management, power control, and circuit design.
  • Technical Context: The dispute is set in the highly competitive market for LED lighting technology, which involves innovations in power efficiency, thermal management, and electronic control systems for solid-state lighting.
  • Key Procedural History: The complaint arises from pre-suit licensing negotiations where Defendants accused Plaintiff’s products of infringement under their "EnabLED" licensing program. Notably, the complaint references a prior International Trade Commission (ITC) proceeding where a claim term from one of the patents-in-suit, U.S. Patent No. 7,262,559, was construed, an event that may influence the interpretation of that patent's scope.

Case Timeline

Date Event
2001-07-19 U.S. Patent No. 6,972,525 Priority Date
2003-05-05 U.S. Patent No. 7,178,941 Priority Date
2004-03-15 U.S. Patent Nos. 7,256,554, 7,262,559, 7,358,706, and 7,737,643 Priority Date
2004-09-10 U.S. Patent Nos. 7,542,257 and 8,272,756 Priority Date
2004-09-20 U.S. Patent No. 7,670,038 Priority Date
2005-01-28 U.S. Patent No. 7,654,703 Priority Date
2005-05-20 U.S. Patent No. 7,348,604 Priority Date
2005-09-27 U.S. Patent No. 7,802,902 Priority Date
2005-12-06 U.S. Patent No. 6,972,525 Issued
2006-03-13 U.S. Patent No. 7,866,845 Priority Date
2007-01-31 U.S. Patent No. 8,063,577 Priority Date
2007-02-20 U.S. Patent No. 7,178,941 Issued
2007-04-24 U.S. Patent No. 7,262,559 Issued
2007-08-14 U.S. Patent No. 7,256,554 Issued
2008-03-25 U.S. Patent No. 7,348,604 Issued
2008-04-15 U.S. Patent No. 7,358,706 Issued
2008-09-12 U.S. Patent No. 8,629,631 Priority Date
2008-10-15 U.S. Patent No. 9,159,521 Priority Date
2009-01-26 U.S. Patent No. 8,246,200 Priority Date
2009-06-02 U.S. Patent No. 7,542,257 Issued
2009-12-08 U.S. Patent No. 7,654,703 Issued
2010-01-05 U.S. Patent No. 7,670,038 Issued
2010-06-22 U.S. Patent No. 7,737,643 Issued
2010-11-23 U.S. Patent No. 7,802,902 Issued
2011-01-11 U.S. Patent No. 7,866,845 Issued
2011-04-21 U.S. Patent No. 9,119,268 Priority Date
2011-10-25 U.S. Patent No. 8,063,577 Issued
2012-08-21 U.S. Patent No. 8,246,200 Issued
2012-09-11 U.S. Patent No. 8,272,756 Issued
2014-03-11 U.S. Patent No. 8,629,631 Issued
2015-09-22 U.S. Patent No. 9,119,268 Issued
2015-10-20 U.S. Patent No. 9,159,521 Issued
2023-06-22 Complaint Filing Date

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

U.S. Patent No. 7,178,941 - "Lighting Methods and Systems"

  • Patent Identification: U.S. Patent No. 7,178,941, titled "Lighting Methods and Systems," issued February 20, 2007.

The Invention Explained

  • Problem Addressed: The patent describes challenges in designing LED lighting fixtures, including the need for specialized power supplies, convenient installation, and effective dissipation of heat generated by both the LEDs and power components to ensure performance and longevity (’941 Patent, col. 1:14-25, col. 2:38-42).
  • The Patented Solution: The invention discloses a lighting system, typically in a linear housing, that physically separates the light sources (LEDs) from the power facility (e.g., driver). It claims a structure with a "first cavity" for the LEDs and a separate "first channel" that shields the light sources from heat produced by the power facility, thereby improving thermal management within an integrated fixture (’941 Patent, Abstract; col. 64:47-52; Fig. 19).
  • Technical Importance: This approach of compartmentalizing heat-generating components within a single housing was a step toward creating more reliable and integrated solid-state lighting fixtures.

Key Claims at a Glance

  • The complaint asserts independent claim 10 (Compl. ¶59).
  • The essential elements of claim 10 include:
    • A substantially linear housing having a first cavity extending longitudinally within the linear housing;
    • A circuit board positioned within the first cavity;
    • A plurality of LED light sources supported by the circuit board within the first cavity;
    • A power facility for providing power to the circuit board; and
    • A first channel extending longitudinally within the housing and spaced apart from the first cavity between the circuit board and the power facility for shielding the light sources from heat produced by the power facility.

U.S. Patent No. 7,262,559 - "LED Power Control Methods and Apparatus"

  • Patent Identification: U.S. Patent No. 7,262,559, titled "LED Power Control Methods and Apparatus," issued April 24, 2007.

The Invention Explained

  • Problem Addressed: The patent's background discusses the complexity and potential inefficiencies of conventional DC-DC converters that use feedback loops (monitoring load voltage or current) to regulate power delivered to a load like an LED (’559 Patent, col. 1:20-2:3).
  • The Patented Solution: The invention proposes a "feed-forward" power driver that provides a controlled, predetermined amount of power to an LED load without requiring a feedback loop from that load. By eliminating the need to monitor the load's voltage or current, the driver circuit can be simplified, potentially improving efficiency and reducing size (’559 Patent, Abstract; col. 12:1-12).
  • Technical Importance: This "feed-forward" control strategy represented an alternative to traditional feedback-based designs, aiming to create smaller, more streamlined, and potentially more efficient power controllers for LED applications.

Key Claims at a Glance

  • The complaint asserts dependent claims 6, 10, and 11, which depend from independent method claim 1 (Compl. ¶64).
  • The essential elements of independent claim 1 include:
    • A method, comprising acts of:
    • (A) generating first radiation having a first spectrum from at least one first LED; and
    • (B) controllably varying a first intensity of the first radiation without monitoring or regulating a first voltage or a first current provided to the at least one first LED,
    • wherein the act (B) comprises storing input energy, providing output energy, and controlling at least one switch.
  • Asserted dependent claim 6 adds a limitation requiring a detection circuit providing a signal with distinct levels for a load condition versus a short/open condition.
  • Asserted dependent claim 10 adds a limitation requiring a differential amplifier.
  • Asserted dependent claim 11 adds a "means for adjusting a gain of said differential amplifier."

Multi-Patent Capsules

  • Patent Identification: U.S. Patent No. 7,348,604, "Light-Emitting Module," issued March 25, 2008.

  • Technology Synopsis: The patent describes a modular LED light-emitting device comprising a thermally conductive substrate for the LEDs, a heat dissipation element, and a housing element. The invention focuses on a structure where the housing can be detachably coupled to the heat sink, enclosing the substrate (’604 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶77).

  • Accused Features: Various fixtures in Current's Evolve and Albeo product lines are accused of infringement (Compl. ¶77).

  • Patent Identification: U.S. Patent No. 7,542,257, "Power Control Methods and Apparatus for Variable Loads," issued June 2, 2009.

  • Technology Synopsis: The patent addresses issues with switching power supplies at near-zero loads, where they can become inefficient or unstable. The described solution involves modifying the power supply, for example by using a processor-controlled "dummy load" to ensure a minimal load is always present, thereby improving performance for variable loads like dimmable LEDs (’257 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶82).

  • Accused Features: Various Current LED drivers and fixtures from the Evolve, Albeo, and Lumination lines are accused of infringement (Compl. ¶82).

  • Patent Identification: U.S. Patent No. 7,654,703, "Directly Viewable Luminaire," issued December 8, 2009.

  • Technology Synopsis: This patent discloses a luminaire with thermally separate compartments for the electronics and the lighting portions to provide thermal isolation. The lighting portion includes an optical device with two linear diffuser elements to create a uniform appearance for a directly viewable fixture (’703 Patent, Abstract).

  • Asserted Claims: Claim 17 (Compl. ¶87).

  • Accused Features: Various fixtures in Current's Evolve, Albeo, and Lumination product lines are accused of infringement (Compl. ¶¶87-88).

  • Patent Identification: U.S. Patent No. 7,670,038, "LED Collimator Element with an Asymmetrical Collimator," issued January 5, 2010.

  • Technology Synopsis: The invention relates to an LED collimator, particularly for vehicle headlights, designed to be asymmetrical. This asymmetry creates a non-uniform light intensity distribution, which can produce a sharp cut-off for a low-beam pattern without significant light loss (’038 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶92).

  • Accused Features: Various fixtures in Current's Evolve and Lumination product lines are accused of infringement (Compl. ¶92).

  • Patent Identification: U.S. Patent No. 7,802,902, "LED Lighting Fixtures," issued November 23, 2010.

  • Technology Synopsis: The patent describes an LED lighting fixture that encloses an LED module. The module includes an LED driver, a thermal management system with a heat sink, and potentially a beam shaper, all integrated within the fixture housing (’902 Patent, Abstract).

  • Asserted Claims: Claim 12 (Compl. ¶97).

  • Accused Features: Various fixtures in Current's Evolve, Lumination, and Albeo product lines are accused of infringement (Compl. ¶¶97, 20).

  • Patent Identification: U.S. Patent No. 7,866,845, "Optical Device for Mixing and Redirecting Light," issued January 11, 2011.

  • Technology Synopsis: This patent discloses an optical device for mixing light from multiple LEDs to create a uniform, asymmetric beam. It uses a reflector body with a symmetric pair of walls and an asymmetric pair of walls, allowing it to mix colors and shape the beam simultaneously (’845 Patent, Abstract).

  • Asserted Claims: Claim 5 (Compl. ¶102).

  • Accused Features: Various fixtures in Current's Evolve product line are accused of infringement (Compl. ¶102).

  • Patent Identification: U.S. Patent No. 8,063,577, "Method and a Driver Circuit for LED Operation," issued October 25, 2011.

  • Technology Synopsis: The patent describes a driver circuit for LEDs that uses a resonant capacitor and a transformer to generate an alternating supply current. The transformed secondary voltage is then rectified and buffered to produce a substantially constant load current for the LEDs, with power controlled by adjusting the frequency of the alternating supply (’577 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶107).

  • Accused Features: Various Current LED drivers and fixtures from the Evolve, Albeo, and Lumination lines are accused of infringement (Compl. ¶107).

  • Patent Identification: U.S. Patent No. 8,246,200, "Illumination Device," issued August 21, 2012.

  • Technology Synopsis: The patent describes an illumination device with an array of optical modules, each having first and second optical components covering corresponding light-emitting elements. This structure allows for the creation of multiple, superimposed illumination distribution patterns from the same set of LEDs (’200 Patent, Abstract).

  • Asserted Claims: Claim 5 (Compl. ¶112).

  • Accused Features: Various fixtures in Current's Evolve product line are accused of infringement (Compl. ¶112).

  • Patent Identification: U.S. Patent No. 8,272,756, "LED-Based Lighting System and Method," issued September 25, 2012.

  • Technology Synopsis: The invention relates to a lighting system with a row of LEDs in a reflective channel or groove. The system integrates a heat sink, such as fins or protrusions, alongside or behind the channel to manage heat via convection (’756 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶117).

  • Accused Features: Fixtures in Current's Evolve and Albeo product lines are accused of infringement (Compl. ¶117).

  • Patent Identification: U.S. Patent No. 8,629,631, "Method and System for Improving Start-Up Time of a Light Emitting Diode (LED) Driver at Reduced Input Voltage," issued March 11, 2014.

  • Technology Synopsis: The patent addresses slow start-up times for LED drivers at low input voltages (e.g., when dimmed). The solution is a "quick start circuit" using a constant current source to rapidly charge the controller's power supply capacitor, which then shuts off after start-up to minimize power loss (’631 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶122).

  • Accused Features: Various Current LED drivers and fixtures from the Evolve and Albeo lines are accused of infringement (Compl. ¶¶122, 25).

  • Patent Identification: U.S. Patent No. 9,119,268, "Driver with Isolation and Surge Signal Protection," issued September 22, 2015.

  • Technology Synopsis: The patent describes a driver for LEDs with an isolation circuit (e.g., a transformer) and a guiding circuit to protect against common mode surge signals. The guiding circuit uses capacitors to direct surge signals to a reference potential, protecting the light circuit (’268 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶127).

  • Accused Features: A wide range of Current's LED drivers and fixtures are accused of infringement (Compl. ¶127).

  • Patent Identification: U.S. Patent No. 9,159,521, "LED Area Lighting Optical System," issued October 20, 2015.

  • Technology Synopsis: This patent describes a dual-reflector assembly for an area light, consisting of an upper and a lower reflector. A light source is positioned between the proximal ends of the reflectors, and the upper reflector surrounds a portion of the lower one, shaping the output beam (’521 Patent, Abstract).

  • Asserted Claims: Claims 1, 2, and 4 (Compl. ¶133).

  • Accused Features: Fixtures in Current's Evolve product line are accused of infringement (Compl. ¶133).

  • Patent Identification: U.S. Patent No. 6,972,525, "LED Switching Arrangement," issued December 6, 2005.

  • Technology Synopsis: The patent describes a specific switching arrangement for operating a load such as an LED. The circuit includes a transformer where an inductive winding in a third circuit path forms the secondary winding of the transformer, which is designed to reduce radio frequency interference (EMI) (’525 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶142).

  • Accused Features: A wide range of Current's LED drivers and fixtures are accused of infringement (Compl. ¶142).

  • Patent Identification: U.S. Patent No. 7,256,554, "LED Power Control Methods and Apparatus," issued August 14, 2007.

  • Technology Synopsis: This patent describes a "feed-forward" power driver for LEDs that provides a controlled amount of power without requiring feedback from the load. The driver combines the functions of a DC-DC converter and a light source controller (’554 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶147).

  • Accused Features: Certain drivers within Current's LRX and Lumination product lines, as well as GE LED Lightech drivers, are accused of infringement (Compl. ¶147).

  • Patent Identification: U.S. Patent No. 7,358,706, "Power Factor Correction Control Methods and Apparatus," issued April 15, 2008.

  • Technology Synopsis: The technology relates to power factor correction (PFC) control methods that use "feed-forward" information about anticipated load conditions. By knowing the desired load power in advance, the PFC control loop response can be improved, especially for loads that vary widely, leading to more stable and efficient power delivery (’706 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶152).

  • Accused Features: Various drivers within Current's LRX product line and fixtures in the Evolve product line are accused of infringement (Compl. ¶152).

  • Patent Identification: U.S. Patent No. 7,737,643, "LED Power Control Methods and Apparatus," issued June 22, 2010.

  • Technology Synopsis: This patent, related to the '554 patent, also describes a "feed-forward" driver for LEDs. It provides power to an LED without monitoring the voltage or current supplied to that LED, combining the functions of a power converter and a controller into a streamlined circuit (’643 Patent, Abstract).

  • Asserted Claims: Claim 1 (Compl. ¶158).

  • Accused Features: Drivers within Current's Lumination and LRX product lines are accused of infringement (Compl. ¶158).

III. The Accused Instrumentality

Product Identification

The complaint identifies "certain Current LED drivers and fixtures" (Compl. ¶50). For the patents analyzed in detail, these include the Albeo, Lumination, and Arize product lines accused of infringing the ’941 Patent, and specific "GED" and "GELD" series drivers and products containing them from the Evolve, Albeo, and Lumination lines accused of infringing the ’559 Patent (Compl. ¶¶59, 64).

Functionality and Market Context

The complaint does not provide a detailed technical description of how the accused instrumentalities operate. Instead, the allegations focus on what the products allegedly lack. For example, the complaint asserts that the accused products do not contain specific structural or functional elements required by the patent claims, such as a "first channel" or a "differential amplifier" (Compl. ¶¶61, 66). The accused product families represent a range of commercial and industrial LED lighting solutions.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,178,941 Infringement Allegations

Claim Element (from Independent Claim 10) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
a first channel extending longitudinally within the housing and spaced apart from the first cavity between the circuit board and the power facility for shielding the light sources from heat produced by the power facility The complaint alleges that the accused fixtures do not contain a "first channel extending longitudinally within the housing" as claimed. ¶¶60-61 col. 64:47-52

U.S. Patent No. 7,262,559 Infringement Allegations

(focusing on disputed elements from dependent claims 6, 10, and 11)

Claim Element Alleged Non-Infringing Functionality Complaint Citation Patent Citation
a differential amplifier (from claim 10) The complaint alleges that none of the accused drivers contain a "differential amplifier." ¶¶65-66 col. 4:28-40
means for adjusting a gain of said differential amplifier (from claim 11) The complaint alleges that the accused drivers lack the specific four-resistor structure (R24, R25, R26, and R27 of Figure 5) that the ITC previously construed as the corresponding structure for this means-plus-function limitation. ¶¶67-70 col. 4:47-50; Fig. 5
a detection signal with a first level representative of a load condition of the LED light source (from claim 6) The complaint alleges that the accused drivers do not have a detection signal with this "first level." ¶¶71-72 col. 4:28-35
a detection signal with a second level representative of either a short condition or an open condition (from claim 6) The complaint alleges that the accused drivers do not have a detection signal with this "second level." ¶¶73-74 col. 4:28-35
  • Identified Points of Contention:
    • For the ’941 Patent, the dispute may center on a question of claim scope and structural definition: What constitutes a "channel" as distinct from the "first cavity" within the context of the patent, and do the accused fixtures contain a structure meeting the claim's definition for shielding purposes? A Certificate of Correction issued for the patent, which changed the word "channel" to "cavity" in a different claim (claim 11), may be raised as evidence that the patentee considered these terms to be distinct.
    • For the ’559 Patent, the analysis raises questions of both technical fact and claim construction. A primary issue will be whether the circuits in the accused drivers perform the functions required by the claims, such as those of a "differential amplifier." A central point of contention appears to be the "means for adjusting a gain" limitation. The complaint leverages a prior ITC construction that identified a specific four-resistor arrangement as the corresponding structure, raising the evidentiary question of whether the accused drivers contain that structure or a legally equivalent one.

V. Key Claim Terms for Construction

For U.S. Patent No. 7,178,941:

  • The Term: "channel"
  • Context and Importance: This term is the explicit basis for Plaintiff's non-infringement argument for claim 10. The case will require determining whether the accused fixtures contain a structure that meets the definition of the claimed "channel," which is described as shielding the light sources from heat produced by the power facility.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The parties may argue that the specification uses terms like "channel," "cavity," and "passageway" in a general sense to refer to any internal space within the housing, which could support a broader reading of the term.
    • Evidence for a Narrower Interpretation: The specification and figures appear to distinguish between the "first cavity" (2700 in Fig. 19) containing the LEDs and a separate "channel" (2720) for thermal shielding (’941 Patent, Fig. 19). Further, the existence of a Certificate of Correction changing "channel" to "cavity" in dependent claim 11 may suggest the patentee viewed these as distinct terms with different scopes.

For U.S. Patent No. 7,262,559:

  • The Term: "means for adjusting a gain of said differential amplifier"
  • Context and Importance: This is a means-plus-function limitation under 35 U.S.C. § 112, ¶ 6 (pre-AIA). Its scope is limited to the corresponding structure disclosed in the specification and its equivalents. The complaint's non-infringement argument relies on a prior ITC construction of this very term.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Narrower Interpretation (The Function and Corresponding Structure): The complaint alleges the ITC has already identified the function as "adjusting a gain of said differential amplifier" and the corresponding structure as "resistors R24, R25, R26, and R27 shown in Figure 5" of the patent (’559 Patent, Fig. 5; Compl. ¶¶68-69). Practitioners may focus on whether the accused devices contain this exact structure or a structure that is insubstantially different.
    • Evidence for a Broader Interpretation (Equivalents): The defendant will have the opportunity to argue that the accused devices contain a structure that is an "equivalent" to the disclosed four-resistor arrangement, which would raise questions about what constitutes an equivalent structure under the law.

VI. Other Allegations

  • Indirect Infringement: The complaint, being an action for declaratory judgment of non-infringement, does not make allegations of indirect infringement. Rather, it seeks a judicial declaration that the plaintiff is not liable for any form of infringement based on accusations made by the defendants.
  • Willful Infringement: The complaint does not allege willfulness. The factual predicate for the declaratory judgment action is the existence of an actual controversy, which the complaint establishes by citing defendants' pre-suit accusations of infringement (Compl. ¶¶17, 50, 54). These same pre-suit communications would likely form the basis for any future claim of willful infringement brought by the defendants against the plaintiff.

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

This declaratory judgment action presents a broad challenge to a significant portion of a patent portfolio related to LED lighting. Based on the complaint, the dispute appears to hinge on several key questions for the court:

  • A primary issue will be one of structural and definitional scope: For the ’941 patent, can the term "channel," in the context of the specification and a related certificate of correction, be interpreted to read on the internal architecture of Plaintiff’s accused fixtures, or are the structures fundamentally different?
  • A second core issue will be a question of technical and legal equivalence, guided by prior construction: For the ’559 patent, given the ITC's prior identification of a specific four-resistor circuit as the "means" for performing a claimed function, do Plaintiff's drivers contain this structure or a legally recognized equivalent? The answer will likely depend on a detailed, fact-intensive comparison of the respective circuit designs and their operation.