BridgeComm LLC v. Armacost Lighting LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: BridgeComm LLC (Texas)
  • Defendant: Armacost Lighting LLC (Maryland)
  • Plaintiff’s Counsel: DNL Zito; Rabicoff Law LLC
• Case Identification: 1:26-cv-3, D. Md., 01/01/2026
• Venue Allegations: Venue is alleged to be proper based on Defendant's incorporation and established place of business within the District of Maryland, where acts of infringement have also allegedly occurred.
• Core Dispute: Plaintiff alleges that Defendant’s lighting systems infringe two patents related to methods for controlling multi-colored lamps to produce variable lighting effects.
• Technical Context: The technology at issue involves electronic control systems for decorative and ornamental lighting, such as LED light strings, that can generate a wide range of colors and dynamic effects.
• Key Procedural History: U.S. Patent No. 8,390,206 is a continuation of the application that resulted in U.S. Patent No. 8,203,275, indicating the patents share a common specification and priority claim. The complaint does not mention any prior litigation or administrative proceedings involving these patents.

Case Timeline

Date	Event
2005-08-16	Priority Date for ’275 and ’206 Patents
2012-06-19	U.S. Patent No. 8,203,275 Issues
2013-03-05	U.S. Patent No. 8,390,206 Issues
2026-01-01	Complaint Filed

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

U.S. Patent No. 8,203,275 - "Variable-effect lighting system"

The Invention Explained

• Problem Addressed: The patent’s background section describes prior art variable-effect lighting systems as either being overly complex or limited in the range and intricacy of the color displays they can produce (ʼ275 Patent, col. 1:47-53, col. 2:6-9).
• The Patented Solution: The invention is a lighting system where multiple multi-colored lamps (e.g., bi-color LEDs) are connected in series to an AC power source (ʼ275 Patent, col. 2:13-16). A lamp controller varies the output color by adjusting the "conduction interval"—the amount of time each color-producing element is active during each AC power cycle—according to a predetermined pattern (ʼ275 Patent, Abstract; col. 4:11-20). The system also allows a user to stop the color variation and retain a desired color, with the controller storing this setting in non-volatile memory for recall after a power cycle (ʼ275 Patent, col. 2:22-25; Claim 1).
• Technical Importance: This approach aims to provide a "relatively simple" system capable of producing a "greater variation in the range of colour displays" compared to prior art methods (ʼ275 Patent, col. 2:7-9).

Key Claims at a Glance

The complaint does not specify which claims of the ’275 Patent are asserted, referring generally to "one or more claims" (Compl. ¶12). Independent claim 1 is representative and includes the following essential elements:

• A lamp assembly with a plurality of 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 output color by varying a "conduction interval" of each illuminating element according to a predetermined pattern.
• The controller is configured to "terminate the variation" upon activation of a user-operable input.
• The controller includes non-volatile memory to retain a "datum associated with the conduction interval" when the user terminates the variation, allowing the setting to be restored upon re-application of power.

U.S. Patent No. 8,390,206 - "Variable-effect lighting system"

The Invention Explained

• Problem Addressed: The patent addresses a potential failure point in lighting systems that rely on fixed timing assumptions: variations in the frequency of the AC power source. If the actual AC frequency deviates from the expected value (e.g., 60 Hz), timing-based control algorithms can fail, producing "unpredictable visual display[s]" (ʼ206 Patent, col. 12:15-24).
• The Patented Solution: The invention is a lighting system with a controller configured to control the "current draw" of each illuminating element and, critically, to "adjust the current draw in accordance with the voltage frequency" (ʼ206 Patent, Abstract). The specification discloses measuring the time between zero-crossings of the AC voltage waveform to calculate the actual line frequency, and then using this measurement to accurately control the lighting elements, thereby ensuring consistent performance even if the power frequency fluctuates (ʼ206 Patent, col. 12:28-34).
• Technical Importance: This innovation provides robustness against real-world power grid fluctuations, allowing for more reliable and predictable generation of complex lighting effects.

Key Claims at a Glance

The complaint does not specify which claims of the ’206 Patent are asserted (Compl. ¶21). Independent claim 1 is representative and includes the following essential elements:

• A lamp assembly with a plurality of 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 for producing different colors.
• 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."

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products. It refers to them generically as "Exemplary Defendant Products" that are identified in external claim chart exhibits (Compl. ¶12, ¶21).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. This information is incorporated by reference to Exhibits 3 and 4, which were not provided with the complaint (Compl. ¶17, ¶26).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim charts in Exhibits 3 and 4, which were not provided (Compl. ¶18, ¶27). The narrative alleges that the "Exemplary Defendant Products" practice the technology claimed by the Patents-in-Suit and satisfy all elements of the asserted claims (Compl. ¶17, ¶26). Without the charts or specific product details, a tabular analysis is not possible.

• Identified Points of Contention:
  • ’275 Patent: An evidentiary question will be whether the Plaintiff can demonstrate that the accused products contain a controller that not only varies the on-time of its LEDs, but does so using a method that meets the specific "conduction interval" limitation of the claims. A further point of contention may arise over whether the accused products possess a "non-volatile memory" feature that saves a user-selected color setting across power cycles, as required by claim 1.
  • ’206 Patent: The central technical question for the ’206 Patent will be whether the accused products' controllers perform the claimed function of "adjust[ing] the current draw in accordance with the voltage frequency." The dispute may focus on whether the accused devices actively measure the AC line frequency and alter their behavior in response, or if they operate using fixed timing parameters that merely assume a standard frequency.

V. Key Claim Terms for Construction

• The Term: "conduction interval" (’275 Patent, Claim 1)
• Context and Importance: This term is at the heart of how the ’275 Patent’s invention controls color. The scope of this term will be critical to determining infringement, as it will define what specific methods of controlling power to the light-emitting elements are covered by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the effect of the control sequence as changing the "period of time each cycle during which the red LED 14a illuminates" and the "period of time each cycle during which the green LED 14b illuminates" (’275 Patent, col. 6:31-35). This language could support an interpretation covering any technique that varies the duty cycle or on-time of the LEDs within an AC cycle.
  • Evidence for a Narrower Interpretation: The primary embodiment describes a specific phase-control method: after detecting a "zero-crossing of the AC voltage source," the controller "delays a predetermined period" before issuing a pulse to a bidirectional switch, which then conducts for the remainder of the half-cycle (’275 Patent, col. 6:9-16). This could support a narrower construction limited to phase-angle control, potentially excluding other methods like high-frequency pulse-width modulation (PWM).
• The Term: "adjust the current draw in accordance with the voltage frequency" (’206 Patent, Claim 1)
• Context and Importance: This limitation defines the core inventive concept of the ’206 Patent—adapting to power source variations. Infringement will hinge on whether an accused product performs this specific frequency-adaptive function.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim uses broad functional language. Practitioners may argue that any system whose output control is modified in response to a change in input frequency meets this limitation, regardless of the specific mechanism used.
  • Evidence for a Narrower Interpretation: The specification discloses a particular method for achieving this function: the algorithm "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" (’206 Patent, col. 12:28-34). This may support an argument that the claim requires an explicit measurement and calculation step, potentially excluding systems that adapt through other means like a phase-locked loop.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents, asserting that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" (Compl. ¶15, ¶24).
• Willful Infringement: The complaint alleges that service of the complaint itself provides Defendant with "actual knowledge of infringement" (Compl. ¶14, ¶23). It further alleges that Defendant continues to infringe "[d]espite such actual knowledge," which provides a basis for a claim of post-filing willful infringement (Compl. ¶15, ¶24).

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

• A primary issue will be an evidentiary one: Given the complaint’s reliance on external exhibits, a key initial phase of the case will involve Plaintiff identifying the specific accused products and presenting technical evidence demonstrating how their controllers allegedly perform the functions required by the asserted claims.
• The infringement analysis for the ’206 Patent will likely turn on a dispositive technical question: Does the accused controller actively measure the AC line frequency and adjust its timing in response, as claimed, or does it operate on a fixed-timing basis that merely assumes a standard frequency (e.g., 60Hz)?
• For the ’275 Patent, the case may center on claim construction: Can the term "conduction interval," which is described in the context of AC phase control, be construed broadly enough to read on the specific power control or dimming mechanisms utilized in the accused modern LED lighting systems?