DCT

2:10-cv-10247

Altair Engineering Inc v. Seesmart LED Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:10-cv-10247, E.D. Mich., 01/19/2010
  • Venue Allegations: Venue is alleged based on Defendant’s offers for sale and sales of accused products within the judicial district, conducted through the internet and other means.
  • Core Dispute: Plaintiff alleges that Defendant’s LED-based replacement light tubes for fluorescent fixtures infringe patents related to the design and power circuitry of such devices.
  • Technical Context: The technology addresses the replacement of traditional fluorescent light tubes with more energy-efficient, durable, and long-lasting light-emitting diode (LED) based equivalents.
  • Key Procedural History: The asserted U.S. Patent No. 7,510,299 is a continuation of U.S. Patent No. 7,049,761. The '761 patent was the subject of a claim construction order in prior litigation in the same district (Altair Eng'g, Inc. v. Leddynamics, Inc., 2:07-cv-13150, E.D. Mich.). Both patents have undergone post-grant proceedings, including multiple Certificates of Correction and, for the '299 patent, multiple ex parte reexaminations which have confirmed or amended the claims. The '299 patent is also subject to a terminal disclaimer.

Case Timeline

Date Event
2000-02-11 Priority Date for ’761 & ’299 Patents
2006-05-23 ’761 Patent Issue Date
2009-03-31 ’299 Patent Issue Date
2010-01-19 Complaint Filing Date

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

U.S. Patent No. 7,049,761, “LIGHT TUBE AND POWER SUPPLY CIRCUIT,” Issued May 23, 2006

The Invention Explained

  • Problem Addressed: The patent identifies several shortcomings of conventional fluorescent lighting systems, including short life expectancy, susceptibility to failure from vibration, high power consumption, and the need for high operating voltages, all of which reduce reliability (’761 Patent, col. 1:22-28).
  • The Patented Solution: The invention proposes a direct replacement light tube that uses an array of light-emitting diodes (LEDs) housed within a cylindrical bulb and fitted with end caps compatible with standard fluorescent fixtures. The patent describes various internal power supply circuits that can power the LEDs, including circuits that can operate with the fixture's existing ballast and others that connect directly to an AC or DC power source, thereby overcoming the issues of conventional tubes (’761 Patent, col. 1:31-40, 4:15-20; Fig. 5).
  • Technical Importance: The invention enables the retrofitting of the vast installed base of fluorescent light fixtures with more robust and energy-efficient LED technology without requiring the complete replacement of the fixtures themselves (’761 Patent, col. 2:25-29).

Key Claims at a Glance

  • The complaint does not identify specific asserted claims, alleging infringement of "one or more of the claims" (Compl. ¶7). Independent claim 19 is representative of the invention’s electrical system.
  • Independent Claim 19:
    • An elongated cylindrical transparent envelope;
    • A base cap at an end of the envelope, comprising an electrical bi-pin connector adapted to electrically communicate with a fluorescent light socket;
    • At least one LED device in electrical communication with the base cap;
    • The at least one LED device is electrically connected to a rectifier; and
    • The at least one LED device is further electrically connected to a pulse-width modulating circuit that receives a direct current signal from the rectifier and supplies a modulated signal to the LED device.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,510,299, “LED LIGHTING DEVICE FOR REPLACING FLUORESCENT TUBES,” Issued March 31, 2009

The Invention Explained

  • Problem Addressed: As with its parent, the '299 Patent addresses the known deficiencies of conventional fluorescent tubes, such as poor durability and high power usage (’299 Patent, col. 1:26-35).
  • The Patented Solution: This invention focuses on the structural arrangement of the LED replacement tube to improve light delivery. It describes an elongate support structure for the LEDs inside a transmissive bulb, where the structure includes "opaque side walls" that direct the light output into a constrained angle (less than 180 degrees). This prevents wasting light by illuminating the inside of the fixture and directs it toward the intended area (’299 Patent, col. 2:50-58; Fig. 3).
  • Technical Importance: By confining the light output to a specific angle, the invention increases the usable illumination efficiency of the LED tube, a critical factor in lighting applications where delivering light to a target surface is paramount (’299 Patent, col. 2:50-55).

Key Claims at a Glance

  • The complaint does not identify specific asserted claims (Compl. ¶7). Independent claim 2, as amended during reexamination, is representative of the invention’s structural features.
  • Independent Claim 2 (as amended by Reexamination Certificate US 7,510,299 C3):
    • An elongate support structure providing a substantially continuous LED mounting surface;
    • A plurality of LEDs arranged along the length of the surface;
    • A light transmissive bulb portion overlying the surface and LEDs;
    • A pair of end caps with male bi-pin connectors for installation in a fluorescent fixture; and
    • The support structure provides "opaque side walls extending above said surface in the light emitting direction to confine the entirety of light emitted" to an "included angle of less than about 180°."
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products generically as "LED based replacement light tubes for fluorescent type light fixtures" and "LED based fluorescent tube replacement lights" (Compl. ¶3, ¶8). No specific product models are named.

Functionality and Market Context

The complaint alleges the accused products are used for providing lighting in locations such as offices, homes, and businesses (Compl. ¶2). It further states that Defendant is in the business of importing, manufacturing, and/or selling these products (Compl. ¶3). The complaint does not provide further technical details about the operation or market position of the accused products.

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for analysis of Plaintiff's infringement theory, as it makes only a conclusory allegation that the accused products "incorporate each and every limitation of at least some of the claims" (Compl. ¶7). No claim chart is provided, and no specific product features are mapped to any claim limitations.

No probative visual evidence provided in complaint.

Identified Points of Contention

  • ’761 Patent Technical Question: A central question for infringement of a claim like claim 19 will be factual: do the accused products’ power supply circuits contain both a "rectifier" and a "pulse-width modulating circuit"? The presence and nature of the power regulation circuitry in the accused products will be a key evidentiary issue.
  • ’299 Patent Scope and Technical Question: For a claim like claim 2, a primary dispute may arise over both claim scope and technical operation. The analysis will focus on whether the accused tubes have a physical structure that meets the definition of "opaque side walls extending above said surface" and whether this structure actually "confine[s] the entirety of light" to an angle less than 180 degrees. This raises the question of whether directionality in the accused products is achieved via the claimed structure or by other means, such as the inherent properties of the LEDs themselves.

V. Key Claim Terms for Construction

Term from the ’761 Patent: "pulse-width modulating circuit" (claim 19)

  • Context and Importance: The presence of this specific circuit element is a critical limitation. Infringement will depend on whether the accused products' method for regulating power to the LEDs falls within the scope of this term, as distinct from simpler, non-infringing designs like linear regulators or purely resistive current limiters.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests several purposes for modulating DC power, including adjusting brightness, improving efficiency, and reducing flicker, stating the "PWM duty cycle can be adjusted or varied" to achieve these ends (’761 Patent, col. 3:49-52, col. 3:52-65). A party might argue this supports a functional definition covering various circuits that use pulsed power to regulate the LEDs.
    • Evidence for a Narrower Interpretation: The patent discloses a specific "switching power supply type current limiter" as an example circuit (’761 Patent, Fig. 6). A party might argue that the term should be limited to circuits with similar components or that actively modulate a duty cycle, distinguishing it from other types of switching regulators that may not be considered "pulse-width modulating."

Term from the ’299 Patent: "opaque side walls extending above said surface... to confine the entirety of light" (claim 2)

  • Context and Importance: This structural limitation is key to the patent's focus on directing light output. Practitioners may focus on this term because whether the accused products have this specific confining structure, as opposed to simply using directional LEDs on a flat board, will be determinative of infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Figure 3 of the patent depicts a circuit board with an "H-shaped cross-section" (’299 Patent, col. 2:59-60). A party could argue that the vertical elements of this "H" shape, if opaque, constitute the claimed "side walls" that extend above the LED mounting surface.
    • Evidence for a Narrower Interpretation: A party could argue that "side walls" requires structures that are distinct from and appended to the primary mounting surface, rather than being integral to the circuit board's cross-sectional profile. The phrase "extending above said surface" may be interpreted to require a significant vertical component designed expressly for light confinement.

VI. Other Allegations

Indirect Infringement

The complaint does not plead facts to support, or make any explicit allegations of, indirect infringement.

Willful Infringement

The complaint alleges willful infringement based on the Defendant's "continuing to make, offer for sale, and sell" the accused products "after being notified of its infringement" (Compl. ¶8). This allegation appears to be based on post-notice conduct rather than any pre-suit knowledge.

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

  • A key evidentiary question will be one of technical implementation: Do the accused LED tubes contain the specific "pulse-width modulating circuit" required by the '761 patent, or do they employ a different, potentially non-infringing power regulation technology?
  • A core issue will be one of structural scope: Can the term "opaque side walls extending above said surface," as claimed in the '299 patent, be construed to read on the physical design of the accused products, or is there a fundamental mismatch between the claimed light-confining structure and the defendant's technology?
  • Given the complaint's 2010 filing date and its lack of specific factual allegations, a threshold procedural question is whether the pleading would survive a challenge under the heightened plausibility standards of Twombly and Iqbal, which generally require more than conclusory statements of infringement.