DCT

2:25-cv-04361

Bulbrite Industries Inc v. EdisonLED LLC

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Bulbrite Industries, Inc. (New Jersey)
- Defendant: EdisonLED LLC (Texas)
- Plaintiff’s Counsel: The Law Office of JASON B. LATTIMORE, ESQ. LLC
Case Identification: 2:25-cv-04361, D.N.J., 05/16/2025
Venue Allegations: Plaintiff Bulbrite asserts that venue is proper in the District of New Jersey because it is the company's home forum, where it conducts business operations, and where the acts accused of constituting infringement occurred. The complaint further alleges that Defendant EdisonLED purposefully directed enforcement activities, including a cease-and-desist letter, into the district, creating substantial contacts.
Core Dispute: Plaintiff seeks a declaratory judgment that its LED lighting products do not infringe eleven U.S. patents owned by Defendant. This action was filed in response to a patent infringement lawsuit previously filed by Defendant against Plaintiff in the Northern District of Texas.
Technical Context: The patents-in-suit relate to the structural design, component arrangement, and manufacturing of light-emitting diode (LED) devices, particularly as applied in LED light bulbs intended to replace traditional incandescent bulbs.
Key Procedural History: The complaint notes that this action for declaratory judgment was filed in response to a lawsuit initiated by EdisonLED against Bulbrite in the Northern District of Texas on March 20, 2025. Prior to that litigation, EdisonLED allegedly sent Bulbrite a cease-and-desist letter asserting infringement of at least one of the patents-in-suit. The complaint also characterizes EdisonLED as a patent monetization entity whose only business is to acquire and litigate patents.

Case Timeline

Date	Event
2001-06-27	’455 Patent Priority Date
2004-04-13	’738 Patent Priority Date
2007-11-13	’881 Patent Priority Date
2009-02-11	’780 Patent Priority Date
2009-07-14	’738 Patent Issue Date
2012-05-29	’022, ’483, ’123, ’436 Patents Priority Date
2012-08-14	’881 Patent Issue Date
2012-08-15	’703 Patent Priority Date
2013-06-11	’340 Patent Priority Date
2013-07-23	’780 Patent Issue Date
2015-06-23	’022 Patent Issue Date
2016-06-14	’483 Patent Issue Date
2017-05-30	’340 Patent Issue Date
2019-03-05	’455 Patent Issue Date
2019-05-07	’123 Patent Issue Date
2019-06-11	’703 Patent Issue Date
2019-06-25	’564 Patent Priority Date
2022-12-06	’564 Patent Issue Date
2023-11-07	’436 Patent Issue Date
2025-03-20	EdisonLED files Texas Action against Bulbrite
2025-05-16	Bulbrite files this Declaratory Judgment Complaint

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

U.S. Patent No. 7,560,738 - "Light-Emitting Diode Array Having an Adhesive Layer"

The Invention Explained

Problem Addressed: The patent background discusses monolithic LED arrays on insulating substrates and notes the difficulty of connecting certain types of LEDs (like quaternary Al-In-Ga-P) where the positive and negative contacts are on opposite sides of the device structure, making planar interconnection challenging (Compl. Ex. 1, ’738 Patent, col. 1:21-41).
The Patented Solution: The invention proposes an LED array where multiple "epitaxial light-emitting stack layers" are mounted on a substrate using an adhesive layer. The key innovation is that for each stack layer, both the P-contact and the N-contact are disposed on the "same side," which facilitates simple, planar electrical interconnections between the individual LED elements (Compl. Ex. 1, ’738 Patent, Abstract; col. 2:54-67; Fig. 1).
Technical Importance: This design simplifies the fabrication and electrical wiring of multiple LED dies on a common substrate, enabling denser and more complex array configurations that are easier to manufacture.

Key Claims at a Glance

The complaint asserts non-infringement of at least independent claim 1 (Compl. ¶19).
Essential elements of claim 1 include:
- A light-emitting diode array comprising:
- a substrate;
- an adhesive layer formed on the substrate; and
- a plurality of electrically connected epitaxial light-emitting stack layers disposed on the adhesive layer, each comprising a P-contact and an N-contact, wherein the P-contact and the N-contact are disposed on the same side of the epitaxial light-emitting stack layer.
The complaint does not explicitly reserve the right to seek declaration of non-infringement of dependent claims for this patent.

U.S. Patent No. 8,240,881 - "Light-Emiting Device Package"

The Invention Explained

Problem Addressed: The patent background describes how conventional LED packages can suffer from low light extraction efficiency because light can be trapped within the device structure due to total internal reflection, or absorbed after being reflected back into the light-emitting layer (Compl. Ex. 2, ’881 Patent, col. 1:18-35).
The Patented Solution: The invention discloses a package where a light-emitting device (itself on a transparent substrate) is mounted onto a "platform" which is part of a "carrier." The key is that the transparent substrate is mounted at a specific angle (45-135 degrees) relative to the platform, which allows for improved lateral light extraction and reduces the amount of light trapped by internal reflection (Compl. Ex. 2, ’881 Patent, Abstract; col. 2:44-55).
Technical Importance: This angled mounting configuration is designed to create a more omnidirectional light source from a typically directional LED chip, an important step in developing LED-based replacements for traditional incandescent bulbs.

Key Claims at a Glance

The complaint asserts non-infringement of at least independent claim 1 (Compl. ¶32).
Essential elements of claim 1 include:
- A light-emitting device package comprising:
- a carrier having a platform; and
- a light-emitting device comprising a transparent substrate and a light-emitting structure;
- wherein an angle between the first surface of the transparent substrate and the platform is 45-135 degrees.
The complaint does not explicitly reserve the right to seek declaration of non-infringement of dependent claims for this patent.

U.S. Patent No. 8,492,780 - "Light-Emitting Device and Manufacturing Method Thereof"

Technology Synopsis: The patent describes an LED device with a substrate having a specially prepared sidewall. The sidewall comprises two distinct areas: one that is "substantially flat" and another that is "substantially textured," a feature intended to enhance light extraction efficiency by altering how light interacts with the edge of the device (Compl. ¶47; Compl. Ex. 3, ’780 Patent, Abstract).
Asserted Claims: The complaint asserts non-infringement of at least independent claim 1 (Compl. ¶47).
Accused Features: The complaint challenges the allegation that the sidewall of the substrate in the accused Bulbrite bulb has a second area with a "substantially textured" morphology as required by the patent (Compl. ¶49-50).

U.S. Patent No. 9,065,022 - "Light Emitting Apparatus"

Technology Synopsis: The patent discloses a light emitting apparatus where an LED chip has a "light emitting angle... wider than 180°" and is arranged such that a portion of the light it emits penetrates into its substrate and emerges from the opposing side. This design aims to create a bidirectional light source from a single chip to improve light distribution (Compl. ¶59; Compl. Ex. 4, ’022 Patent, Abstract).
Asserted Claims: The complaint asserts non-infringement of at least independent claim 1 (Compl. ¶59).
Accused Features: The complaint disputes that the accused product contains an LED chip with "a plurality of light emitting surfaces," that the light emitting angle is wider than 180°, that light "penetrates into said substrate," or that the internal glass stem constitutes a "support base" as claimed (Compl. ¶62, ¶65, ¶67).

U.S. Patent No. 9,368,483 - "Illumination Device Capable of Decreasing Shadow of Lighting Effect"

Technology Synopsis: This patent describes an illumination device with multiple semiconductor light emitting elements arranged on supports around a "symmetrical center" of a "supporting base." The elements are tilted to provide "bidirectional light emitting function" and decrease shadowing, creating a more uniform, omnidirectional light pattern (Compl. ¶76; Compl. Ex. 5, ’483 Patent, Abstract).
Asserted Claims: The complaint asserts non-infringement of at least independent claim 1 (Compl. ¶76).
Accused Features: The complaint contests that the accused bulb's internal structure qualifies as a "supporting base having a symmetrical center," that the LED elements are "disposed on the supporting base," or that they are "tilted" in the specific manner claimed (Compl. ¶79, ¶82, ¶89).

U.S. Patent No. 9,664,340 - "Light Emitting Device"

Technology Synopsis: The patent relates to an LED device structure comprising a carrier with top and bottom surfaces, and electrodes arranged on both surfaces. A "transparent body" covers the light-emitting components and electrodes (Compl. ¶98; Compl. Ex. 6, ’340 Patent, Abstract).
Asserted Claims: The complaint asserts non-infringement of at least independent claim 1 (Compl. ¶98).
Accused Features: The complaint challenges the allegations that the accused product has a "first electrode having... a second part formed on the bottom surface" or that the phosphor coating on the LEDs constitutes a "transparent body" as claimed (Compl. ¶101, ¶104-105).

U.S. Patent No. 10,224,455 - "Light Emitting Device and Method of Forming the Same"

Technology Synopsis: This patent describes a layered LED structure with an epitaxial structure, a transparent substrate, and two distinct transparent layers between them. One of these layers is specified as being "made of oxygen and only one metallic element" (Compl. ¶115; Compl. Ex. 7, ’455 Patent, Abstract).
Asserted Claims: The complaint asserts non-infringement of at least independent claim 1 (Compl. ¶115).
Accused Features: The complaint disputes that the accused product contains the claimed "second transparent layer... arranged between the first transparent layer and the epitaxial structure" and also disputes the arrangement of the "first electrode" relative to these layers (Compl. ¶118, ¶121).

U.S. Patent No. 10,281,123 - "Illumination Device"

Technology Synopsis: The invention describes an illumination device having a "supporting base" and a "light-emitting element" which itself includes a substrate and an LED structure. A key feature is a "first wavelength conversion layer covering the LED structure without covering the side surface" of the substrate (Compl. ¶130; Compl. Ex. 8, ’123 Patent, Abstract).
Asserted Claims: The complaint asserts non-infringement of at least independent claim 11 (Compl. ¶130).
Accused Features: The complaint argues that the accused product does not have a "supporting base" as claimed, that its wavelength conversion layer does not meet the specific coverage limitations, and that its connecting conductors are not on the "same side" of the element as required (Compl. ¶133, ¶136, ¶139).

U.S. Patent No. 10,319,703 - "Light Bulb"

Technology Synopsis: The patent claims a light bulb with two "optoelectronic units" connected by a "conductive element." These components are covered by a "transparent structure, pervious to light... and having a curved surface." The terminals connecting the units are formed on the same side of this transparent structure (Compl. ¶148; Compl. Ex. 9, ’703 Patent, Abstract).
Asserted Claims: The complaint asserts non-infringement of at least independent claim 1 (Compl. ¶148).
Accused Features: Bulbrite argues that the phosphor coating on its LEDs is not a "transparent structure" as the term is used in the patent and that the terminals are not "formed on a same side of the transparent structure" (Compl. ¶151-152, ¶156).

U.S. Patent No. 11,519,564 - "Light Emitting Bulb"

Technology Synopsis: The invention relates to an LED device with a specific electrode layout on a carrier. It describes a "first electrode strip" and a "second electrode strip," each having a main "stripe" and multiple "branches" extending in different directions, creating a comb-like or interdigitated pattern for connecting to light-emitting units (Compl. ¶166; Compl. Ex. 10, ’564 Patent, Abstract).
Asserted Claims: The complaint asserts non-infringement of at least independent claim 1 (Compl. ¶166).
Accused Features: The complaint disputes that the accused product's electrode strips have stripes and branches with "different" extending directions as required by the claims, arguing instead that they extend in the same direction (Compl. ¶170, ¶173).

U.S. Patent No. 11,808,436 - "Light Emitting Apparatus"

Technology Synopsis: The patent is directed to a light emitting apparatus with two light emitting devices mounted on a support base. A key feature is that the first device's LEDs are on its upper surface and emit light that "penetrat[es] the first substrate," and it has wavelength conversion layers on both its upper and bottom surfaces (Compl. ¶181; Compl. Ex. 11, ’436 Patent, Abstract).
Asserted Claims: The complaint asserts non-infringement of at least independent claim 1 (Compl. ¶181).
Accused Features: The complaint argues that the accused product does not have LEDs that emit light "penetrating the first substrate" and that its internal structure does not meet the claim's requirements for a "support base connected to the first light emitting device by a first angle and connected to the second light emitting device by a second angle" (Compl. ¶184, ¶187).

III. The Accused Instrumentality

Product Identification

The complaint specifically identifies the "Bulbrite Clear A19 2700K 8.5W Bulb" and the "Bulbrite BT56 Clear 2200K 4W Bulb" in its exemplary analyses and refers more broadly to "the Accused Products" (Compl. ¶6, and claim charts, e.g., p. 6, 40).

Functionality and Market Context

The accused products are LED light bulbs designed to replicate the appearance and omnidirectional light distribution of traditional incandescent filament bulbs (Compl. p. 8, photograph). They feature multiple LED "filaments"—which are strings of small LED dies mounted on transparent substrates—arranged within a clear glass envelope to mimic the aesthetic of a classic light bulb. This "filament-style" LED bulb is a significant product category in the consumer lighting market. The complaint does not contain allegations regarding the products' specific commercial importance.

IV. Analysis of Infringement Allegations

'738 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a plurality of electrically connected epitaxial light-emitting stack layers disposed on the adhesive layer,	The Bulbrite bulb's LED filament, which comprises multiple LED dies, is alleged to be a "plurality of... stack layers".	¶21	col. 2:58-60
each of the epitaxial light-emitting stack layers comprising a P-contact and an N-contact, wherein the P-contact and the N-contact are disposed on the same side of the epitaxial light-emitting stack layer.	The P-contact and N-contact for each LED die are alleged to be on the same surface, allowing for series connection along the filament. A photograph provided in the complaint identifies these contacts.	¶21	col. 2:62-67

Identified Points of Contention:
- Technical Question: A primary point of contention is factual: are the P-contact and N-contact of the LED dies in the accused product located on the "same side of the epitaxial light-emitting stack layer" as claimed? The complaint asserts they are on opposite sides, directly contradicting the infringement allegation (Compl. ¶23). The provided visual evidence shows contacts on a single surface, but this may not represent a complete cross-section of the "stack layer." (Compl. p. 6).
- Scope Question: A secondary question is whether the LED dies, encapsulated within the filament structure, are properly characterized as being "disposed on the adhesive layer" as required by the claim language (Compl. ¶22).

'881 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a carrier having a platform; and	The internal glass mount of the light bulb is alleged to be the "carrier," and the smaller glass struts that hold the LED filaments are alleged to be the "platform".	¶34	col. 1:46-47
an angle between the first surface of the transparent substrate and the platform is 45-135 degree.	The LED filament (the "transparent substrate") is mounted at an angle to the glass strut (the "platform"), which is alleged to fall within the claimed 45-135 degree range. A photograph with an angle overlay illustrates this allegation.	¶37	col. 2:4-6

Identified Points of Contention:
- Scope Question: The central dispute will be one of claim construction. Can the terms "carrier" and "platform," which are depicted in the patent as distinct mechanical mounting components, be interpreted broadly enough to read on the integrated internal glass stem and support structure of a consumer light bulb? The complaint argues they cannot, suggesting a fundamental mismatch between the claimed invention and the accused product's structure (Compl. ¶35, ¶38). The visual evidence shows the accused filament support structure, which bears little resemblance to the patent's figures. (Compl. p. 8, comparing photograph to ’881 Patent, Figs. 1, 6-8).

V. Key Claim Terms for Construction

'738 Patent

The Term: "disposed on the same side of the epitaxial light-emitting stack layer"
Context and Importance: The location of the P and N contacts is central to the non-infringement argument. Bulbrite alleges its contacts are on opposite sides of the stack layer (Compl. ¶23). The construction of "same side" and the definition of the boundaries of the "stack layer" will be critical.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification's general description emphasizes achieving a planar structure for easy connection. Language such as making P and N contacts "coplanar" could be argued to support a broader functional definition that covers any arrangement where contacts are accessible from a single plane (Compl. Ex. 1, ’738 Patent, Abstract).
- Evidence for a Narrower Interpretation: The patent's figures and detailed description show a specific "flip-chip" type structure where material is etched away to expose a lower layer for one of the contacts (Compl. Ex. 1, ’738 Patent, Fig. 1; col. 3:16-25). A defendant could argue the term is limited to this disclosed embodiment where both contacts are formed on the top-facing surface of the processed die.

'881 Patent

The Term: "platform"
Context and Importance: Bulbrite explicitly denies that the accused product contains a "platform" as the term would be understood in the context of the patent (Compl. ¶35, ¶38). The entire infringement theory for claim 1 hinges on this term reading on the internal glass struts of the accused light bulb. Practitioners may focus on this term because the visual dissimilarity between the patent's drawings of a platform and the accused product's structure is significant.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the platform as a surface to which the light-emitting device is attached, without imposing significant structural limitations in the text itself (Compl. Ex. 2, ’881 Patent, col. 4:1-5). An argument could be made that any surface that supports the LED substrate at the required angle serves this function.
- Evidence for a Narrower Interpretation: The patent's figures consistently depict the platform (603) as a distinct, solid, and often planar feature of the carrier, intended for mounting (Compl. Ex. 2, ’881 Patent, Figs. 6-7). The Abstract states the substrate is "attached to the platform by an adhering layer," which may suggest a more substantial structure than the thin glass supports in the accused bulb.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement allegations, as it is a complaint for declaratory judgment of non-infringement and thus focuses on denying liability.

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

A primary procedural question will be one of jurisdiction and venue: will this declaratory judgment action be allowed to proceed in Bulbrite's chosen New Jersey forum, or will it be dismissed or transferred in favor of the first-filed infringement action by EdisonLED in Texas?
A core substantive issue will be one of definitional scope: can terms rooted in semiconductor packaging, such as "carrier" and "platform" in the ’881 Patent, be construed broadly enough to encompass the distinct internal glass framework of a consumer filament-style LED light bulb, or is there a fundamental mismatch in the technologies?
A key evidentiary question will be one of physical structure: for the ’738 Patent, are the positive and negative electrical contacts on the LED dies within the accused bulb's filaments located on the "same side" of the semiconductor stack as claimed, or are they on opposite sides as Plaintiff contends? This question will likely turn on expert analysis of the accused product's construction.