DCT

3:25-cv-13543

EdisonLED LLC v. Bulbrite Industries Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:

  • Case Identification: 3:25-cv-13543, D.N.J., 10/21/2025

  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of patent infringement in the District of New Jersey and maintains one or more regular and established places of business within the district.

  • Core Dispute: Plaintiff alleges that Defendant’s various LED light bulb products infringe ten U.S. patents related to the design, structure, packaging, and optical performance of LED devices and arrays.

  • Technical Context: The technology at issue involves foundational aspects of modern LED lighting, focusing on methods to improve light efficiency, heat dissipation, and achieve omnidirectional light patterns similar to traditional incandescent bulbs.

  • Key Procedural History: The complaint is a First Amended Complaint that follows an Original Complaint filed in the Northern District of Texas. Plaintiff alleges that Defendant has been on notice of the patents-in-suit since at least June 18, 2015, when Plaintiff served preliminary infringement contentions containing 173 claim charts.

Case Timeline

Date Event
2003-07-04 Earliest Priority Date for U.S. Patent No. 7,560,738
2007-01-24 Earliest Priority Date for U.S. Patent No. 10,224,455
2008-11-13 Priority Date for U.S. Patent No. 8,240,881
2009-07-14 Issue Date for U.S. Patent No. 7,560,738
2012-05-29 Earliest Priority Date for U.S. Patent No. 11,808,436
2012-08-14 Issue Date for U.S. Patent No. 8,240,881
2012-08-15 Earliest Priority Date for U.S. Patent No. 10,319,703
2013-03-18 Priority Date for U.S. Patent No. 9,065,022
2013-05-28 Earliest Priority Date for U.S. Patent No. 9,368,483
2013-06-11 Earliest Priority Date for U.S. Patent Nos. 9,664,340 & 11,519,564
2013-10-22 Earliest Priority Date for U.S. Patent No. 10,281,123
2015-06-18 Plaintiff allegedly served preliminary infringement contentions
2015-06-23 Issue Date for U.S. Patent No. 9,065,022
2016-06-14 Issue Date for U.S. Patent No. 9,368,483
2017-05-30 Issue Date for U.S. Patent No. 9,664,340
2019-03-05 Issue Date for U.S. Patent No. 10,224,455
2019-05-07 Issue Date for U.S. Patent No. 10,281,123
2019-06-11 Issue Date for U.S. Patent No. 10,319,703
2022-12-06 Issue Date for U.S. Patent No. 11,519,564
2023-11-07 Issue Date for U.S. Patent No. 11,808,436
2025-10-21 First Amended Complaint Filing Date

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

U.S. Patent No. 7,560,738 - "Light-emitting diode array having an adhesive layer"

Issued July 14, 2009

The Invention Explained

  • Problem Addressed: The patent addresses challenges with prior art LED arrays, particularly their incompatibility with certain types of diodes (quaternary Al-In-Ga-P) that use a conductive rather than insulating substrate, and related problems with electrical connectivity and heat dissipation as array sizes increased (’738 Patent, col. 1:31-41; Compl. ¶24).
  • The Patented Solution: The invention proposes an LED array structure that uses an adhesive layer on a substrate to mount a plurality of "epitaxial light-emitting stack layers" (’738 Patent, col. 1:48-51; Compl. ¶25). A key feature of this solution is that both the P-contact and the N-contact for each stack layer are disposed on the same side, a configuration which the patent asserts improves the heat-dissipation efficiency of the array (’738 Patent, col. 1:54-56, col. 4:17-23; Compl. ¶25).
  • Technical Importance: This design aimed to improve the thermal performance and manufacturing flexibility of LED arrays, which were critical for enabling more powerful and reliable solid-state lighting products (’738 Patent, col. 1:45-47).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶86).
  • Claim 1 requires, in essence:
    • A substrate
    • An adhesive layer formed on the substrate
    • A plurality of electrically connected epitaxial light-emitting stack layers disposed on the adhesive layer
    • Each stack layer comprising a P-contact and an N-contact
    • The P-contact and the N-contact are disposed on the same side of the epitaxial light-emitting stack layer (Compl. ¶25).

U.S. Patent No. 8,240,881 - "Light-emitting device package"

Issued August 14, 2012

The Invention Explained

  • Problem Addressed: The patent identifies an efficiency problem in traditional light-emitting devices where the LED chip is mounted parallel to a carrier surface (’881 Patent, col. 1:31-37; Compl. ¶31). In this arrangement, light emitted downward is reflected, but with larger chips, this reflected light has a higher chance of being re-absorbed by the light-emitting layer, which reduces overall light efficiency (’881 Patent, col. 1:37-42; Compl. ¶32). The complaint provides a prior art diagram from the patent illustrating this parallel attachment and reflection path (Compl. ¶31, citing FIG. 1).
  • The Patented Solution: The invention discloses a "light-emitting device package" where the light-emitting device is mounted on a "platform" at a specified angle (’881 Patent, col. 1:46-54). Specifically, the angle between the primary surface of the transparent substrate (on which the LED is formed) and the platform is between 45 and 135 degrees (’881 Patent, col. 1:53-54; Compl. ¶33).
  • Technical Importance: By mounting the LED chip at an angle instead of parallel to the carrier platform, the invention seeks to alter the reflection path of downward-emitted light to reduce absorption and thereby increase light extraction efficiency (’881 Patent, col. 1:37-42; Compl. ¶32).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶94).
  • Claim 1 requires, in essence:
    • A carrier having a platform
    • A light-emitting device comprising a transparent substrate and a light-emitting structure
    • An angle between the first surface of the transparent substrate and the platform is 45-135 degrees (Compl. ¶33).

U.S. Patent No. 9,065,022 - "Light-emitting apparatus"

Issued June 23, 2015

  • Technology Synopsis: The patent addresses the low efficiency, high cost, and limited flexibility of traditional LED lamps that used planar, firm, and opaque substrates, making them unsuitable substitutes for lamps requiring wide lighting angles (Compl. ¶¶38-39). The disclosed solution is a light-emitting apparatus with a diode chip that has a light emitting angle wider than 180°, allowing light to penetrate into the substrate and emerge from an opposing surface, which is then coupled to a support base at an angle to provide uniform, intense lighting (Compl. ¶40).
  • Asserted Claims: Claim 1 (Compl. ¶102).
  • Accused Features: The complaint accuses the "’022 Accused Products," a list of Bulbrite LED bulbs, of infringement without specifying which features correspond to the patent's claims (Compl. ¶101).

U.S. Patent No. 9,368,483 - "Illumination device capable of decreasing shadow of lighting effect"

Issued June 14, 2016

  • Technology Synopsis: The patent recognizes that conventional LEDs emit light from a single side with relatively low efficiency, making them ill-suited for certain applications (Compl. ¶45). The invention describes an illumination device with multiple light-emitting elements tilted on a symmetrical supporting base, where light can be emitted bidirectionally from the elements to decrease shadowing and improve luminous efficiency (Compl. ¶46).
  • Asserted Claims: Claim 1 (Compl. ¶110).
  • Accused Features: The complaint accuses the "’483 Accused Products," a list of Bulbrite LED bulbs, of infringement without specifying which features correspond to the patent's claims (Compl. ¶109).

U.S. Patent No. 9,664,340 - "Light-emitting device"

Issued May 30, 2017

  • Technology Synopsis: The patent addresses a need for light-emitting devices with an omnidirectional light pattern not available in conventional apparatuses (Compl. ¶51). The solution involves a device with a carrier, multiple electrodes, a light-emitting unit, and a transparent body covering these components, configured to allow light to emit in different directions to achieve an omnidirectional pattern (Compl. ¶52).
  • Asserted Claims: Claim 1 (Compl. ¶118).
  • Accused Features: The complaint accuses the "’340 Accused Products," a list of Bulbrite LED bulbs, of infringement without specifying which features correspond to the patent's claims (Compl. ¶117).

U.S. Patent No. 10,224,455 - "Light-emitting device and method of forming the same"

Issued March 5, 2019

  • Technology Synopsis: The patent addresses the problem of light reduction in conventional LEDs due to total internal reflection, where light beams are absorbed after reflecting within the device, reducing brightness and luminous efficiency (Compl. ¶¶57-58). The complaint provides prior art diagrams from the patent illustrating this absorption problem (Compl. ¶¶57, 58, citing Figs. 1A-1B). The solution is a light-emitting device with a specific layered structure, including a transparent substrate with a top surface area at least 1.6 times that of the active layer, designed to improve brightness (Compl. ¶59).
  • Asserted Claims: Claim 1 (Compl. ¶126).
  • Accused Features: The complaint accuses the "’455 Accused Products," a list of Bulbrite LED bulbs, of infringement without specifying which features correspond to the patent's claims (Compl. ¶125).

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

Issued May 7, 2019

  • Technology Synopsis: The patent recognizes that conventional LEDs emit light from a single side with low efficiency, limiting their use in general illumination applications (Compl. ¶64). The invention discloses an illumination device where a light-emitting element is inserted into a supporting base, and a wavelength conversion layer covers the light-emitting chip but only a portion of its supporting surface, a configuration intended to enhance wavelength converting efficiency and light emitting performance (Compl. ¶65).
  • Asserted Claims: Claim 11 (Compl. ¶134).
  • Accused Features: The complaint accuses the "’123 Accused Products," a list of Bulbrite LED bulbs, of infringement without specifying which features correspond to the patent's claims (Compl. ¶133).

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

Issued June 11, 2019

  • Technology Synopsis: The patent addresses the inefficiency of incandescent lamps and the environmental toxicity of compact fluorescent lamps (CFLs) (Compl. ¶70). The proposed solution is a light-emitting device comprising multiple light-emitting units, a transparent structure, and a conductive element connecting at least two of the units (Compl. ¶70).
  • Asserted Claims: Claim 1 (Compl. ¶142).
  • Accused Features: The complaint accuses the "’703 Accused Products," a list of Bulbrite LED bulbs, of infringement without specifying which features correspond to the patent's claims (Compl. ¶141).

U.S. Patent No. 11,519,564 - "Light emitting bulb"

Issued December 6, 2022

  • Technology Synopsis: The patent addresses the need for a light-emitting apparatus with an omnidirectional light pattern unavailable in conventional devices (Compl. ¶75). The invention describes a device with a carrier and a complex electrode strip geometry (stripes and branches with different extending directions) to which light-emitting units are connected, enabling an omnidirectional light pattern (Compl. ¶76).
  • Asserted Claims: Claim 1 (Compl. ¶150).
  • Accused Features: The complaint accuses the "’564 Accused Products," a list of Bulbrite LED bulbs, of infringement without specifying which features correspond to the patent's claims (Compl. ¶149).

U.S. Patent No. 11,808,436 - "Light-emitting apparatus"

Issued November 7, 2023

  • Technology Synopsis: The patent identifies limitations in traditional LED lamps, including low efficiency, high cost, and inflexibility due to planar, opaque substrates, which are not suitable for wide-angle lighting (Compl. ¶¶81-82). The invention discloses a complex multi-part light-emitting apparatus with first and second light-emitting devices, multiple substrates, and wavelength conversion layers arranged on a support base to provide sufficient and uniform lighting performance (Compl. ¶83).
  • Asserted Claims: Claim 1 (Compl. ¶158).
  • Accused Features: The complaint accuses the "’436 Accused Products," a list of Bulbrite LED bulbs, of infringement without specifying which features correspond to the patent's claims (Compl. ¶157).

III. The Accused Instrumentality

Product Identification

The accused products are a wide range of commercial LED light bulbs sold by Defendant, including various models such as the Bulbrite Clear A19, B11, ST18, G25, and G40 series bulbs (collectively, the "Accused Products") (Compl. ¶¶2, 85, 93).

Functionality and Market Context

The complaint describes the Accused Products as commercial lighting products that are "marketed, offered, and distributed throughout the United States" (Compl. ¶2). The complaint does not provide specific technical details about the internal operation or construction of the Accused Products, instead identifying them by their commercial model names and referencing external exhibits (not provided) for detailed infringement analysis (Compl. ¶¶86, 94). The complaint alleges infringement by the making, using, selling, offering for sale, and/or importing of these products (Compl. ¶2).

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement of each of the ten patents-in-suit and references exemplary claim charts in Exhibits 20-30, which were not provided with the complaint (Compl. ¶¶86, 94, 102, 110, 118, 126, 134, 142, 150, 158). The complaint does not provide a narrative infringement theory or detailed mapping of accused product features to claim elements for any of the asserted patents. Therefore, there is insufficient detail for a claim-chart-based analysis of the infringement allegations.

Identified Points of Contention

  • ’738 Patent: An analysis would question whether the internal structure of the accused bulbs contains an "adhesive layer" used to mount "epitaxial light-emitting stack layers" in a configuration where the P-contact and N-contact are on the "same side," as required by claim 1. The dispute may turn on the material composition and structural function of the bonding agents and electrical contacts within the accused bulbs.
  • ’881 Patent: The central infringement question for the ’881 Patent will likely be one of geometric configuration. The analysis will depend on whether the accused products contain a light-emitting device mounted on a "platform" at an "angle...[of] 45-135 degree[s]," as claim 1 requires. This suggests a potential dispute over both the definition of a "platform" and the physical arrangement of the LED components inside the bulbs.

V. Key Claim Terms for Construction

Term: "adhesive layer" (’738 Patent)

  • Context and Importance: This term is foundational to the claimed structure. The outcome of the infringement analysis may depend on whether the material used to bond the LED stack layers to the substrate in the accused products falls within the legal definition of an "adhesive layer." Practitioners may focus on this term because Defendant could argue that its bonding material (e.g., a solder, eutectic bond, or other material) does not meet the ordinary or specification-defined meaning of "adhesive."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The complaint's summary of the invention describes the patent as seeking to "provide an LED array having an adhesive layer to overcome the drawbacks of the prior art" generally, which may support a functional definition encompassing any layer that serves the bonding purpose (Compl. ¶25).
    • Evidence for a Narrower Interpretation: The patent specification (not provided) may define "adhesive layer" by referencing specific examples, such as polymers or epoxies. If the accused products use a metallic or solder-based bonding layer, Defendant may argue such embodiments narrow the claim scope to exclude non-polymeric materials.

Term: "platform" (’881 Patent)

  • Context and Importance: The relationship between the light-emitting device and the "platform" defines the core inventive concept of an angled mounting. The definition of "platform" is critical; if it is construed narrowly to require a specific, distinct structural feature that is absent from the accused products, infringement may be avoided.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language recited in the complaint—"a carrier having a platform"—could support a reading where the "platform" is simply the surface of the carrier to which the light-emitting device is attached (Compl. ¶33).
    • Evidence for a Narrower Interpretation: The patent's description of the prior art problem involves a chip attached to a "carrier 3 with an attached surface 1" (Compl. ¶31). The solution's use of the different term "platform" may suggest an intended distinction, potentially requiring a structure that is more than just a generic surface on the carrier.

VI. Other Allegations

Willful Infringement

The complaint alleges that Defendant’s infringement has been and continues to be willful and deliberate for all asserted patents. The basis for this allegation is post-suit knowledge, stemming from the filing of an Original Complaint in the Northern District of Texas and the service of preliminary infringement contentions on June 18, 2015 (Compl. ¶¶8, 87, 95, 103, 111, 119, 127, 135, 143, 151, 159). Plaintiff alleges that Defendant’s continued infringing activities after receiving such notice constitute willful infringement, entitling Plaintiff to enhanced damages.

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

  • A key evidentiary question will be one of structural correspondence: Do the internal assemblies of Defendant's commercial LED bulbs, upon inspection and reverse engineering, actually contain the specific multi-part structures recited in the asserted claims? For instance, does the angled mounting of an LED element on a "platform" (’881 Patent) or the use of an "adhesive layer" for same-sided contacts (’738 Patent) exist in the accused products?
  • A core legal issue will be one of claim scope and construction: Can terms such as "adhesive layer" (’738 Patent), "platform" (’881 Patent), and "light emitting angle... wider than 180°" (’022 Patent) be construed broadly enough to read on the components and configurations found in mass-market LED bulbs, or will intrinsic evidence from the patent specifications narrow their meaning to specific embodiments not practiced by the Defendant?
  • A central procedural question will concern the sufficiency of the pleadings: The complaint asserts ten distinct patents against dozens of products in a generalized manner, relying on external exhibits not attached to the pleading. This may raise questions regarding whether the complaint provides sufficient factual detail to support a plausible claim for infringement for each patent against each accused product family under modern pleading standards.