Invictus Lighting LLC v. Signify North America Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Invictus Lighting LLC (North Carolina)
  • Defendant: Signify North America Corporation (Delaware)
  • Plaintiff’s Counsel: Hecht Partners LLP
• Case Identification: 3:26-cv-01166, D.N.J., 02/05/2026
• Venue Allegations: Plaintiff alleges venue is proper in the District of New Jersey because Defendant transacts business, has a regular and established place of business, and offers the accused products for sale within the district.
• Core Dispute: Plaintiff alleges that Defendant’s wattage-selectable LED lighting products infringe a patent related to technology for setting a maximum power output for a light fixture that works in concert with a separate dimming control.
• Technical Context: The technology addresses the need for energy-efficient lighting fixtures that offer both a guaranteed maximum energy consumption level for installers and flexible brightness control for end-users, a key concern in large-scale commercial retrofits.
• Key Procedural History: The patent-in-suit is a continuation of a prior application and claims priority to two provisional applications filed in 2013 and 2014. The complaint alleges that the patented feature, "wattage selectability," has been recognized by the Design Lights Consortium as a new product category called "Field Adjustable Lighting."

Case Timeline

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

U.S. Patent No. 9,801,245 - "Light Fixture"

• Patent Identification: U.S. Patent No. 9,801,245 (“the ’245 Patent”), issued October 24, 2017.

The Invention Explained

• Problem Addressed: The patent’s background section describes the challenges faced by Energy Services Companies (ESCo’s) in performing large-scale lighting retrofits ʼ245 Patent, col. 1:33-36 ESCo’s need to guarantee energy savings, but facilities often have a wide variety of fixtures with different wattage requirements, complicating inventory and installation ʼ245 Patent, col. 2:41-54 Standard dimmers do not solve this problem because they do not cap the maximum possible energy consumption, which undermines the ESCo's ability to promise a specific return on investment ʼ245 Patent, col. 2:60-64
• The Patented Solution: The patent describes a "hybrid lighting control system" that decouples the maximum power setting from the user's dimming control ʼ245 Patent, col. 6:26-27 An installer uses an "adjustable resistor" or similar component to pre-set a maximum wattage for the fixture, effectively creating a power ceiling ʼ245 Patent, col. 6:30-34 A separate, secondary dimmer then allows the end-user to adjust the light level, but only within the range up to the pre-set maximum ʼ245 Patent, col. 6:34-38 This architecture is illustrated in the circuit diagram of Figure 1 ʼ245 Patent, Fig. 1
• Technical Importance: This approach allows a single model of light fixture to be adapted for many different installation environments, simplifying inventory and logistics for large projects while ensuring contractually required energy savings are met ʼ245 Patent, col. 6:47-52

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2, 7, and 8 Compl. ¶25
• Independent Claim 1 elements:
  • A light fixture comprising a housing configured to receive a light;
  • A driver within the housing with an input for a power source and an output to power the light;
  • An adjustable wattage limiter on or in the housing, connected to the driver and configured to set a maximum output power;
  • Wherein the driver and wattage limiter are configured to vary the power to the light in response to a dimming input, between a minimum output power and the maximum output power set by the limiter.

III. The Accused Instrumentality

Product Identification

The complaint identifies several product families as the "Accused Products," including the Day-Brite NWL Utility Wrap Series, Day-Brite SDS LED Strip Series, DSRT Center Basket Troffer Family, FluxPanel Selectable LED (SBP) Series, and SlimFlood Selectable Outdoor Luminaires Compl. ¶21

Functionality and Market Context

The complaint alleges the Accused Products incorporate "selectable wattage functionality" through "internal selector switches" that define a maximum power output Compl. ¶22 Compl. ¶30 This feature is allegedly combined with support for 0-10V dimming, which allows a user to control brightness within the installer-defined range Compl. ¶22 The complaint alleges that this functionality is highlighted in Defendant's marketing materials, datasheets, and installation manuals Compl. ¶24

IV. Analysis of Infringement Allegations

• Claim Chart Summary: The complaint alleges that the Accused Products directly infringe at least claim 1 of the ’245 Patent Compl. ¶25 The complaint provides a side-by-side visual comparison of what is alleged to be Plaintiff's switch and Defendant's "Field Adjustable Wattage Selector ('FAWS')" to support its allegations Compl. ¶23

’245 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over the proper construction of "adjustable wattage limiter." The analysis may question whether the accused "internal selector switches," which may provide discrete power levels, fall within the scope of a term that the patent specification often describes as an "adjustable resistor," "trimpot," or "linear potentiometer" ʼ245 Patent, col. 5:46-48, components that can suggest continuous or near-continuous adjustability.
  • Technical Questions: The complaint alleges the accused selector switch and dimmer function in a complementary manner as claimed Compl. ¶30 A technical question for the court may be whether the accused system's circuitry and logic for processing inputs from the selector switch and the 0-10V dimming control operate in the specific manner required by the claim language, particularly the element requiring the driver and limiter to vary power "in response to a dimming input... between a minimum... and the maximum... set by the wattage limiter."

V. Key Claim Terms for Construction

• The Term: "adjustable wattage limiter"
• Context and Importance: This term is the core of the asserted independent claim and defines the central innovative concept. The outcome of the case may depend on whether Defendant's "internal selector switches" are found to be an "adjustable wattage limiter." Practitioners may focus on this term because the patent's specific examples differ from the componentry alleged to be in the accused products.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 uses the broad, functional term "limiter," not the more specific "resistor" used elsewhere in the patent. The specification also refers to various physical adjusters, including a "knob" or a "slidable controller," which could support a construction that is not limited to a specific type of electrical component '245 Patent, col. 4:6-9
  • Evidence for a Narrower Interpretation: The detailed description of the invention repeatedly and consistently refers to the component as an "adjustable resistor 14" '245 Patent, col. 5:43-44, a "slide resistor," a "linear potentiometer" ('245 Patent, col. 5:46-48), or a "trimpot" '245 Patent, col. 4:2 A defendant may argue that these specific embodiments define the true scope of the invention and limit the term to analog-style, continuously variable components rather than switches with discrete settings.

VI. Other Allegations

• Indirect Infringement: While no separate count for indirect infringement is pleaded, the complaint alleges facts that could support such a claim. It states that Defendant's "marketing materials, datasheets, and installation manuals repeatedly highlight" the accused features, which may suggest allegations of active inducement by instructing others (e.g., installers and end-users) on how to use the products in an infringing manner Compl. ¶24 Compl. ¶31
• Willful Infringement: The complaint alleges that Defendant "has had knowledge of the '245 Patent and its claimed invention at least as of the filing and issuance date, if not earlier" and that its continued infringement is "willful, deliberate, and in reckless disregard of Invictus's patent rights" Compl. ¶24 Compl. ¶26 Compl. ¶32

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

The resolution of this dispute may turn on two central questions for the court:

1. A core issue will be one of definitional scope: can the claim term "adjustable wattage limiter," which the patent specification primarily exemplifies as a continuously variable component like a resistor or potentiometer, be construed broadly enough to encompass the accused products' "internal selector switches," which may provide a finite number of discrete power settings?
2. A key evidentiary question will be one of operational equivalence: does the combination of the accused "selector switch," LED driver, and 0-10V dimming input function in the specific cooperative manner required by the claim—where the driver and limiter together vary power in response to the dimming signal within a range capped by the limiter—or is there a fundamental difference in the circuitry's technical operation?