Smart Billiard Lighting LLC v. Lucid BallSports Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Smart Billiard Lighting LLC (Illinois)
  • Defendant: Lucid BallSports, Inc. (New York)
  • Plaintiff’s Counsel: Spiro Harrison & Nelson; Fitch, Even, Tabin & Flannery LLP
• Case Identification: 2:23-cv-02457, E.D.N.Y., Filing Date: 03/30/2023
• Venue Allegations: Venue is asserted on the basis that Defendant is a New York corporation with a principal place of business in Jericho, New York, within the district, and has allegedly committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s "Predator Arena Light" infringes a utility patent related to peripheral, uniform billiard table lighting systems and a design patent for an ornamental light frame.
• Technical Context: The technology concerns specialized lighting fixtures designed to eliminate shadows and "hot spots" common with traditional, centrally-hung billiard lights, thereby improving conditions for both players and automated video analysis systems.
• Key Procedural History: The complaint notes that Plaintiff provided Defendant with actual notice of the patents and infringement allegations via a letter on August 3, 2021, and that subsequent negotiations between the parties did not resolve the dispute.

Case Timeline

Date	Event
2014-08-01	’713 Patent Earliest Priority Date
2015-12-10	’328 Design Patent Priority (Filing) Date
2017-01-10	’328 Design Patent Issue Date
2017-10-13	Plaintiff's website notice of ’328 Patent
2020-06-01	Alleged first infringing activity by Defendant
2021-06-29	’713 Patent Issue Date
2021-08-03	Plaintiff provides actual notice letter to Defendant
2021-12-25	Plaintiff's website notice of ’713 Patent (by this date)
2023-03-30	Complaint Filing Date

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

U.S. Patent No. 11,045,713 - Billiard Table Lighting, issued June 29, 2021

The Invention Explained

• Problem Addressed: The patent’s background section states that traditional billiard table lights, typically placed over the center of the table, create uneven illumination, with a bright center and darker corners and rails. This unevenness can be detrimental to computerized image analysis for ball tracking and automated game recording (’713 Patent, col. 2:3-10).
• The Patented Solution: The invention proposes a lighting apparatus with a frame that supports lights around the periphery of the billiard table, rather than over the middle. This configuration is designed to provide "substantially uniform" lighting across the entire playing surface, which is more suitable for imaging applications (’713 Patent, Abstract; col. 2:49-54). The structure, described as a "troffer frame," also serves to hold diffusers and can mount other devices like cameras and sensors, as illustrated in FIG. 1 and FIG. 7 (’713 Patent, col. 8:35-39; Fig. 1).
• Technical Importance: By creating uniform, shadowless light, this peripheral lighting approach sought to enable more reliable and cost-effective automated video recording and computer-vision-based analysis of billiard games (’713 Patent, col. 1:60-65).

Key Claims at a Glance

• The complaint asserts independent claim 33 and dependent claims 34 and 36 (Compl. ¶24).
• Independent Claim 33 recites the following essential elements:
  • A "troffer frame" configured to support lights for a billiard table surface.
  • The frame supports the lights "around a periphery" of the table surface so that "no light sources are placed approximately directly above a middle portion" of the table.
  • The troffer frame is "substantially hollow," with "opposing sides" that "extend down from the top portion" to encase the lights.
  • The troffer frame supports a "bottom diffuser" between the lights and the table, configured to allow light to pass through to the table.

U.S. Design Patent No. D776,328 - Light Frame, issued January 10, 2017

The Invention Explained

• Problem Addressed: This patent does not address a technical problem but instead protects a specific aesthetic and non-functional design.
• The Patented Solution: The patent claims the specific ornamental design for a light frame "as shown and described" (’328 Patent, Claim). The claimed design, depicted in solid lines in its figures, consists of a rectangular frame with rounded corners and a central transverse bar or element that appears to divide the frame into two sections. The design is for the visual appearance of the frame itself, not its function.

Key Claims at a Glance

• The complaint asserts the single claim of the design patent (Compl. ¶45).
• The claim protects the overall ornamental visual appearance of the light frame as depicted in the patent's drawings, such as in FIG. 1.

III. The Accused Instrumentality

Product Identification

The accused product is the "Predator Arena Light" (Compl. ¶17).

Functionality and Market Context

The complaint alleges the Predator Arena Light is a lighting system for billiard tables marketed as providing "[u]nique balanced illumination" that avoids "dark corners and 'hot spots'" (Compl. ¶17). It is alleged to use a segmented, "U-shaped" frame to house LED light elements and is designed to be installed over the periphery of the table (Compl. ¶28, ¶29). An image from Defendant’s website shows the Predator Arena Light prepared for installation over the rails of a billiard table (Compl. p. 8). The product is allegedly used in professional billiard tournaments, suggesting a position in the high-performance segment of the market (Compl. ¶20).

IV. Analysis of Infringement Allegations

’713 Patent Infringement Allegations

Claim Element (from Independent Claim 33)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a troffer frame configured to support one or more lights to provide light to the billiard table surface;	The accused light uses a "troffer frame" to support its lights, which is described as a "substantially hollow frame" made of U-shaped segments that encase the lights. An image from an installation video shows the assembly of these hollow segments.	¶27	col. 8:35-39
the troffer frame configured to support the one or more lights around a periphery of the billiard table surface such that no light sources are placed approximately directly above a middle portion of the billiard table surface;	The accused light is designed to hang above the table's periphery, with marketing materials and installation photos showing no lights over the middle portion of the table. A product image illustrates the light hanging above the periphery.	¶29	col. 8:41-44
wherein the troffer frame is substantially hollow in its inner structure, wherein the inner structure is configured to support the one or more lights, wherein opposing sides of the troffer frame extend down from the top portion encasing the one or more lights;	The frame is alleged to be a "substantially hollow frame that encases" the lights. An image of the frame segments shows a U-shaped channel structure consistent with having opposing sides extending downward from a top surface.	¶27	col. 8:40-48
wherein the troffer frame supports a bottom diffuser between the one or more lights and the billiard table surface, wherein the bottom diffuser is configured such that at least some of the light...can pass through...to the billiard table.	The accused light is alleged to support a "bottom diffuser." An image from Defendant's website shows the diffuser, and an installation video screenshot explicitly instructs users on handling the "diffuser-side" of the frame segments.	¶31, p. 10	col. 9:26-34

Identified Points of Contention

• Scope Questions: A central dispute may arise over the term "troffer frame". The patent describes it as a "narrow inverted trough" (col. 8:37-38). The question for the court will be whether the accused product's segmented aluminum extrusion frame meets this definition, or if the term is limited to a more specific structure.
• Technical Questions: For dependent claim 34, which requires "substantially uniform illumination," the complaint relies on Defendant's marketing claims of "even lux intensity" (Compl. ¶34). A key evidentiary question will be whether the Predator Arena Light actually meets the technical standard for uniformity disclosed in the patent (e.g., a coefficient of variation of 14% or less, as described at col. 7:30-34), which will likely require empirical testing.

’328 Design Patent Infringement Allegations

The complaint alleges that the ornamental design of the Predator Arena Light is "substantially the same" as the design claimed in the '328 Patent, such that it would deceive an ordinary observer into purchasing the accused product believing it to be the patented design (Compl. ¶47). This allegation is supported by presenting a figure from the patent and a photograph of the accused product in a pool hall setting (Compl. pp. 13-14). A key question for the fact-finder will be a direct visual comparison of the two designs, focusing on their non-functional, ornamental aspects.

V. Key Claim Terms for Construction

The Term: "troffer frame" (’713 Patent, Claim 33)

• Context and Importance: This term defines the core structure of the apparatus. The outcome of the infringement analysis for the '713 patent may hinge on its construction. Practitioners may focus on this term because its definition will determine whether the accused product's segmented frame is within the scope of the claim.
• Intrinsic Evidence for a Broader Interpretation: The patent does not provide a formal definition in a dedicated section. The term could be argued to cover any trough-like frame used to hold lighting elements, consistent with its general use in the lighting industry.
• Intrinsic Evidence for a Narrower Interpretation: The specification provides a specific description in the context of an embodiment: "the frame 1120 is in the shape of a troffer, i.e., a narrow inverted trough, serving as a light source support, reflector, and holder of diffusers" (’713 Patent, col. 8:35-39). A party could argue this language, along with the detailed depiction in FIG. 11, limits the term to a structure with all these characteristics.

The Term: "periphery of the billiard table surface" (’713 Patent, Claim 33)

• Context and Importance: This term is critical as it defines the inventive placement of the lights, distinguishing it from prior art central lighting. The parties may dispute how far from the edge this "periphery" extends.
• Intrinsic Evidence for a Broader Interpretation: The term is not defined with precise geometric boundaries, which may support an interpretation covering a general zone around the perimeter of the table's playing surface.
• Intrinsic Evidence for a Narrower Interpretation: The specification provides an exemplary range: "within ten inches of the vertical projection of the cushion's 117 edge, and more preferably within five inches" (’713 Patent, col. 8:47-50). A party may argue this language narrows the scope of the term. The complaint itself points to Defendant's instructions to hang the frame "directly over the rails," a specific peripheral location (Compl. ¶30).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement of the '713 patent, asserting that Defendant provides customers with installation videos and instructions that guide them to install and use the Predator Arena Light in a manner that directly infringes the patent's claims (Compl. ¶37).
• Willful Infringement: Willfulness is alleged for both patents. The claim is based on Defendant's alleged continued infringement after receiving an actual notice letter from Plaintiff on August 3, 2021, which allegedly identified the patents and the infringing product (Compl. ¶3, ¶39, ¶48).

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

This case appears to present several distinct questions for the court:

• A core issue will be one of claim construction: can the term "troffer frame", which the patent describes as a "narrow inverted trough," be construed to read on the accused product's frame, which is assembled from extruded aluminum segments? The resolution of this question may be dispositive for the utility patent claim.

• For the design patent, the central question is one of visual comparison: in the eye of an ordinary observer familiar with billiard lighting, is the overall ornamental appearance of the accused Predator Arena Light "substantially the same" as the design claimed in the '328 patent, or are the visual differences significant enough to avoid infringement?

• Finally, a key evidentiary question will surround willfulness. The complaint pleads pre-suit notice, raising the question of whether Defendant’s alleged conduct after August 3, 2021, was objectively reckless, potentially exposing it to enhanced damages if infringement is found.