DCT
1:20-cv-05537
Globe Electric Co Inc v. All Star Lighting Supplies Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Globe Electric Company Inc. (Canada)
- Defendant: All Star Lighting Supplies, Inc. d/b/a Luxrite (New York)
- Plaintiff’s Counsel: Greenberg Traurig, LLP
- Case Identification: 1:20-cv-05537, S.D.N.Y., 07/17/2020
- Venue Allegations: Venue is alleged to be proper in the Southern District of New York because the Defendant is incorporated in New York, resides in the district, and has committed alleged acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s recessed LED lighting products infringe a patent related to an easily accessible switch for changing the light's color temperature.
- Technical Context: The technology concerns modern LED light fixtures that allow users to select the color temperature (e.g., warm yellow vs. cool white light) to suit different environments.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the patent-in-suit via a letter dated February 14, 2020, approximately five months before filing the lawsuit. This alleged pre-suit notice forms the basis for the willfulness claim.
Case Timeline
| Date | Event |
|---|---|
| 2018-03-26 | '091 Patent Priority Date |
| 2019-03-19 | '091 Patent Issue Date |
| 2020-02-14 | Plaintiff allegedly sent notice letter to Defendant |
| 2020-07-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,234,091 - Ceiling Mountable LED Light Fixture with Accessible CCT Selectable Switch, issued March 19, 2019
The Invention Explained
- Problem Addressed: For ceiling-mounted LED fixtures with adjustable color temperature (CCT), the selection switch is often located on the driver housing, which is installed behind the ceiling drywall (e.g., gypsum board). After installation, changing the color temperature requires the difficult and potentially damaging task of pulling the entire driver housing through a small mounting hole to access the switch ('091 Patent, col. 1:45-65).
- The Patented Solution: The invention solves this problem by moving the selector switch from the driver housing onto the flexible cable that connects the driver to the light fixture itself. The cable is designed with enough length so that a user can simply pull the light fixture out of its mounting hole, exposing the in-line switch for easy adjustment, and then push the fixture back into place without disturbing the driver housing behind the ceiling ('091 Patent, Abstract; col. 2:40-45).
- Technical Importance: This design improves user convenience and serviceability for a popular feature in modern lighting, eliminating the need for specialized tools or potential damage to the ceiling for post-installation adjustments ('091 Patent, col. 2:16-21).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 ('091 Patent, Compl. ¶15).
- Independent Claim 1 recites the following essential elements:
- A ceiling mountable LED light fixture comprising an LED light housing with at least two sets of LEDs for generating different correlated color temperatures (CCT).
- A driver housing with a driver circuit, adapted for mounting behind ceiling material and spaced from the fixture mounting hole.
- A cable interconnecting the driver circuit and the LED light housing.
- Detachable retention means (e.g., spring clips) to secure the light fixture in the mounting hole.
- The cable having a "predetermined length" to permit the LED light fixture to be withdrawn from the mounting hole a "predetermined distance."
- This withdrawal provides access to a "selector switch mounted in said cable."
- The switch permits selective activation of the LED sets to generate a desired CCT.
- The complaint does not explicitly reserve the right to assert dependent claims but states infringement of "one or more claims" (Compl. ¶13).
III. The Accused Instrumentality
Product Identification
- Defendant’s "color CCT switch lighting products," including but not limited to model numbers LR23760, LR23763, LR23755, LR23758, LR23750, and LR23753 (Compl. ¶4, ¶13).
Functionality and Market Context
- The accused products are recessed LED lighting fixtures that allow users to select the color temperature of the light they emit (Compl. ¶15, ¶17). The complaint alleges that Defendant provides installation guides and instruction materials for these products that instruct customers on their use (Compl. ¶17). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges that the accused products meet every limitation of at least Claim 1 of the ’091 patent (Compl. ¶15). While the complaint references an "Exhibit B" containing a claim chart for model LR23763, that exhibit was not attached to the publicly filed document (Compl. ¶16). The infringement theory is based on the allegation that Defendant’s "color CCT switch lighting products" possess the features recited in the claim (Compl. ¶15, ¶17).
'091 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A ceiling mountable LED light fixture comprising an LED light housing, at least two sets of LED's mounted in said housing for generating light at different correlated color temperature (CCT)... | The complaint alleges Defendant’s products are "color CCT switch lighting products" which, by implication, contain multiple sets of LEDs to produce different color temperatures. | ¶15, ¶17 | col. 6:12-16 |
| a driver housing having a driver circuit mounted therein, said driver housing being adapted for mounting behind a ceiling sheet material and spaced from a fixture mounting hole... | The complaint alleges the accused products are lighting fixtures for ceiling installation, which implies the presence of a driver housing separate from the visible fixture. | ¶17 | col. 6:16-21 |
| a cable interconnecting said driver circuit in said driver housing to said LED light housing for supplying output current... | The complaint's reference to "color CCT switch lighting products" and their installation implies a standard architecture with a cable connecting a driver to the light engine. | ¶17 | col. 6:21-25 |
| said cable having a predetermined length to permit said LED light fixture to be withdrawn from said fixture mounting hole a predetermined distance to provide access to a selector switch mounted in said cable... | The complaint alleges infringement of this limitation but provides no specific facts regarding the location of the switch or the length of the cable on the accused products. | ¶15 | col. 6:31-37 |
| ...to permit selective activation of either one of said at least two sets of LED's or both sets of LED's simultaneously to cause said LED light fixture to generate light at a selected desired correlated color temperature (CCT). | The complaint alleges the products are "color CCT switch lighting products," which directly suggests the function of selectively activating LEDs to change color temperature. | ¶15, ¶17 | col. 6:37-39 |
Identified Points of Contention
- Structural Questions: The central infringement question will be factual: are the accused products' selector switches "mounted in said cable"? The complaint does not provide photos or detailed descriptions to substantiate this core structural limitation.
- Functional Questions: Does the cable on the accused products have the "predetermined length" required by the claim to allow the fixture to be withdrawn a "predetermined distance" specifically to provide access to the switch? The defense may argue its cable length is incidental or for general installation convenience, not for the specific access function recited in the claim.
V. Key Claim Terms for Construction
- The Term: "a selector switch mounted in said cable"
- Context and Importance: This term appears to be the point of novelty. The location of the switch is the central feature of the invention claimed to overcome the prior art problem. The outcome of the infringement analysis will likely depend on whether the accused products' switches are located "in" the cable, as opposed to on the fixture housing or on the driver housing.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that "in said cable" does not require the switch to be a fully enclosed, in-line component, but could also cover a switch integrated into a connector or junction box that is part of the overall cable assembly. The claim itself does not specify the form factor of the switch beyond its location.
- Evidence for a Narrower Interpretation: The specification and figures consistently depict the selector switch (18) as a distinct component situated along the length of the cable (15), separate from both the light fixture housing (12) and the driver housing (16) ('091 Patent, Fig. 1; col. 2:40-42). This may support a construction requiring the switch to be an in-line element physically located on the flexible cord itself.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "installation guides and other instruction material" that actively encourage and instruct its customers to use the products in a manner that infringes the ’091 patent (Compl. ¶17).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged knowledge of the ’091 patent since "at least as early as February 14, 2020," when Plaintiff allegedly sent a notice letter (Compl. ¶11, ¶19). The complaint alleges that Defendant continued its infringing conduct despite this knowledge and "despite an objectively high likelihood that its actions constituted infringement" (Compl. ¶19).
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute centers on the specific placement and accessibility of a color-selection switch in an LED light fixture. The case will likely turn on two primary questions:
- A central evidentiary question of structure: Does discovery show that the accused Luxrite products physically embody the core limitation of Claim 1—a selector switch that is "mounted in said cable" connecting the driver to the light fixture? The complaint's allegations are conclusory on this point.
- A key question of claim scope and function: Assuming the switch is on the cable, does the cable's length serve the specific, claimed function of allowing the fixture to be withdrawn a "predetermined distance to provide access" to that switch, or can the defendant demonstrate a non-infringing design purpose for its cable length and switch placement?