Lime Green Lighting LLC v. Savant Systems Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lime Green Lighting, LLC (Michigan)
  • Defendant: Savant Systems, Inc. (Delaware)
  • Plaintiff’s Counsel: David J. Hoffman
• Case Identification: 1:25-cv-00084, S.D.N.Y., 01/03/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Southern District of New York because Defendant maintains a "regular and established place of business" in the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s smart lighting systems infringe a patent related to self-adaptive, scheduled lighting control technology that utilizes an external server.
• Technical Context: The technology at issue concerns smart home systems that automatically adjust lighting based on environmental data and user inputs, which are processed by a remote server to generate and refine lighting schedules.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity. It preemptively addresses the patent marking statute (35 U.S.C. § 287), alleging that prior settlement licenses granted by its predecessors-in-interest did not authorize any party to produce a patented article and therefore did not trigger marking requirements.

Case Timeline

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

U.S. Patent No. 9,699,874 - "System, method, and apparatus for self-adaptive scheduled lighting control"

• Patent Identification: U.S. Patent No. 9,699,874, "System, method, and apparatus for self-adaptive scheduled lighting control," issued July 4, 2017.

The Invention Explained

• Problem Addressed: The patent's background section notes that prior art lighting systems, including early "smart" bulbs, require manual user intervention to change settings and cannot anticipate a user's desires ('874 Patent, col. 2:36-50). It identifies a need for a "self-adaptive scheduled lighting control" to overcome these limitations ('874 Patent, col. 2:50-53).
• The Patented Solution: The invention is a lighting control device that includes sensors, a dimmer, and a wireless transceiver. The device is configured to collect environmental data (e.g., ambient light) and user input, transmit this data to an "external server," and in return, obtain and execute a "lighting operating schedule" from that server ('874 Patent, Abstract). The server can analyze data from one or more devices to generate new, adaptive schedules that define lighting intensity or color as a function of time ('874 Patent, col. 2:10-22, 38-48).
• Technical Importance: The technology represents a shift from direct-command lighting control to a learning-based ecosystem where schedules are automated and refined based on collected data from the user's environment.

Key Claims at a Glance

• The complaint asserts claims 1-20 of the '874 patent (Compl. ¶12). Independent claim 1 is representative of the asserted device claims.
• Independent Claim 1 recites a lighting control device with the following essential elements:
  • a microcontroller;
  • a memory with executable instructions;
  • at least one wireless transceiver;
  • at least one dimmer;
  • at least one powered lighting output connected to the dimmer;
  • at least one environmental sensor;
  • at least one input device;
  • wherein the microcontroller executes instructions to perform a method of: obtaining environmental data, obtaining input data, transmitting the data to an external server, obtaining a lighting operating schedule from the server, and executing that schedule.
• The complaint reserves the right to assert dependent claims (Compl. ¶12).

III. The Accused Instrumentality

Product Identification

• The complaint does not name specific accused products. It refers generally to Defendant's "products and services" and "the use of lights with ceiling fans and related systems" (Compl. ¶13), as well as an "infringing product and/or service with instruction or advertisement" on Defendant's website (Compl. ¶14).

Functionality and Market Context

• The complaint asserts that Defendant's products are used to perform infringing methods (Compl. ¶2). It further alleges that Defendant provides instructions through its website and manuals that encourage infringing use (Compl. ¶13, 14). The complaint states that detailed support for these allegations is contained in an exhibit that was not included with the public filing (Compl. ¶11), preventing a more detailed analysis of the accused functionality.

IV. Analysis of Infringement Allegations

The complaint states that support for its infringement allegations may be found in an appended table, Exhibit B (Compl. ¶11). However, Exhibit B was not included with the publicly filed complaint. Therefore, a detailed claim chart analysis cannot be performed based on the provided documents. The infringement theory, based on the complaint's narrative, is that Defendant's smart lighting systems possess the components of the claimed device and perform the claimed method steps of collecting data, communicating with a server, and executing a lighting schedule.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the architecture of Defendant’s system aligns with the specific claim recitation of a "lighting control device" communicating with an "external server". The inquiry may focus on whether the accused product is a single, integrated device as described in claim 1, or if its functions are distributed across multiple components in a way that may not satisfy the claim's structural limitations.
  • Technical Questions: The dispute may turn on whether the accused system generates and executes a "lighting operating schedule" as contemplated by the patent. This raises the question of whether the system implements a pre-defined, time-based plan derived from server analysis, or if it primarily responds to direct, real-time commands from a user, which could present a mismatch with the claimed functionality. The complaint does not provide evidence to distinguish between these modes of operation.

V. Key Claim Terms for Construction

• The Term: "external server"

• Context and Importance: This term appears in independent claims 1 and 15 and is central to the patented architecture, which offloads schedule generation from the local device. The definition of what constitutes an "external" server will be critical to determining infringement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification does not explicitly define "external." A party could argue it simply means any server that is not physically integrated within the main housing of the "lighting control device" itself ('874 Patent, Fig. 2).
  • Evidence for a Narrower Interpretation: The patent describes a system where a server receives data from a "plurality of lighting control devices" to generate schedules ('874 Patent, col. 8:50-54). This could support an interpretation that "external server" requires a centralized, remote system capable of aggregating data from multiple users, not merely a local server on a home network.

• The Term: "lighting operating schedule"

• Context and Importance: This term, recited in independent claims 1, 15, and 20, defines the output of the server and the input for execution by the local device. Its construction will determine what type of instruction qualifies as a "schedule."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party might argue that any set of commands from the server that controls the lights constitutes a "schedule."
  • Evidence for a Narrower Interpretation: The specification states that the "new lighting operating schedule defines the lighting intensity and/or the lighting color for one or more lights as a function of time" ('874 Patent, col. 2:42-44). This language, along with the description of generating schedules from weighted historical data ('874 Patent, Claim 20), may support a narrower construction that requires a time-based plan, as distinct from a simple, instantaneous command.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant actively encourages infringement by providing instructions on its website and in product manuals (Compl. ¶12, 14). It also alleges contributory infringement, claiming the accused products are not staple articles of commerce and are sold with knowledge of their infringing use (Compl. ¶13).
• Willful Infringement: Willfulness is alleged based on Defendant's knowledge of the '874 patent from "at least the filing date of the lawsuit" (Compl. ¶12, 13). Plaintiff reserves the right to amend if discovery reveals an earlier date of knowledge (Compl. p. 4, n.1).

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

• A core issue will be one of architectural mapping: Does the Defendant's system architecture, particularly the division of functionality between its in-home hardware and any associated cloud service, meet the specific structural limitations of the claimed "lighting control device" that obtains information from an "external server"?
• A key question will be functional in nature: Does the accused system primarily operate by generating and executing a "lighting operating schedule"—a predictive, time-based plan as described in the patent—or does it function as a real-time remote control, which may not perform the method steps required by the claims?
• Finally, an evidentiary question will be paramount: As the complaint relies on a missing exhibit for its detailed infringement contentions, a threshold issue will be whether discovery produces evidence sufficient to show that the accused products actually perform the claimed data collection, transmission to a server, and schedule execution.