DCT
1:25-cv-05829
Invictus Lighting LLC v. RAB Lighting Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Invictus Lighting LLC (North Carolina)
- Defendant: RAB Lighting, Inc. (New York)
- Plaintiff’s Counsel: Hecht Partners LLP
- Case Identification: 1:25-cv-05289, S.D.N.Y., 07/15/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is incorporated in New York and maintains a regular and established place of business within the judicial district, where it has allegedly committed acts of infringement.
- Core Dispute: Plaintiff alleges that Defendant’s LED lighting fixtures featuring "wattage selectability" infringe a patent related to light fixtures with an installer-adjustable maximum power output that works in concert with a separate dimming control.
- Technical Context: The technology addresses field-adjustable lighting, allowing a single fixture model to be configured for various applications at the time of installation, thereby reducing inventory complexity and improving energy efficiency.
- Key Procedural History: The complaint notes that during prosecution, the patent application overcame the "Reed" prior art reference (US 2013/0163243), distinguishing the invention based on its integration within a fixture, use of standard drivers, and cooperation with existing dimmer infrastructure. This prosecution history may inform the scope of the patent's claims.
Case Timeline
| Date | Event |
|---|---|
| 2013-07-26 | Earliest Priority Date for U.S. Patent No. 9,801,245 |
| 2017-10-24 | U.S. Patent No. 9,801,245 Issued |
| 2025-07-15 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,801,245 - "Light Fixture," issued October 24, 2017
The Invention Explained
- Problem Addressed: The patent's background section describes the logistical and financial challenges faced by installers, particularly Energy Services Companies (ESCos), who needed to stock numerous light fixtures with different, factory-set wattage outputs to meet the specific lighting requirements of diverse installation environments ( Compl. ¶¶10, 13; ’245 Patent, col. 1:41-2:14). Standard dimmers could only modulate brightness within a single, unchangeable maximum wattage, offering limited flexibility (Compl. ¶14; ’245 Patent, col. 2:60-64).
- The Patented Solution: The invention is a light fixture containing an "adjustable wattage limiter" (e.g., an adjustable resistor or trimpot) that is electrically connected to a light driver ('245 Patent, Abstract; col. 5:14-18). This allows an installer to select a specific maximum power output for the fixture from multiple available settings. This pre-set maximum works cooperatively with a standard dimming controller (e.g., a 0-10V dimmer), which then provides granular control of the light output at levels up to the selected maximum ('245 Patent, col. 6:24-42). This creates a two-tiered control system: a high-level power limit set by the installer and a dynamic brightness control for the end-user (Compl. ¶28).
- Technical Importance: The complaint alleges this "wattage selectability" feature was a breakthrough that simplified inventory, reduced costs, and was recognized by the Design Lights Consortium as a new product category called "Field Adjustable Lighting" (Compl. ¶¶7-8).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2, 7, and 8 (Compl. ¶40).
- Independent Claim 1 recites:
- a housing configured to receive a light;
- a driver disposed within the housing, having an input to connect to a power source and an output to provide power to the light;
- an adjustable wattage limiter disposed on or in the housing, electrically connected to the driver and configured to set a maximum output power; and
- wherein the driver and the wattage limiter are configured to provide power and vary that power in response to a dimming input from a dimming controller, between a minimum output power and the maximum output power set by the limiter.
III. The Accused Instrumentality
Product Identification
The complaint names several product families as the "Accused Products," including the WPLEDFC Wall Pack Series, ALED5T/WS Area Lights, FFLED39/WS Floodlights, VXBRLED/WS Vaporproof Fixtures, and EZPAN/WS Flat Panels (Compl. ¶¶33, 36). The WPLEDFC/WS wall pack is used as a representative example (Compl. ¶34).
Functionality and Market Context
The complaint alleges the Accused Products incorporate a system architecture that includes three key components:
- "Selectable wattage settings" (e.g., 36W / 29W / 20W) enabled by an "internal selector switch" that is only accessible after removing part of the housing, such as a lens cover (Compl. ¶34).
- Support for standard "0–10V dimming control" through a dedicated wire pair for connection to an external dimmer (Compl. ¶34).
- An "integrated LED driver and output circuitry" that interprets the settings from both the internal selector switch and the external dimming input to produce a controlled light output (Compl. ¶34).
The complaint states that Defendant’s marketing materials identify these products as "Wattage Selectable" (Compl. ¶34).
IV. Analysis of Infringement Allegations
’245 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing configured to receive a light | The WPLEDFC/WS wall pack lighting fixture includes a housing that contains the light source and other components. | ¶34 | col. 3:4-5 |
| a driver disposed within the housing, said driver including an input configured to connect to a power source and an output configured to provide power to the light | The accused products contain an "integrated LED driver and output circuitry" within the fixture housing. | ¶34 | col. 5:49-54 |
| an adjustable wattage limiter disposed on or in said housing, said wattage limiter being electrically connected to the driver and configured to set a maximum output power provided by the driver | The accused products include an "internal selector switch" for selecting wattage settings (e.g., 36W / 29W / 20W), which is located inside the housing and connected to the driver. | ¶34 | col. 5:14-18 |
| wherein the driver and the wattage limiter are configured to provide power to the light and to vary the power, in response to a dimming input from a dimming controller, between a minimum output power and the maximum output power set by the wattage limiter | The integrated LED driver allegedly interprets both the selector switch setting and the 0-10V dimming input to regulate power delivery and produce a controlled light output within the selected range. | ¶35 | col. 6:24-42 |
The complaint provides a circuit diagram, labeled as Figure 1 of the ’245 Patent, illustrating the relationship between the dimming controller (12), adjustable resistor (14), and driver (16) (Compl. ¶22). This figure is presented to explain the cooperative architecture of the claimed invention.
Identified Points of Contention
- Scope Questions: A central dispute may arise over whether the accused "internal selector switch" with discrete settings (e.g., 20W/29W/36W) falls within the scope of the term "adjustable wattage limiter." The patent specification often refers to components like an "adjustable resistor" or a "trimpot," which can suggest continuous or "near infinite" adjustability (Compl. ¶27; ’245 Patent, col. 6:20-21). The defense may argue that a switch with a few fixed options is technically distinct from the disclosed embodiments.
- Technical Questions: Claim 1 requires that the "driver and the wattage limiter" are configured to "vary the power" in response to a dimmer. It raises the question of whether the accused selector switch, once set, is a passive component that merely establishes an upper boundary, or if it actively participates in "varying the power" alongside the driver as required by the claim language. The analysis will likely focus on whether the switch is part of the dynamic power-varying configuration or simply a static pre-selector.
V. Key Claim Terms for Construction
The Term: "adjustable wattage limiter"
- Context and Importance: This term is the core of the invention. The outcome of the case may depend on whether the accused product's "internal selector switch" is construed as an "adjustable wattage limiter."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that the term should be read broadly to encompass any mechanism that allows an installer to select a maximum wattage, consistent with the problem solved by the patent. The specification lists "adjustable resistor," "slide resistor," "linear potentiometer," and "trimpot" as examples, suggesting the term is not limited to any single structure ('245 Patent, col. 3:25-27, 4:1).
- Evidence for a Narrower Interpretation: Defendant may argue that the consistent use of terms describing continuously variable components (resistor, potentiometer) and the patent's reference to enabling "near infinite wattage and lumen control" ('245 Patent, col. 6:20-21) limits the term to non-discrete adjusters. This could exclude a switch with only a few fixed positions.
The Term: "wherein the driver and the wattage limiter are configured to ... vary the power"
- Context and Importance: Practitioners may focus on this term because it defines the functional relationship between the key components. Infringement will depend on whether the accused limiter (the switch) is considered part of the active configuration for varying power in response to a dimmer.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may point to language describing a "hybrid lighting control system" where the components work "in conjunction" ('245 Patent, col. 6:27-37). Under this view, the limiter's act of setting the maximum power is an integral part of the overall "configuration" that enables the driver to vary power within that new, constrained range.
- Evidence for a Narrower Interpretation: Defendant may argue for a stricter reading, where the claim requires both the driver and the limiter to be actively involved in the variation of power. If the accused switch is set once and then functions as a passive circuit element, one could argue that only the driver, not the limiter, is subsequently "varying the power" in response to the dimmer input.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain a formal count for indirect infringement. However, it alleges that Defendant provides "marketing materials, datasheets, and installation manuals" that highlight the infringing features, which could be used to support a future claim for induced infringement (Compl. ¶38).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's knowledge of the ’245 Patent, "at least as of the filing and issuance date, if not earlier" (Compl. ¶39, 41).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Does the term "adjustable wattage limiter," which the patent illustrates with continuously variable components like resistors and potentiometers, read on the accused products' "internal selector switch" that provides a few discrete power settings?
- A second key issue will be one of functional operation: Does the accused system satisfy the claim requirement that the "driver and the wattage limiter" are configured to "vary the power" in response to a dimming signal? This will likely turn on whether the limiter is found to be an active participant in the power variation process or merely a passive, one-time selector of a static power ceiling.