DCT
1:24-cv-00473
Feit Electric Co Inc v. Savant Tech LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Feit Electric Company, Inc. (California)
- Defendant: Savant Technologies LLC d/b/a GE Lighting ( Delaware)
- Plaintiff’s Counsel: Benesch Friedlander Coplan & Aronoff LLP
- Case Identification: 1:24-cv-00473, N.D. Ohio, 03/13/2024
- Venue Allegations: Venue is alleged to be proper in the Northern District of Ohio because the Defendant maintains its principal place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s LED filament light bulbs infringe a patent related to technology for improving the aesthetic appearance of such bulbs.
- Technical Context: The technology concerns LED lighting, specifically filament-style bulbs, and methods to make them appear white, rather than yellow, when in their non-operational "off" state.
- Key Procedural History: The complaint alleges that Plaintiff sent a notice letter to Defendant on December 12, 2023, identifying the patent-in-suit and the accused technology, which forms the basis for the willfulness allegation.
Case Timeline
| Date | Event |
|---|---|
| 2010-10-05 | U.S. Patent No. 8,604,678 Priority Date |
| 2013-12-10 | U.S. Patent No. 8,604,678 Issued |
| 2023-12-12 | Plaintiff sent notice letter to Defendant |
| 2024-03-06 | Plaintiff purchased samples of the First Accused Product |
| 2024-03-13 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,604,678 - "Wavelength Conversion Component With a Diffusing Layer," issued December 10, 2013
The Invention Explained
- Problem Addressed: The patent describes two issues with prior "remote phosphor" LED lighting devices. First, when in the "OFF" state, the phosphor gives the device an undesirable "yellowish, yellow-orange, or orange-color appearance" which can be unappealing to consumers. Second, when "ON," the color of the light can vary depending on the viewing angle, creating perceptible non-uniformity. (’678 Patent, col. 2:6-23).
- The Patented Solution: The invention proposes a wavelength conversion component that includes two distinct but contacting layers: a "wavelength conversion layer" containing photoluminescent (phosphor) particles and a separate "light diffusing layer" containing light-scattering particles (e.g., titanium dioxide). (’678 Patent, col. 3:5-14). This diffusing layer is designed to improve the white appearance in the OFF state and, during operation, can be configured to scatter the LED's blue excitation light more than the phosphor's emitted light, which can reduce the amount of costly phosphor material needed. (’678 Patent, col. 3:15-24; col. 4:1-15).
- Technical Importance: This approach sought to make filament-style LED bulbs more aesthetically competitive with traditional incandescent bulbs by solving the unappealing color of the phosphor when the bulb is unlit. (’678 Patent, col. 2:11-17).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1. (Compl. ¶18).
- The essential elements of Claim 1 are:
- a wavelength conversion layer comprising particles of at least one photoluminescence material;
- and a light diffusing layer comprising particles of a light scattering material,
- wherein the light diffusing layer improves an off-state white appearance of the wavelength conversion component;
- wherein the wavelength conversion component is configured such that in operation a portion of excitation light comprising blue light (wavelength ≥ 440 nm) generated by the light emitting device is emitted through the component to contribute to a final visible emission product.
- The complaint reserves the right to assert other claims. (Compl. ¶19).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the GE LED Pearl Filament Model No. LED6DBC/DL9GCQWF-3T as the "First Accused Product." (Compl. ¶13).
Functionality and Market Context
- The accused product is an LED filament light bulb. (Compl. ¶17). The complaint alleges the product is constructed with one or more LEDs covered by a light conversion material inside a bulb enclosure. (Compl. ¶17).
- A key feature highlighted in the complaint is the product's aesthetic appearance when unlit. The complaint references the product packaging, which markets the bulb's "Pearl Filament" as seamlessly blending into décor and being superior to "standard yellow LED filaments that disrupt a fixture's aesthetic." (Compl. ¶16, ¶18). This marketing suggests the product is positioned to address the same "off-state" appearance problem described in the ’678 Patent.
IV. Analysis of Infringement Allegations
’678 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a wavelength conversion layer comprising particles of at least one photoluminescence material; | The complaint alleges, based on an image of a dissected filament, that the "yellow material" indicated by a red arrow is a wavelength conversion layer containing phosphor mixed in a carrier like silicone. (Compl. ¶18, p.4). | ¶18 | col. 8:56-61 |
| and a light diffusing layer comprising particles of a light scattering material, | The complaint alleges, based on the same dissected filament image, that the "white material" indicated by a blue arrow is a light diffusing layer containing a light scattering material like titanium dioxide mixed in silicone. (Compl. ¶18, p.5). | ¶18 | col. 8:19-22 |
| wherein the light diffusing layer improves an off-state white appearance of the wavelength conversion component; | The complaint alleges the LED filament has a white off-state appearance, contrasting it with the yellow of typical filaments. (Compl. ¶18, p.5). This is supported by an image showing the isolated white filament (Compl. ¶18, p.5, bottom right image) and by quoting the product's packaging, which claims the "subtle filament" avoids the aesthetic disruption of "standard yellow LED filaments." (Compl. ¶16, ¶18). | ¶18 | col. 11:19-28 |
| wherein the wavelength conversion component is configured such that in operation a portion of excitation light ... is emitted through the wavelength conversion component to contribute to a final visible emission product. | On information and belief, the complaint alleges that the product's LEDs emit blue light (≥440 nm) that is converted to white light by the conversion layer and scattered by the diffusing layer to create the final emission product. (Compl. ¶18, p.6). This is supported by an image of the bulb in an operational, lit state. (Compl. ¶18, p.6). | ¶18 | col. 10:21-27 |
Identified Points of Contention
- Technical Questions: The complaint alleges the material composition of the infringing layers (e.g., phosphor, titanium dioxide, silicone) on "information and belief." (Compl. ¶18). A central question for discovery will be to determine the actual composition and microstructure of these layers and whether they meet the claim limitations. What evidence will Plaintiff provide that the accused "white material" functions as a "light diffusing layer" in the specific optical manner described by the patent?
- Scope Questions: Claim 1 requires that the diffusing layer "improves an off-state white appearance." The complaint relies heavily on the defendant's own marketing claims from the product packaging to meet this limitation. (Compl. ¶18). This raises the question of whether subjective marketing statements are sufficient to prove infringement of this functional limitation, or if the court will require objective, colorimetric data of the type the patent itself uses to demonstrate the invention's benefits. (’678 Patent, Figs. 4-8).
V. Key Claim Terms for Construction
The Term: "light diffusing layer"
- Context and Importance: This term is the core of the asserted invention's novelty. Its definition will determine whether the accused product's outer white coating falls within the scope of the claims. Practitioners may focus on this term because the dispute will likely involve whether any layer that scatters light meets the limitation, or if it must have the specific properties and functions described in the patent's embodiments.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves broadly define the term as "a light diffusing layer comprising particles of a light scattering material." (’678 Patent, Claim 1). This could support an argument that any layer meeting this general description infringes.
- Evidence for a Narrower Interpretation: The specification describes embodiments where the diffusing layer has specific properties, such as being composed of titanium dioxide, having a specific particle size (e.g., <150 nm), and having a particular weight loading (e.g., 7% to 35%) to achieve the desired optical effects of improving off-state appearance and on-state color uniformity. (’678 Patent, col. 8:19-22; col. 11:51-54; col. 12:53-56). This may support a narrower construction tied to these functional characteristics.
The Term: "improves an off-state white appearance"
- Context and Importance: This is a functional limitation that is critical to infringement. The parties will likely dispute the standard of proof required to show "improvement."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The background section describes the problem in consumer-facing terms as a "yellowish, yellow-orange, or orange-color appearance" that is "off-putting or undesirable to ... potential purchasers." (’678 Patent, col. 2:9-16). This could support an argument that an "improvement" can be established by evidence of improved consumer appeal, such as the marketing claims on the accused product's packaging.
- Evidence for a Narrower Interpretation: The patent's detailed description quantifies "improvement" using objective, scientific measurements, such as "CIE color change" and chromaticity diagrams. (’678 Patent, col. 11:37-41; Fig. 4). This may support an argument that infringement requires objective proof via colorimetric data, not just subjective marketing claims.
VI. Other Allegations
Indirect Infringement
- The complaint does not provide sufficient detail for analysis of indirect infringement.
Willful Infringement
- The complaint alleges willful infringement based on pre-suit knowledge of the ’678 Patent. It states that Plaintiff sent a notice letter via FedEx on December 12, 2023, to Defendant's Senior Counsel, which specifically identified the ’678 patent and warned that "lamps incorporating white LED filament packages" would likely infringe. (Compl. ¶¶ 22-28).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: How will the court define the functional limitation "improves an off-state white appearance"? The case may turn on whether this requires objective, colorimetric proof of a change in "whiteness" as detailed in the patent's specification, or if subjective evidence, such as the defendant's own marketing claims about superior aesthetics, is sufficient to meet the limitation.
- A key evidentiary question will be one of technical proof: Can the Plaintiff, through discovery and expert testing, demonstrate that the accused product's layered filament structure—alleged on "information and belief"—actually contains the materials and performs the specific optical functions required by the claims? This includes proving not only the presence of a "wavelength conversion layer" and a "light diffusing layer" but also that they operate together in the manner claimed by the patent.