DCT

1:25-cv-02283

Prosperina Ventures LLC v. Kichler Lighting LLC

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Prosperina Ventures LLC (Texas)
- Defendant: Kichler Lighting LLC (Delaware)
- Plaintiff’s Counsel: Durst Kerridge LLC; KENT & RISLEY LLC
Case Identification: 5:25-cv-02283, N.D. Ohio, 10/23/2025
Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of patent infringement in the district and maintains a regular and established place of business there.
Core Dispute: Plaintiff alleges that Defendant’s LED lighting products, including various LED bulbs and a ceiling light rail system, infringe five U.S. patents related to lighting fixture connectors, optical diffusers, and LED lamp design.
Technical Context: The patents relate to technologies for improving the mechanical security, light distribution uniformity, and thermal management of modern solid-state (LED) lighting products.
Key Procedural History: The complaint does not reference any prior litigation between the parties, Inter Partes Review (IPR) proceedings concerning the patents-in-suit, or any pre-suit licensing negotiations.

Case Timeline

Date	Event
2010-06-08	U.S. Patent No. 10,107,487 Priority Date
2010-10-08	U.S. Patent No. 9,310,030 Priority Date
2011-01-03	U.S. Patent No. 8,435,060 Priority Date
2011-04-25	U.S. Patent No. 9,470,882 Priority Date
2013-03-14	U.S. Patent No. 9,651,239 Priority Date
2013-05-07	U.S. Patent No. 8,435,060 Issued
2016-04-12	U.S. Patent No. 9,310,030 Issued
2016-10-18	U.S. Patent No. 9,470,882 Issued
2017-05-16	U.S. Patent No. 9,651,239 Issued
2018-10-23	U.S. Patent No. 10,107,487 Issued
2025-10-23	Complaint Filing Date

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

U.S. Patent No. 8,435,060 - “Fixtures, apparatuses, and related methods for providing load bearing connections for lighting devices,” issued May 7, 2013 (’060 Patent)

The Invention Explained

Problem Addressed: The patent describes a potential deficiency in the GU-24 socket and base system, a common non-Edison connector for energy-efficient lighting. It notes that when a lighting device using this system is held at an angle, it can have a tendency to "untwist," potentially leading to electrical disconnection or complete disengagement from the socket ('060 Patent, col. 3:17-31).
The Patented Solution: The invention proposes a fixture that includes a "lamp lock" with an "engagement device," such as a protrusion, that physically engages a corresponding "fastening receiver" (e.g., a recess or aperture) on the lamp housing. This mechanical interlock is designed to create a secure, load-bearing connection that prevents the lamp from untwisting or falling out, particularly in angled applications like track lighting ('060 Patent, Abstract; col. 6:33-54).
Technical Importance: The technology aims to improve the safety and mechanical reliability of lighting fixtures that use twist-and-lock connectors, which are prevalent in energy-efficient lighting standards.

Key Claims at a Glance

The complaint asserts infringement of at least independent claim 1 (Compl. ¶ 29).
The essential elements of claim 1 include:
- A fixture comprising a non-Edison connection for a lighting device.
- A fixture housing.
- A non-Edison socket securable to the fixture housing.
- An engagement device securable to the fixture housing, comprising a protrusion configured to engage a fastening receiver of a lamp housing upon insertion and engagement with the non-Edison socket.
The complaint does not explicitly reserve the right to assert other claims.

U.S. Patent No. 9,310,030 - “Non-uniform diffuser to scatter light into uniform emission pattern,” issued April 12, 2016 (’030 Patent)

The Invention Explained

Problem Addressed: The patent notes that solid-state light sources, such as co-planar arrangements of LEDs, typically produce a "forward directed light intensity profile" (e.g., a Lambertian pattern). This is often undesirable for general lighting applications intended to replace traditional incandescent bulbs, which have a more omnidirectional light output (’030 Patent, col. 3:45-56).
The Patented Solution: The invention describes a lamp with a light source and a separate, spaced-apart diffuser. The diffuser is engineered to have "varying scattering properties" across its surface. This non-uniformity is designed to alter the forward-directed light pattern, redirecting light to create a more uniform, omnidirectional emission pattern that better mimics traditional bulbs (’030 Patent, Abstract; col. 4:1-14). The variation can be achieved through changes in material thickness, scattering particle density, or surface texture (’030 Patent, col. 9:1-11).
Technical Importance: The technology provides a method for shaping the light output of efficient, directional LED sources to meet consumer expectations and industry standards (e.g., Energy Star) for omnidirectional replacement bulbs.

Key Claims at a Glance

The complaint asserts infringement of at least independent claim 1 (Compl. ¶ 34).
The essential elements of claim 1 include:
- A solid state light source emitting a substantially forward emission pattern.
- A diffuser to alter said forward emission pattern to create a more uniform pattern.
- Wherein the diffuser comprises a plurality of diffuser attributes to control a desired emission profile.
- Wherein the diffuser comprises varying scattering properties over its surface based on the desired emission profile.
The complaint does not explicitly reserve the right to assert other claims.

U.S. Patent No. 9,470,882 - “Optical arrangement for a solid-state lamp,” issued October 18, 2016 (’882 Patent)

Technology Synopsis: This patent addresses light loss in lamps that use total internal reflection (TIR) optics. The invention adds a "highly reflective secondary reflector" located adjacent to, but not in contact with, the primary TIR optical element to recapture and redirect stray light that escapes, thereby improving the lamp's overall efficiency (’882 Patent, Abstract; col. 1:40-50).
Asserted Claims: At least claim 1 (Compl. ¶ 39).
Accused Features: The complaint accuses Kichler MR8 and MR16 series bulbs of infringing the ’882 Patent (Compl. ¶ 39).

U.S. Patent No. 9,651,239 - “LED lamp and heat sink,” issued May 16, 2017 (’239 Patent)

Technology Synopsis: This patent describes a heat sink for an LED lamp designed to maximize surface area for heat dissipation while conforming to standard bulb form factors. The heat sink includes a plurality of fins, where each fin comprises a "first overhang that extends over a portion of the enclosure and a second overhang that extends over a portion of the base," increasing the heat-dissipating surface area in a compact design (’239 Patent, Abstract).
Asserted Claims: At least claim 1 (Compl. ¶ 44).
Accused Features: The complaint accuses various Kichler MR11 and MR16 series bulbs of infringing the ’239 Patent (Compl. ¶ 44).

U.S. Patent No. 10,107,487 - “LED light bulbs,” issued October 23, 2018 (’487 Patent)

Technology Synopsis: This patent relates to the structure of an LED light bulb designed for efficient cooling and manufacturability. The invention describes an "LED light engine" fabricated from a planar substrate that is shaped (e.g., bent) to form a "substantially rigid upright support structure" for the LEDs inside the bulb, which can facilitate convective cooling through openings in the bulb's base or cover (’487 Patent, Abstract).
Asserted Claims: At least claim 1 (Compl. ¶ 49).
Accused Features: The complaint accuses a wide range of Kichler LED bulbs (MR16, MR11, MR8, T5) of infringing the ’487 Patent (Compl. ¶ 49).

III. The Accused Instrumentality

Product Identification

The complaint accuses the "Kichler Ceiling Light Rail" of infringing the ’060 Patent and various Kichler-branded LED bulbs (including MR16, MR8, MR11, and T5 models) of infringing the ’030, ’882, ’239, and ’487 patents (Compl. ¶¶ 2, 29, 34, 39, 44, 49).

Functionality and Market Context

The complaint does not provide specific details regarding the technical functionality, operation, or market context of the accused products. The allegations are based on the products' general identities as LED lighting systems and bulbs (Compl. ¶ 2).

IV. Analysis of Infringement Allegations

The complaint asserts that the accused products infringe, either literally or under the doctrine of equivalents, at least claim 1 of each of the five patents-in-suit (Compl. ¶¶ 29, 34, 39, 44, 49). For each patent, the complaint references an external exhibit containing an "exemplary claim chart" that purportedly provides evidence of infringement (Compl. ¶¶ 30, 35, 40, 45, 50). As these exhibits were not filed with the complaint, the pleading itself contains no specific factual allegations or narrative theory explaining how any accused product meets the limitations of the asserted claims.

No probative visual evidence provided in complaint.

Identified Points of Contention:
- ’060 Patent: A central question will be one of structural correspondence. The infringement analysis will depend on whether the "Kichler Ceiling Light Rail" system includes a fixture with a discrete "lamp lock" containing a "protrusion" that physically interlocks with a lamp housing, as required by claim 1. The defense may argue that the accused product uses a different, non-infringing mechanism for securing the lamp.
- ’030 Patent: A key issue will be one of evidentiary proof. The infringement case will turn on Plaintiff's ability to demonstrate through technical evidence (e.g., materials analysis, optical testing) that the diffusers in the accused Kichler bulbs possess "varying scattering properties" across their surface, and that these properties perform the claimed function of transforming the light pattern. The question is whether the accused diffusers are intentionally engineered in this manner or are conventional diffusers with incidental manufacturing variations.

V. Key Claim Terms for Construction

’060 Patent

The Term: "engagement device"
Context and Importance: This term is the core of the claimed locking mechanism. Its construction will determine the scope of structures that can meet this limitation. Practitioners may focus on this term because its definition will be critical to distinguishing the patented invention from conventional connectors that provide friction-fit or other forms of non-interlocking retention.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The body of claim 1 defines the device functionally as comprising "a protrusion configured to engage a fastening receiver." This language may support an interpretation covering various shapes and forms of protrusions.
- Evidence for a Narrower Interpretation: The specification's embodiments consistently depict the "engagement device" as a protrusion on a flexible or cantilevered arm that snaps into a recess (e.g., '060 Patent, Fig. 1A, element 36A; col. 6:55-62). This could support an argument that the term is limited to such deflectable locking structures.

’030 Patent

The Term: "varying scattering properties"
Context and Importance: This term defines the central technical feature of the non-uniform diffuser. The case may hinge on whether the accused products' diffusers meet the definition of "varying." Practitioners may focus on this term because it is the primary point of novelty asserted by the patent over conventional, uniform diffusers.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that variation can be due to "changes in the scattering nature of the surfaces and/or variations in the amount of scattering material," suggesting multiple avenues for achieving the claimed feature (’030 Patent, col. 9:1-4).
- Evidence for a Narrower Interpretation: The embodiments and figures often illustrate this concept through discrete, engineered features, such as "a thicker band coating" in a specific region or "multiple partial coats" applied to the diffuser (’030 Patent, col. 32:7-13; col. 31:55-62). This could support an interpretation requiring intentionally applied, structurally distinct regions of diffusion rather than gradual or incidental variations.

VI. Other Allegations

Indirect Infringement: The complaint includes a boilerplate allegation of "indirectly" infringing for each count but does not plead any specific facts to support the requisite elements of knowledge of the patents and intent to encourage infringement (e.g., Compl. ¶ 29).
Willful Infringement: The complaint does not contain an explicit allegation of willful infringement.

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

A Threshold Pleading Question: Given the absence of factual allegations detailing infringement beyond references to unfiled exhibits, a primary question is whether the complaint meets the plausibility standard required by Twombly/Iqbal, or if it will be subject to a motion to dismiss for failure to state a claim.
A Structural Question: For the ’060 patent, a core issue will be one of structural correspondence. Does the accused "Ceiling Light Rail" system incorporate a mechanical "lamp lock" with a "protrusion" that maps onto the specific structures claimed, or does it achieve lamp security through a fundamentally different, non-infringing design?
An Evidentiary Question: For the ’030 patent and its counterparts, a key question will be one of technical proof. What evidence will establish that the accused bulbs' diffusers, heat sinks, and optical arrangements possess the specific, engineered properties claimed (e.g., "varying scattering properties," "overhangs," a shaped "upright support structure"), as distinguished from conventional designs with inherent or incidental structural variations?