DCT
5:25-cv-00193
Lime Green Lighting LLC v. Jasco Products Co LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lime Green Lighting, LLC (Michigan)
- Defendant: Jasco Products Co LLC (Oklahoma)
- Plaintiff’s Counsel: Phillip Free Law, PLLC
- Case Identification: 5:25-cv-00193, W.D. Okla., 03/27/2025
- Venue Allegations: Venue is alleged to be proper based on Defendant having regular and established places of business within the district and having committed alleged acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s ENBRIGHTEN smart lighting products infringe patents related to self-adaptive scheduled lighting control systems.
- Technical Context: The technology at issue involves lighting control systems that collect environmental and user data, transmit it to a remote server for analysis, and receive back an adaptive lighting schedule to execute.
- Key Procedural History: Plaintiff identifies itself as a non-practicing entity. The complaint discloses prior settlement licenses with other entities, asserting that these licenses did not constitute an admission of infringement and were not licenses to produce a patented article, a point which may become relevant to potential defenses regarding patent marking and the calculation of pre-suit damages.
Case Timeline
| Date | Event |
|---|---|
| 2014-09-12 | '874 and '798 Patents Priority Date |
| 2017-07-04 | '874 Patent Issue Date |
| 2020-10-06 | '798 Patent Issue Date |
| 2025-03-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,699,874
- Patent Identification: U.S. Patent No. 9,699,874, "System, Method, And Apparatus for Self-Adaptive Scheduled Lighting Control," issued July 4, 2017. (Compl. ¶10).
The Invention Explained
- Problem Addressed: The patent's background section notes that while "smart" LED bulbs allow for remote control, they still require manual user intervention to change brightness or color, rather than anticipating a user's desires and adapting automatically. (’874 Patent, col. 1:45-53).
- The Patented Solution: The invention is a lighting control device that bridges this gap by collecting data from local sources (an environmental sensor and a user input device), transmitting this data to an external server, and in return obtaining a "lighting operating schedule" from that server. (’874 Patent, Abstract). The device then executes this schedule, creating a lighting environment that can adapt over time based on collected data, as illustrated in the system diagram of Figure 3. (’874 Patent, col. 2:1-9; Fig. 3).
- Technical Importance: The technology aims to create a more intelligent and autonomous lighting system that learns from user behavior and environmental conditions, thereby reducing the need for constant manual adjustments. (’874 Patent, col. 1:50-53).
Key Claims at a Glance
- The complaint asserts infringement of claims 1-20. (Compl. ¶12). Independent claim 1 is a system claim and its essential elements include:
- A microcontroller, memory, wireless transceiver, dimmer, powered lighting output, environmental sensor, and input device.
- The microcontroller is configured to perform a method of:
- obtaining environmental data from the sensor and input data from the input device;
- transmitting this data to an external server;
- obtaining a "lighting operating schedule" from the external server based on the data; and
- executing that schedule.
- The complaint reserves the right to assert dependent claims. (Compl. ¶12).
U.S. Patent No. 10,798,798
- Patent Identification: U.S. Patent No. 10,798,798, "System, Method, And Apparatus for Self-Adaptive Scheduled Lighting Control," issued October 6, 2020. (Compl. ¶18).
The Invention Explained
- Problem Addressed: The patent, a continuation of the application leading to the ’874 patent, addresses the same general problem of creating an adaptive lighting system. (’798 Patent, col. 1:28-58).
- The Patented Solution: The invention builds on the '874 patent's system by adding a specific "interrupt operation." When a user makes a manual change to the lighting, the system is configured to suspend its automated schedule, implement the user's change, and then resume the automated schedule only after a "time-out period" has elapsed without further user changes. (’798 Patent, col. 12:4-14). This process is detailed in the flowchart of Figure 7, which shows the system detecting a user change (704), interrupting the schedule (706), and starting a time-out period (710).
- Technical Importance: This feature addresses a critical usability issue in automated systems by allowing for temporary manual overrides without forcing the user to completely disable the automation. (’798 Patent, col. 9:12-24).
Key Claims at a Glance
- The complaint asserts infringement of claims 1-20. (Compl. ¶20). Independent claim 1 is a system claim and its essential elements include:
- A microcontroller and memory configured to perform a method of obtaining data, transmitting it to a remote server, receiving a schedule, and executing that schedule by controlling smart bulbs.
- A specific method step of executing an "interrupt operation," which includes:
- suspending execution of the schedule based on interrupt data from a user change;
- implementing the user change; and
- resuming execution of the schedule.
- The complaint reserves the right to assert dependent claims. (Compl. ¶20).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are Defendant's "ENBRIGHTEN product and/or service." (Compl. ¶16).
Functionality and Market Context
The complaint alleges that Defendant makes, uses, and sells products that perform self-adaptive, scheduled lighting control. (Compl. ¶6, ¶11). The allegations suggest these products are used with "lights with ceiling fans and related systems." (Compl. ¶15). The complaint does not describe the specific technical architecture or operation of the ENBRIGHTEN products but alleges that Defendant offers them with instructions that suggest an infringing use. (Compl. ¶16). The complaint does not provide specific details on the commercial importance of the accused products.
IV. Analysis of Infringement Allegations
The complaint references, but does not include, claim chart exhibits (Exhibits 2 and 4). The following summary is based on the asserted claims and the complaint's narrative infringement theory.
'874 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A lighting control device comprising: a microcontroller; a memory...; at least one wireless transceiver; at least one dimmer; at least one powered lighting output; at least one environmental sensor; [and] at least one input device | The ENBRIGHTEN system is alleged to be a lighting control device containing these hardware components. | ¶12 | col. 4:60-61; 5:19-24; 5:41-43; 5:58-61 |
| obtaining environmental data from at least one environmental sensor; [and] obtaining input data from at least one input device | The accused system allegedly collects data about its environment and from user inputs. | ¶12, ¶13 | col. 2:3-4 |
| transmitting the environmental data and the input data to an external server | The accused system allegedly sends the collected data to a remote server for processing. | ¶12, ¶13 | col. 2:4-5 |
| obtaining, from the external server, a lighting operating schedule based on the environmental data and the input data | The accused system allegedly receives an adaptive schedule from the server that was generated based on the transmitted data. | ¶12, ¶13 | col. 2:5-7 |
| executing the lighting operating schedule | The accused system allegedly implements the received schedule to control lighting. The complaint references an illustration from Defendant's website, included as Exhibit 2, which allegedly shows the ENBRIGHTEN product being offered with instructions for an infringing use. | ¶12, ¶13, ¶16 | col. 2:8-9 |
'798 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| ...a method comprising: obtaining environmental data...; obtaining input data...; transmitting... to a remote server; obtaining from the remote server a lighting operating schedule... | As with the ’874 patent, the ENBRIGHTEN system is alleged to perform the core method of data collection, transmission to a server, and receipt of a schedule. | ¶20, ¶21 | col. 2:2-9 |
| executing the lighting operating schedule...by controlling one or more smart bulbs... | The accused system allegedly executes the received schedule by controlling smart lighting products. The complaint references an illustration, described as being from Defendant's website and included as Exhibit 4, that allegedly advertises an infringing use. | ¶20, ¶21, ¶24 | col. 11:58-65 |
| executing an interrupt operation by: suspending execution of the lighting operating schedule based on interrupt data...corresponding to a user change... | The accused system allegedly detects a manual user change and, in response, pauses the execution of its automated schedule. | ¶20, ¶21 | col. 12:4-9 |
| implementing the user change to the lighting operating schedule | The accused system allegedly adjusts the lighting to match the user's manual input. | ¶20, ¶21 | col. 12:10-11 |
| resuming execution of the lighting operating schedule with the user change implemented | After implementing the manual change, the accused system allegedly resumes the automated schedule. | ¶20, ¶21 | col. 12:12-14 |
Identified Points of Contention
- Architectural Questions: A central question for both patents is whether the accused ENBRIGHTEN system uses a "remote server" to generate an adaptive "lighting operating schedule," as claimed. The complaint does not provide evidence to distinguish this architecture from one where scheduling logic is contained locally on a device or within a smartphone application.
- Functional Questions: The infringement case for the ’798 patent appears to hinge on whether the accused product performs the specific, three-step "interrupt operation." The complaint's general allegations raise the question of what evidence will be presented to show the accused system specifically "suspends," "implements," and then "resumes" a schedule, as opposed to simply allowing a manual input to overwrite a pre-set program.
V. Key Claim Terms for Construction
Term: "lighting operating schedule" (’874 Patent, Claim 1)
- Context and Importance: This term defines the output of the server. Its construction is critical to determining whether any set of time-based lighting commands meets the limitation, or if it must be the result of a dynamic, data-driven analysis performed by the server.
- Intrinsic Evidence for a Broader Interpretation: The specification states the schedule "defines the lighting intensity and/or the lighting color for one or more lights as a function of time," which could be argued to cover any time-based instructions. (’874 Patent, col. 2:43-45).
- Intrinsic Evidence for a Narrower Interpretation: The patent consistently describes the schedule as being generated "based on the environmental data and the input data" and as a "modified version of the preexisting lighting operating schedule which incorporates the weighted environmental data." (’874 Patent, col. 2:5-7, 2:47-50). This language may support an interpretation requiring the schedule to be the output of an adaptive process.
Term: "interrupt operation" (’798 Patent, Claim 1)
- Context and Importance: This is the novel feature of the independent claims of the ’798 patent. Practitioners may focus on this term because infringement of the ’798 patent depends entirely on whether the accused system performs this specific function.
- Intrinsic Evidence for a Broader Interpretation: A party might argue that any feature allowing a user to temporarily override an automated setting constitutes an "interrupt operation."
- Intrinsic Evidence for a Narrower Interpretation: The claim itself explicitly defines the term as a three-part sequence: "suspending execution," "implementing the user change," and "resuming execution." (’798 Patent, col. 12:4-14). The specification further illustrates this with specific logic involving a "fixed time-out period." (’798 Patent, col. 9:42-61; Fig. 7). This could support a narrower construction requiring all of these discrete steps to be present.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement based on Defendant's "website and product instruction manuals," which allegedly instruct customers on how to use the products in an infringing manner. (Compl. ¶14-15, ¶22-23). It also alleges contributory infringement, asserting the products are not staple articles of commerce and have no substantial non-infringing uses. (Compl. ¶15, ¶23).
- Willful Infringement: The complaint alleges Defendant has known of the patents "from at least the filing date of the lawsuit," establishing a basis for post-suit willfulness. (Compl. ¶14, ¶22). Plaintiff reserves the right to amend its allegations if discovery reveals evidence of pre-suit knowledge. (Compl. ¶14, fn. 1).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of system architecture: Can Plaintiff provide evidence that the accused ENBRIGHTEN products use a remote server to generate and deliver adaptive lighting schedules, as recited in the claims, or is the operative functionality self-contained within the local hardware or a user's mobile application?
- A key evidentiary question will be one of functional operation: Does the accused system perform the specific, multi-step "interrupt operation" required by the '798 patent—suspending a schedule, implementing a manual change, and then resuming after a time-out—or is there a fundamental mismatch between the accused functionality and the precise language of the claims?
- The case may also turn on a question of claim scope: Will the term "lighting operating schedule" be construed broadly to cover any time-based set of commands, or will it be limited to schedules that are demonstrably generated through the adaptive, data-weighting process described in the patent specifications?