DCT

2:22-cv-00194

Brightplus Ventures LLC v. TCL Electronics Holdings Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:22-cv-00194, E.D. Tex., 11/03/2022
  • Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Defendants are foreign corporations.
  • Core Dispute: Plaintiff alleges that Defendant’s televisions and other display products infringe nine U.S. patents related to LED backlighting systems for liquid crystal displays (LCDs).
  • Technical Context: The patents address foundational aspects of modern LED backlighting, including the physical construction of light-emitting panels, optical components for diffusing and directing light, and electronic control systems.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the Patents-in-Suit and their alleged infringement via letters dated May 6, 2022 and May 9, 2022, approximately six months prior to filing suit. This allegation forms the basis for Plaintiff's claim of willful infringement.

Case Timeline

Date Event
2006-04-21 ’075 & '835 Patents - Earliest Priority Date
2007-03-16 ’812 Patent - Earliest Priority Date
2007-07-29 ’705 Patent - Earliest Priority Date
2008-03-11 ’382 Patent - Earliest Priority Date
2010-04-06 ’812 Patent - Issue Date
2011-01-18 ’705 Patent - Issue Date
2011-08-09 RE42,598 Patent - Issue Date
2012-05-15 ’382 Patent - Issue Date
2012-10-23 ’075 Patent - Issue Date
2012-12-11 ’710 Patent - Issue Date
2015-01-27 ’331 Patent - Issue Date
2015-11-10 RE45,796 Patent - Issue Date
2017-03-28 ’835 Patent - Issue Date
2022-05-06 Pre-suit notice letter sent to TCL
2022-05-09 Second pre-suit notice letter sent to TCL
2022-11-03 Complaint Filing Date

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

U.S. Patent No. 7,690,812 - Apparatus And Methods For Conformable Diffuse Reflectors For Solid State Lighting Devices

The Invention Explained

  • Problem Addressed: The patent background discusses challenges in constructing solid-state lighting panels, noting that a reflective sheet placed over a substrate can press against and potentially damage protruding surface features, such as large wire interconnects used to link lighting tiles together (’812 Patent, col. 5:12-19).
  • The Patented Solution: The invention describes a solid-state lighting "tile" comprising a substrate with a lighting element (e.g., an LED) and a reflector sheet. The key feature is that the reflector sheet is "configured to conform to a shape of a protruding feature on the tile" (’812 Patent, col. 8:44-45). This can be achieved by molding or creating recesses in the reflector sheet to provide relief for components like the wire interconnects, thereby avoiding mechanical stress and potential damage during assembly (’812 Patent, col. 5:9-15).
  • Technical Importance: This approach facilitates the modular assembly of large-area LED lighting panels by managing the physical interface between the optical reflector layer and the underlying electronic topography, which may improve manufacturing yield and reliability.

Key Claims at a Glance

  • The complaint asserts independent claim 1 and method claim 15 (Compl. ¶¶40, 43).
  • Essential elements of independent claim 1 include:
    • A substrate.
    • A solid state lighting element mounted on a surface of the substrate.
    • A reflector sheet on the surface of the substrate, where the reflector sheet is configured to conform to a shape of a protruding feature on the tile.

U.S. Patent No. 7,872,705 - LED Backlight System For LCD Displays

The Invention Explained

  • Problem Addressed: The patent identifies a key limitation of early edge-lit LCD screens, where using side-emitting LEDs to illuminate a waveguide from a single edge restricted the practical screen size to about 12-14 inches diagonally. Larger screens suffered from a lack of light uniformity and "hot spots" near the light source (’705 Patent, col. 2:39-52).
  • The Patented Solution: The invention discloses an LCD system that uses at least one waveguide element with a "plurality of light entry regions." A first light source (e.g., a strip of LEDs) injects light at a first entry region, while a second light source injects light at a second entry region of the same waveguide (’705 Patent, col. 13:35-49). This dual-source approach, often implemented by placing LED strips on opposite edges of a display, allows for more powerful and uniform illumination across larger surface areas than was possible with a single-entry design. The system includes a common control circuit for the LEDs (’705 Patent, col. 13:50-54).
  • Technical Importance: This architecture was a key enabler for the development of large, thin, and power-efficient edge-lit LCD televisions and monitors, overcoming the size limitations of earlier designs.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶48).
  • Essential elements of independent claim 1 include:
    • An LCD panel.
    • At least one waveguide element comprising a plurality of light entry regions.
    • A first light-emitting source (first plurality of LEDs in a first strip) positioned to emit light into a first light entry region.
    • A second light-emitting source (second plurality of LEDs in a second strip) positioned to emit light into a second light entry region.
    • A common control circuit in electrical communication with at least one of the LED pluralities.

Multi-Patent Capsules

  • Multi-Patent Capsule: U.S. Patent No. 8,177,382

    • Patent Identification: U.S. Patent No. 8,177,382, Apparatus And Methods For Multiplanar Optical Diffusers And Display Panels For Using The Same, issued May 15, 2012.
    • Technology Synopsis: This patent addresses light diffusion in backlights. It describes a "multiplane light diffuser" with at least two diffusion planes separated by a gap to improve light mixing and uniformity before the light reaches the LCD panel (’382 Patent, Abstract). The distance of the diffusion planes from the light emitters and the distance between emitters are functionally related.
    • Asserted Claims: At least claim 13 (method) is asserted (Compl. ¶54).
    • Accused Features: The complaint alleges that the TCL 32S21 television performs a method of providing diffused light using multiple diffusion planes at specific distances from the LEDs, which are arranged in a planar configuration (Compl. ¶54).

  • Multi-Patent Capsule: U.S. Patent No. 8,294,075

    • Patent Identification: U.S. Patent No. 8,294,075, Solid State Luminaires For General Illumination, issued October 23, 2012.
    • Technology Synopsis: This patent describes the layered structure of a direct-lit lighting panel. The invention consists of a substrate with LEDs, a reflector sheet on the substrate, and a brightness enhancement film (BEF) positioned over the reflector sheet (’075 Patent, Abstract). The BEF is configured to preferentially transmit light in one orientation while reflecting light of other orientations back into the panel for recycling, improving on-axis brightness.
    • Asserted Claims: At least claim 1 is asserted (Compl. ¶60).
    • Accused Features: The TCL 40S330 television is alleged to have a lighting panel with a substrate, LEDs, a reflector sheet, and a brightness enhancement film arranged in the claimed configuration (Compl. ¶60).

  • Multi-Patent Capsule: U.S. Patent No. 8,330,710

    • Patent Identification: U.S. Patent No. 8,330,710, Systems And Methods For Controlling A Solid State Lighting Panel, issued December 11, 2012.
    • Technology Synopsis: This patent relates to the electronic control of an LED backlight. It describes a system with multiple strings of LEDs, a current supply circuit to drive them, and a control system that receives a user input (e.g., an image to display) and provides control signals to the supply circuit (’710 Patent, Abstract). The control system includes "firing logic" to determine the firing order of the LED strings.
    • Asserted Claims: At least claim 1 is asserted (Compl. ¶66).
    • Accused Features: The TCL 55R635 television is alleged to have a lighting system with strings of LEDs, a current supply circuit, and a control system with firing logic that selectively drives the strings in response to a user input image (Compl. ¶66).

  • Multi-Patent Capsule: U.S. Patent No. 8,941,331

    • Patent Identification: U.S. Patent No. 8,941,331, Solid State Lighting Panels With Variable Voltage Boost Current Sources, issued January 27, 2015.
    • Technology Synopsis: This patent describes a control system for a lighting panel with at least two strings of LEDs that may have different brightness levels. It specifies first and second current supply circuits for the respective strings and a pulse width modulation (PWM) controller that provides separate PWM control signals to each circuit, allowing for independent brightness control of different LED strings (’331 Patent, Abstract).
    • Asserted Claims: At least claim 17 is asserted (Compl. ¶72).
    • Accused Features: The TCL 50S546 television is alleged to have a lighting system with at least two LED strings, corresponding current supply circuits, and a PWM controller that supplies distinct control signals to those strings (Compl. ¶72).

  • Multi-Patent Capsule: U.S. Patent No. 9,605,835

    • Patent Identification: U.S. Patent No. 9,605,835, Solid-State Luminaires For General Illumination, issued March 28, 2017.
    • Technology Synopsis: This patent describes a layered lighting panel architecture similar to the '075 patent, but adds a "generally planar diffuser sheet" between the reflector and the brightness enhancement film. This structure is intended to further improve light recycling and uniformity (’835 Patent, Abstract).
    • Asserted Claims: At least claim 1 is asserted (Compl. ¶78).
    • Accused Features: The TCL 32S21 television is alleged to have a lighting panel with a substrate, LEDs, a reflector, a brightness enhancement film, and a diffuser sheet located between the reflector and the film (Compl. ¶78).

  • Multi-Patent Capsule: U.S. Reissued Patent No. RE42,598

    • Patent Identification: U.S. Reissued Patent No. RE42,598, Light Emitting Diode Arrays For Direct Backlighting Of Liquid Crystal Displays, issued August 9, 2011.
    • Technology Synopsis: This patent describes a display panel for a direct-lit LCD. It specifies a "solid block" behind the planar array of LCD devices, with LEDs mounted on the face of the block that points toward the LCDs. This solid block can be constructed from a plurality of "solid block tiles" arranged in an array congruent with the LCD pixels (’598 Patent, Abstract).
    • Asserted Claims: At least claim 43 is asserted (Compl. ¶84).
    • Accused Features: The TCL 55R635 television is alleged to have a display panel with a solid block lighting unit made of tiles arranged in an array that is congruent with the LCD devices (Compl. ¶84).

  • Multi-Patent Capsule: U.S. Reissued Patent No. RE45,796

    • Patent Identification: U.S. Reissued Patent No. RE45,796, Light Emitting Diode Arrays For Direct Backlighting Of Liquid Crystal Displays, issued November 10, 2015.
    • Technology Synopsis: This patent appears related to the '598 patent, also describing a flat panel made of a plurality of "solid metal block tiles." The tiles are connected end-to-end and include mating surfaces, with LEDs mounted on the face of each tile pointing towards the display panel (’796 Patent, Abstract).
    • Asserted Claims: At least claim 37 is asserted (Compl. ¶90).
    • Accused Features: The TCL 55R646 television is alleged to have a flat panel that includes solid metal block tiles connected end-to-end with mating surfaces and LEDs mounted on the tile faces (Compl. ¶90).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are TCL-branded televisions, monitors, and displays incorporating LED lighting units (Compl. ¶37). The complaint specifically identifies the following television models: TCL 55R646, TCL 50S446, TCL 32S21, TCL 40S330, TCL 55R635, and TCL 50S546 (Compl. ¶¶40, 48, 54, 60, 66, 72).

Functionality and Market Context

  • The complaint characterizes the accused products as televisions that incorporate various forms of LED backlight technology for illuminating their LCD panels (Compl. ¶¶37, 40, 48). The allegations describe both direct-lit backlights, where LEDs are arranged behind the entire panel, and edge-lit backlights, where LEDs are placed along the perimeter and use a waveguide to distribute light (Compl. ¶¶40, 48). The complaint alleges that Defendants form an interrelated group of companies that are one of the largest makers and sellers of televisions in the world (Compl. ¶18). The complaint's infringement allegations rely on references to "exemplary teardown images" for the accused products (Compl. ¶37). A teardown image allegedly shows the TCL 55R646 LED lighting tile includes a reflector sheet that conforms to a wire interconnect on the substrate (Compl. ¶40, Exs. 5, 8-10). Another allegedly shows the TCL 50S446 LCD system includes LED strips positioned on the left and right sides of a waveguide (Compl. ¶48, Exs. 65, 67-69).

IV. Analysis of Infringement Allegations

'812 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a substrate The accused TCL 55R646 television includes an LED lighting tile that contains a substrate. ¶40 col. 8:41
a solid state lighting element mounted on a surface of the substrate The LED lighting tile in the accused product has an LED mounted on the surface of the substrate. ¶40 col. 8:42-43
a reflector sheet on the surface of the substrate, the reflector sheet configured to conform to a shape of a protruding feature on the tile The LED lighting tile in the accused product includes a reflector sheet that conforms to the shape of a protruding wire interconnect on the substrate surface. ¶40 col. 8:44-46

Identified Points of Contention

  • Scope Questions: A central question may be the construction of the phrase "configured to conform to a shape of a protruding feature." The dispute may turn on whether providing a simple cutout or hole in the reflector sheet for a component like a "wire interconnect" meets this limitation, or if the patent requires a more specific three-dimensional shaping (e.g., thermoforming) of the reflector material around the feature.
  • Technical Questions: What evidence does the complaint provide that the reflector sheet in the TCL 55R646 is specifically shaped to match a protruding feature, beyond simply having an opening? The resolution will depend on the physical evidence from the accused product teardowns.

'705 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a) a LCD panel The accused TCL 50S446 television includes an LCD panel. ¶48 col. 13:36
b) at least one waveguide element comprising a plurality of light entry regions The accused product's LCD system includes at least one waveguide element with multiple light entry regions. ¶48 col. 13:37-38
c) a first light-emitting source comprising a first plurality of LEDs arranged in a first strip and positioned to emit light into the at least one waveguide element at a first light entry region... The accused product's LCD system includes a first strip of LEDs positioned to emit light into a first light entry region of the waveguide element. ¶48 col. 13:39-44
d) a second light-emitting source comprising a second plurality of LEDs arranged in a second strip and positioned to emit light into the at least one waveguide element at a second light entry region... The accused product's LCD system includes a second strip of LEDs positioned to emit light into a second light entry region of the waveguide element. ¶48 col. 13:45-49
e) a common control circuit in electrical communication with at least one of the first plurality of LEDs and the second plurality of LEDs The accused product's LCD system includes a common control circuit connected to the first and second strips of LEDs. ¶48 col. 13:50-54

Identified Points of Contention

  • Scope Questions: The analysis may focus on whether the accused light guide plate is properly characterized as the claimed "waveguide element." A defendant could argue that its component is structurally or functionally distinct from the element disclosed and claimed in the patent.
  • Technical Questions: Does the accused "common control circuit" perform the functions consistent with the patent's disclosure for controlling both LED strips? The complaint's allegations appear to map the physical components of the TCL 50S446 directly onto the elements of the claim, suggesting the primary dispute may be one of claim construction rather than technical operation.

V. Key Claim Terms for Construction

Term from the ’812 Patent: "configured to conform to a shape of a protruding feature"

  • Context and Importance: This term is the central point of novelty in claim 1 and is critical to the infringement analysis. The infringement allegation hinges on whether the accused reflector sheet, which is alleged to have an opening for a wire interconnect, meets this definition. Practitioners may focus on this term because its construction will determine whether a simple cutout suffices or if a more complex, three-dimensional shaping is required.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that the reflector sheet can be "thermoformable and configured to conform to a shape of a protruding feature" (’812 Patent, col. 2:19-22). The word "and" could suggest these are two distinct, non-required capabilities. The specification also describes recesses being "molded into the reflector sheet 14 and/or created by removing material" (’812 Patent, col. 5:10-12), which could support an interpretation that includes cutouts.
    • Evidence for a Narrower Interpretation: The repeated use of "conform" and the specific example of "recesses 14B" in the figures could support an argument that the term requires the reflector sheet to follow the contours of the feature, rather than merely avoiding it via a hole (’812 Patent, col. 5:9-10; Fig. 3). The explicit mention of "thermoformable" material could be argued as context suggesting a shaping process beyond simple cutting.

Term from the ’705 Patent: "at least one waveguide element"

  • Context and Importance: The claim requires light from two different sources to be emitted into "at least one waveguide element." The construction of this term is key to determining if the accused product's light guide plate falls within the scope of the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification provides a broad definition, stating a waveguide "may comprise a hollow structure with a reflective internal surface; alternatively, a waveguide may be substantially solid in nature" and can be made of materials like "Glass, quartz, plexiglass, and other optically transmissive materials" (’705 Patent, col. 5:56-62). This supports a broad construction covering various physical forms of light guides.
    • Evidence for a Narrower Interpretation: A defendant might argue that the term should be limited by the specific embodiments depicted in the patent's figures, which show particular geometric configurations for the waveguide and its extensions (’705 Patent, Figs. 2-4). However, courts are generally reluctant to limit claim scope to preferred embodiments.

VI. Other Allegations

  • Indirect Infringement: For each asserted patent, the complaint alleges induced infringement under 35 U.S.C. § 271(b). The allegations are based on Defendants actively "inducing, directing, causing, and encouraging" others (e.g., partners, resellers, customers) by providing the accused products along with "specifications, instructions, manuals, advertisements, marketing materials, and technical assistance" related to their use (Compl. ¶¶41, 49, 55).
  • Willful Infringement: The complaint alleges that Defendants' infringement has been willful. This allegation is based on alleged pre-suit knowledge of the patents-in-suit, stemming from notification letters sent by Plaintiff to TCL on May 6 and May 9, 2022 (Compl. ¶¶36, 45, 51, 57).

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

  • A central issue will be one of definitional scope and factual proof: For the '812 patent, does providing a reflector with a cutout for a "wire interconnect" meet the claim requirement of being "configured to conform to a shape of a protruding feature"? The resolution will depend on both the court's interpretation of the claim language and the physical evidence from the accused products.
  • A key evidentiary question will be one of structural correspondence: Across the nine asserted patents, which cover a wide range of backlight technologies from physical component layouts to electronic control methods, the case will require a detailed, model-by-model comparison of the internal architecture of TCL's televisions to the specific elements recited in each asserted claim.
  • A significant legal and financial question will be the impact of willfulness: Given the allegation of pre-suit notice for a large portfolio, a finding of infringement could expose the defendant to the possibility of enhanced damages, making the circumstances and content of the May 2022 notification letters a critical area of discovery.