DCT
2:22-cv-00379
Litepanels Ltd v. Xiamen Came Technology Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Litepanels, Ltd. (United Kingdom)
- Defendant: Xiamen Came Technology Co., Ltd. (China)
- Plaintiff’s Counsel: Boon Calk Echols Coleman & Goolsby, PLLC; Armstrong Teasdale LLP
- Case Identification: 2:22-cv-00379, E.D. Tex., 09/30/2022
- Venue Allegations: Plaintiff alleges venue is proper based on Defendant’s sales and distribution of accused products to consumers and distributors in the Eastern District of Texas, establishing sufficient minimum contacts.
- Core Dispute: Plaintiff alleges that Defendant’s LED-based photographic lighting products infringe a patent related to stand-mounted light panels designed for natural-looking illumination.
- Technical Context: The technology concerns LED lighting systems for professional film, television, and photography, a market where precise color temperature and flicker-free dimming are critical.
- Key Procedural History: The complaint notes that in a prior case, Litepanels v. Flolight, LLC in the Eastern District of Texas, the court construed the claim terms "frame" and "front", which may inform how those terms are interpreted in the current litigation.
Case Timeline
| Date | Event |
|---|---|
| 2001-09-07 | U.S. Patent No. 7,972,022 Earliest Priority Date |
| 2011-07-05 | U.S. Patent No. 7,972,022 Issue Date |
| 2020-08-06 | Earliest website visit cited in complaint referencing availability of Accused Products |
| 2022-09-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,972,022 - "Stand-Mounted Light Panel For Natural Illumination in Film, Television or Video"
- Patent Identification: U.S. Patent No. 7,972,022, "Stand-Mounted Light Panel For Natural Illumination in Film, Television or Video," issued July 5, 2011.
The Invention Explained
- Problem Addressed: The patent describes the drawbacks of conventional lighting systems used in film and photography, such as incandescent lights that generate excessive heat and change color hue when dimmed, and fluorescent lights that can flicker at low intensities, both of which are undesirable for high-quality image capture (’022 Patent, col. 1:55-2:55).
- The Patented Solution: The invention is a lighting apparatus that uses a plurality of semiconductor light elements, such as LEDs, mounted on a panel or frame. By using a mix of LEDs with different, stable color temperatures (e.g., "daylight" and "tungsten"), the apparatus can produce a blended, high-quality light that is dimmable without the adverse hue shifts or flickering associated with older technologies, and is suitable for mounting on a stand for flexible positioning ('022 Patent, Abstract; col. 8:16-56).
- Technical Importance: This approach provided a portable, energy-efficient, and cool-running lighting solution that gave cinematographers and photographers greater control over the color and intensity of illumination to match specific film stocks or creative needs ('022 Patent, col. 3:6-15).
Key Claims at a Glance
- The complaint asserts independent claim 1 and reserves the right to assert others (Compl. ¶18).
- The essential elements of independent claim 1 are:
- An apparatus for illuminating a subject for film, photography or video.
- A frame having a front.
- A plurality of semiconductor light elements on the front of the frame, configured for continuous illumination, with a color temperature suitable for image capture.
- At least one of the semiconductor light elements emits light in a daylight or tungsten color temperature range.
- A dimmer for user adjustment of illumination intensity.
- The frame is adapted for being mounted to and readily disengaged from a stand.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "LED Light" series, "Boltzen Perseus" series, and "Ultra Slim LED Light" series as "Accused Products" (Compl. ¶13). It uses the "CameTV's 1024 LED Light product" ("LED1024") as an exemplary and representative product for its infringement allegations (Compl. ¶19).
Functionality and Market Context
- The accused LED1024 product is marketed as a "mobile studio lighting solution" (Compl. ¶20). Functionally, it is alleged to be an LED panel light available in a "daylight" version with a color temperature of 5600K and a "bi-color" version with an adjustable color temperature from 3200K to 5600K (Compl. ¶24). The product is advertised as having a dimmer knob for adjusting brightness from 10% to 100% and is shown in marketing images mounted on a light stand (Compl. ¶25, ¶26). One such image shows the front of the LED1024 product, including its frame and LED array (Compl. p. 6).
IV. Analysis of Infringement Allegations
’022 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a frame having a front; | The LED1024 product includes a supporting structure, or frame, from which light is emitted. The complaint provides an image of the accused product's frame. | ¶21 | col. 8:16-19 |
| a plurality of semiconductor light elements disposed on the front of the frame and configured to provide a continuous source of illumination, said semiconductor light elements having a color temperature suitable for image capture... | The LED1024 contains an array of semiconductor light elements on its front, marketed as providing "a perfect color balance." An image shows a close-up of this array. | ¶22, ¶23 | col. 9:55-61 |
| ...at least one of said semiconductor light elements individually emitting light in a daylight color temperature range or a tungsten color temperature range; | The LED1024 is available in a "daylight" version (5600K) and a "bi-color" version (3200K to 5600K), corresponding to the daylight and tungsten ranges. | ¶24 | col. 15:50-53 |
| a dimmer whereby an illumination intensity of said semiconductor light elements may be user adjusted; | The LED1024 has a dimmer knob for adjusting brightness from "10%-100%," as shown in a provided image of the product's controls. | ¶25 | col. 38:19-29 |
| wherein said frame is adapted for being mounted to and readily disengaged from a stand. | The LED1024 is advertised on Defendant's website with images showing it mounted on a stand with adjustable knobs. | ¶26 | col. 38:29-31 |
Identified Points of Contention
- Scope Questions: The complaint proactively cites a construction of "frame" from a prior case, suggesting its definition ("supporting structure") may be a focal point (Compl. ¶21, n.8). A potential dispute could arise over the meaning of "readily disengaged from a stand"—whether it requires a specific type of quick-release mechanism as shown in the patent's embodiments or if a simple knob-based attachment suffices.
- Technical Questions: The complaint relies on Defendant's marketing materials to establish technical features like "continuous source of illumination" and specific color temperatures. A key question for the court will be whether Plaintiff can provide independent evidence that the accused products actually perform as advertised and meet the specific technical requirements of the claim language as construed.
V. Key Claim Terms for Construction
The Term: "frame"
- Context and Importance: This term defines the foundational structure of the apparatus. Its construction is critical as it anchors the location of the other claimed elements. Practitioners may focus on this term because the complaint highlights its prior construction in another case, signaling its potential for dispute (Compl. ¶21, n.8).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification uses the term generally, referring to a "panel frame" or "lighting frame" without limiting it to a specific shape, which could support a broad interpretation as any structure that holds the lights (e.g., '022 Patent, col. 8:16-19).
- Evidence for a Narrower Interpretation: The patent's figures predominantly show specific embodiments, such as a ring-shaped frame (Fig. 4) and a rectangular panel (Fig. 35), which could be used to argue for a construction limited to these depicted forms.
The Term: "readily disengaged from a stand"
- Context and Importance: This functional limitation defines the required ease of mounting and removal. The interpretation of "readily" will determine whether the accused product's standard mounting hardware meets this requirement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not explicitly define "readily," which may support an argument that the term should be given its plain and ordinary meaning, covering any method that is not unduly difficult, including standard adjustable knobs.
- Evidence for a Narrower Interpretation: The specification discloses specific "twist-locked" quick-release mechanisms (e.g., Fig. 23). This may support an argument that "readily" implies a more specialized, tool-less, or rapid action than a simple screw or knob ('022 Patent, col. 12:55-62).
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing reference to indirect infringement but does not plead specific facts to support the elements of inducement or contributory infringement, such as knowledge or intent (Compl. ¶13). The formal count for infringement is limited to direct infringement (Compl. ¶18).
- Willful Infringement: The complaint does not contain allegations of pre-suit knowledge of the patent or other facts that would typically support a claim for willful infringement. However, the prayer for relief requests enhanced damages, the statutory remedy for willfulness (Compl. p. 8, C).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: Can the term "readily disengaged," which is not explicitly defined, be satisfied by the conventional knob-based stand mount of the accused product, or will it be construed more narrowly to require a quick-release mechanism of the type shown in the patent's specific embodiments?
- A second issue will be evidentiary: The infringement case, as pleaded, relies on the defendant's marketing statements. This raises the evidentiary question of whether the plaintiff can prove, through testing or other technical evidence, that the accused products' actual operational characteristics—particularly concerning color temperature accuracy and the quality of "continuous" illumination—meet the specific limitations of the patent claims.