LED Apogee LLC v. Microchip Technology Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: LED Apogee LLC (Delaware)
  • Defendant: Microchip Technology Incorporated (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00020, E.D. Tex., 01/12/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that certain unidentified products made by Defendant infringe a patent related to methods for driving light-emitting diodes (LEDs).
• Technical Context: The technology at issue concerns electronic circuits designed to power LEDs efficiently, a fundamental component in a vast range of modern electronic devices.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Patent No. 6,982,527, "Method for driving light emitting diode", issued January 3, 2006 (’527 Patent). (Compl. ¶9).

U.S. Patent No. 6,982,527 - "Method for driving light emitting diode"

The Invention Explained

• Problem Addressed: The patent's background section describes a problem with prior art circuits for driving LEDs, where a current mirror controlled by a charge pump has a fixed high output voltage (e.g., 5V). When this fixed voltage is used to drive an LED that requires a lower voltage (e.g., 3.1V-3.8V), the mismatch results in "excess power loss" and inefficiency. (’527 Patent, col. 1:38-48).
• The Patented Solution: The invention proposes a method to improve efficiency by actively managing the voltage supplied to the LED. Instead of a fixed high voltage, it uses an inductive circuit to increase the input voltage to a current mirror. Crucially, it then uses an input of the LED itself as a "voltage feedback point" to regulate the circuit, thereby "keeping a constant voltage difference" between the current mirror's input and output. (’527 Patent, Abstract; col. 2:1-5). This dynamic regulation minimizes the voltage mismatch and reduces wasted power. (’527 Patent, col. 4:32-37).
• Technical Importance: This method provides a more power-efficient way to drive LEDs, which is particularly valuable in battery-powered devices and systems where minimizing heat generation and power consumption is critical. (’527 Patent, col. 1:56-62).

Key Claims at a Glance

• The complaint does not identify specific claims, instead referencing "Exemplary '527 Patent Claims" in a separate exhibit not provided with the complaint. (Compl. ¶11). Independent claim 1 is representative of the core invention.
• The essential elements of independent claim 1 include:
  • providing a control terminal voltage of said current mirror as a reference voltage;
  • increasing a voltage of an input of said current mirror and providing an input of said light emitting diode as a voltage feedback point for keeping a constant voltage difference between said input and said output of said current mirror; and
  • driving said light emitting diode by a voltage at said output of said current mirror.
    (’527 Patent, col. 5:8-19).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products in its text. It refers to "Exemplary Defendant Products" that are purportedly identified in "charts incorporated into this Count" via an external "Exhibit 2," which was not filed with the complaint. (Compl. ¶¶ 11, 16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context, as all such information is deferred to the unprovided Exhibit 2. (Compl. ¶¶ 14, 16).

IV. Analysis of Infringement Allegations

The complaint alleges infringement but incorporates the specific comparisons of claim elements to accused products by reference to an external "Exhibit 2," which was not provided. (Compl. ¶¶ 16-17). Therefore, a detailed claim chart analysis cannot be performed based on the available documents. The narrative theory asserts that Defendant's "Exemplary Defendant Products" practice the claimed technology and satisfy all elements of the asserted claims. (Compl. ¶16). No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The Term: "voltage feedback point"

• Context and Importance: This term is central to the invention’s control mechanism. Its construction will determine what types of circuit architectures can be found to infringe. The dispute will likely focus on whether the term is limited to the patent's specific examples or can cover a wider range of feedback implementations.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 itself describes the function of the feedback point—"for keeping a constant voltage difference"—without limiting its specific structure. (’527 Patent, col. 5:14-17). A plaintiff may argue this functional language should not be confined to the disclosed embodiments.
  • Evidence for a Narrower Interpretation: The specification describes a preferred embodiment where "the nodes A42, A43 and A44 of the respective inputs of the white light emitting diodes D42, D43 and D44 are provided as voltage feedback points." (’527 Patent, col. 4:14-18; Fig. 4). A defendant may argue that the term should be construed as being limited to this direct use of an LED's input node.

The Term: "keeping a constant voltage difference"

• Context and Importance: This phrase defines the outcome of the feedback loop. Practitioners may focus on this term because its definition—whether it requires absolute constancy or allows for operational fluctuations—is critical to determining if an accused device meets this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that in the context of analog circuits, "constant" should be understood to mean "regulated to be substantially constant," allowing for minor variations inherent in the operation of such systems.
  • Evidence for a Narrower Interpretation: The specification explains that by fixing the voltage difference (VX), the power loss is significantly decreased, as shown in the equation P_LEDLOSS=I_LED*VX. (’527 Patent, col. 4:32-37). A party could argue this implies a stable, non-fluctuating value is required to achieve the patent's stated objective.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Defendant induces infringement by distributing "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner. (Compl. ¶14).

Willful Infringement

The complaint bases its willfulness allegation on Defendant's alleged continued infringement after having "actual knowledge" of the patent, with such knowledge established by the service of the complaint itself. (Compl. ¶¶ 13, 15). This is an allegation of post-suit, rather than pre-suit, willful infringement.

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

Given the limited factual detail in the complaint, the litigation will likely center on the following fundamental questions:

1. A central evidentiary question will be whether Plaintiff can demonstrate that the accused products, once identified, actually implement the specific feedback control mechanism recited in the claims. The case will depend on the technical evidence showing the accused circuits use an LED input as a "voltage feedback point" to regulate the current mirror's input voltage.

2. A core issue will be one of claim scope: can the phrase "keeping a constant voltage difference," as described in the patent, be construed to read on the real-world operational characteristics of Defendant's products? The outcome may depend on whether the court defines "constant" strictly or as "substantially regulated," a distinction that will be critical to the infringement analysis.