DCT

2:24-cv-00818

BX LED LLC v. Govee Moments Trading Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00818, E.D. Tex., 10/07/2024
  • Venue Allegations: Venue is alleged to be proper because Defendants are not U.S. residents, and the sales, offers to sell, and importation of the accused products that give rise to the infringement claims occurred in the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s smart LED lighting products infringe four patents related to LED chip geometry, color temperature tunability, and segmented LED architecture.
  • Technical Context: The technologies at issue concern methods for improving the efficiency, brightness, and functional capabilities of light-emitting diodes (LEDs) for use in general illumination.
  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history concerning the patents-in-suit.

Case Timeline

Date Event
2003-05-13 U.S. Patent No. 6,869,812 Priority Date
2005-03-22 U.S. Patent No. 6,869,812 Issue Date
2007-04-13 U.S. Patent No. 8,203,260 Priority Date
2009-02-26 U.S. Patent No. 9,913,333 Priority Date
2009-02-26 U.S. Patent No. 10,966,300 Priority Date
2012-06-19 U.S. Patent No. 8,203,260 Issue Date
2018-03-06 U.S. Patent No. 9,913,333 Issue Date
2021-03-30 U.S. Patent No. 10,966,300 Issue Date
2024-10-07 Complaint Filing Date

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

U.S. Patent No. 6,869,812 - "High power AlInGaN based multichip light emitting diode," Issued March 22, 2005

The Invention Explained

  • Problem Addressed: The patent’s background section describes how prior art light-emitting diodes suffered from insufficient illumination and poor efficiency, particularly as their physical size increased ('812' Patent, col. 1:24-31). Larger device sizes led to lower light extraction efficiency because internally generated light would be trapped, bouncing multiple times and losing energy before it could escape the device ('812 Patent, col. 3:12-16; Compl. ¶¶19-20).
  • The Patented Solution: The invention proposes an LED chip with an "elongated geometry." This high aspect-ratio shape is designed to reduce the average distance light travels before exiting, allowing light to "easily escape from the long dimension side." This configuration is described as substantially enhancing the brightness of the device and improving heat dissipation, which in turn permits operation at higher current levels for further increased light output and efficiency ('812 Patent, col. 8:62-9:3; Compl. ¶22).
  • Technical Importance: This design aimed to overcome fundamental physical limitations that capped the practical brightness and efficiency of high-power LEDs, thereby making them more suitable for general illumination applications ('812 Patent, col. 1:24-31).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶48).
  • The essential elements of claim 1 are:
    • A light emitting diode chip comprising:
    • a substantially transparent substrate;
    • an active region formed upon the substrate; and;
    • wherein an aspect ratio of the active area is greater than approximately 1.5 to 1.
  • The complaint reserves the right to assert additional claims (Compl. ¶48).

U.S. Patent No. 8,203,260 - "Color temperature tunable white light source," Issued June 19, 2012

The Invention Explained

  • Problem Addressed: At the time of the invention, generating tunable white light from LEDs was inefficient. Prior art methods required using a large number of individual LEDs with narrow spectral outputs or cumbersome filters, which increased cost and complexity ('260' Patent, col. 1:55-65; Compl. ¶27). Traditional white light sources were typically fixed at either a "warm" or "cold" color temperature ('260 Patent, col. 1:20-29; Compl. ¶26).
  • The Patented Solution: The patent discloses an apparatus comprising two distinct LED arrangements. The first arrangement emits light in a first wavelength range (e.g., warm white), while the second emits light in a second, different wavelength range (e.g., cold white) ('260 Patent, col. 2:21-28). By controlling the relative drive currents to each arrangement using, for example, a potential divider, the color temperature of the combined white light output can be electrically tuned ('260 Patent, col. 2:50-52; Compl. ¶28).
  • Technical Importance: This approach provided a more efficient and less complex method for creating a single light source capable of producing white light across a wide range of color temperatures, enhancing its versatility for various commercial and domestic applications ('260 Patent, col. 2:61-65, col. 8:51-53; Compl. ¶29).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶65).
  • The essential elements of claim 1 are:
    • A color temperature tunable white light source, the source comprising:
    • an array of first LED arrangements operable to emit white light with a color correlated temperature (CCT) in a range of 2500 K to 4000 K;
    • second LED arrangements operable to emit white light with a CCT in a range of 6000 K to 10,000 K;
    • wherein the LED arrangements are configured such that a composite light is emitted by the array;
    • wherein the relative drive currents of the first and second LED arrangements are controllable, and thus variable in relative magnitude, such that the CCT of the composite light is electrically tunable.
  • The complaint reserves the right to assert additional claims (Compl. ¶65).

U.S. Patent No. 9,913,333 - "Light sources utilizing segmented LEDs to compensate for manufacturing variations in the light output of individual segmented LEDs," Issued March 6, 2018

  • Technology Synopsis: This patent addresses problems with heat dissipation, conversion efficiency, and reliability in high-power LED light sources (Compl. ¶43). The invention describes using a "single LED die that is divided into N segments that are serially connected to one another" and then connecting a plurality of these segmented LEDs in parallel to a power bus, creating an improved and more robust light-emitting device (Compl. ¶44; '333' Patent, Abstract).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶83).
  • Accused Features: The Govee H7010 String Light is accused of infringing the ’333 Patent. The allegations center on the product’s use of a plurality of segmented LEDs connected in parallel, where each segmented LED is itself an LED die divided into multiple serially connected segments (Compl. ¶¶85-86).

U.S. Patent No. 10,966,300 - "Light sources utilizing segmented LEDs to compensate for manufacturing variations in the light output of individual segmented LEDs," Issued March 30, 2021

  • Technology Synopsis: This patent, which shares a specification with the '333 patent, also addresses the limitations of conventional LEDs regarding heat, efficiency, and failure rates (Compl. ¶35). The solution involves utilizing segmented LEDs—a single die divided into serially connected segments—that are connected in parallel between two power rails to provide an "improved, less expensive, and longer-lasting" light source (Compl. ¶36; '300' Patent, Abstract).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶100).
  • Accused Features: The Govee A19 Smart Bulb and Govee H7010 String Light are accused of infringing the ’300 Patent. The complaint alleges these products contain a light source with a plurality of segmented LEDs connected between power rails, where each segmented LED is provided by a single LED die divided into multiple serially connected segments (Compl. ¶¶102-105).

III. The Accused Instrumentality

Product Identification

  • The complaint names the Govee A19 Bulb, Govee BR30 Smart Bulb, Govee Smart Corner Floor Lamp, Govee Flow Plus Light Bar, Govee Smart Ceiling Light, Govee H7010 String Lights, and other "substantially similar products" as the Accused Products (Compl. ¶2).

Functionality and Market Context

  • The Accused Products are a range of consumer smart lighting devices sold throughout the United States (Compl. ¶¶3, 10). Based on the complaint's allegations, the relevant technical functionalities include:
    • The use of LED chips that allegedly have an elongated active region with an aspect ratio greater than 1.5:1 (Compl. ¶¶52, 16).
    • The ability to produce tunable white light by combining separate "warm white" and "cool white" LED arrangements, with the color temperature being adjustable via a mobile application (Compl. ¶¶66-70).
    • The alleged use of an internal architecture comprising segmented LEDs, where each die is divided into serially connected segments, and multiple such dies are connected in parallel on a power bus (Compl. ¶¶85-86, 103-105).

The complaint provides a visual from the Govee H7010 String Light packaging, which describes the product as a "Warm White Dimmable" string light (Compl. p. 26).

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,869,812 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A light emitting diode chip comprising: The Govee Smart Corner Floor Lamp, Govee Flow Plus Light Bar, and Govee Smart Ceiling Light each comprise a "light emitting diode chip." The complaint offers a microscopic image of an LED chip from each product. A representative image shows the LED chip from the Govee Flow Plus Light Bar (Compl. p. 12). ¶49 col. 11:37-44
a substantially transparent substrate; The accused products' LED chips are alleged to comprise a "substantially transparent substrate," which is identified with an annotation in a photographic cross-section of the chip. ¶50 col. 11:39-40
an active region formed upon the substrate; and; The accused products' LED chips are alleged to comprise an "active region formed upon the substrate," which is identified with an annotation in a photographic cross-section of the chip. ¶51 col. 11:41-42
wherein an aspect ratio of the active area is greater than approximately 1.5 to 1. The active region of the LED chips in the accused products is alleged to have an aspect ratio greater than 1.5 to 1. The complaint provides a table of aspect ratios derived from pixel measurements of photographs, such as 1.599 for the Govee Smart Corner Floor Lamp (Compl. p. 16). ¶52 col. 11:43-44
  • Identified Points of Contention:
    • Scope Questions: The central limitation is an aspect ratio "greater than approximately 1.5 to 1." The complaint alleges ratios such as 1.599, 3.616, and 2.570 (Compl. p. 16). For the 1.599 value, a dispute may arise over the meaning of "approximately" and whether this value is sufficiently "greater than" 1.5 to meet the claim limitation.
    • Technical Questions: The complaint's evidence for the aspect ratio consists of pixel measurements derived from photographs of the LED chips (Compl. pp. 15-16). The court may need to assess the reliability of this photographic evidence and the methodology used to calculate the ratios to determine if it accurately reflects the physical dimensions of the chip's active area.

U.S. Patent No. 8,203,260 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A color temperature tunable white light source, the source comprising: The Govee Smart A19 and BR30 Smart Bulbs are identified as "color temperature tunable white light sources." ¶66 col. 2:15-17
an array of first LED arrangements operable to emit white light with a color correlated temperature (CCT) in a range of 2500 K to 4000 K and; The accused bulbs are alleged to contain a first LED arrangement that emits "warm white" light in the 2500K-4000K range. The complaint provides an image of an illuminated bulb with an annotation identifying these specific LEDs, corresponding to a mobile app setting of "2700K" (Compl. p. 21). ¶67 col. 2:21-28
second LED arrangements operable to emit white light with a color correlated temperature (CCT) in a range of 6000 K to 10,000 K The accused bulbs are alleged to contain a second LED arrangement that emits "cool white" light in the 6000K-10,000K range. The complaint provides a visual showing different LEDs illuminated, corresponding to a mobile app setting of "6500K" (Compl. p. 22). ¶68 col. 2:21-28
wherein the LED arrangements are configured such that a composite light is emitted by the array; The complaint alleges that the warm and cool white LED arrangements are placed next to each other and are tunable, so they emit a composite, uniform white light. ¶69 col. 2:24-25
wherein the relative drive currents of the first and second LED arrangements are controllable...such that the...CCT of the composite light...is electrically tunable The complaint alleges that the color temperature is electrically tunable by controlling the relative drive currents. Evidence is presented through mobile app screenshots showing a user interface for selecting different color temperatures, which in turn controls the output of the first and second LED arrangements (Compl. pp. 20-22). ¶70 col. 2:50-52
  • Identified Points of Contention:
    • Scope Questions: Claim 1 requires two distinct "LED arrangements." The complaint's evidence shows different sets of LEDs within the same bulb housing (Compl. pp. 20-22). The infringement analysis may turn on whether these sets of LEDs, though physically co-located, constitute separate "arrangements" as the term is used in the patent.
    • Technical Questions: The claim recites specific CCT ranges (2500K-4000K and 6000K-10,000K). The complaint alleges operation at specific points within these ranges (e.g., 2700K and 6500K) based on app screenshots. A factual question for the court will be whether the accused products are operable across the full claimed ranges, and whether the photographic evidence sufficiently proves that the identified LEDs individually produce light within those specific CCT ranges.

V. Key Claim Terms for Construction

For the ’812 Patent:

  • The Term: "greater than approximately 1.5 to 1" (from Claim 1)
  • Context and Importance: This term is the primary quantitative limitation differentiating the claimed invention from prior art. The infringement allegation for at least one product rests on a measured ratio of 1.599 (Compl. p. 16), making the interpretation of "approximately" and "greater than" dispositive for that product. Practitioners may focus on this term because the proximity of the alleged value to the claimed threshold makes it a likely point of dispute.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification repeatedly emphasizes the general concept and benefits of an "elongated geometry" without being strictly tied to a single numerical value, which may support a flexible interpretation ('812 Patent, col. 8:62-9:3). The use of the word "approximately" itself suggests the patentee did not intend a rigid, absolute numerical boundary ('812 Patent, col. 11:44).
    • Evidence for a Narrower Interpretation: The specification provides an exemplary embodiment with a 4-to-1 aspect ratio (250x1000 microns) ('812 Patent, col. 11:51-53). A party could argue that this example sets the context for what "greater than" means, implying a significant, not marginal, difference from the 1.5 to 1 floor.

For the ’260 Patent:

  • The Term: "first LED arrangements" and "second LED arrangements" (from Claim 1)
  • Context and Importance: The claim requires two separate types of arrangements, one for warm white and one for cool white. The infringement theory depends on identifying two such distinct systems within the accused bulbs. The construction of "arrangements" will determine whether physically interspersed LEDs can satisfy this limitation. Practitioners may focus on this term because the physical implementation in the accused product (multiple LED types in one bulb) may not map directly to the patent's more schematic descriptions.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the arrangements in functional terms based on the wavelength range they emit ('260 Patent, col. 2:21-28). This could support a reading where any two electrically separable groups of LEDs that perform the distinct "warm" and "cool" functions would qualify as two "arrangements," irrespective of their physical placement.
    • Evidence for a Narrower Interpretation: Figure 1a of the patent depicts the first and second arrangements as distinct blocks of LEDs in an array ('260 Patent, Fig. 1a). A party could argue that this figure implies a requirement for some degree of physical separation or grouping, and that a simple intermixing of different LED types does not constitute two distinct "arrangements" as taught by the patent.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all four patents-in-suit. The inducement allegations are based on Defendants' promotion, advertising, and instructions (e.g., product websites) that allegedly encourage customers to use the products in an infringing manner (Compl. ¶¶55, 73, 90, 108). The contributory infringement claims assert that the accused products are not staple articles of commerce and are especially adapted for infringing use (Compl. ¶¶57, 75, 92, 110).
  • Willful Infringement: Willfulness is alleged for all asserted patents. The primary basis for knowledge is post-suit, "at least as early as the filing and/or service of the Complaint." The complaint also contains a conclusory allegation of pre-suit willful blindness, stating Defendants knew or "should have known" of the patents' existence (Compl. ¶¶56, 74, 91, 109).

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

  • A core issue will be one of definitional scope: For the ’812 patent, can the phrase "greater than approximately 1.5 to 1" be met by a value, such as the alleged 1.599, that is only marginally above the 1.5 threshold? The case may turn on the interpretation of "approximately" in this context.
  • A second central issue will be one of structural proof: For the '333 and '300 patents, which claim a specific architecture of serially-connected segments on a die that are then connected in parallel, can the plaintiff provide sufficient evidence to demonstrate that the internal, microscopic structure of the accused LEDs actually embodies this configuration?
  • A key evidentiary question will be one of functional mapping: For the ’260 patent, do the intermingled sets of warm- and cool-light-emitting diodes in the accused bulbs constitute two distinct "LED arrangements" as required by the claim, or is there a mismatch between the physical implementation and the claimed architecture?