BridgeComm LLC v. Shenzhen Ustellar Technology Ltd Novostella

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: BridgeComm LLC (Texas)
  • Defendant: Shenzhen Ustellar Technology Ltd. (Novostella) (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00955, E.D. Tex., 11/21/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the Eastern District of Texas and has committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s variable-effect lighting products infringe two patents related to systems for controlling the color and display patterns of LED lights powered by an AC source.
• Technical Context: The patents address the control of multi-colored LED light strings, a technology central to decorative, festive, and architectural lighting, where creating varied and synchronized visual effects is a key market feature.
• Key Procedural History: The complaint asserts two related patents. U.S. Patent No. 8,390,206 is a continuation of the application that resulted in U.S. Patent No. 8,203,275, indicating a shared specification and a focus on related aspects of the same underlying invention.

Case Timeline

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

U.S. Patent No. 8,203,275 - Variable-effect lighting system

The Invention Explained

• Problem Addressed: The patent describes a need for a "relatively simple variable-effect lighting system" that allows for a greater variation in color displays than existing technologies, which were often complex or limited in their range of effects (ʼ275 Patent, col. 2:6-9).
• The Patented Solution: The invention is a lighting system where multiple bi-color lamps (e.g., red/green LEDs) are connected in series to a standard AC power source. A lamp controller varies the perceived color by precisely adjusting the "conduction interval"—the portion of the AC power cycle during which each color's illuminating element is active—according to predetermined patterns ('275 Patent, Abstract; col. 4:35-42). A key feature is a user-operable switch that can stop the color-changing pattern, with the controller retaining the setting for the selected color in non-volatile memory for future use ('275 Patent, col. 28:1-17).
• Technical Importance: This approach aimed to provide sophisticated, dynamic color-changing effects using simple, series-wired hardware compatible with standard AC wall outlets, while also adding user-friendly "memory" functionality. (ʼ275 Patent, col. 3:65-67; col. 4:5-10).

Key Claims at a Glance

• The complaint asserts exemplary claims, with Independent Claim 1 being representative.
• Independent Claim 1 requires:
  • A lamp assembly with a plurality of multi-colored lamps connected in series with an AC voltage source.
  • Each lamp has a first and second illuminating element for producing two different colors.
  • A lamp controller that varies the color by varying the "conduction interval" of each illuminating element according to a pattern.
  • The controller is configured to "terminate the variation" when a user-operable input is activated.
  • The controller includes a non-volatile memory to "retain...a datum associated with the conduction interval" when the user input is activated, allowing the setting to be restored upon re-application of power.
• The complaint does not specify if dependent claims will be asserted.

U.S. Patent No. 8,390,206 - Variable-effect lighting system

The Invention Explained

• Problem Addressed: As a continuation of the application for the '275 Patent, this patent addresses the same general problem of creating variable lighting effects with simple hardware ('206 Patent, col. 1:12-2:10).
• The Patented Solution: This invention focuses on a different aspect of control: ensuring display stability and predictability when the frequency of the AC power source fluctuates. The lamp controller is configured to control the current supplied to the illuminating elements and, critically, to "adjust the current draw in accordance with the frequency of the voltage source" ('206 Patent, Abstract). The detailed description explains that the controller can measure the period between zero-crossings of the AC signal to calculate the line frequency, and then use that calculation to accurately time the conduction intervals, preventing display errors that would otherwise occur if the frequency deviated from an assumed standard like 60 Hz ('206 Patent, col. 12:26-34).
• Technical Importance: This technology allows for robust and consistent lighting effects across different power grids or in environments with unstable power, a key reliability feature for electronic devices. ('206 Patent, col. 11:60 - col. 12:7).

Key Claims at a Glance

• The complaint asserts exemplary claims, with Independent Claim 1 being representative.
• Independent Claim 1 requires:
  • A lamp assembly with a plurality of multi-colored lamps connected in series with an AC voltage source that has a frequency.
  • Each lamp has a first and second illuminating element for producing two different colors.
  • A lamp controller for "controlling a current draw" of each said illuminating element.
  • The controller is configured to "adjust the current draw in accordance with the voltage frequency."
• The complaint does not specify if dependent claims will be asserted.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶12, ¶21).

Functionality and Market Context

The complaint does not describe the specific technical operation or features of the accused products in its narrative. Instead, it alleges that infringement is demonstrated in claim chart exhibits attached to the complaint (Compl. ¶17, ¶26). As these exhibits were not provided, there is insufficient detail in the complaint itself for an independent analysis of the accused products' functionality. The products are presumably variable-effect LED lighting systems sold by Defendant Novostella.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations for both patents are made by incorporating external exhibits (Exhibits 3 and 4), which were not provided. The tables below summarize the elements of the primary independent claim for each patent and cite the complaint paragraph that incorporates the corresponding non-proffered exhibit.

'275 Patent Infringement Allegations

No probative visual evidence provided in complaint.

Identified Points of Contention

• Technical Questions: A central evidentiary question will be whether the accused products contain a "non-volatile memory" that performs the specific function of retaining a "datum associated with the conduction interval" upon user activation, as claimed. Plaintiff would need to show not just that the products have memory, but that it is used in the precise manner required by the claim.
• Scope Questions: The case may turn on how the term "terminate the variation" is construed. Does this require stopping a continuous color-changing sequence, or could it read on any user input that selects a static color from a set of options?

'206 Patent Infringement Allegations

No probative visual evidence provided in complaint.

Identified Points of Contention

• Technical Questions: The pivotal factual question is whether the accused products' controllers actually "adjust the current draw in accordance with the voltage frequency." This suggests an active process of measuring the AC frequency and altering the timing of the current draw in response, rather than simply being designed to operate at a fixed, standard frequency like 50 or 60 Hz.
• Scope Questions: The infringement analysis will likely hinge on the construction of "in accordance with." A key question for the court will be whether this phrase requires a dynamic, responsive adjustment or if it can be met by a system pre-configured to operate correctly at a known, nominal frequency.

V. Key Claim Terms for Construction

Term from the '275 Patent: "datum associated with the conduction interval"

Context and Importance

This term is critical because it ties the claimed user-activated "memory" function to a specific technical parameter ("conduction interval"). Infringement requires showing that the accused products not only save a user's color preference but that they do so by storing a value representing this specific timing interval. Practitioners may focus on this term to dispute whether a general-purpose "save favorite color" feature meets this technical limitation.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The term "datum" itself is general. An argument could be made that any stored value (e.g., an RGB value, a preset number) that corresponds to a particular conduction interval qualifies. The patent does not explicitly define "datum."
• Evidence for a Narrower Interpretation: The specification describes storing "current conduction angle" values in EEPROM ('206 Patent, col. 12:15-25). A defendant may argue "datum" must be a direct numerical representation of the timing delay or angle, not merely a pointer to a preset color.

Term from the '206 Patent: "adjust the current draw in accordance with the voltage frequency"

Context and Importance

This is the central inventive concept of the '206 patent's independent claims. The entire infringement case for this patent rests on whether the accused products perform this specific function.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: A plaintiff might argue that any system designed to work properly with a given AC frequency (e.g., a product switchable between 50Hz and 60Hz modes) is "adjusting" its operation "in accordance with" the frequency.
• Evidence for a Narrower Interpretation: The specification strongly supports a narrower reading, describing an algorithm that "measures the period of time between instances of zero voltage crossings of the AC source voltage, and uses the calculated period to calculate the line frequency" to "accurately track the actual conduction interval" ('206 Patent, col. 12:26-34). This suggests a dynamic, real-time measurement and adjustment process is required.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Defendant induces infringement by distributing "product literature and website materials" that instruct end users to operate the accused products in a manner that infringes the patents (Compl. ¶15, ¶24).

Willful Infringement

The complaint does not explicitly allege "willful infringement." However, it alleges that the service of the complaint itself provides Defendant with "actual knowledge" of infringement (Compl. ¶14, ¶23). These allegations may form the basis for a later claim of post-suit willful infringement or a request for enhanced damages under 35 U.S.C. § 284.

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

1. An Evidentiary Question of Functionality: Given the complaint’s reliance on unprovided exhibits, a primary issue will be what evidence Plaintiff can produce through discovery and testing to demonstrate that the accused products' controllers perform the specific, nuanced functions required by the claims—namely, storing a "datum associated with the conduction interval" in non-volatile memory ('275 patent) and dynamically "adjust[ing] the current draw in accordance with the voltage frequency" ('206 patent).

2. A Definitional Question of Scope: The case will likely turn on the construction of key claim limitations. A central question for the court will be whether the phrase "adjust... in accordance with the voltage frequency" requires a dynamic, feedback-based system as described in the specification, or if it can be construed more broadly to cover devices simply designed to be compatible with standard AC frequencies.

3. A Question of Infringing Action: The dispute over the '275 patent may focus on the specific user interaction claimed. The key question will be whether the accused products' user interface for selecting and saving a color maps to the claimed sequence of "terminat[ing] the variation upon activation of a user-operable input" and retaining the specific conduction data.