BridgeComm LLC v. Honeywell Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: BridgeComm LLC (TX)
  • Defendant: Honeywell International Inc. (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00957, E.D. Tex., 11/21/2024
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified lighting products infringe two patents related to systems for creating variable color effects with multi-colored lamps.
• Technical Context: The technology concerns electronic control systems for decorative and ornamental lighting, such as LED light strings, to produce dynamic color-changing effects.
• Key Procedural History: 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 direct technological lineage between the two patents-in-suit.

Case Timeline

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

U.S. Patent No. 8,203,275 - "Variable-effect lighting system" (issued Jun. 19, 2012)

The Invention Explained

• Problem Addressed: The patent describes a need for a "relatively simple variable-effect lighting system" capable of producing a "greater variation in the range of colour displays" than was possible with prior art systems, which were often limited in their effects or overly complex (’275 Patent, col. 2:7-10).
• The Patented Solution: The invention is a lighting system where multiple multi-colored lamps are connected in series with an alternating current (AC) power source (’275 Patent, col. 3:58-4:2). Each lamp contains at least two illuminating elements (e.g., different colored LEDs connected back-to-back) that emit light based on the direction of the AC current (’275 Patent, col. 4:11-24). A lamp controller creates variable color effects by precisely varying the "conduction interval"—the portion of each AC power cycle during which each illuminating element is allowed to conduct electricity and produce light (’275 Patent, Abstract).
• Technical Importance: The approach of controlling the conduction interval of series-connected lamps on an AC power line provides a method for generating complex color-changing patterns without requiring complex wiring or a step-down power transformer for each light string (’275 Patent, col. 3:58-4:6).

Key Claims at a Glance

• The complaint asserts "one or more claims" but does not identify any specific independent claims in its text, instead incorporating them by reference via an unprovided exhibit (Compl. ¶12).

U.S. Patent No. 8,390,206 - "Variable-effect lighting system" (issued Mar. 5, 2013)

The Invention Explained

• Problem Addressed: As a continuation of the ’275 Patent application, this patent addresses the same general problem of creating varied lighting effects (’206 Patent, col. 2:7-10). It specifically addresses a problem that arises when the frequency of the AC power source is not constant, which can lead to "unpredictable visual display[s]" if the control timing is fixed (’206 Patent, col. 12:21-25).
• The Patented Solution: The invention is a lighting system with a controller configured to "control the current draw of each said illuminating element, and to adjust the current draw in accordance with the frequency of the voltage source" (’206 Patent, Abstract). The controller actively measures the period of the AC voltage waveform (e.g., the time between zero-crossings) to calculate the actual line frequency and then uses this information to accurately time its control signals, ensuring the intended visual effects are produced even if the power frequency fluctuates (’206 Patent, col. 12:26-40).
• Technical Importance: By making the control system responsive to the actual frequency of the power source, the invention allows for robust and predictable operation across different power grids or in environments with unstable power, a key feature for a mass-market electronic device (’206 Patent, col. 11:58-12:5).

Key Claims at a Glance

• The complaint asserts "one or more claims" but does not identify any specific independent claims in its text, instead incorporating them by reference via an unprovided exhibit (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" and "numerous other devices" that allegedly infringe (Compl. ¶12, ¶21).

Functionality and Market Context

The complaint does not provide any description of the accused products' technical functionality, design, or operation. It alleges that the products "practice the technology claimed" by the patents-in-suit, but supports this only by reference to unprovided exhibits (Compl. ¶17, ¶26). No information regarding the products' market context or commercial importance is provided. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits 3 and 4) that were not provided with the pleading; therefore, a claim chart summary cannot be created. The infringement allegations are made in a conclusory manner, stating that the "Exemplary Defendant Products" practice the claimed technology and "satisfy all elements of the Exemplary... Patent Claims" (Compl. ¶17, ¶26). The complaint lacks specific factual allegations detailing how any particular feature of a Honeywell product meets any specific limitation of an asserted patent claim.

• Identified Points of Contention:
  • Evidentiary Questions: The primary point of contention will be evidentiary. Given the lack of factual detail in the complaint, the case will depend on whether Plaintiff can obtain evidence in discovery to show that Defendant's unspecified products perform the specific functions required by the patents.
  • Technical Questions (’275 Patent): A key question is whether the accused products utilize an AC power source and control color by varying the "conduction interval" of series-connected, back-to-back illuminating elements, as the patent describes.
  • Technical Questions (’206 Patent): A more specific technical question is whether the accused products' controllers "adjust the current draw in accordance with the voltage frequency." This raises the question of whether the products contain circuitry to measure the AC line frequency and use that measurement to modify control timing, or if they operate in a frequency-agnostic manner.

V. Key Claim Terms for Construction

As the complaint does not identify specific asserted claims, the following terms are identified from the patent specifications as being central to the inventions and likely to be at issue in any infringement analysis.

For the ’275 Patent:

• The Term: "conduction interval"
• Context and Importance: This term is the core of the control mechanism described in the patent. Its definition will be critical for determining whether the accused products' method of modulating light output falls within the scope of the claims.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term is used generally in the summary of the invention to mean the period during which an element conducts current, which might support an interpretation covering various forms of power modulation (’275 Patent, col. 2:22-24).
  • Evidence for a Narrower Interpretation: The detailed description teaches a specific method of varying this interval by detecting an AC zero-crossing, delaying a "predetermined period," and then triggering a bidirectional switch, which remains on for the rest of the half-cycle (’275 Patent, col. 5:7-16). This may support a narrower construction limited to this type of AC phase-angle control.

For the ’206 Patent:

• The Term: "adjust the current draw in accordance with the voltage frequency"
• Context and Importance: This limitation appears to be a key inventive concept of the ’206 Patent. The infringement analysis for this patent will likely hinge on whether the accused products perform this specific adjustment.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself does not specify how the adjustment must be made, potentially leaving room for arguments that any system that behaves differently at different line frequencies meets the limitation.
  • Evidence for a Narrower Interpretation: The specification describes a specific mechanism: "measure[ing] the period of time between instances of zero voltage crossings of the AC source voltage, and us[ing] the calculated period to calculate the line frequency" to then control the LEDs (’206 Patent, col. 12:26-34). This suggests a construction requiring an active measurement and compensation system, not merely a passive response to frequency changes.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶15, ¶24). The factual basis for this allegation is incorporated by reference from unprovided exhibits.
• Willful Infringement: The complaint does not use the term "willful." It does, however, plead a basis for post-filing willfulness by alleging that the filing of the complaint provides Defendant with "Actual Knowledge of Infringement" and that Defendant continues its allegedly infringing conduct despite this knowledge (Compl. ¶14-15, ¶23-24). No facts are alleged to support pre-suit knowledge.

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

1. A primary issue will be one of evidence and specificity: Can Plaintiff, through discovery, uncover and present evidence that Defendant’s unnamed products function in the precise manner described by the patents, given that the complaint itself provides no specific factual allegations linking any product to any claim?
2. A central technical question will be one of operational correspondence: Do Defendant’s products, which are not described in the complaint, actually employ the specific AC phase-control methodology of varying a "conduction interval" as taught in the ’275 patent, or a different control scheme?
3. A key distinguishing issue for the second patent will be one of active compensation: Does the evidence show that Defendant’s products perform the specific function of measuring the AC line frequency and "adjust[ing] the current draw in accordance with the voltage frequency" as required by the ’206 patent, or do they lack this adaptive capability?