BridgeComm LLC v. Samsung Electronics America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: BridgeComm LLC (TX)
  • Defendant: Samsung Electronics America, Inc. (NY)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00960, E.D. Tex., 11/21/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Eastern District of Texas and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that certain of Defendant's products infringe two patents related to variable-effect lighting systems, such as those used in decorative lighting.
• Technical Context: The technology concerns electronic control systems for multi-color light-emitting diode (LED) strings, enabling complex color-changing effects by precisely managing power delivery.
• Key Procedural History: The complaint indicates that U.S. Patent No. 8,390,206 is a continuation of the application that resulted in U.S. Patent No. 8,203,275, suggesting a shared specification and close technical relationship 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 June 19, 2012

The Invention Explained

• Problem Addressed: The patent describes prior art variable-effect lighting systems as having limitations, such as a restricted range of producible color displays or requiring complex and costly components to achieve intricate effects (’275 Patent, col. 1:36-44, col. 2:7-9).
• The Patented Solution: The invention proposes a simplified system where a string of multi-colored lamps (e.g., back-to-back red and green LEDs) are connected in series with an AC power source (’275 Patent, col. 3:50-54, Fig. 1a). A lamp controller varies the color output by adjusting the "conduction interval"—the portion of the AC power cycle during which each color's illuminating element is active—according to a predetermined pattern (’275 Patent, Abstract; col. 4:5-11). A key feature is the ability for a user to stop the color variation and for the system to retain that state in non-volatile memory, even after a power loss (’275 Patent, col. 2:22-26, claim 1).
• Technical Importance: The system aims to provide a greater variety of color displays from a relatively simple and cost-effective circuit design, suitable for consumer applications like decorative lighting (’275 Patent, col. 2:7-9, col. 3:56-59).

Key Claims at a Glance

• The complaint does not identify specific asserted claims, instead referencing "Exemplary '275 Patent Claims" in an external exhibit not filed with the complaint (Compl. ¶12). Claim 1 is the first independent claim.
• Independent Claim 1 of the ’275 Patent recites the following essential elements:
  • A lamp assembly with a plurality of multi-colored lamps connected in series with an AC voltage source.
  • Each lamp comprising at least a first and a second illuminating element for producing different colors.
  • A lamp controller that varies the color by varying a "conduction interval" of each illuminating element based on a predetermined pattern.
  • The controller is configured to terminate the color variation upon activation of a user-operable input.
  • The controller includes a non-volatile memory to retain a "datum associated with the conduction interval" of an element, allowing the setting to be restored upon re-application of power.
• The complaint does not explicitly reserve the right to assert dependent claims.

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

The Invention Explained

• Problem Addressed: As a continuation, this patent addresses the same general problems as the ’275 Patent regarding the limitations of prior art lighting systems (’206 Patent, col. 1:39-49). It further addresses the problem of unpredictable visual displays that can occur if the frequency of the AC power source is not constant, as assumed by simpler control algorithms (’206 Patent, col. 11:51-65).
• The Patented Solution: The invention claims a system with a lamp controller that controls the "current draw" of each illuminating element and, critically, is configured to "adjust the current draw in accordance with the voltage frequency" (’206 Patent, Abstract, claim 1). The specification describes a method for achieving this by measuring the time between zero-crossings of the AC voltage to calculate the actual line frequency, and then using that calculated frequency to accurately control the timing of the lighting effects (’206 Patent, col. 11:60 - col. 12:12).
• Technical Importance: This approach allows the lighting system to self-synchronize and produce consistent, predictable color effects even when the AC power frequency deviates from the standard (e.g., 60 Hz), enhancing reliability (’206 Patent, col. 11:51-65).

Key Claims at a Glance

• The complaint does not identify specific asserted claims, instead referencing "Exemplary '206 Patent Claims" in an external exhibit not filed with the complaint (Compl. ¶21). Claim 1 is the first independent claim.
• Independent Claim 1 of the ’206 Patent recites the following essential elements:
  • A lamp assembly with a plurality of multi-colored lamps connected in series with an AC voltage source having a frequency.
  • Each lamp comprising at least a first and a second illuminating element for producing different colors.
  • A lamp controller coupled to the assembly for controlling a "current draw" of each illuminating element.
  • The controller is configured to "adjust the current draw in accordance with the voltage frequency."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are detailed in claim charts attached as Exhibits 3 and 4 (Compl. ¶¶ 12, 21). These exhibits were not filed with the public version of the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context. It makes only broad allegations that these unnamed products "practice the technology claimed" by the patents-in-suit (Compl. ¶¶ 17, 26).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's "Exemplary Defendant Products" infringe the patents-in-suit and incorporates by reference claim charts in Exhibits 3 and 4, which are not publicly available (Compl. ¶¶ 18, 27). The complaint asserts that these charts demonstrate that the accused products "satisfy all elements of the Exemplary [...] Patent Claims" for each respective patent (Compl. ¶¶ 17, 26). Without the charts or identification of the accused products, a detailed element-by-element analysis is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • '275 Patent: A central question will be one of functional correspondence. The complaint provides no facts to support the allegation that the accused products perform the specific functions required by the claims, such as terminating color variation via a user input and storing a "datum associated with the conduction interval" in non-volatile memory to survive a power cycle. Evidence of these specific software or hardware features will be critical.
  • '206 Patent: The primary technical question will be whether the accused products perform the core function of adjusting current draw "in accordance with the voltage frequency." The infringement analysis will likely focus on whether the accused products contain circuitry or logic to measure the AC frequency and actively adjust timing, as taught in the patent, or if they merely operate based on a fixed, assumed frequency (e.g., 60 Hz), which may suggest a functional mismatch with the claim language.

V. Key Claim Terms for Construction

For the ’275 Patent

• The Term: "a datum associated with the conduction interval" (from Claim 1)
• Context and Importance: The infringement analysis hinges on what information the accused product must store in non-volatile memory. Practitioners may focus on this term because its scope determines whether simply storing a user's selected color "mode" is sufficient, or if the product must store a specific timing value (the "conduction interval" itself) or a parameter directly used to calculate it.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "datum associated with" could be argued to encompass any data that has a relationship to the resulting conduction interval, not necessarily the interval value itself.
  • Evidence for a Narrower Interpretation: The specification describes storing the "current conduction angle" in EEPROM to allow the system to "reimplement[] the selected colour or intensity, using the stored conduction angle" after a power loss, suggesting the "datum" is a specific quantitative value directly related to power timing (’275 Patent, col. 16:19-25).

For the ’206 Patent

• The Term: "adjust the current draw in accordance with the voltage frequency" (from Claim 1)
• Context and Importance: This term is the central point of novelty for the ’206 patent's independent claims. The viability of the infringement claim depends on whether the accused products' operation falls within the scope of this language.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that any system designed to work on an AC line inherently operates "in accordance with" its frequency, even without active measurement.
  • Evidence for a Narrower Interpretation: The specification provides a very specific technical meaning, teaching an algorithm that "measures the period of time between instances of zero voltage crossings" and "uses the calculated period to calculate the line frequency" to then "accurately track the actual conduction interval" (’206 Patent, col. 11:60 - col. 12:6). This suggests "in accordance with" requires an active measurement and adjustment loop, not a passive or assumed relationship.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents. The basis for this allegation is that Defendant distributes "product literature and website materials" that allegedly instruct end users to operate the accused products in a manner that directly infringes the patent claims (Compl. ¶¶ 15, 24).
• Willful Infringement: The complaint does not use the term "willful," but it lays a foundation for enhanced damages under 35 U.S.C. § 284. It alleges that the filing of the complaint provides Defendant with "Actual Knowledge" of the patents and infringement, and that Defendant has continued its infringing activities despite this knowledge (Compl. ¶¶ 14-15, 23-24). The prayer for relief also requests that the case be found "exceptional" under 35 U.S.C. § 285 (Compl. ¶ G.i).

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

1. Evidentiary Substantiation: The complaint is presently devoid of specific factual allegations linking any particular Samsung product to the patent claims, relying instead on non-public exhibits. A threshold question will be whether Plaintiff can produce discovery evidence that demonstrates a specific accused product actually performs the detailed functions recited in the claims, moving the case from generalized pleading to a concrete technical dispute.
2. Functional Operation vs. Claim Language: The core of the case will likely turn on a question of functional equivalence. For the '206 patent specifically, a key issue will be whether the accused products perform the claimed function of actively measuring and adjusting their operation "in accordance with the voltage frequency." The court may need to decide if a system that merely assumes a standard frequency (e.g., 60 Hz) meets this limitation, or if the patent requires the specific adaptive behavior described in the specification.
3. Definitional Scope: For the '275 patent, the dispute may focus on the definitional scope of what it means to store a "datum associated with the conduction interval" in non-volatile memory. The case could turn on whether the data retained by the accused products (e.g., a high-level "mode" setting) is sufficiently linked to the specific timing intervals recited in the claim, or if the claim requires a more direct, quantitative value to be stored.