LED Apogee LLC v. Kinetic Technologies

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: LED Apogee LLC (Delaware)
  • Defendant: Kinetic Technologies (Cayman Islands)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: LED Apogee LLC v. Kinetic Technologies, 2:24-cv-00997, E.D. Tex., 12/03/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains an established place of business in the District and has committed the alleged acts of patent infringement there.
• Core Dispute: Plaintiff alleges that certain unnamed products made by Defendant infringe a patent related to methods for driving light-emitting diodes (LEDs).
• Technical Context: The technology concerns electronic circuits designed to improve the power efficiency of driving LEDs, which are fundamental components in modern lighting, consumer electronics, and display technologies.
• 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

U.S. Patent No. 6,982,527 - "Method for driving light emitting diode," issued Jan. 3, 2006

The Invention Explained

• Problem Addressed: The patent addresses inefficiencies in prior art circuits used to drive LEDs. Specifically, it identifies that conventional charge-pump circuits, which boost voltage to power LEDs, suffer from "excess power loss" because they supply a fixed, high voltage to a current mirror, regardless of the actual voltage required by the LED, which can vary ('527 Patent, col. 1:40-48). This creates an unnecessary voltage drop across the current mirror, wasting energy as heat ('527 Patent, col. 2:1-2).
• The Patented Solution: The invention proposes a method that dynamically adjusts the voltage supplied to the LED driver circuit to minimize this waste. Instead of a fixed high voltage, it uses an inductive charge pumping circuit and a feedback loop. The method uses an input to the light-emitting diode itself as a "voltage feedback point" to actively regulate the input voltage to the current mirror, thereby "keeping a constant voltage difference between the input and the output of the current mirror" ('527 Patent, Abstract; col. 4:14-18). This adaptive voltage control significantly reduces the power loss described as a key problem in the prior art ('527 Patent, col. 4:32-37).
• Technical Importance: This method provides a more power-efficient way to drive LEDs, a critical consideration for battery-powered devices and for reducing overall energy consumption and heat generation in lighting systems ('527 Patent, col. 2:54-62).

Key Claims at a Glance

• The complaint alleges infringement of one or more claims, identifying them as the "Exemplary '527 Patent Claims" in an unprovided exhibit (Compl. ¶11). Independent claim 1 is representative of the core invention.
• The essential elements of independent claim 1 are:
  • 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.
• The complaint does not specify which dependent claims may be asserted.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products in its main body. It refers to them as the "Exemplary Defendant Products" and states they are identified in charts contained in an Exhibit 2 (Compl. ¶11, ¶13). This exhibit was not filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant directly infringes the ’527 Patent by making, using, selling, or importing the "Exemplary Defendant Products" (Compl. ¶11). It further states that claim charts in the unprovided Exhibit 2 demonstrate how these products "practice the technology claimed by the '527 Patent" (Compl. ¶13). However, the complaint itself does not contain any factual allegations that map specific features of any accused product to the limitations of the asserted claims. Without access to the referenced exhibit, a substantive analysis of the infringement allegations is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

Based on the patent's language, the construction of the following terms from independent claim 1 may be central to resolving the dispute.

• The Term: "current mirror"

  • Context and Importance: This term defines a core component of the claimed circuit. The scope of this term will determine what types of circuit architectures fall within the claims. Practitioners may focus on this term to determine if the accused products' driver circuits, which may use different transistor configurations, meet this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims state a current mirror is "formed by coupling a plurality of MOS transistors," suggesting any such coupling that performs the function of a current mirror could suffice ('527 Patent, col. 5:22-23).
    • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where the current mirror "is constructed by four metal-oxide-semiconductor transistors" arranged in a particular way as shown in Figure 4 ('527 Patent, col. 3:55-58, Fig. 4). A defendant might argue the term should be limited to architectures similar to this disclosed embodiment.

• The Term: "providing an input of said light emitting diode as a voltage feedback point for keeping a constant voltage difference"

  • Context and Importance: This limitation describes the core inventive concept of the feedback mechanism. The infringement analysis will likely turn on whether the accused products' control systems function in the specific manner required by this language.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A plaintiff might argue this language covers any system that uses a voltage associated with the LED to regulate the input voltage to the driver stage in a way that maintains a relatively stable voltage drop.
    • Evidence for a Narrower Interpretation: The patent states that "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 for keeping a constant voltage difference between Vout and one of VA42, VA43 and VA44" ('527 Patent, col. 4:14-18). This specific disclosure of using the direct input node of the LED to maintain a constant difference could support a narrower construction requiring a direct feedback topology, rather than a more general or indirect control loop.

VI. Other Allegations

• Indirect Infringement: The complaint does not allege indirect infringement. Count 1 is for direct infringement only (Compl. ¶11).
• Willful Infringement: The complaint does not allege willful infringement or plead any facts regarding pre- or post-suit knowledge by the Defendant. The prayer for relief includes a request for a finding that the case is "exceptional" under 35 U.S.C. § 285, but no factual basis for this request is provided in the pleadings (Compl. ¶E.i).

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

• An Evidentiary Question of Infringement: The complaint's reliance on an unprovided exhibit creates a significant evidentiary gap. A primary question for the case is whether Plaintiff can produce discovery evidence demonstrating that Defendant's unnamed products contain a circuit that practices each step of the asserted method claims, particularly the specific feedback control mechanism.
• A Definitional Question of Claim Scope: The case will likely hinge on claim construction. A core issue will be whether the term "voltage feedback point," as used in the patent, requires a specific circuit topology where the LED's direct input voltage is used to maintain a constant voltage drop, as shown in the patent's embodiment, or if it can be construed more broadly to cover any control system that regulates the driver's input voltage based on an LED-related parameter.