LightSure LLC v. Sengled Optoelectronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: LightSure LLC (New Mexico)
  • Defendant: Sengled Optoelectronics Co., Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00620, E.D. Tex., 06/11/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant having an established place of business within the Eastern District of Texas and having committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s smart lighting products infringe a patent related to dynamically managing lighting system energy use in response to local activity.
• Technical Context: The technology concerns networked lighting systems, such as streetlights, that conserve energy by operating at low levels until sensors detect nearby activity, at which point they temporarily increase brightness.
• Key Procedural History: The asserted patent is subject to a terminal disclaimer, which may limit its enforceable term. The patent is a continuation of an earlier application that issued as U.S. Patent No. 8,502,456. The complaint does not mention any prior litigation or administrative proceedings involving the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,716,942 - “Managing light system energy use,” issued May 6, 2014

The Invention Explained

• Problem Addressed: The patent identifies the significant energy costs associated with conventional street and parking lot lights, which are typically either fully powered on or off, leading to inefficient energy use, particularly during periods of low activity (’942 Patent, col. 1:18-24).
• The Patented Solution: The invention describes a smart lighting system where individual lighting assemblies receive a "lighting profile" (e.g., a schedule) from a remote central controller. The assemblies operate according to this low-energy profile but are equipped with sensors (e.g., for motion or sound). When activity is detected, the assembly deviates from the profile to temporarily increase its brightness. Crucially, it then transmits a message back to the central controller reporting this deviation and its own identifier, allowing for a system-wide log of activity and energy use (’942 Patent, Abstract; col. 2:32-60; Fig. 7).
• Technical Importance: This technology enables a responsive, on-demand lighting system that aims to balance energy conservation with public safety by providing illumination only when and where it is needed (’942 Patent, col. 3:9-18).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying them, instead referencing an external exhibit (Compl. ¶11). The patent contains two independent claims, Claim 1 (method) and Claim 22 (apparatus).
• Independent Claim 1 (Method) includes the essential steps of:
  • Receiving, at a first lighting assembly, a lighting profile from a remote control center.
  • Implementing the profile, causing a light to illuminate at a first intensity.
  • Receiving, at a sensing module, an input indicating proximate activity.
  • Deviating from the profile by causing the light to illuminate at a different, second intensity for a predetermined time.
  • Wirelessly transmitting a message to the control center with an indication of the second intensity and an identifier for the assembly.
• Independent Claim 22 (Apparatus) includes the essential components of:
  • A light.
  • A communications receiver configured to receive a lighting profile from a remote control center.
  • A light control module configured to implement the profile at a first intensity.
  • A sensor module to receive an input indicating proximate activity.
  • The light control module is also configured to deviate from the profile to a second intensity in response to the sensor input.
  • A communications transmitter configured to wirelessly transmit a message to the control center indicating the second intensity and an assembly identifier.
• The complaint does not explicitly reserve the right to assert dependent claims, but the broad language suggests this possibility.

III. The Accused Instrumentality

Product Identification

The complaint does not name specific accused products in its main body. It refers to "Exemplary Defendant Products" which are identified in claim charts attached as Exhibit 2 (Compl. ¶11, ¶16). This exhibit was not provided with the complaint document.

Functionality and Market Context

The complaint alleges that Defendant makes, uses, sells, and imports products that "practice the technology claimed by the '942 Patent" (Compl. ¶11, ¶16). It further alleges that Defendant distributes "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶14). The complaint does not provide sufficient detail for analysis of the specific technical functionality of the accused products beyond the general allegation that they meet the limitations of the asserted claims.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim charts in an unattached Exhibit 2, precluding the creation of a detailed claim chart summary (Compl. ¶16-17). The narrative theory is that the Defendant's products, when operated as intended, perform all steps of the patented method and contain all elements of the patented apparatus. The complaint alleges direct infringement through Defendant's own making, selling, and internal testing of the products (Compl. ¶11-12) and induced infringement through the sale of these products with instructional materials (Compl. ¶15).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central dispute may arise over the meaning of "lighting profile" and whether the accused products "receive" such a profile from a "remote control center." The analysis will question if the accused products operate based on instructions from a networked, central server or if they function autonomously based on factory-set parameters.
• Technical Questions: A primary evidentiary question will be whether the accused products perform the claimed step of "wirelessly transmitting a message ... for receipt by the control center" that includes both "an indication of the increased light intensity and an identifier" (’942 Patent, col. 17:21-26). The presence or absence of this specific two-part reporting functionality will be a critical point in the infringement analysis.

V. Key Claim Terms for Construction

The Term: "lighting profile"

• Context and Importance: This term defines the baseline operation from which the invention "deviates." The scope of this term is critical because if the accused product’s baseline operation is not considered a "lighting profile," its subsequent actions cannot be a "deviation."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests flexibility, stating a profile "can take any number of forms" and can "include a power function over time" or a "schedule of light intensities" (’942 Patent, col. 5:3-6). This could support an argument that any set of operational rules, however simple, qualifies.
  • Evidence for a Narrower Interpretation: The patent’s figures and examples illustrate detailed, time-based schedules that correlate light intensity with the time of day and ambient conditions (’942 Patent, Figs. 2A-2C; col. 7:28-40). A party could argue the term is limited to these more complex, pre-determined schedules received from a central controller.

The Term: "deviating from the received lighting profile"

• Context and Importance: This is the core inventive concept of responsive illumination. Infringement will depend on whether the accused product's sensor-triggered brightening is properly characterized as a "deviation."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states that the "lighting assembly may deviate from the received lighting profile by altering illumination characteristics... based on one or more inputs sensed at or near the lighting assembly" (’942 Patent, col. 3:57-61). This supports viewing any sensor-based change from the baseline as a "deviation."
  • Evidence for a Narrower Interpretation: A defendant might argue that a fully pre-programmed, sensor-based response is not a "deviation" but is instead part of a more complex, singular set of operating instructions. The specification's discussion of a central controller sending a "second lighting profile that overrides the first lighting profile" could be used to argue that a true "deviation" requires an external command rather than an autonomous, pre-set reaction (’942 Patent, col. 5:50-54).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant sells the accused products with knowledge of the '942 Patent and with the intent that its customers will use them in an infringing manner. The factual basis cited is the distribution of "product literature and website materials" that instruct users on the products' infringing functionality (Compl. ¶14-15).

Willful Infringement

The complaint alleges that Defendant has had "actual knowledge" of its infringement at least since the service of the complaint and its attached claim charts (Compl. ¶13, ¶15). This forms the basis for a claim of post-filing willful infringement. No allegations of pre-suit knowledge are made.

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

1. A key evidentiary question will be one of operational capability: does the accused product architecture include a "communications transmitter" that reports back to a "control center" with a message containing both an "indication of the increased light intensity and an identifier associated with the first lighting assembly," as explicitly required by the independent claims? The absence of this specific reporting-back feature could be dispositive for non-infringement.
2. A core issue will be one of claim scope: can the phrase "deviating from the received lighting profile" be construed to cover a device's autonomous, pre-programmed reaction to a sensor input? Or does the term require a departure from a set of instructions that was not contemplated by the device's own internal logic until the external stimulus occurred? The court's construction of this term will likely determine the outcome of the infringement analysis.