LightSure LLC v. Parrot SA

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: LightSure LLC (NM)
  • Defendant: Parrot SA (France)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00630, E.D. Tex., 06/13/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the Eastern District of Texas and has committed the alleged acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s unmanned aerial vehicles infringe a patent related to UAV communication, traffic monitoring, and management systems that use ground-based infrastructure.
• Technical Context: The technology concerns systems for managing unmanned aerial vehicle (UAV) traffic using communications equipment co-located with roadway infrastructure, a key area for enabling safe and scalable commercial drone operations.
• 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. Plaintiff is the assignee of the asserted patent.

Case Timeline

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

• U.S. Patent No. 9,087,451, “Unmanned aerial vehicle communication, monitoring, and traffic management,” issued July 21, 2015

The Invention Explained:

• Problem Addressed: The patent background describes public concerns over the domestic use of UAVs, including "privacy concerns... regarding unauthorized or intrusive surveillance," as well as "potential for injury or property damage" and nuisance. (’451 Patent, col. 1:42-52).
• The Patented Solution: The invention proposes a computer-implemented method where a ground-based "lighting assembly" (e.g., a streetlight) communicates with a UAV to manage its flight. (’451 Patent, Abstract). The system works through a three-step communication exchange: (1) the lighting assembly’s communications station transmits a first message to a nearby UAV; (2) it receives a second message back from the UAV containing a UAV identifier; and (3) it transmits a third message telling the UAV the altitude at which it should fly. (’451 Patent, Abstract; col. 2:1-4). This creates a localized, infrastructure-based system for directing UAV traffic, as illustrated in the environment of Figure 1, which depicts communications stations (101) on lighting assemblies (144) interacting with a UAV (150) near a roadway (102).
• Technical Importance: This approach sought to create a verifiable, ground-based traffic management system for low-altitude UAVs, directly addressing the safety and oversight concerns that were perceived as barriers to widespread commercial and civil drone operations. (’451 Patent, col. 1:42-52, col. 4:14-29).

Key Claims at a Glance:

• The complaint does not specify which claims are asserted, instead incorporating by reference an unprovided exhibit containing claim charts (Compl. ¶ 16). The primary independent method claim, Claim 1, is representative of the core invention.
• Independent Claim 1 recites a method with the following essential elements:
  • Transmitting a first message from a communications station mounted to a lighting assembly located near a roadway.
  • The lighting assembly is in physical contact with the ground.
  • Receiving a second message from the UAV, which includes an identifier for the UAV.
  • Transmitting a third message to the UAV, which includes an indication of an altitude at which the UAV should fly.
• The complaint reserves the right to assert additional claims. (Compl. ¶ 11).

III. The Accused Instrumentality

Product Identification:

• The complaint accuses "at least the Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')." (Compl. ¶ 11). The referenced charts (Exhibit 2) were not provided with the complaint.

Functionality and Market Context:

• The complaint does not describe the specific functionality of the accused products. It makes the conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '7451 Patent" and "satisfy all elements of the Exemplary '7451 Patent Claims." (Compl. ¶ 16). Defendant Parrot SA is a commercial manufacturer of UAVs. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant directly infringes the ’451 Patent by making, using, selling, and importing the accused products. (Compl. ¶ 11). It incorporates by reference "charts comparing the Exemplary '7451 Patent Claims to the Exemplary Defendant Products" (Exhibit 2), which were not filed with the complaint. (Compl. ¶ 16-17). Without this exhibit, a detailed element-by-element analysis is not possible based on the complaint's text alone. The narrative infringement theory is that the accused products, when used, perform the patented method. (Compl. ¶ 16).

Identified Points of Contention:

• Factual Question: A central question will be whether Plaintiff can produce evidence that Defendant’s UAVs are designed to, or in practice do, engage in the specific three-step communication protocol (transmit from station, receive from UAV, transmit altitude instruction to UAV) with a ground-based "lighting assembly" as required by the claims. The complaint does not allege facts to support this interaction.
• Technical Question: It will be necessary to determine whether the accused products' navigation and control systems rely on a third-party, roadway-based infrastructure for altitude commands, as claimed in the patent, or if they operate using a different architecture, such as pre-programmed flight plans, user-controller commands, or a centralized, cloud-based system.

V. Key Claim Terms for Construction

• The Term: "communications station"

• Context and Importance: This term is central to defining the ground-based infrastructure. Practitioners may focus on this term because its scope will determine whether the claims read on general-purpose communication networks (e.g., cellular) that Defendant's products might use, or if they are limited to the specialized, dedicated hardware depicted in the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that communications stations "may be positioned on streetlights, traffic lights, utility poles, towers (e.g., cell towers), communications station poles, road signs... or other structures within a proximity of a roadway." (’451 Patent, col. 6:51-59). The explicit mention of "cell towers" could support an interpretation that includes existing network infrastructure.
  • Evidence for a Narrower Interpretation: The patent's abstract, summary, and claims consistently describe the "communications station" as being part of, or "mounted to," a "lighting assembly." (’451 Patent, Abstract; Claim 1; Claim 28). Figure 5 depicts the "Communications Station" 252 as a discrete system with its own specific components (e.g., Receiver 256, Transmitter 258, Traffic Management 270), suggesting a purpose-built device rather than a general network node.

• The Term: "lighting assembly"

• Context and Importance: This term anchors the invention to physical roadway infrastructure. The infringement analysis may depend on whether any part of the accused system can be characterized as a "lighting assembly."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides a broad list of structures on which a communications station may be placed, including not only streetlights but also "utility poles," "towers," "buildings, trees, billboards, [and] bridges." (’451 Patent, col. 6:52-59). This could support an argument that the term is not limited to a traditional light pole and luminaire.
  • Evidence for a Narrower Interpretation: Independent claim 28, which defines "A lighting assembly," requires it to comprise "a light pole," "a luminaire attached to the light pole," and "a communications station mounted to the light pole." This definition from a separate independent claim could be used to argue that the term as used in Claim 1 should be interpreted consistently to require, at a minimum, a structure whose primary purpose relates to illumination.

VI. Other Allegations

Indirect Infringement:

• The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '7451 Patent." (Compl. ¶ 14).

Willful Infringement:

• The allegation of willfulness is based on post-suit conduct. The complaint asserts that "The service of this Complaint... constitutes actual knowledge of infringement" and that Defendant's continued infringing activities thereafter are willful. (Compl. ¶¶ 13-14).

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

• A central evidentiary question will be one of technical operation: can Plaintiff demonstrate that Defendant’s accused UAVs engage in the specific three-step communication protocol with a ground-based infrastructure as required by claim 1, or do they operate on a fundamentally different, self-contained or cloud-based navigation and control architecture?
• The case will also likely turn on a question of definitional scope: can the term "communications station mounted to a lighting assembly," which the patent’s figures and embodiments describe as dedicated hardware on a streetlight, be construed broadly enough to cover the general-purpose network infrastructure (such as cellular networks) that Defendant’s products may use for communication and data exchange?