DCT

2:25-cv-00805

BridgeComm LLC v. Shenzhen Zhenhuan Technology Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00805, E.D. Tex., 08/18/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas on the basis that Defendant is a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s lighting products infringe two U.S. patents related to variable-effect lighting systems that use multi-colored illuminating elements.
  • Technical Context: The technology at issue involves electronic control circuits for decorative lighting, such as multi-color LED light strings, to produce a variety of dynamic color-changing and flashing effects.
  • Key Procedural History: The complaint is the initial pleading in this matter. U.S. Patent No. 8,390,206 is a continuation of the application that resulted in U.S. Patent No. 8,203,275, indicating the patents share a common specification. No other procedural events are mentioned.

Case Timeline

Date Event
2005-08-16 Priority Date for ’275 and ’206 Patents
2006-08-16 Application Filing Date for ’275 Patent
2012-06-18 Application Filing Date for ’206 Patent
2012-06-19 Issue Date for U.S. Patent No. 8,203,275
2013-03-05 Issue Date for U.S. Patent No. 8,390,206
2025-08-18 Complaint Filed

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

U.S. Patent No. 8,203,275 - "Variable-effect lighting system"

The Invention Explained

  • Problem Addressed: The patent’s background section describes prior art variable-effect lighting systems as being overly complex, limited in the range of producible color displays, or restricted in their rate of color change (U.S. Patent No. 8,203,275, col. 1:19-col. 2:10).
  • The Patented Solution: The invention proposes a simplified lighting system where multiple multi-colored lamps are connected in series with an alternating current (AC) voltage source. A lamp controller varies the color output by adjusting the "conduction interval"—the portion of the AC cycle during which each colored illuminating element is active—according to a predetermined pattern. The system also includes a user-operable input to start or stop the color variation ('275 Patent, Abstract; Fig. 1a).
  • Technical Importance: The design enables the creation of intricate color displays using a relatively simple series circuit, which avoids the need for more complex components like step-down transformers and is well-suited for consumer products like decorative lights ('275 Patent, col. 2:8-10, col. 3:6-10).

Key Claims at a Glance

  • The complaint alleges infringement of "exemplary claims" identified in an external chart (Exhibit 3), which was not filed with the complaint (Compl. ¶12). Independent claim 1 is representative and includes the following essential elements:
    • A lamp assembly with a plurality of multi-colored lamps connected in series with each other and with an AC voltage source.
    • Each lamp comprises a first illuminating element for a first color and a second illuminating element for a second color.
    • A lamp controller that varies the color by varying a "conduction interval" of each illuminating element according to a "predetermined pattern."
    • The controller is configured to "terminate the variation" when a user-operable input is activated.

U.S. Patent No. 8,390,206 - "Variable-effect lighting system"

The Invention Explained

  • Problem Addressed: As a continuation of the ’275 Patent’s application, the ’206 Patent addresses the same limitations in prior art lighting systems (U.S. Patent No. 8,390,206, col. 1:16-col. 2:10).
  • The Patented Solution: This patent claims a system that actively adapts to fluctuations in the AC power source. The controller is configured to control the current draw of the illuminating elements and, crucially, to "adjust the current draw in accordance with the voltage frequency" ('206 Patent, Abstract). The specification explains that this is accomplished by measuring the time between zero-crossings of the AC signal to calculate the actual line frequency, which prevents the unpredictable visual displays that could result from assuming a fixed frequency like 60 Hz ('206 Patent, col. 11:58-col. 12:12).
  • Technical Importance: This frequency-adaptive control allows the lighting system to produce reliable and synchronized color effects even with unstable power sources or in different regions with different standard frequencies (e.g., 50 Hz vs. 60 Hz), enhancing product reliability and international applicability (’206 Patent, col. 12:4-12).

Key Claims at a Glance

  • The complaint alleges infringement of "exemplary claims" identified in an external chart (Exhibit 4), which was not filed with the complaint (Compl. ¶21). Independent claim 1 is representative and includes the following essential elements:
    • A lamp assembly with a plurality of multi-colored lamps in series with an AC voltage source that has a frequency.
    • Each lamp comprises first and second illuminating elements for producing two different colors.
    • A lamp controller that controls a "current draw" of each illuminating element.
    • The controller is configured to "adjust the current draw in accordance with the voltage frequency."

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" detailed in Exhibits 3 and 4, which were incorporated by reference but not provided with the pleading (Compl. ¶12, ¶21).

Functionality and Market Context

The complaint does not describe the functionality of the accused products beyond conclusory statements that they "practice the technology claimed" by the patents-in-suit (Compl. ¶17, ¶26). It alleges that Defendant has been "making, using, offering to sell, selling and/or importing" these products in the United States (Compl. ¶12, ¶21). No further details on the products' features, operation, or market positioning are provided in the complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim chart Exhibits 3 and 4, which are not available for analysis (Compl. ¶18, ¶27). The narrative allegations are summarized below. No probative visual evidence provided in complaint.

  • ’275 Patent Infringement Allegations Summary: Plaintiff alleges that the unspecified "Exemplary Defendant Products" directly infringe one or more claims of the ’275 Patent (Compl. ¶12). The complaint asserts that these products contain the necessary components to satisfy all claim elements, including a controller that varies color effects based on a predetermined pattern (Compl. ¶17).
  • ’206 Patent Infringement Allegations Summary: Plaintiff alleges that the same products directly infringe one or more claims of the ’206 Patent (Compl. ¶21). The core of this allegation is that the products contain a controller that practices the claimed technology of adjusting the lights' current draw based on the frequency of the AC voltage source (Compl. ¶26).
  • Identified Points of Contention:
    • Evidentiary Questions: The complaint's reliance on unfiled exhibits raises the primary question of what factual evidence Plaintiff possesses to support its claims. Discovery and reverse engineering will be necessary to determine if the accused products' circuitry and control logic perform the specific functions required by the claims.
    • Technical Questions (’206 Patent): A central technical dispute for the ’206 Patent may be whether the accused products’ controller performs simple synchronization with the AC power cycle's zero-crossings or if it executes the more complex, claimed function of actively measuring the "voltage frequency" and "adjust[ing] the current draw" accordingly.

V. Key Claim Terms for Construction

  • The Term: "conduction interval" (from ’275 Patent, Claim 1)
  • Context and Importance: This term defines the fundamental mechanism of control in the ’275 Patent. The scope of this term will be critical to determining whether the accused products' method of controlling their light elements infringes.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the effect of varying the "conduction interval" as changing the "period of time each cycle during which the red LED 14a illuminates" versus the green LED 14b, suggesting the term could encompass any method of time-based power modulation for each element within an AC cycle ('275 Patent, col. 6:31-36).
    • Evidence for a Narrower Interpretation: The preferred embodiment discloses a specific method where a microcontroller "delays a predetermined period" after a zero-crossing before issuing a pulse to a bidirectional switch, a form of phase control ('275 Patent, col. 6:9-13). A defendant may argue that "conduction interval" should be construed as being limited to this disclosed phase-delay mechanism.
  • The Term: "adjust the current draw in accordance with the voltage frequency" (from ’206 Patent, Claim 1)
  • Context and Importance: This phrase is the central feature of the ’206 Patent's asserted independent claim and the key distinction from the parent ’275 Patent. Infringement will likely depend entirely on whether the accused products perform this specific function.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A plaintiff might argue this language covers any system whose design inherently compensates for or is robust to changes in AC frequency, thereby "adjusting" its operation by design.
    • Evidence for a Narrower Interpretation: The specification provides a very specific definition for this function: the algorithm "measures the period of time between instances of zero voltage crossings of the AC source voltage, and uses the calculated period to calculate the line frequency" to then determine the correct conduction intervals ('206 Patent, col. 12:4-12). This language strongly supports a narrower construction requiring an active measurement and calculation process, not just passive synchronization.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for both patents, asserting that Defendant provides "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶15, ¶24). Knowledge is alleged "at least since being served by this Complaint" (Compl. ¶16, ¶25).
  • Willful Infringement: The complaint does not use the term "willful," but it alleges that Defendant continues to infringe despite having "actual knowledge" of the patents from the service of the complaint (Compl. ¶15, ¶24). This forms a basis for post-filing willful infringement and a request for enhanced damages under 35 U.S.C. § 284 (Compl. p. 6, ¶F).

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

  • A core issue will be one of evidentiary proof: Given the complaint’s lack of specific factual allegations regarding the accused products' operation, the case will depend on Plaintiff's ability to demonstrate through technical evidence that the products' internal hardware and software function in the precise manner required by the claims.
  • A key technical question will be one of functional distinction: For the ’206 Patent, the dispute may center on whether the accused products’ controller merely synchronizes its timing to the AC power cycle, a common technique, or whether it performs the specific and more sophisticated claimed step of measuring the line frequency and actively "adjust[ing] the current draw in accordance with" that measurement.