Dense Matrix LLC v. Oledcomm SAS

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dense Matrix LLC (New Mexico)
  • Defendant: Oledcomm SAS (France)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00816, E.D. Tex., 08/19/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation, and further alleges that Defendant has committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to solid-state lighting systems with integrated optical communication capabilities.
• Technical Context: The technology at issue involves integrating broadband data communication functions into standard LED lighting fixtures, enabling "smart building" applications where lighting systems can both illuminate and serve as nodes in an optical data network.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

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

U.S. Patent No. 9,826,597 - "Solid state light system with broadband optical communication capability"

• Patent Identification: U.S. Patent No. 9,826,597, "Solid state light system with broadband optical communication capability," issued November 21, 2017 (’597 Patent).

The Invention Explained

• Problem Addressed: The patent describes a need to create "smart buildings" where environmental systems like HVAC and lighting can be controlled automatically while also providing robust data communication, overcoming the limitations of separate, independent systems (’597 Patent, col. 2:39-44). Conventional building systems operate independently, and wireless technologies like Wi-Fi have coverage limitations (’597 Patent, col. 1:12-43).
• The Patented Solution: The invention proposes a system integrated into a conventional light bulb or tube form factor, using Light Emitting Diodes (LEDs) for both illumination and data transmission (’597 Patent, col. 2:45-54). The system includes an optical transceiver, such as a multiband-type ultra-wideband (UWB) transceiver, coupled to the LEDs and a controller. This allows the light fixture to adjust its light output while simultaneously communicating over a broadband optical network, effectively turning the lighting infrastructure into a data network (’597 Patent, Abstract; Fig. 5).
• Technical Importance: This approach seeks to leverage ubiquitous lighting infrastructure to create a pervasive, high-speed data network within a building, simplifying the retrofitting of existing spaces for "smart" functionality and data connectivity (’597 Patent, col. 4:4-14).

Key Claims at a Glance

• The complaint asserts "one or more claims" and refers to "Exemplary '597 Patent Claims" but does not specify which claims are asserted (Compl. ¶¶ 11, 16). The analysis below focuses on the patent’s first independent claim.
• Independent Claim 1:
  • A system for use in conjunction with a standardized electrical connector of a conventional light bulb or tube, comprising:
  • one or more light emitting diodes (LEDs) electrically coupled to at least one electrical connector compatible with a conventional light connector and an optical transceiver with at least one transmitter and receiver,
  • wherein at least one of the LEDs is associated with a predetermined geographical position and optically coupled to a broadband optical network greater than 1 Mbps;
  • a controller coupled to the LEDs, the controller adjusting LED light output and communicating with the transmitter and receiver over the broadband optical network; and
  • a mobile device proximal to a user or object receiving light from the LED to receive the geographical position data and to provide information over the broadband optical network about a nearby user or object.
• 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 or model number. It refers generally to "Exemplary Defendant Products" and other "numerous other devices" made, used, sold, or imported by Defendant (Compl. ¶11).

Functionality and Market Context

• The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '597 Patent" (Compl. ¶16). It further alleges that Defendant distributes "product literature and website materials" related to these products (Compl. ¶14). The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market positioning.
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or detailed, element-by-element infringement allegations in its body. Instead, it incorporates by reference the allegations from an "Exhibit 2," which was not publicly filed with the complaint (Compl. ¶¶ 16, 17).

The complaint’s narrative infringement theory asserts that the "Exemplary Defendant Products incorporated in these charts satisfy all elements of the Exemplary '597 Patent Claims" either literally or under the doctrine of equivalents (Compl. ¶¶ 11, 16). The complaint also alleges direct infringement through Defendant's internal testing and use of the products (Compl. ¶12). Without access to the referenced claim charts, a detailed analysis of the infringement theory is not possible.

• Identified Points of Contention:
  • Evidentiary Questions: A primary issue will be whether Plaintiff can produce evidence demonstrating that the unspecified "Exemplary Defendant Products" perform each and every function recited in the asserted claims. The complaint’s conclusory allegations will require substantial factual support during discovery.
  • Technical Questions: Given the claims’ focus on a "broadband optical network" and communication of a "predetermined geographical position," a key technical question will be whether Defendant's products, in fact, create such a network and transmit such data, as opposed to providing simpler, non-networked lighting control.

V. Key Claim Terms for Construction

"broadband optical network"

• Context and Importance: This term is central to defining the required capability of the claimed system. The scope of "broadband" (defined in the claim as "greater than 1 Mbps") and "optical network" will be critical to determining if the accused products, which may perform some form of optical communication, rise to the level of the claimed invention. Practitioners may focus on this term because Defendant may argue its products use a simpler, lower-speed communication protocol that does not constitute a "broadband... network."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discusses various communication protocols in the context of the invention, including "WiFi, cable modem, or DSL transmission speed" as examples of broadband, and mentions tunneling protocols like BACnet over the optical link, which could suggest that any optical link capable of carrying such data protocols qualifies (’597 Patent, col. 7:27-30; col. 8:25-27).
  • Evidence for a Narrower Interpretation: The specification repeatedly discusses the system in the context of "smart building" control and UWB transceivers, suggesting the "network" may need to be a cohesive, multi-node system for building automation, not merely a point-to-point communication link (’597 Patent, col. 2:45-54; col. 4:1-2).

"predetermined geographical position"

• Context and Importance: This limitation requires that the LED system be associated with and transmit location data. The case may turn on whether the accused products are configured with such specific position data and whether they transmit it for use by a mobile device as claimed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 3, which depends from Claim 1, states that "each light bulb stores positioning or location information to uniquely identify a position of an occupant," which could imply that any unique identifier that allows for location determination within a building map would suffice (’597 Patent, col. 30:2-4).
  • Evidence for a Narrower Interpretation: The language suggests a fixed, "predetermined" position, akin to a GPS coordinate or a specific room number, rather than a dynamic or relative position. Defendant may argue its products lack any such pre-configured geographical data. The patent states the invention "can locate a person immediately, even in a large area... and can keep track of a large population simultaneously," which may suggest a requirement for precise, absolute, or grid-based positioning data (’597 Patent, col. 24:3-6).

VI. Other Allegations

• Indirect Infringement: Plaintiff alleges induced infringement, asserting that Defendant distributes "product literature and website materials" that actively and intentionally direct end-users to use the accused products in an infringing manner (Compl. ¶¶ 14, 15).
• Willful Infringement: The complaint does not allege pre-suit knowledge or willful infringement. It alleges that "service of this Complaint... constitutes actual knowledge of infringement," which may form the basis for a claim of post-filing willful infringement and enhanced damages under 35 U.S.C. § 284 (Compl. ¶13).

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

This dispute, as framed in the complaint, will likely center on two fundamental questions for the court:

1. A core issue will be one of evidentiary proof: Can the plaintiff substantiate its broad allegations by demonstrating, with technical evidence, that Oledcomm’s unspecified products actually perform the specific functions of a "broadband optical network" and transmit a "predetermined geographical position" as required by the asserted claims?
2. A secondary question will be one of definitional scope: How should the term "broadband optical network" be construed? The resolution will depend on whether the term requires a complex, multi-node building automation network as described in the patent's embodiments, or if it can be read more broadly to cover any optical data link exceeding 1 Mbps.