Ultravision Tech LLC v. Ledvance GmbH

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ultravision Technologies, LLC (Delaware)
  • Defendant: Ledvance GmbH (Germany)
  • Plaintiff’s Counsel: BRAGALONE OLEJKO SAAD PC
• Case Identification: 2:25-cv-00874, E.D. Tex., 08/26/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign entity not resident in the United States and may therefore be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s LED area and street lighting products infringe four U.S. patents related to the design of LED assemblies and optical elements for achieving uniform, reliable illumination over large surfaces.
• Technical Context: The technology relates to high-intensity LED lighting for large-scale applications like billboards and streetlights, where achieving even light distribution from an off-center source while managing heat and ensuring durability presents significant technical challenges.
• Key Procedural History: The complaint does not reference prior litigation between the parties, Inter Partes Review proceedings, or licensing history. Plaintiff states that it marks its products in accordance with patent marking statutes.

Case Timeline

Date	Event
2012-07-30	Earliest Priority Date ('881, '102, '488, '511 Patents)
2017-03-07	U.S. Patent No. 9,589,488 Issues
2017-05-23	U.S. Patent No. 9,659,511 Issues
2017-06-20	U.S. Patent No. 9,685,102 Issues
2021-01-12	U.S. Patent No. 10,891,881 Issues
2025-08-26	Complaint Filed

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

U.S. Patent No. 10,891,881 - "LIGHTING ASSEMBLY WITH LEDS AND OPTICAL ELEMENTS"

• Patent Identification: U.S. Patent No. 10,891,881, "LIGHTING ASSEMBLY WITH LEDS AND OPTICAL ELEMENTS," issued January 12, 2021.

The Invention Explained

• Problem Addressed: The patent background describes the difficulty of evenly illuminating large surfaces like billboards from an off-center position using LEDs, which can create undesirable "hot spots," waste light (light pollution), and suffer from reliability issues due to heat and moisture exposure in outdoor environments (’881 Patent, col. 3:55-61; col. 4:11-21).
• The Patented Solution: The invention is a lighting apparatus comprising an array of LEDs on a circuit board, a thermally conductive substrate for heat dissipation, and a plurality of optical elements (lenses) (’881 Patent, Abstract). Each optical element is designed to be "substantially the same" and redirects light from its associated LED to cover the entire off-center target area, creating a uniform "rectangular waveform" of light. This design ensures that if one or more LEDs fail, the overall brightness decreases, but the uniformity of the light pattern across the target surface is maintained (’881 Patent, col. 6:22-31).
• Technical Importance: This approach provided a robust solution for large-area lighting by creating redundancy at the individual light-source level, ensuring that the failure of some LEDs does not compromise the quality of the overall illumination pattern.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶31).
• Claim 1 of the ’881 Patent recites the following essential elements:
  • A lighting apparatus with a circuit board, a plurality of LEDs in a planar array, and a thermally conductive support substrate.
  • A plurality of optical elements, each being "substantially the same" and configured to create a "rectangular waveform."
  • Each LED is associated with a single optical element, which has a convex portion overlying the LED.
  • The apparatus is configured to illuminate a "substantially rectangular surface that is off-center" with uniformity.
  • Functionally, failure of one or more LEDs causes the illumination level to decrease while the uniformity "remains substantially the same."
• The complaint does not explicitly reserve the right to assert dependent claims, though this is common practice.

U.S. Patent No. 9,685,102 - "LED LIGHTING ASSEMBLY WITH UNIFORM OUTPUT INDEPENDENT OF NUMBER OF NUMBER OF ACTIVE LEDS, AND METHOD"

• Patent Identification: U.S. Patent No. 9,685,102, "LED LIGHTING ASSEMBLY WITH UNIFORM OUTPUT INDEPENDENT OF NUMBER OF NUMBER OF ACTIVE LEDS, AND METHOD," issued June 20, 2017.

The Invention Explained

• Problem Addressed: The complaint does not provide the background section of the patent, but the title and asserted claims suggest the patent addresses the problem of maintaining a uniform light distribution pattern from an LED array even when individual LEDs fail.
• The Patented Solution: The patent claims a method of illuminating an area using a light assembly where each optical element has a specific three-part structure (Compl. ¶48). This structure is defined by the geometric relationship between a "first element," a "second element that intersects with the first," and a "third element extending beyond" them. This specialized geometry directs light from each individual LED "across the area," ensuring that if some LEDs fail, light from the remaining operative LEDs continues to cover the entire target area uniformly (Compl. ¶¶47, 49).
• Technical Importance: This claimed method provides a design for highly reliable lighting systems where the specified illumination pattern is preserved throughout the product’s operational life, despite individual component failures.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶45).
• Claim 1 of the ’102 Patent, as described in the complaint, recites the following essential method steps:
  • Illuminating an area using a light assembly with LEDs and associated optical elements.
  • Directing light from the LEDs toward the area such that light from each optical element is "directed across the area."
  • Each optical element comprises a specific three-part structure: a first element, an intersecting second element (with intersecting surface normals), and an extending third element.
  • If some LEDs fail, the method includes directing light from the "operative ones" of the LEDs toward the area such that light from each is directed across the area.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,589,488 - "LED LIGHT ASSEMBLY WITH THREE-PART LENS"

• Patent Identification: U.S. Patent No. 9,589,488, "LED LIGHT ASSEMBLY WITH THREE-PART LENS," issued March 7, 2017 (Compl. ¶20).
• Technology Synopsis: This patent claims a method of illuminating an area using a light assembly whose optical elements have a specific three-part geometry. The structure is defined by a "first convex-shaped surface" and a "second convex-shaped surface that intersects with the first... at an acute angle," along with a "third element extending beyond" the first two. This geometry allegedly ensures light from the LED exits through both convex surfaces to properly illuminate the target area (Compl. ¶¶61-63).
• Asserted Claims: At least claim 1 (Compl. ¶60).
• Accused Features: The complaint alleges that the use of Defendant's AREAFLD product performs the claimed method, accusing the product's optical elements of having the claimed three-part structure with intersecting convex surfaces (Compl. ¶63).

U.S. Patent No. 9,659,511 - "LED LIGHT ASSEMBLY HAVING THREE-PART OPTICAL ELEMENTS"

• Patent Identification: U.S. Patent No. 9,659,511, "LED LIGHT ASSEMBLY HAVING THREE-PART OPTICAL ELEMENTS," issued May 23, 2017 (Compl. ¶21).
• Technology Synopsis: This patent claims an apparatus comprising a lighting assembly with a three-part optical element. The structure is defined by a "first portion," "second portion," and "third portion," with specific geometric requirements, including that their curved surfaces intersect and are "shaped so that at least one surface normal of the first portion... intersects with at least one surface normal of the second portion." The claimed arrangement is alleged to prevent "hot spots or... dead spots" as long as some LEDs are functional (Compl. ¶¶76-80).
• Asserted Claims: At least claim 1 (Compl. ¶74).
• Accused Features: The complaint accuses Defendant's AREAFLD product of being an apparatus that embodies the claimed lighting assembly, including the specific three-part optical element structure (Compl. ¶¶75-76).

III. The Accused Instrumentality

Product Identification

• The complaint names several product lines, including Defendant's Value Class Wattage Selectable Area Lights ("AREAFLD"), Performance Class OPTI-SELECT Area Lights, Performance Class Dual Selectable Area Lights, and Streetlight Flex Luminaires (Compl. ¶24). The infringement analysis focuses primarily on the AREAFLD product.

Functionality and Market Context

• The Accused Products are described as LED-based outdoor area and street lighting fixtures (Compl. ¶6). The complaint includes teardown photographs of the AREAFLD product, showing it comprises a housing, a thermally conductive substrate, a circuit board with an array of LEDs, and a corresponding array of optical elements (lenses) to direct the light (Compl. ¶25, p. 15). An included photometric chart for a 300W fixture depicts a "Type IV Distribution," which is a standard industry pattern for directing light forward and laterally, suitable for illuminating roadways and parking areas from a side-mounted position (Compl. ¶25, p. 16). This chart shows the product is designed to create an off-center, substantially rectangular illumination pattern.

IV. Analysis of Infringement Allegations

The provided documents do not include U.S. Patent Nos. 9,685,102, 9,589,488, or 9,589,511; therefore, patent citations for those patents cannot be supplied.

’881 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a circuit board; a plurality of light emitting diodes (LEDs) attached to the circuit board... arranged in an array... in a single plane;	The AREAFLD product contains a circuit board with LEDs arranged in a planar array of rows and columns. A photograph shows this internal construction (Compl. ¶25, p. 15).	¶33	col. 4:33-35
a support substrate supporting the circuit board, the support structure made of a thermally conductive material and configured to dissipate heat...	The product includes a support substrate made of a thermally conductive material for heat dissipation, visible in a teardown photograph (Compl. ¶25, p. 15).	¶33	col. 4:36-39
a plurality of optical elements... each optical element being substantially the same as all other optical elements and configured to shape and direct light in a rectangular waveform...	The product uses multiple, seemingly identical optical elements to create an off-center, rectangular illumination pattern, as illustrated by an industry-standard photometric chart (Compl. ¶25, p. 16).	¶33	col. 6:8-13
wherein each optical element comprises a convex portion at least partially overlying the associated LED...	Photographs show each optical element has a convex portion positioned over its corresponding LED (Compl. ¶25, p. 16).	¶33	col. 5:56-58
wherein the lighting apparatus is configured so that when all of the LEDs are operating a substantially rectangular surface that is off-center... is illuminated with... uniformity;	The product's photometric distribution chart allegedly demonstrates its configuration to illuminate an off-center rectangular surface with uniformity (Compl. ¶25, p. 16).	¶34	col. 6:22-26
and wherein failure of one or more of the LEDs will cause the illumination level... to decrease while the uniformity... remains substantially the same.	The complaint alleges this functional outcome, supported by a diagram illustrating how light from each LED is spread across the entire target surface (Compl. ¶25, p. 17).	¶35	col. 6:27-31

• Identified Points of Contention:
  • Scope Questions: A potential dispute may arise over whether the photometric pattern produced by the accused product meets the claim term "rectangular waveform."
  • Technical Questions: A key evidentiary question will be whether the accused product meets the functional limitation that uniformity "remains substantially the same" upon LED failure. The complaint provides an illustrative diagram, but this operational characteristic would likely require testing and expert analysis to prove or disprove.

’102 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
...directing light... such that light exiting from each optical element is directed across the area.	The complaint alleges the product's optical elements direct light from each LED across the entire target area, supported by diagrams of the light distribution (Compl. ¶26, p. 20).	¶47	N/A
...each optical element includes: a first element; a second element that intersects with the first element... wherein... at least one surface normal of the first element intersect with at least one surface normal of the second element...	The complaint provides annotated close-up photographs of the accused optical element purporting to identify distinct "first" and "second" elements that intersect as claimed (Compl. ¶26, p. 21).	¶48	N/A
...and a third element extending beyond the region between the first and second element in a direction away from the associated LED.	Annotated photographs are also provided to show a "third element" extending away from the LED as described in the claim (Compl. ¶26, p. 22).	¶48	N/A
...if some of the LEDs... fail to operate... directing the light from operative ones... such that the light from each operative LED is directed across the area.	This functional result is alleged and supported by a diagram showing that the light pattern is maintained by the remaining operative LEDs (Compl. ¶26, p. 23).	¶49	N/A

• Identified Points of Contention:
  • Scope Questions: The central dispute will likely concern claim construction of the terms "first element," "second element," and "third element." The parties may contest whether these terms require physically separate components or can read on different surfaces of a single monolithic lens.
  • Technical Questions: A factual question will be whether the accused product's physical lens geometry, as depicted in the complaint's photographs, actually satisfies the claimed structural and geometric relationships (e.g., "intersecting surface normals").

V. Key Claim Terms for Construction

• The Term: "substantially the same" (’881 Patent, Claim 1)

• Context and Importance: This term describes the relationship between the individual optical elements in the array. Its construction is critical because if Defendant's optical elements have intentional variations (e.g., different lens shapes for edge vs. center LEDs to optimize the beam), it may argue they are not "substantially the same," thereby avoiding infringement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent's overall goal is to create a uniform illumination pattern from an array of sources (’881 Patent, col. 6:22-31). Language throughout the specification may support an interpretation where minor manufacturing variations or slight design differences that do not defeat this overall purpose still fall within the scope of "substantially the same."
  • Evidence for a Narrower Interpretation: The patent repeatedly emphasizes this feature in the abstract and claims, suggesting its importance. Specific embodiments, such as Figure 5C showing identical lens structures (522), could be used to argue that the term implies near-identicality and does not cover intentionally varied designs.

• The Term: "first element," "second element," "third element" (’102 Patent, Claim 1)

• Context and Importance: These terms define the specific three-part structure of the optical element required by the method claim. The infringement analysis hinges on whether the accused lens can be mapped to these three distinct structural limitations.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The complaint's annotated photographs suggest these "elements" are different surfaces or regions of a single, monolithic piece of plastic (Compl. ¶26, pp. 21-22). Plaintiff will likely argue that the patent's specification defines these elements in terms of their geometry and function, not as requiring separate physical components.
  • Evidence for a Narrower Interpretation: A defendant may argue that the term "element" implies a more distinct structural identity than merely a different contoured surface on a single lens. The patent's description of these elements "intersecting" might be argued to require a clearer demarcation than what is present in the accused product.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for all four patents, asserting that Defendant actively encourages infringement by supplying the accused products to customers, installers, and distributors with knowledge and intent that they will be used in an infringing manner (e.g., Compl. ¶¶36-37, 51-52, 65-66, 81-82). For the method patents (’102 and ’488), the complaint also alleges there are "no substantial non-infringing uses," which could support a claim for contributory infringement (Compl. ¶¶50, 64).
• Willful Infringement: Willfulness is pleaded based on alleged "knowledge and intent, or with willful blindness" (Compl. ¶38). The complaint specifically alleges knowledge "At least as of the date of the filing of this Complaint," establishing a basis for post-suit willful infringement (Compl. ¶39).

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

• A core issue will be one of claim construction and structural mapping: can the various geometric features of the accused product's single-piece lens be fairly mapped onto the claimed "first element," "second element," and "third element" (or "portions") recited with specific intersecting relationships in the '102, '488, and '511 patents, or does this constitute an impermissible dissection of an integrated structure?
• A key evidentiary question will be one of functional performance: for the '881 patent, what technical evidence will be presented to prove or disprove that the uniformity of the accused product's illumination pattern "remains substantially the same" when one or more LEDs fail, as required by the functional language of the claim?