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., 11/14/2025
• Venue Allegations: Venue is alleged to be proper as Defendant is a foreign corporation and may be sued in any judicial district. The complaint also alleges Defendant has significant ties to the district, including sales of accused products and solicitation of employees.
• Core Dispute: Plaintiff alleges that Defendant’s LED area and street lighting products infringe four patents related to optical systems for achieving uniform illumination and maintaining performance despite individual LED failures.
• Technical Context: The technology concerns high-power LED luminaires for large-scale outdoor lighting, focusing on optical lens design to distribute light evenly from an off-center source and manage thermal output.
• Key Procedural History: This First Amended Complaint follows an original complaint. The complaint notes that attorneys from the same law firms have previously represented both LEDVANCE GmbH and its U.S. subsidiary, LEDVANCE LLC, in prior patent litigation.

Case Timeline

Date	Event
2012-07-30	Earliest Patent Priority Date for all Patents-in-Suit
2017-03-07	U.S. Patent No. 9,589,488 Issued
2017-05-23	U.S. Patent No. 9,659,511 Issued
2017-06-20	U.S. Patent No. 9,685,102 Issued
2021-01-12	U.S. Patent No. 10,891,881 Issued
2022-06-24	Shipment of "Lighting Materials" from LEDVANCE GmbH to LEDVANCE LLC
2025-08-26	Date of original complaint filing mentioned in willfulness allegations
2025-10-07	Date of press release regarding Accused Products
2025-11-14	First Amended Complaint Filing Date

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

U.S. Patent No. 10,891,881 - "LIGHTING ASSEMBLY WITH LEDS AND OPTICAL ELEMENTS" (Issued Jan. 12, 2021)

The Invention Explained

• Problem Addressed: The patent's background describes the difficulty of using LED fixtures to evenly illuminate large, rectangular surfaces like billboards, particularly from an off-center mounting position. Conventional approaches can create undesirable "hot spots," waste light by spilling it beyond the target area (light pollution), and suffer from performance degradation when individual LEDs fail (’881 Patent, col. 4:1-12). Additional problems addressed include heat dissipation and protecting LEDs from environmental factors like moisture (’881 Patent, col. 4:13-18).
• The Patented Solution: The invention is a lighting apparatus comprising an array of LEDs on a circuit board, which is mounted on a thermally conductive support substrate. Over this array is a corresponding array of optical elements (lenses), with each LED associated with a single, substantially identical optical element. These optical elements are specifically configured to shape and redirect light into a uniform, rectangular waveform that illuminates an off-center target surface. A key aspect of the design is that the failure of one or more LEDs will decrease the overall illumination level, but the uniformity of the light across the target surface will remain "substantially the same." (’881 Patent, Abstract; col. 6:25-48).
• Technical Importance: The technology aimed to create more reliable and efficient large-area LED lighting systems that deliver consistent illumination quality over the product's lifespan, even with partial component failure.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶56).
• Claim 1 (Apparatus) requires:
  • A circuit board.
  • A plurality of LEDs attached to the circuit board in an array of rows and columns, with all LEDs arranged in a single plane.
  • A support substrate made of a thermally conductive material, supporting the circuit board and configured to dissipate heat.
  • A plurality of optical elements configured to redirect light, with each element being substantially the same and configured to shape light in a rectangular waveform.
  • Each LED is associated with a single optical element, and each element has a convex portion at least partially overlying the LED.
  • The optical elements are part of an outer, exposed surface of the apparatus.
  • The apparatus is configured so that when all LEDs are operating, a substantially rectangular, off-center surface is illuminated with a specific "illumination level and a uniformity."
  • The apparatus is configured such that the failure of one or more LEDs causes the illumination level to decrease while the "uniformity of light... remains substantially the same."

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: Similar to the other patents in the family, this patent addresses the challenge of providing consistent, uniform illumination for large areas from an array of LEDs, and ensuring the light pattern remains stable even when some LEDs in the array fail (’102 Patent, col. 3:12-21, 4:2-13).
• The Patented Solution: The patent claims a method of illuminating an area using a light assembly. The method involves directing light from an array of LEDs through specially designed optical elements. Each optical element is described as having three distinct functional parts: a "first element," a "second element," and a "third element." The geometry is defined by the intersection of these elements and their surface normals, and the third element extends away from the LED. This configuration directs light from each optical element "across the area" and is designed to maintain overall light distribution if some LEDs become inoperative. (’102 Patent, Abstract; col. 9:26-62).
• Technical Importance: This patent focuses on the specific method of using a multi-part lens geometry to achieve a resilient and uniform light distribution pattern for large-scale applications.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶73).
• Claim 1 (Method) requires:
  • Illuminating an area using a light assembly with LEDs and associated optical elements.
  • A step of "directing light away from the plurality of LEDs toward the area," such that light from each optical element is directed "across the area."
  • Each optical element includes a "first element," a "second element that intersects with the first element," and a "third element extending beyond" the intersection region.
  • The first and second elements are shaped so that "at least one surface normal of the first element intersect with at least one surface normal of the second element."
  • If some LEDs fail, the method includes the step of "directing the light from operative ones" of the LEDs toward the area such that light from each operative LED is directed across the area.

U.S. Patent No. 9,589,488 - "LED LIGHT ASSEMBLY WITH THREE-PART LENS" (Issued March 7, 2017)

• Technology Synopsis: This patent claims a method of illuminating an area. The method utilizes an optical element with three parts: a first element with a first convex surface, a second element with a second convex surface that intersects the first at an acute angle, and a third element extending away from the LED. This geometry is designed to ensure light from the associated LED exits through both the first and second convex surfaces to illuminate the target area. (’488 Patent, Abstract; col. 9:8-40).
• Asserted Claims: At least Claim 1 (Compl. ¶91).
• Accused Features: The complaint alleges that Defendant’s AREAFLD product performs the claimed method by using optical elements with the specified three-part, dual-convex-surface structure (Compl. ¶¶92-94).

U.S. Patent No. 9,659,511 - "LED LIGHT ASSEMBLY HAVING THREE-PART OPTICAL ELEMENTS" (Issued May 23, 2017)

• Technology Synopsis: This patent claims an apparatus comprising a lighting assembly with a plurality of separate optical elements, each having three portions. The invention is defined by the geometry of these portions, including a first portion with a first curved surface and a second portion with a second curved surface that intersects the first. The shape is further defined such that a surface normal of the first portion intersects a surface normal of the second portion, and a third portion extends away from the LED. (’511 Patent, Abstract; col. 9:44-col. 10:9).
• Asserted Claims: At least Claim 1 (Compl. ¶108).
• Accused Features: The complaint accuses the AREAFLD product of being an apparatus that embodies the claimed three-part optical element structure (Compl. ¶¶109-114).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products as various LED lighting fixtures, with a primary focus on the "Value Class Wattage Selectable Area Lights," exemplified by the "AREAFLD" product line (e.g., AREAFLD5AS300UNHD840T4BZ). Other accused product families include "Performance Class OPTI-SELECT Area Lights," "Streetlight Flex Luminaires," and "Performance Class OPTI-SELECT Cut Off Wall Pack." (Compl. ¶41).

Functionality and Market Context

The accused products are outdoor LED luminaires sold for area and street lighting applications under the LEDVANCE and SYLVANIA brands (Compl. ¶¶9, 46). The complaint provides teardown photographs indicating that the AREAFLD product contains a circuit board with an array of LEDs, a thermally conductive support substrate, and a molded lens panel with an array of individual optical elements positioned over the LEDs (Compl. ¶42, p. 33). The complaint also includes a photometric chart for a "300W Fixture, Type IV Distribution," which allegedly corresponds to an accused product and illustrates the creation of an off-center, rectangular illumination pattern (Compl. ¶42, p. 34). This chart shows the light distribution for a fixture mounted at a 35-foot height (Compl. p. 34).

IV. Analysis of Infringement Allegations

'881 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a circuit board;	The AREAFLD product contains a circuit board on which LEDs are mounted.	¶58, p. 33	col. 5:40-41
a plurality of light emitting diodes (LEDs) attached to the circuit board, the LEDs being arranged in an array of row and columns, wherein all of the LEDs attached to the circuit board are arranged in a single plane;	The product's circuit board contains multiple LEDs arranged in a grid pattern on a flat plane. An annotated photograph shows this array (Compl. p. 33).	¶58, p. 33	col. 5:40-47
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 thermally conductive support substrate that holds the circuit board and functions as a heat sink.	¶58, p. 33	col. 5:48-52
a plurality of optical elements configured to redirect light from the plurality of LEDs, 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 has a lens panel with multiple, repeating optical elements. A photometric chart is provided to show the product generates a rectangular "Type IV Distribution" light pattern (Compl. p. 34).	¶58, p. 34	col. 5:53-59
...wherein each optical element comprises a convex portion at least partially overlying the associated LED, and wherein the optical elements are part of an outer surface that forms an exposed surface of the lighting apparatus;	Annotated photographs show each optical element having a convex shape over an LED and forming the external face of the light fixture. The complaint shows the lens array as the outer exposed surface of the apparatus (Compl. p. 35).	¶58, pp. 34-35	col. 5:60-65
wherein the lighting apparatus is configured so that when all of the LEDs are operating a substantially rectangular surface that is off-center relative to the lighting apparatus is illuminated with an illumination level and a uniformity;	The provided photometric chart for the accused product allegedly demonstrates the creation of a substantially rectangular, off-center illumination pattern.	¶59, p. 34	col. 6:25-32
and wherein failure of one or more of the LEDs will cause the illumination level of light impinging the substantially rectangular surface to decrease while the uniformity of light impinging the substantially rectangular surface remains substantially the same.	The complaint alleges this functional result, supported by a diagram illustrating how light from remaining LEDs continues to cover the target area after a failure.	¶60, p. 35	col. 6:32-37

'102 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method of illuminating an area using a light assembly that includes a plurality of light emitting diodes (LEDs) and a plurality of optical elements...	The operation of the AREAFLD product, which contains LEDs and optical elements, is alleged to perform the claimed method.	¶74, p. 37	col. 9:26-31
...directing light away from the plurality of LEDs toward the area, wherein directing the light comprises directing the light such that light exiting from each optical element is directed across the area.	The product's optical elements allegedly direct light from each individual LED to cover the entire target area, as illustrated in a photometric chart and a light-ray diagram (Compl. p. 38).	¶75, p. 38	col. 9:32-35
...wherein each optical element includes: a first element; a second element that intersects with the first element in a region between the first element and the second element...	Annotated photographs of the accused product's lens are used to identify distinct "first" and "second" elements and the region where they allegedly intersect (Compl. p. 39).	¶76, p. 39	col. 9:36-40
...wherein the first element and the second element are shaped so that at least one surface normal of the first element intersect with at least one surface normal of the second element;	An annotated photograph purports to show that the shapes of the identified "first" and "second" elements cause their surface normals to intersect.	¶76, p. 39	col. 9:40-44
and a third element extending beyond the region between the first element and the second element in a direction away from the associated LED.	An annotated photograph identifies a "third element" on the accused product's lens that allegedly extends away from the LED beyond the intersection of the first two elements.	¶76, p. 40	col. 9:44-48
and wherein if some of the LEDs fail to operate during directing the light..., the step of directing the light comprises directing the light from operative ones of the plurality of LEDs toward the area such that the light from each operative LED is directed across the area.	The complaint alleges that the design of the optical elements ensures that light from the remaining functional LEDs continues to be directed across the entire area, maintaining coverage despite failures.	¶77, p. 41	col. 9:49-55

Identified Points of Contention

• Scope Questions: A central issue may be whether the single, continuous molded surface of the accused product's optical element can be said to include the distinct "first element," "second element," and "third element" as required by the claims of the ’102, ’488, and ’511 patents. The dispute will likely focus on whether these are merely descriptive labels for different regions of a lens or if they require distinct structural features that the accused product may lack.
• Technical Questions: A key factual question for the '881 Patent will be whether the accused product's illumination "uniformity... remains substantially the same" after one or more LEDs fail. This functional limitation suggests a need for empirical evidence and expert testimony to compare the product's performance against the standard set by the claim language and the patent specification, which discloses a target uniformity ratio (’881 Patent, col. 6:35-42).

V. Key Claim Terms for Construction

The Term: "uniformity of light impinging the substantially rectangular surface remains substantially the same" (’881 Patent, Claim 1)

• Context and Importance: This term defines a required functional outcome of the apparatus when LEDs fail. Its construction is critical because infringement depends on a performance characteristic, not just structure. Practitioners may focus on this term because its inherent ambiguity ("substantially the same") invites dispute over the required degree of performance and how it should be measured.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not set a specific numerical threshold, which may support a construction that only requires the general character of the light distribution to be preserved, without a strict mathematical constraint.
  • Evidence for a Narrower Interpretation: The specification states, "What is meant by 'evenly' is that the illumination with a uniformity that achieves a 3:1 ratio of the average illumination to the minimum." (’881 Patent, col. 6:35-37). A party could argue that "substantially the same" uniformity requires maintaining a value at or near this 3:1 ratio post-failure.

The Term: "a first element," "a second element," "a third element" (e.g., ’102 Patent, Claim 1)

• Context and Importance: These terms describe the constituent parts of a single optical element. Because the accused product's optical element is a single piece of molded material, the boundaries between these "elements" are not physically separate. The definition of these terms will determine whether the claim language can be mapped onto the accused product's structure.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification and the complaint's annotated figures (Compl. pp. 39-40) treat these as contiguous regions on a single lens surface, suggesting that "element" can refer to a functional portion of a monolithic structure rather than a discrete component.
  • Evidence for a Narrower Interpretation: The patent figures (e.g., ’488 Patent, Figs. 8D-8G) depict these "elements" with relatively clear edges and distinct surface curvatures. A party may argue that these depictions define specific structural characteristics and boundaries that must be present, and that the accused lens, if shaped differently, does not meet the limitation.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement. Inducement allegations are based on Defendant’s alleged acts of selling the Accused Products to customers, installers, and distributors with the knowledge and intent that they will be used in an infringing manner. These acts allegedly include creating marketing materials, providing user manuals and technical support, and managing U.S. distribution channels (Compl. ¶¶62-67, 80-85).

Willful Infringement

The complaint alleges willful infringement based on Defendant's alleged knowledge of the patents-in-suit. This knowledge is asserted to have arisen from Plaintiff's marking of its own patented products, and has allegedly continued post-suit (Compl. ¶¶40, 61, 68). The complaint alleges an objectively high likelihood of infringement that Defendant disregarded.

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

• A core issue will be one of structural interpretation: can the claimed multi-part "elements" of the asserted optical lens claims, which describe distinct geometric and functional regions, be construed to read on the continuous, monolithic surfaces of the accused product's lenses? The case may turn on whether the patent's language requires distinct structural boundaries or simply describes functional zones on a single surface.
• A second central issue will be one of functional performance: does the accused product's lighting system, upon partial LED failure, demonstrate that the "uniformity of light... remains substantially the same," as required by Claim 1 of the '881 patent? The resolution of this question will likely depend on expert testing and a judicial determination of the quantitative meaning of "substantially the same" in the context of the patent's specification.