DCT

2:26-cv-00015

Fairlight Innovations LLC v. TCT Mobile Intl Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00015, E.D. Tex., 01/08/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendants conduct substantial business in the state and district, and the accused products are available for purchase there. The complaint also asserts that as foreign corporations, Defendants may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s LED, QLED, and QD-MINI LED televisions and displays infringe five U.S. patents related to the structure, manufacturing, and performance characteristics of light-emitting diodes (LEDs).
  • Technical Context: The technology at issue involves specific structural and material improvements to LEDs, which are the core components used in the backlights of modern high-performance consumer displays and televisions.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of U.S. Patent No. 7,626,209 based on a notice letter dated March 10, 2021. For the four other asserted patents, knowledge is alleged to have begun with the filing of the instant complaint.

Case Timeline

Date Event
2007-08-09 '181 & '895 Patents Priority Date
2007-12-18 '209 Patent Priority Date
2009-12-01 '921 Patent Priority Date
2009-12-01 '209 Patent Issue Date
2012-03-12 '395 Patent Priority Date
2012-08-07 '181 Patent Issue Date
2014-01-28 '895 Patent Issue Date
2014-04-01 '395 Patent Issue Date
2018-05-22 '921 Patent Issue Date
2021-03-10 Pre-suit notice letter sent regarding '209 Patent
2026-01-08 Complaint Filing Date

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

U.S. Patent No. 9,978,921 - “Light emitting device and method of manufacturing the same”

The Invention Explained

  • Problem Addressed: The complaint alleges that conventional LED packages faced several performance and reliability issues, including the ingress of foreign materials like moisture, short-circuiting between the package body and electrodes, poor heat dissipation from small electrode surface areas, and weak bonding strength between components (Compl. ¶26).
  • The Patented Solution: The invention claims to solve these problems through a novel LED package structure that includes a protective cap to prevent ingress of foreign materials, an insulating layer, modified electrode configurations to increase surface area, and various "coupling" features to secure the package body and electrodes more firmly ('921 Patent, Abstract; Compl. ¶26). The protective cap is described as projecting between the first and second electrodes to cover gaps and prevent moisture infiltration ('921 Patent, col. 4:60-65).
  • Technical Importance: The claimed features are directed at improving the physical robustness, thermal performance, and long-term reliability of packaged LEDs used in electronic devices (Compl. ¶26).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 ('921 Patent; Compl. ¶50).
  • Essential elements of Claim 1 include:
    • A body.
    • A first electrode and a separated second electrode, both within the body.
    • At least one light emitting chip on one of the electrodes.
    • A spacer in contact with both electrodes, having a first portion with a "gradually increasing width."
    • Each electrode including "two end portions" and "at least two holes" passing through it.
    • The electrodes having a "curved surface or a step structure at a plurality of corner regions."
    • The electrodes including a "recess with a curvature between the two end portions."
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,686,395 - “Bond type flip-chip light-emitting structure and method of manufacturing the same”

The Invention Explained

  • Problem Addressed: The patent's background describes conventional flip-chip LEDs as using tin balls to connect the LED to a substrate, which resulted in a small contact area, leading to poor heat dissipation and low light radiation efficiency ('395 Patent, col. 1:59-67). The complaint also notes issues of overly large negative electrodes, complex manufacturing, and high costs (Compl. ¶31).
  • The Patented Solution: The invention replaces the problematic tin balls with a "bonded metal layer" that increases the contact area between the LED chip and the substrate, thereby improving heat dissipation ('395 Patent, col. 2:19-22; Compl. ¶32). The patented structure also allows for an electrode pattern designed to reduce the negative electrode's area, which in turn increases the light-emitting area and improves device efficiency ('395 Patent, col. 5:56-62; Compl. ¶32).
  • Technical Importance: The invention purports to provide a more efficient and manufacturable flip-chip LED structure with superior thermal management compared to prior art designs (Compl. ¶32).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 ('395 Patent; Compl. ¶56).
  • Essential elements of Claim 1 include:
    • An epitaxy layer with n-type, multi-quantum-well, and p-type semiconductor layers.
    • A positive electrode on the p-type layer.
    • A negative electrode located on a "side wall" of the multi-quantum-well light-emitting layer.
    • An insulation layer on parts of the electrodes, exposing a via hole for each.
    • A "bonded metal layer" composed of a first and second insulated metal unit connected to the respective electrodes.
    • A substrate with metal layers for bonding to the bonded metal layer.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,626,209 - “Light emitting diode having active region of multi quantum well structure”

Technology Synopsis

The patent addresses carrier overflow and reduced luminous efficiency in conventional LEDs ('209 Patent, col. 2:13-29). The proposed solution is an active region with a multi-quantum well structure that includes a plurality of both relatively thick and relatively thin barrier layers, which is asserted to improve charge stability and light emission quality under various current conditions (Compl. ¶36; '209 Patent, col. 3:43-52).

Asserted Claims

Independent Claim 8 (Compl. ¶62).

Accused Features

The LED components within the accused televisions and displays are alleged to incorporate the claimed multi-quantum well structure (Compl. ¶¶2, 60).

U.S. Patent No. 8,237,181 - “Semiconductor light emitting device and method of manufacturing the same”

Technology Synopsis

The patent is directed to improving the optical characteristics of LEDs ('181 Patent, Abstract). The complaint alleges the invention achieves this by incorporating one or more "thin insulating layers" at various locations within the semiconductor to diffuse holes and improve the quantum efficiency of the active region (Compl. ¶40; '181 Patent, col. 5:34-40).

Asserted Claims

Independent Claim 1 (Compl. ¶68).

Accused Features

The LED components within the accused televisions are alleged to contain the claimed thin insulating layers (Compl. ¶¶2, 66).

U.S. Patent No. 8,637,895 - “Semiconductor light emitting device having a high resistive layer”

Technology Synopsis

Similar to the '181 Patent, this invention is directed at improving LED optical characteristics ('895 Patent, Abstract). The complaint alleges it does so by using a "high resistive layer" and thin insulating layers to diffuse holes throughout other semiconductor layers, thereby improving the quantum efficiency of the active region (Compl. ¶44; '895 Patent, col. 5:63-6:2).

Asserted Claims

Independent Claim 1 (Compl. ¶74).

Accused Features

The LED components within the accused televisions are alleged to contain the claimed high resistive and thin insulating layers (Compl. ¶¶2, 72).

III. The Accused Instrumentality

Product Identification

The accused products are identified as TCL's "LED, QLED, and QD-MINI LED televisions or displays" and their components, including specific product lines such as the S2, S3, S4, S5, 3-Series, 4-Series, C8-Series, P6-Series, S-Series, Q-Class, Q5, Q6, Q7, QM7, QM8, and NXTFRAME products (Compl. ¶2).

Functionality and Market Context

The accused products are consumer televisions that utilize LED-based backlight technology to illuminate the display panel (Compl. ¶2). The complaint provides visual evidence of a "TCL QLED television" being offered for sale and in-store pickup at a Walmart in the judicial district, indicating their availability in the U.S. consumer market. The complaint describes this product as being located on "Aisle N26" of the "Marshall Supercenter" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint alleges infringement of the asserted patents but refers to claim chart exhibits (Ex. F, G, H, I, J) that were not filed with the public complaint (Compl. ¶¶50, 56, 62, 68, 74). The complaint does not provide sufficient detail for a tabular analysis. The narrative infringement theory is conclusory, alleging that the Accused Instrumentalities meet all limitations of the asserted claims by way of making, using, selling, or importing the products (Compl. ¶¶48, 54, 60, 66, 72).

Identified Points of Contention for the '921 Patent

The infringement analysis for the '921 Patent may raise questions of structural correspondence. Specifically, the inquiry will focus on whether the accused LED packages contain the precise physical structures recited in Claim 1, such as a "spacer" with a "gradually increasing width," electrodes featuring "at least two holes," and specific geometries at the corners including a "curved surface or a step structure" and a "recess with a curvature."

Identified Points of Contention for the '395 Patent

The analysis for the '395 Patent will likely center on its unconventional layered structure. Key questions may include whether the accused LED components utilize a "bonded metal layer" composed of two insulated units instead of conventional connectors, and, critically, whether the "negative electrode" is physically "located on a side wall of said multi-quantum-well light-emitting layer" as the claim requires.

V. Key Claim Terms for Construction

Term from the '921 Patent: "spacer"

  • Context and Importance: This term is central to Claim 1, which requires the spacer to have specific geometric and relational properties, including a "first portion having a gradually increasing width." The construction of "spacer" will be critical to determining whether any component in the accused device that separates the electrodes meets this complex structural limitation.
  • Intrinsic Evidence for a Broader Interpretation: The specification may provide a general definition of the spacer as a component that maintains separation between electrodes, which could support a broader reading of its function ('921 Patent, col. 8:19-23).
  • Intrinsic Evidence for a Narrower Interpretation: The figures and their corresponding descriptions portray a spacer with a very specific T-shaped cross-section and inclined lateral sides ('921 Patent, Fig. 13; col. 8:12-18). This detailed embodiment may be used to argue for a narrower construction limited to the depicted geometry.

Term from the '395 Patent: "negative electrode...located on a side wall of said multi-quantum-well light-emitting layer"

  • Context and Importance: This phrase describes a highly specific and potentially non-standard placement of an electrode. Infringement will depend on whether the accused TCL LEDs are manufactured with this exact configuration, making the term's construction a likely point of significant dispute.
  • Intrinsic Evidence for a Broader Interpretation: A party might argue that "on a side wall" could encompass any structure where the electrode makes contact with the side wall, even if it also contacts other surfaces.
  • Intrinsic Evidence for a Narrower Interpretation: The patent's figures and manufacturing method description show the negative electrode being formed after an etching process creates a distinct mesa structure with an exposed side wall of the underlying n-type and multi-quantum-well layers ('395 Patent, Fig. 4C; col. 4:28-34). This may support an argument that the claim is limited to this specific fabricated structure.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement to infringe all five patents. The basis for these allegations includes Defendant's affirmative acts of manufacturing, selling, and distributing the accused products, as well as providing "instructions, documentation, ... technical support, marketing, product manuals, advertisements, and online documentation" that allegedly encourage infringing use by customers (Compl. ¶¶51, 57, 63, 69, 75).

Willful Infringement

Willfulness is alleged for all five patents. For the '209 patent, the allegation is based on pre-suit knowledge stemming from a notice letter dated March 10, 2021 (Compl. ¶61). For the '921, '395, '181, and '895 patents, the allegation is based on knowledge acquired no later than the filing of the complaint (Compl. ¶¶49, 55, 67, 73).

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

  • A core issue will be one of structural correspondence: The asserted claims, particularly in the '921 and '395 patents, recite highly specific, multi-part geometric configurations for the internal components of the LED packages (e.g., spacers with increasing widths, electrodes with holes and recesses, side-wall electrode placement). A central question for the court will be whether the mass-produced, commodity LED components within TCL's commercial televisions actually embody these precise and potentially complex physical structures.
  • The case also presents a key evidentiary question: The complaint's infringement contentions rely on claim-chart exhibits that are not part of the public record. This raises the question of what specific technical evidence, presumably derived from reverse engineering or internal discovery, exists to map the internal micro-structures of the accused LEDs to the detailed limitations of the asserted claims, thereby substantiating the currently conclusory allegations.