DCT
4:25-cv-00177
SemiLED Innovations LLC v. Lowe's Companies Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SemiLED Innovations LLC (Texas)
- Defendant: Lowe's Companies, Inc. and Lowe's Home Centers, LLC (North Carolina)
- Plaintiff’s Counsel: Key Kesan Dallmann PLLC
- Case Identification: 4:25-cv-00177, E.D. Tex., 02/21/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas based on Defendant’s operation of numerous retail stores and at least one distribution center within the district.
- Core Dispute: Plaintiff alleges that a range of LED lighting products sold by Defendant infringes five patents related to LED package structure, semiconductor device design, and lighting module assembly.
- Technical Context: The patents-in-suit relate to the design and manufacture of light-emitting diodes (LEDs), a technology central to the modern residential and commercial lighting market.
- Key Procedural History: The complaint does not allege any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2004-07-01 | ’454 Patent Priority Date |
| 2006-10-31 | ’454 Patent Issue Date |
| 2010-02-16 | ’246 Patent Filing Date |
| 2010-12-21 | ’971 Patent Filing Date |
| 2012-11-13 | ’971 Patent Issue Date |
| 2012-11-27 | ’246 Patent Issue Date |
| 2014-01-22 | ’196 Patent Filing Date |
| 2015-02-24 | ’196 Patent Issue Date |
| 2015-08-03 | ’942 Patent Filing Date |
| 2016-12-27 | ’942 Patent Issue Date |
| 2025-02-21 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,963,196 - Slim LED package
- Issued: February 24, 2015
The Invention Explained
- Problem Addressed: The patent addresses technical challenges in prior art LED packages, including excessive thickness which complicated the fabrication of thin devices, and the "yellowing phenomenon" of encapsulation material which decreased luminescence and lifetime (’196 Patent, col. 1:53-57; Compl. ¶21). Prior solutions involving heat dissipation slugs also complicated the manufacturing process (’196 Patent, col. 1:58-64).
- The Patented Solution: The invention proposes forming a "chip mounting recess" on a lead frame, allowing the LED chip to be mounted at a lower position. This configuration is intended to reduce the overall package thickness by creating an overlap between the vertical profile of the chip and the lead frame (’196 Patent, col. 2:62-66; Compl. ¶22). This design also aims to increase the exposed bottom surface area of the lead frame, thereby improving thermal dissipation efficiency (’196 Patent, col. 3:1-5; Compl. ¶22).
- Technical Importance: This approach sought to create thinner and more thermally efficient LED packages, enabling their integration into a broader array of compact lighting fixtures and electronic devices. (Compl. ¶23).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2 and 8. (Compl. ¶55).
- Essential elements of independent claim 1 include:
- A light emitting diode (LED) package, comprising:
- a first lead frame and a second lead frame separated from each other;
- an LED Chip disposed on the first lead frame and electrically connected to the first lead frame and the second lead frame;
- a wire connecting the LED chip to the second lead frame;
- wherein opposing sides of the first lead frame and the second lead frame face each other in a slanted state to the other sides of the lead frame.
- The complaint does not explicitly reserve the right to assert additional claims.
U.S. Patent No. 9,530,942 - Slim LED Package
- Issued: December 27, 2016
The Invention Explained
- Problem Addressed: The patent identifies similar problems to the ’196 Patent, namely that prior art LED packages had housings with excessive thickness, and encapsulation materials that would yellow over time due to energy from the LED chip, degrading performance. (’942 Patent, col. 1:57-62; Compl. ¶29).
- The Patented Solution: The invention describes an LED package with a specific lead frame structure designed to improve thermal dissipation and reduce thickness. Key features include a chip mounting recess and grooves on the lower surface of the lead frames, which may enhance the bonding force with the encapsulation material. (’942 Patent, col. 3:1-11; Compl. ¶¶30-31).
- Technical Importance: The claimed invention provides the benefits of improved "thermal dissipation efficiency" and a reduction of package thickness compared to the prior art. (Compl. ¶31).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claim 3. (Compl. ¶68).
- Essential elements of independent claim 1 include:
- A light emitting diode (LED) package, comprising;
- a first lead frame and a second lead frame separated from each other;
- an LED Chip disposed on the first lead frame and electrically connected with the second lead frame;
- a resin covering at least portions of surfaces of the first and second lead frames, wherein;
- at least one of the first and second lead frames comprises a first edge facing the other lead frame and a second side opposite the first side;
- the first lead frame comprising a first groove disposed on a lower surface thereof, and the second lead frame comprises a second groove disposed on the lower surface thereof;
- each of the first and second grooves is open only on the lower surfaces of the first and second lead frames, respectively; and;
- a depth of the first groove is equal to a depth of the second groove.
- The complaint does not explicitly reserve the right to assert additional claims.
U.S. Patent No. 8,309,971 - Light emitting diode having electrode pads
- Issued: November 13, 20212 (Compl. ¶32)
Technology Synopsis
The patent addresses inefficient current distribution in the semiconductor layers of large-area, high-output LEDs. Prior art transparent electrode layers had limited thickness and thus provided limited current spreading. (’971 Patent, col. 1:61-67; Compl. ¶37). The invention discloses specific structures for electrode pads and extensions that are spaced apart from the semiconductor layer to enhance current spreading and improve luminous efficacy. (’971 Patent, col. 2:26-35; Compl. ¶38).
Asserted Claims
Claims 1, 7-9, and 11 are asserted, with claim 1 being independent. (Compl. ¶83).
Accused Features
The light emitting diodes within the Utilitech LED 4-Panel Garage Light and Lithonia Lighting HGX Floodlight. (Compl. ¶82).
U.S. Patent No. 7,128,454 - Light emitting diode module for automobile headlights and automobile headlight having the same
- Issued: October 31, 2006 (Compl. ¶39)
Technology Synopsis
The patent addresses the need for LED modules that can withstand external moisture while also efficiently dissipating the significant heat they generate, a challenge not present with older halogen lamp technology. (’454 Patent, col. 1:43-47; Compl. ¶44). The invention provides an LED module with an integrated waterproof structure and a heat radiating structure, comprising a module body made of a high thermal conductivity material, a sealed connector, and a transparent member to protect the lighting unit. (’454 Patent, col. 1:59-65; Compl. ¶44).
Asserted Claims
Claims 1 and 15 are asserted, with claim 1 being independent. (Compl. ¶101).
Accused Features
The Utilitech Recessed Retrofit Light is accused of infringement. (Compl. ¶100).
U.S. Patent No. 8,319,246 - Semiconductor device and method for manufacturing same
- Issued: November 27, 2012 (Compl. ¶46)
Technology Synopsis
The patent addresses reliability and cost issues in prior art flip-chip mounting for LEDs. Prior art methods for increasing the aspect ratio of metal columns for better heat transfer resulted in reduced joining strength and reliability. (’246 Patent, col. 1:29-37; Compl. ¶51). The invention discloses using multiple fine metal pillars, which can achieve a high aspect ratio to better absorb stress and improve reliability without increasing height or cost. (’246 Patent, col. 4:23-49; Compl. ¶52).
Asserted Claims
Claim 1 is asserted. (Compl. ¶113).
Accused Features
The Kobalt Handheld Cordless Spotlight is accused of infringement. (Compl. ¶112).
III. The Accused Instrumentality
Product Identification
The complaint names the Harbor Breeze Mazon Fan, allen + roth 19in Round LED Flushmount, Utilitech LED 4-Panel Garage Light, Lithonia Lighting HGX Floodlight, GE Relax HD A19 LED Bulb, Utilitech Recessed Retrofit Light, and Kobalt Handheld Cordless Spotlight as the "Accused Products." (Compl. ¶2).
Functionality and Market Context
The Accused Products are residential and commercial LED lighting fixtures and bulbs. (Compl. ¶2). The complaint alleges that certain brands, including Kobalt, allen + roth, Utilitech, and Harbor Breeze, are private label brands produced or caused to be produced by Defendant. (Compl. ¶11). The infringement allegations focus on the internal LED packages and chips within these products, with the complaint providing numerous annotated photographic exhibits from product teardowns. For example, Figure 1B-1 provides a magnified cross-section of the LED package from a Harbor Breeze Mazon Fan, annotating the "First lead frame" and "Second lead frame." (Compl. ¶57, p. 13). Similarly, Figure 3B-1 provides a scanning electron microscope (SEM) image of a light emitting diode from a Lithonia Lighting HGX Floodlight, identifying the "Substrate." (Compl. ¶85, p. 36).
IV. Analysis of Infringement Allegations
'196 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first lead frame and a second lead frame separated from each other | The accused LED packages comprise two physically distinct lead frames, as shown in annotated photographs. Figure 1B-1 illustrates this separation in the Harbor Breeze Mazon Fan. | ¶57 | col. 5:1-2 |
| an LED Chip disposed on the first lead frame and electrically connected to the first lead frame... | The LED chip is mounted on the first lead frame. Figure 1B-4 shows the connection between the first lead frame and the LED chip. | ¶58 | col. 5:3-5 |
| ...and the second lead frame | The LED chip is electrically connected to the second lead frame. Figure 1B-6 shows the electrical connection to the second lead frame in the allen + roth product. | ¶58 | col. 5:3-5 |
| a wire connecting the LED chip to the second lead frame | A wire bond connects the LED chip to the second lead frame. Figure 1B-10 shows this wire connection in the Harbor Breeze Mazon Fan. | ¶59 | col. 5:6-7 |
| wherein opposing sides of the first lead frame and the second lead frame face each other in a slanted state | The sides of the lead frames that face each other are angled. Figure 1B-13 shows a cross-section of the Harbor Breeze Mazon Fan with annotations pointing to these "Opposing sides." | ¶60 | col. 6:49-52 |
- Identified Points of Contention:
- Scope Questions: The central dispute may involve the term "slanted state." A question for the court could be whether the angled surfaces of the lead frames in the accused products, as depicted in Figure 1B-13 (Compl. p. 18), fall within the scope of this term as used in the patent. The analysis may depend on whether the patent requires a specific angle or functional purpose for the slant that is not met by the accused design.
'942 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first lead frame and a second lead frame separated from each other | The accused LED packages contain first and second lead frames that are physically separate. Figure 2B-1 shows this separation. | ¶70 | col. 5:32-33 |
| a resin covering at least portions of surfaces of the first and second lead frames | An encapsulating resin covers parts of both lead frames. Figure 2B-7 shows this resin coverage. | ¶72 | col. 5:38-40 |
| at least one of the first and second lead frames comprises a first edge facing the other lead frame and a second side... | The lead frames have opposing edges and sides. Figure 2B-10 and Figure 2B-11 identify these "First Sides" and "Second Sides" on the lead frames. | ¶73 | col. 5:41-44 |
| the first lead frame comprising a first groove disposed on a lower surface thereof, and the second lead frame...a second groove... | Both lead frames are alleged to have grooves on their lower surfaces. Figure 2B-16 shows annotated "First Groove" and "Second Groove" on the lower surfaces of the respective lead frames in the Harbor Breeze Mazon Fan. | ¶74 | col. 5:45-49 |
| each of the first and second grooves is open only on the lower surfaces of the first and second lead frames | The complaint alleges the grooves are open only on the bottom. Figure 2B-19 shows the location of the grooves relative to the "Lower Surface of First Lead Frame" and "Lower Surface of Second Lead Frame." | ¶75 | col. 5:50-53 |
| a depth of the first groove is equal to a depth of the second groove | The complaint alleges that the depths of the two grooves are equal. Figure 2B-22 provides a visual basis for this allegation. | ¶76 | col. 5:54-55 |
- Identified Points of Contention:
- Technical and Scope Questions: The infringement analysis may raise questions about the terms "groove" and "equal." A technical question is whether the indentations shown in Figure 2B-16 (Compl. p. 30) are "grooves" as contemplated by the patent, or simply artifacts of a manufacturing process. A key factual question will be whether the depths of these features are "equal," a precise limitation that may require expert testimony and measurement beyond the visual evidence provided.
V. Key Claim Terms for Construction
For the '196 Patent
- The Term: "slanted state"
- Context and Importance: This term defines the core geometry of the claimed lead frame arrangement. The infringement case for this patent hinges on whether the angled surfaces of the accused products meet this definition. Practitioners may focus on this term because it is not defined with a specific angular range and its scope will determine whether common lead frame designs are covered.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the slanted part as being formed on "opposite sides... facing each other" ('196 Patent, col. 6:49-50), which could suggest any non-perpendicular orientation is sufficient.
- Evidence for a Narrower Interpretation: The specification notes that this slanted state can widen the separation between the lead frames and may be formed with a "depressed part" ('196 Patent, col. 6:54-57). A defendant may argue that "slanted state" should be limited to embodiments that serve this specific widening function.
For the '942 Patent
- The Term: "groove"
- Context and Importance: The presence, location, and characteristics of the "groove" are essential limitations of claim 1. The dispute will likely focus on whether the surface indentations on the accused products qualify as "grooves."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's summary states grooves can be formed on an upper or lower surface "to increase a bonding force" ('942 Patent, col. 2:35-39), suggesting any surface feature that achieves this function could be considered a groove.
- Evidence for a Narrower Interpretation: Figure 8 of the patent depicts distinct, U-shaped channels (122', 142'). A defendant may argue that the term "groove" should be construed to require a similar, deliberately machined channel, rather than a mere surface indentation. The claim also requires the groove to be "open only on the lower surfaces," which could be used to narrow the term to exclude features that affect the side or top profiles of the lead frame.
VI. Other Allegations
- Indirect Infringement: The complaint includes boilerplate allegations of direct and/or indirect infringement for each asserted patent. (Compl. ¶¶54, 67, 82, 100, 112). However, it does not plead specific facts to support the knowledge and intent elements required for claims of induced or contributory infringement.
- Willful Infringement: The complaint does not contain an explicit count for willful infringement or plead facts demonstrating pre-suit knowledge of the patents. It does, however, seek a finding that the case is "exceptional" under 35 U.S.C. § 285 for each patent, which is a request for an award of attorneys' fees. (Compl. ¶¶63, 78, 96, 108, 122).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can structural terms from the patents, such as "slanted state" ('196 Patent) and "groove" ('942 Patent), be construed to cover the physical features observed in the mass-produced commercial lighting components sold by Defendant? The resolution will depend on how the court interprets these terms in light of the patent specifications.
- A key evidentiary question will be one of factual compliance: for the ’942 Patent, does the evidence show that the depths of the accused "grooves" are "equal" as strictly required by the claim language? This presents a specific factual hurdle for the Plaintiff that will likely require technical measurement and expert analysis beyond the visual evidence currently provided.
- A central strategic question will concern case complexity: how will the Plaintiff connect the distinct technologies of five different patents to the varied designs of at least seven different accused product families? The court may require the Plaintiff to narrow its claims or provide more detailed infringement contentions to manage the scope of discovery and trial.