LightSure LLC v. Eaton Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: LightSure LLC (NM)
  • Defendant: Eaton Corporation (OH)
  • Plaintiff’s Counsel: Rabicoff Law LLC; DNL Zito
• Case Identification: 3:25-cv-01600, N.D. Tex., 06/22/2025
• Venue Allegations: Venue is asserted based on Defendant having an established place of business in the district and having committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unnamed lighting products infringe a patent related to systems for managing the energy use of networked lights.
• Technical Context: The lawsuit concerns "smart" lighting systems, which use sensors and network communication to dynamically adjust illumination based on local activity, aiming to reduce energy consumption compared to traditional static lighting.
• Key Procedural History: The asserted patent is a continuation of a prior application, now U.S. Patent No. 8,502,456, indicating a broader patent family. The complaint asserts knowledge and willfulness based solely on the filing of the lawsuit itself, not on any pre-suit notice.

Case Timeline

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

U.S. Patent No. 8,716,942: “Managing light system energy use” (Issued May 6, 2014)

The Invention Explained

• Problem Addressed: The patent identifies that conventional street and parking lot lights consume significant energy, often representing a large portion of a city's budget. Simple ambient light sensors that merely turn lights on at dusk and off at dawn are inefficient because they provide full power all night, regardless of actual need (U.S. Patent No. 8,716,942, col. 1:17-29).
• The Patented Solution: The invention describes a networked lighting system where individual light assemblies receive a base "lighting profile" from a central controller, which dictates a low-power illumination level. Each assembly is equipped with local sensors (e.g., motion, audio, RF) to detect nearby activity. Upon detecting activity, the assembly can temporarily "deviate" from its profile to provide brighter light for a set period. It then transmits a message back to the central controller reporting this deviation, allowing for system-wide monitoring and data collection ('942 Patent, Abstract; col. 3:40-67; Fig. 7).
• Technical Importance: The technology represents a shift from static, centrally-controlled lighting to a decentralized, responsive system that balances energy savings with on-demand safety and illumination by reacting to real-world events ('942 Patent, col. 3:8-14).

Key Claims at a Glance

• The complaint does not identify specific claims, referring only to "Exemplary '942 Patent Claims" (Compl. ¶11). For analysis, independent claim 1 is representative.
• Independent Claim 1: A method for managing energy use in a system of lights, comprising the steps of:
  • receiving, at a first lighting assembly, a lighting profile from a remote control center;
  • implementing the profile, including causing a light to illuminate at a first intensity;
  • receiving, at a sensing module, an input indicating an activity level in a proximate region;
  • deviating from the profile by varying the light's intensity to a second, different intensity for a predetermined period in response to the input; and
  • wirelessly transmitting a message to the control center, the message comprising an indication of the second intensity and an identifier for the lighting assembly.
• The complaint notes that Plaintiff may assert infringement of other claims, including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products by name or model, referring to them only as "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

• The complaint alleges that the accused products "practice the technology claimed by the '942 Patent" (Compl. ¶16). It further alleges that Defendant sells these products to customers and distributes "product literature and website materials" that instruct end users on how to use them in an infringing manner (Compl. ¶14). The complaint does not provide further detail on the specific functionality, operation, or market context of the accused products.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts attached as Exhibit 2 (Compl. ¶16, ¶17). As this exhibit was not provided with the complaint, a claim chart summary cannot be constructed. The infringement theory is articulated in conclusory terms, stating that the "Exemplary Defendant Products incorporate in these charts satisfy all elements of the Exemplary '942 Patent Claims" (Compl. ¶16). No probative visual evidence provided in complaint.

• Identified Points of Contention: Given the lack of factual detail, the entire infringement case remains an open question. Key technical and legal disputes may arise over whether the accused products actually perform the specific steps recited in the claims.
  • Scope Questions: A principal question will be whether the accused products operate using a "lighting profile" received from a remote source, as the claim requires. The court may need to determine if the accused products' operational logic can be characterized as receiving a baseline "profile" and then "deviating" from it, or if they operate on a different, non-infringing principle.
  • Technical Questions: A key evidentiary question will be whether the accused products, upon detecting activity, "transmit a message" back to a central system that contains both "an indication of the increased light intensity and an identifier associated with the first lighting assembly" ('942 Patent, col. 2:56-61). Plaintiff will need to provide evidence that the accused systems' communication protocol includes this specific combination of data.

V. Key Claim Terms for Construction

• The Term: "lighting profile"

• Context and Importance: This term is the foundation of the claimed method. The infringement analysis depends on whether the accused products receive and implement a "profile." Practitioners may focus on this term because its scope will determine whether a wide range of programming instructions or only specific types of pre-set energy schedules qualify.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the profile as containing "instructions for operation" and says it can "take any number of forms" ('942 Patent, col. 5:1-4), which may support a broad definition covering any set of operational commands.
  • Evidence for a Narrower Interpretation: The patent's examples consistently show the profile as a time-based schedule of light intensities (e.g., Fig. 2C) or a plan designed to supplement ambient light to achieve a target total illumination (e.g., Figs. 2A-2B) ('942 Patent, col. 5:21-35; col. 7:30-41). This could support a narrower construction limited to such pre-planned energy-saving schedules.

• The Term: "deviating from the received lighting profile"

• Context and Importance: This term defines the core inventive step of reacting to local stimuli. The dispute will center on what actions constitute "deviating." This is critical because if the accused product's standard operation includes changing light levels in response to sensors, it may not be "deviating" from a baseline profile but rather executing its only profile.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself is broad, simply requiring "varying the intensity of the light" in response to an input ('942 Patent, col. 18:15-17). This could be argued to cover any change from the baseline intensity.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the deviation as a temporary increase in intensity for a "predetermined period of time," after which the system "revert[s] to the received lighting profile" ('942 Patent, col. 2:48-54; col. 8:8-10). This may support a narrower construction requiring a temporary change from a persistent, underlying profile.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant distributes "product literature and website materials" that instruct customers on how to use the accused products in an infringing manner (Compl. ¶14). The allegation of knowledge for inducement is tied to the service of the complaint itself (Compl. ¶15).
• Willful Infringement: Willfulness is alleged based on Defendant’s continuation of infringing activities after receiving "Actual Knowledge of Infringement" via the service of the complaint and its attached (but un-filed) claim charts (Compl. ¶¶13-14). The complaint does not allege any pre-suit knowledge.

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

1. Evidentiary Sufficiency: The central threshold question is whether Plaintiff can produce factual evidence, absent from the complaint itself, to support its conclusory allegations. The case will depend on the specific functionalities of the unnamed "Exemplary Defendant Products" as detailed in the un-filed "Exhibit 2" and substantiated in discovery.

2. Definitional Scope: The case will likely turn on a question of claim construction: can the term "lighting profile" be construed to read on the operational programming of the accused products? The outcome will depend on whether Defendant's products are found to operate on a static baseline that is temporarily overridden, or on a fully dynamic logic that does not distinguish between a "profile" and a "deviation."

3. Functional Operation: A key technical question will be one of operational correspondence: do the accused systems, when responding to sensor input, transmit the specific data combination recited in the claim—an "indication of the second intensity" and an "identifier"—back to a central controller, or does their communication protocol function differently?