LightSure LLC v. Acuity Brands Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: LightSure LLC (NM)
  • Defendant: Acuity Brands, Inc. (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC; DNL Zito
• Case Identification: 3:25-cv-01691, N.D. Tex., 06/30/2025
• Venue Allegations: Venue is alleged to be proper because Defendant maintains an established place of business in the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s smart lighting products infringe a patent related to dynamically managing light system energy use in response to local activity.
• Technical Context: The technology concerns networked lighting systems, such as streetlights, that conserve energy by operating at low levels but temporarily increase brightness when nearby activity is detected, while also reporting these events to a central system.
• Key Procedural History: The patent-in-suit is a continuation of a prior application, which matured into U.S. Patent No. 8,502,456. The complaint does not mention other prior litigation or administrative proceedings.

Case Timeline

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

U.S. Patent No. 8,716,942 - "Managing light system energy use"

• Patent Identification: U.S. Patent No. 8,716,942, "Managing light system energy use", issued May 6, 2014.

The Invention Explained

• Problem Addressed: The patent addresses the significant energy costs associated with conventional street and parking lot lights, which are often fully powered regardless of the actual, immediate need for illumination (’942 Patent, col. 1:17-22).
• The Patented Solution: The invention proposes a networked lighting system where each light assembly receives a "lighting profile" (e.g., a schedule of intensities) from a central controller. While following this low-energy profile, a local sensor on the light assembly can detect activity (e.g., motion, sound, RF signals) and "deviate" from the profile by temporarily increasing its brightness. Crucially, after this deviation, the assembly transmits a message back to the central controller indicating the change in intensity and identifying itself (’942 Patent, Abstract; Fig. 7). This creates an adaptive, energy-efficient system with a central reporting feedback loop.
• Technical Importance: This approach allows for large-scale energy savings by dimming lights during periods of inactivity, while responsively increasing illumination for safety and utility when needed, and providing system-wide data on these events (’942 Patent, col. 3:8-18).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring only to "Exemplary '942 Patent Claims" identified in a referenced but unattached exhibit (Compl. ¶11). The patent’s first independent claim is Claim 1, a method claim.
• The essential elements of independent Claim 1 include:
  • 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 activity proximate to the assembly.
  • "Deviating" from the profile in response to the input by causing the light to illuminate at a "second intensity" different from the first.
  • Wirelessly transmitting a message for receipt by the control center, the message "comprising an indication of the second intensity and an identifier associated with the first 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 name any specific accused products. It refers to "Exemplary Defendant Products" that are purportedly identified in charts within an Exhibit 2, which was not provided with the complaint (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market position. It alleges generally that the accused products "practice the technology claimed by the '942 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim charts detailing its infringement theories (Compl. ¶17). It alleges narratively that the "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶16). The core of the infringement allegation is that Defendant's products are networked lighting systems that operate according to a baseline illumination level, increase their brightness in response to local sensors, and communicate information about this operational change back to a central system, thereby practicing the patented method.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Technical Questions: A primary factual question will be whether the accused products perform the final step of the asserted method claim: transmitting a message back to a central controller that includes an "indication of the second [increased] intensity." Discovery will likely focus on the nature and content of data communicated by the accused products to any central management software. The case may turn on whether the products merely react to local stimuli or if they also engage in the specific reporting behavior required by the claims.
  • Scope Questions: The dispute may involve the scope of "lighting profile." A question for the court could be whether a simple, time-based dimming schedule qualifies as a "lighting profile," or if the term, in the context of the patent, requires a more complex set of instructions, for example, based on historical or environmental data as described in the specification (’942 Patent, col. 5:21-26).

V. Key Claim Terms for Construction

"deviating from the received lighting profile" (Claim 1)

• Context and Importance: This term is central to the invention's responsive functionality. Its construction will determine what type of sensor-triggered action constitutes infringement. Practitioners may focus on this term because it distinguishes the invention from a light that simply follows a static, pre-programmed schedule.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes this step as "increasing the intensity of the light...in response to the received input" (’942 Patent, col. 2:49-54), suggesting any sensor-triggered increase in brightness not explicitly scheduled in the profile could be considered a "deviation."
  • Evidence for a Narrower Interpretation: The patent provides numerous examples of deviating in specific ways based on the type of input (e.g., increasing to 80% for a pedestrian versus 100% for a police siren) (’942 Patent, col. 15:6-8; col. 16:54-61). A party could argue this implies a "deviation" requires more than a simple binary bright/dim change and involves a more intelligent, context-dependent response.

"a message comprising an indication of the second intensity" (Claim 1)

• Context and Importance: This limitation defines the critical feedback loop to the central controller. Infringement will hinge on whether the accused products transmit this specific type of information.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim requires only "an indication," which could be argued to cover any data from which the new intensity level can be derived, even if not explicitly stated as "intensity is now X%." The abstract describes the message as including "an indication of the increased light intensity" (’942 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The purpose of this step is to report the deviation event. A party could argue that this requires a message whose purpose is to report the change, as opposed to routine diagnostic data or status logs that might happen to contain intensity information but are not transmitted because of the deviation. The flowchart in Figure 7 shows this transmission as a distinct step following the deviation (’942 Patent, Fig. 7, steps 725, 730).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant sells the accused products to customers and provides "product literature and website materials" that instruct end users on how to operate the products in a manner that allegedly infringes the ’942 Patent (Compl. ¶14-15).

Willful Infringement

The complaint does not use the term "willful," but it alleges that service of the complaint provides Defendant with "Actual Knowledge of Infringement" and that Defendant's continued infringing activities are performed despite this knowledge (Compl. ¶13-14). This forms a basis for alleging post-filing willfulness and supports the prayer for a declaration that the case is exceptional (Compl. Prayer ¶E.i).

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

• A key evidentiary question will be one of operational function: Pending discovery that identifies the accused products and their operation, the central factual dispute will be whether Defendant’s systems perform the complete, multi-step method of Claim 1. Specifically, do the products transmit a message to a central controller that contains "an indication of the second intensity" as a direct result of deviating from a lighting profile?
• The case will also present a core issue of claim scope: Can the term "lighting profile" be construed broadly to cover any pre-set illumination schedule, or does the patent’s detailed description of profiles based on environmental and historical data limit its scope to more technologically sophisticated systems?
• A third central question will be one of infringement evidence: Given the complaint's lack of specificity regarding the accused products and its reliance on unattached exhibits, a threshold challenge for the Plaintiff will be to produce concrete evidence through discovery linking the specific functionality of an Acuity Brands product to each element of an asserted patent claim.