DCT
4:23-cv-01231
Cedar Lane Tech Inc v. Houlight
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Cedar Lane Technologies Inc. (Canada)
- Defendant: HouLight (Texas)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 4:23-cv-01231, S.D. Tex., 03/31/2023
- Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Southern District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s lighting products infringe two patents related to lighting devices that incorporate both a primary power source and a secondary battery backup, enabling multiple modes of operation such as for normal and emergency use.
- Technical Context: The technology concerns self-contained lighting systems, such as LED bulbs, that can automatically switch to an internal battery during a power outage, often entering a power-saving or emergency signaling mode.
- Key Procedural History: U.S. Patent No. 7,391,159 is a continuation of the application that resulted in U.S. Patent No. 7,218,056 and is subject to a terminal disclaimer. The complaint alleges infringement but relies on external exhibits, not included in the complaint document, to provide detailed infringement contentions.
Case Timeline
| Date | Event |
|---|---|
| 2006-03-13 | Priority Date for '056 and '159 Patents |
| 2007-05-15 | U.S. Patent No. 7,218,056 Issued |
| 2008-06-24 | U.S. Patent No. 7,391,159 Issued |
| 2023-03-31 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,218,056 - "Lighting device with multiple power sources and multiple modes of operation," issued May 15, 2007
The Invention Explained
- Problem Addressed: The patent identifies the problem that conventional lighting devices become inoperable when their main power source is lost, which can be problematic in situations where continuous lighting is desired ('056 Patent, col. 1:16-24).
- The Patented Solution: The invention is a self-contained lighting device, such as a screw-in light bulb, that includes a main power connection, an internal rechargeable battery, and a controller. During normal operation, it draws power from the main source to illuminate its light sources (e.g., LEDs). If main power fails, the controller automatically switches to the battery to power the device in a "backup operation" mode. The patent describes that this backup mode can be configured to power a reduced number of light sources to conserve battery life ('056 Patent, Abstract; col. 3:20-30). This architecture integrates normal and emergency lighting functions into a single unit.
- Technical Importance: The design allows for a standard light fixture to be retrofitted with an emergency lighting capability simply by changing the bulb, obviating the need for separate, dedicated emergency lighting hardware and wiring ('056 Patent, col. 3:55-65).
Key Claims at a Glance
- The complaint asserts infringement of one or more claims, incorporating by reference an "Exemplary '056 Patent Claims" chart in an external exhibit (Compl. ¶12). Independent claim 1 is representative of the core invention.
- Independent Claim 1 requires:
- At least two light sources mounted on a single printed circuit board (PCB).
- A battery configured to store power.
- A controller to receive power from a main source and the battery and control its distribution.
- The controller is configured to power the light sources from the main source during "normal operation" and power a "limited number" of those light sources from the battery during "backup operation," where the limited number is less than the number powered during normal operation.
- The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶12).
U.S. Patent No. 7,391,159 - "Lighting device with multiple power sources and multiple modes of operation," issued June 24, 2008
The Invention Explained
- Problem Addressed: As a continuation of the '056 patent, the '159 Patent addresses the same problem of lighting failure during a power outage ('159 Patent, col. 1:21-29).
- The Patented Solution: The invention is again a lighting device with dual power sources, but the claims are structured around distinct "modes" of operation. The controller distributes power to "a selective one or more of the light sources" according to a "first mode" for non-emergency illumination and a "second mode" for emergency illumination. The patent also explicitly claims a common housing for the light sources, controller, and battery ('159 Patent, Abstract; col. 2:50-65).
- Technical Importance: This patent further refines the concept of an integrated, multi-functional lighting device by framing the invention in terms of distinct, selectable operational modes for different circumstances (e.g., non-emergency vs. emergency).
Key Claims at a Glance
- The complaint asserts infringement of one or more claims via an external "Exemplary '159 Patent Claims" chart (Compl. ¶21). Independent claim 1 is representative.
- Independent Claim 1 requires:
- A number of light sources on a common PCB.
- A controller that distributes power from a main source and a battery to a "selective one or more" of the light sources according to a "first mode" (non-emergency) and a "second mode" (emergency).
- A battery for powering the light sources in the second mode.
- A housing that encloses the light sources, controller, and battery.
- The complaint reserves the right to assert other claims (Compl. ¶21).
III. The Accused Instrumentality
Product Identification
- The complaint does not name specific accused products in its text. It refers generally to "Exemplary Defendant Products" that are identified in external Exhibits 3 and 4, which were not included with the complaint document (Compl. ¶12, ¶21).
Functionality and Market Context
- The complaint alleges that the accused products "practice the technology claimed" by the patents-in-suit (Compl. ¶17, ¶26). Based on these allegations and the subject matter of the patents, the accused products are lighting devices alleged to contain a controller, a main power input, a backup battery, and the capability to operate in different modes corresponding to the availability of main power. The complaint does not provide specific details regarding the accused products' technical operation or their commercial importance.
IV. Analysis of Infringement Allegations
The complaint’s infringement allegations are made by incorporating external claim chart exhibits by reference (Compl. ¶18, ¶27). As these exhibits are not available for analysis, the following tables summarize the infringement theory based on the language of the representative independent claims and the complaint's general allegations.
No probative visual evidence provided in complaint.
'056 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| at least two light sources mounted on a single printed circuit board (PCB), the light sources configured to emit light as a function of current received through the PCB; | The complaint alleges, by incorporating Exhibit 3, that the accused products contain multiple light sources (e.g., LEDs) on a common PCB. | ¶17, ¶18 | col. 2:58-62 |
| a battery configured to store power; | The complaint alleges, by incorporating Exhibit 3, that the accused products contain a battery for backup power. | ¶17, ¶18 | col. 3:20-24 |
| a controller configured to receive power from a power source and the battery and to control power distribution therefrom; | The complaint alleges, by incorporating Exhibit 3, that the accused products contain a controller that manages power from both a main source and the internal battery. | ¶17, ¶18 | col. 2:65-3:1 |
| wherein the controller is configured to distribute power from the power source to the at least two light sources during normal operation and to distribute power from the battery to a limited number of the at least two light sources during backup operation, the limited number...being less than the number...powered during normal operation. | The complaint alleges, by incorporating Exhibit 3, that the accused products' controller switches from main power to battery power upon power loss and, in doing so, powers fewer light sources than it does during normal operation. | ¶17, ¶18 | col. 4:34-44 |
'159 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a number of light sources mounted on a common printed circuit board (PCB); | The complaint alleges, by incorporating Exhibit 4, that the accused products contain multiple light sources on a common PCB. | ¶26, ¶27 | col. 2:55-61 |
| a controller for distributing power from a main power source and a secondary battery power source to a selective one or more of the light sources according to a first mode and second mode of operation, the first mode...being associated with non-emergency illumination and the second mode...being associated with emergency illumination; | The complaint alleges, by incorporating Exhibit 4, that the accused products' controller operates in distinct modes for non-emergency (main power) and emergency (battery power) illumination. | ¶26, ¶27 | col. 2:50-57 |
| a battery for powering the selected one or more light sources in the second mode of operation; and | The complaint alleges, by incorporating Exhibit 4, that the accused products' battery provides power for the emergency mode. | ¶26, ¶27 | col. 3:25-33 |
| a housing defining a common enclosure for housing the light sources, controller, and battery. | The complaint alleges, by incorporating Exhibit 4, that the accused products have a housing that encloses the key components, consistent with a self-contained light bulb design. | ¶26, ¶27 | col. 3:46-50 |
- Identified Points of Contention:
- Evidentiary Questions: The complaint's reliance on external exhibits means the specific factual basis for infringement is not detailed in the pleading itself. A central question will be whether the evidence produced during discovery substantiates the conclusory allegation that the accused products meet every element of the asserted claims.
- Technical Questions: A key technical question for the '056 patent infringement theory is whether the accused products, during battery operation, power a "limited number" of light sources that is "less than the number...powered during normal operation." An accused product that instead dims all light sources equally may give rise to a non-infringement argument. For the '159 Patent, the dispute may focus on whether the accused backup function is truly a "second mode of operation...associated with emergency illumination" or serves a more general purpose.
V. Key Claim Terms for Construction
- Term: "backup operation" ('056 Patent, Claim 1)
- Context and Importance: This term defines the condition under which the key differentiating feature of claim 1—powering a reduced number of lights from the battery—is triggered. The scope of this term is critical to determining when infringement can occur.
- Intrinsic Evidence for a Broader Interpretation: The specification suggests this mode is triggered by a loss of main power (e.g., "if the main power source is lost," col. 1:19-20; "in the absence of power from the power source 16," col. 3:28-30). This could support an interpretation where any loss of main power constitutes "backup operation."
- Intrinsic Evidence for a Narrower Interpretation: The patent frequently links this functionality to "emergency egress lighting" (col. 6:37-38). A defendant might argue that "backup operation" is limited to specific, programmed emergency scenarios, not just any user-initiated power-off event at a wall switch.
- Term: "second mode of operation being associated with emergency illumination" ('159 Patent, Claim 1)
- Context and Importance: This phrase links the claimed "second mode" to a specific purpose. Whether the accused device's battery-powered operation is for "emergency illumination" will be a central infringement question. Practitioners may focus on this term because it appears to add a purpose-based limitation to the claim.
- Intrinsic Evidence for a Broader Interpretation: Plaintiff could argue that any illumination provided when main power is out is inherently "associated with" an emergency, as its primary purpose is to provide light where there would otherwise be none.
- Intrinsic Evidence for a Narrower Interpretation: The patent specification discusses specific emergency-related functions, such as creating directional patterns or displaying warnings (col. 5:30-35; col. 6:58-64), and claim 9 explicitly recites flashing to "display an emergency warning." A defendant could argue that "emergency illumination" requires more than just providing steady light.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct customers on how to use the accused products in an infringing manner (Compl. ¶15, ¶24). Knowledge is alleged to exist at least from the date the complaint was served (Compl. ¶16, ¶25).
- Willful Infringement: The complaint establishes a basis for post-filing willful infringement by asserting that the service of the complaint itself provides "actual knowledge" of the patents and the alleged infringement (Compl. ¶14, ¶23). There are no allegations of pre-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
- Evidentiary Substantiation: Given the notice-pleading style of the complaint, which relies on external exhibits to detail its infringement theory, a primary issue will be whether discovery produces technical evidence that substantiates the plaintiff's allegations. The case will depend on the actual, documented operation of the accused products.
- Functional Operation vs. Claim Language: The dispute will likely focus on the precise functionality of the accused products' battery-powered state. A key question for the court will be one of technical and definitional mapping: does the accused products' backup function—whether it involves dimming all lights or powering fewer lights—fall within the scope of the '056 patent's requirement for powering a "limited number" that is "less than" the normal number?
- Purpose and Intent: For the '159 patent, a central question will be one of scope based on purpose: can the accused products' general battery-backup feature be construed as a mode "associated with emergency illumination" as required by the claims, or is its function more generic? This will likely be a key battleground for claim construction and infringement analysis.