DCT
4:25-cv-02768
LightSure LLC v. Emerson Electric Co
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: LightSure LLC (New Mexico)
- Defendant: Emerson Electric Co. (Missouri)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 4:25-cv-02768, S.D. Tex., 06/13/2025
- Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business within the Southern District of Texas, having allegedly committed acts of infringement in the district, and Plaintiff having suffered harm there.
- Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to systems and methods for managing energy use in networked lighting systems.
- Technical Context: The technology concerns intelligent lighting networks, such as for streetlights, that dynamically adjust illumination based on both pre-programmed schedules and local sensor-detected activity to conserve energy.
- Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit. The allegations of knowledge and willfulness are based on the notice provided by the filing of the instant lawsuit.
Case Timeline
| Date | Event |
|---|---|
| 2010-09-09 | U.S. Patent 8,716,942 Earliest Priority Date |
| 2013-08-02 | Application for U.S. Patent 8,716,942 Filed |
| 2014-05-06 | U.S. Patent 8,716,942 Issued |
| 2025-06-13 | Complaint Filed |
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 ("the ’942 Patent"), Managing light system energy use, issued May 6, 2014. (Compl. ¶9).
The Invention Explained
- Problem Addressed: The patent identifies that energy costs for large-scale lighting systems, such as municipal streetlights, represent a significant budgetary expense, and that conventional on/off controls are inefficient. (’942 Patent, col. 1:18-24).
- The Patented Solution: The invention describes a networked lighting system where individual light assemblies receive a centrally-managed "lighting profile" that dictates their intensity over time to save energy (e.g., dimming during low-traffic hours). (’942 Patent, col. 1:35-42). Crucially, each assembly is equipped with local sensors to detect proximate activity (e.g., a pedestrian or vehicle) and can temporarily deviate from its profile to increase brightness on demand, after which it transmits a message back to the central controller reporting the deviation. (’942 Patent, col. 1:45-60; Fig. 7).
- Technical Importance: This technology aims to provide a hybrid control architecture that combines the benefits of centralized energy optimization with the safety and responsiveness of localized, on-demand lighting. (’942 Patent, col. 3:8-18).
Key Claims at a Glance
- The complaint alleges infringement of "exemplary claims" identified in an attached exhibit, which was not available for this analysis. (Compl. ¶¶11, 16). The analysis below focuses on independent claim 1, a representative method claim.
- The essential elements of independent claim 1 include:
- Receiving, at a lighting assembly, a "lighting profile" from a remote control center.
- Implementing the profile by illuminating a light at a "first intensity."
- Receiving, at a local "sensing module," an input indicating "activity" in proximity to the assembly.
- "Deviating" from the profile in response to the input by illuminating the light at a "second intensity."
- Transmitting a message back to the control center that includes an indication of the new intensity and an identifier for the lighting assembly.
- The complaint reserves the right to assert other claims, including dependent claims. (Compl. ¶11).
III. The Accused Instrumentality
Product Identification
- The complaint refers to "Exemplary Defendant Products" that are identified in claim charts attached as Exhibit 2. (Compl. ¶11). As Exhibit 2 was not provided, specific accused products cannot be identified.
Functionality and Market Context
- The complaint offers only conclusory allegations that the accused products "practice the technology claimed by the '942 Patent." (Compl. ¶16). It does not provide specific details regarding the technical operation, features, or market position of the accused products. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges infringement via claim charts in an unattached exhibit. (Compl. ¶17). The following table summarizes the infringement theory for representative independent claim 1 based on the complaint's general allegations.
’942 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving, at a communications receiver of a first lighting assembly, a lighting profile that instructs the first lighting assembly to operate according to the lighting profile over a first period of time... | The accused products allegedly contain a communications receiver to receive operating schedules from a central controller. | ¶¶11, 16 | col. 12:35-42 |
| implementing, at the first lighting assembly, the received lighting profile, including causing a light of the first lighting assembly to illuminate at a first intensity | The accused products allegedly operate according to the received schedule, causing their lights to illuminate at a first, programmed intensity. | ¶¶11, 16 | col. 12:43-45 |
| receiving, at a sensing module of the first lighting assembly, an input acquired in proximity to the first lighting assembly, the input indicating an activity level in a region proximate the first lighting assembly | The accused products allegedly include one or more sensors (e.g., motion or ambient light sensors) to detect activity near the light fixture. | ¶¶11, 16 | col. 12:45-49 |
| deviating from the received lighting profile by varying the intensity of the light of the first lighting assembly, in response to the received input...by causing the light...to illuminate at a second intensity... | In response to a sensor trigger, the accused products allegedly override their schedule to increase light intensity to a second level. | ¶¶11, 16 | col. 12:50-59 |
| wirelessly transmitting a message via a communications transmitter...for receipt by the control center, the message comprising an indication of the second intensity and an identifier... | The accused products allegedly transmit data back to the central controller indicating the change in light intensity and identifying the specific unit. | ¶¶11, 16 | col. 12:59-66 |
- Identified Points of Contention:
- Scope Questions: A potential dispute may arise over the definition of "lighting profile." The question is whether a simple time-based on/off schedule, as might be used in some lighting control systems, meets the definition of a "lighting profile" as contemplated by the patent, which describes more complex, multi-level intensity functions. (’942 Patent, Figs. 2A-2C).
- Technical Questions: A key question for the court will be whether the accused products perform the complete, closed-loop process required by the claim. Specifically, what evidence does the complaint provide that the products not only deviate from a schedule based on a local sensor but also "transmit a message" back to a control center containing both an "indication of the second intensity" and an "identifier" for that specific lighting assembly?
V. Key Claim Terms for Construction
The Term: "lighting profile"
Context and Importance: This term is foundational to the claim. Its construction will determine whether the patent covers a wide range of programmable lighting systems or is limited to those implementing more sophisticated, variable-intensity schedules. Practitioners may focus on this term because its scope could be the difference between non-infringement and infringement for systems using simple timers.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is general, referring to a profile that "instructs the first lighting assembly to operate... over a first period of time." (’942 Patent, col. 17:2-5). This could arguably encompass any set of timed operating instructions.
- Evidence for a Narrower Interpretation: The specification repeatedly describes the profile in more detailed terms, such as a "power function over time" or a "schedule of light intensities over time." (’942 Patent, col. 5:4-7). The patent's exemplary figures all depict profiles with multiple, varying intensity levels, not a simple on/off state, which may suggest a narrower scope. (’942 Patent, Figs. 2A-2C).
The Term: "deviating from the received lighting profile"
Context and Importance: This term defines the allegedly inventive, responsive action of the lighting assembly. The dispute will likely center on whether any temporary change in operation qualifies as "deviating," or if the change must be of a particular character or duration.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language does not place explicit limits on the nature of the deviation beyond it being "in response to the received input." (’942 Patent, col. 17:16-18). The specification gives numerous examples of triggers, from pedestrians to gunshots, each causing a deviation. (’942 Patent, Fig. 4).
- Evidence for a Narrower Interpretation: A defendant might argue that "deviating" implies a temporary departure from an ongoing, underlying profile to which the system subsequently reverts. The patent describes this behavior, for example by initiating a "timer" for the deviation and "reverting to the received lighting profile" after the timer expires. (’942 Patent, col. 2:7-11). This could be used to argue that systems that simply switch to a different permanent state do not "deviate" in the claimed manner.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner. (Compl. ¶14).
- Willful Infringement: The complaint bases its willfulness allegation on Defendant's continued infringement after having "actual knowledge" of the ’942 Patent from the service of the complaint and its attached claim charts. (Compl. ¶¶13, 15). There is no allegation of pre-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
A primary issue will be one of evidentiary proof: The complaint is "bare-bones" and lacks specific factual allegations mapping product features to claim limitations. The case will therefore depend heavily on whether discovery reveals that the accused products actually perform the full, closed-loop method claimed—specifically, whether they receive a central profile, deviate based on local sensors, and transmit a specific report back to the control center.
A second core issue will be one of definitional scope: The outcome may turn on the construction of the term "lighting profile." The key question for the court will be whether the term is broad enough to read on common, simple timed schedules, or if it is limited by the specification's more detailed examples to cover only systems capable of managing variable, multi-level intensity functions.