DCT

1:25-cv-01821

Polaris PowerLED Tech LLC v. Apple Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01821, W.D. Tex., 11/12/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas based on Defendant’s regular and established places of business in the district, including corporate campuses, manufacturing facilities, engineering centers, and retail stores, as well as the commission of infringing acts within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s MacBook and iPhone products, which feature automatic display brightness adjustment, infringe a patent related to controlling display brightness using both ambient light sensor data and user preference settings.
  • Technical Context: The technology addresses methods for automatically adjusting the brightness of electronic displays to enhance readability in various lighting conditions, reduce user eye strain, and conserve battery power in portable devices.
  • Key Procedural History: The complaint notes that the patent-in-suit, U.S. Patent No. 8,223,117, was previously asserted in Polaris PowerLED Technologies, LLC v. Dell et al, Case No. 1:22-cv-00973-ADA (W.D. Tex), and that the court in that matter has already conducted a Markman hearing concerning the patent. This history suggests that key claim terms may have already been construed by the court, a factor that could significantly influence the current proceedings.

**Case Timeline**

Date Event
2004-02-09 '117 Patent Priority Date
2008-12-17 '117 Patent Application Filing Date
2012-07-17 '117 Patent Issue Date
2020-01-27 Alleged date Apple received notice of the '117 Patent
2025-11-12 Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 8,223,117, "Method and Apparatus to Control Display Brightness with Ambient Light Correction," issued July 17, 2012.
  • The Invention Explained:
    • Problem Addressed: The patent describes a problem with prior art display brightness controls, which were often "crude" and failed to properly account for both changing ambient light conditions and individual user preferences. In bright environments, display contrast is reduced, while in dark environments, a screen that is too bright can cause eye fatigue and waste power, particularly in battery-operated devices like notebook computers (’117 Patent, col. 1:15-52).
    • The Patented Solution: The invention discloses a control system that generates a brightness control signal based on the "mathematical product of a light sensor output and a user selectable brightness control" (’117 Patent, col. 1:63-66). This system combines an input from an ambient light sensor with an input representing the user's preferred brightness setting, for example, through a "multiplier circuit" (’117 Patent, col. 2:40-44). The system also incorporates a "dark level bias" to ensure the display maintains a minimum level of brightness even in complete darkness, preventing it from becoming unreadable (’117 Patent, Abstract; col. 2:58-62). Figure 1 illustrates this concept, showing a "LIGHT SENSOR" input and a "DIMMING CONTROL" (user) input being fed to a multiplier, with a "DARK LEVEL BIAS" also included in the calculation.
    • Technical Importance: This approach allows for a "fully automatic and fully adaptable" method of adjusting display brightness that improves ergonomics by maintaining consistent perceived brightness while also conserving power (’117 Patent, col. 1:59-63, col. 2:48-53).
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 1 (Compl. ¶15).
    • Essential elements of Claim 1 include:
      • a first input configured to receive a user signal indicative of a user selectable brightness setting;
      • a light sensor configured to sense ambient light and to output a sensing signal indicative of the ambient light level;
      • a multiplier configured to selectively generate a combined signal based on both the user signal and the sensing signal; and
      • a dark level bias configured to adjust the combined signal to generate a brightness control signal... such that the brightness control signal is maintained above a predetermined level when the ambient light level decreases to approximately zero.
    • The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" (Compl. ¶15).

III. The Accused Instrumentality

  • Product Identification: The "Apple Accused Products" include the MacBook Air and MacBook Pro series laptops, as well as a wide range of mobile phones from the iPhone 11 through the iPhone 17 series (Compl. ¶15).
  • Functionality and Market Context: The accused functionality is the "automatic brightness control feature" in macOS and the "Auto-Brightness" feature in iOS (Compl. ¶16, ¶19). These features utilize an "ambient light sensor" to detect environmental light levels and adjust the display brightness accordingly (Compl. ¶16, ¶24). Users can selectively enable or disable this automatic adjustment and can also provide a manual brightness preference via a slider bar (Compl. ¶17, ¶21). The complaint provides a screenshot of the "Automatically adjust brightness" toggle in macOS System Settings, which notes the feature can be turned on or off (Compl. p. 7).

IV. Analysis of Infringement Allegations

  • '117 Patent Infringement Allegations
Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first input configured to receive a user signal indicative of a user selectable brightness setting The Accused Products include a brightness slider bar that allows a user to select a brightness setting, which generates a user signal in hardware and/or software. ¶21 col. 12:30-34
a light sensor configured to sense ambient light and to output a sensing signal indicative of the ambient light level The Accused Products contain an "ambient light sensor" that is configured to sense ambient light and output a corresponding signal. ¶24 col. 12:35-39
a multiplier configured to selectively generate a combined signal based on both the user signal and the sensing signal The Accused Products allegedly have a "multiplier in hardware and/or software" that generates a combined signal based on the user signal and the sensing signal. ¶25 col. 12:40-44
a dark level bias configured to adjust the combined signal to generate a brightness control signal... such that the brightness control signal is maintained above a predetermined level when the ambient light level decreases to approximately zero The Accused Products allegedly include a "dark level bias" stored in hardware or as a software variable that is used to adjust the combined signal to prevent the display from becoming unreadable in very low light conditions. ¶26 col. 12:45-53
  • Identified Points of Contention:
    • Scope Questions: The complaint alleges that software functions meet the "multiplier" and "dark level bias" limitations of the claimed "brightness control circuit." A central question for the court may be whether the term "circuit," as used in the patent, can be construed broadly enough to read on the software-based implementation in the accused digital devices.
    • Technical Questions: What evidence does the complaint provide that the accused products use a "multiplier" to generate a "combined signal" in the manner claimed? The complaint's allegations on this element are conclusory (Compl. ¶25). Furthermore, it raises the question of whether Apple's method for ensuring minimum brightness functions as a "dark level bias configured to adjust the combined signal," or if it operates as a separate software-based floor function applied after the primary brightness calculation. The complaint includes a screenshot from an iPhone's Display & Text Size settings showing the "Auto-Brightness" toggle (Compl. p. 8).

V. Key Claim Terms for Construction

  • The Term: "multiplier configured to selectively generate a combined signal"

    • Context and Importance: This term appears to be the central novel element of the claimed invention, describing how the user preference and ambient light data are combined. The interpretation of "multiplier" and whether it is limited to specific hardware implementations will likely be dispositive for the infringement analysis. Practitioners may focus on this term because the accused products are digital systems that likely use software algorithms, whereas the patent specification provides examples of analog and mixed-signal circuits.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests that a "software algorithm can be used to multiply the light sensor output with the user selectable brightness control," which may support reading the claim on a software-based implementation (’117 Patent, col. 2:7-9).
      • Evidence for a Narrower Interpretation: The claim preamble recites a "brightness control circuit," and the detailed description provides specific circuit diagrams (e.g., Fig. 4, using current-steering diodes) to perform the multiplication (’117 Patent, Claim 1; col. 6:33-34). This could support a narrower construction limited to the disclosed hardware embodiments or their equivalents.

  • The Term: "dark level bias configured to adjust the combined signal"

    • Context and Importance: This term defines how the system ensures a minimum brightness level. The dispute may center on the word "adjust," specifically whether the accused software applies a simple floor value or performs an adjustment to the "combined signal" itself, as the claim requires.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The summary of the invention describes the function broadly as ensuring a "predefined (or minimum) brightness in total ambient darkness," which might encompass any method of achieving that result (’117 Patent, col. 2:58-62).
      • Evidence for a Narrower Interpretation: The claim language requires that the bias be "configured to adjust the combined signal." This suggests a specific sequence of operations where the bias is applied to the output of the "multiplier." The block diagram in Figure 2, for example, shows a "summing circuit" adding the bias after the multiplication step, which could be argued to define the required structure and sequence (’117 Patent, col. 5:21-24).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Apple induces infringement by providing customers with advertising materials, product manuals, and websites that instruct on how to use the accused "automatic brightness" and "Auto-Brightness" features (Compl. ¶27).
  • Willful Infringement: The willfulness allegation is based on Apple's alleged actual knowledge of the ’117 patent as of January 27, 2020, via a letter from the plaintiff. The complaint alleges that Apple continued its infringing activities despite this notice (Compl. ¶31).

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

  • A core issue will be one of claim construction: can the term "multiplier," arising from the context of a "brightness control circuit," be construed to encompass the software-based algorithms allegedly used in Apple's highly integrated digital processing systems, or is it limited to the analog and mixed-signal hardware disclosed in the patent? The outcome of the prior Markman hearing in the Dell case may provide an early indication of the court's direction on this question.
  • A second key issue will be evidentiary: assuming a favorable claim construction, the case will turn on technical evidence demonstrating how the accused Apple software actually operates. Specifically, does it perform a mathematical multiplication of sensor and user inputs, and does its method of ensuring a minimum brightness level meet the claim requirement of a "dark level bias configured to adjust the combined signal"?