DCT

6:22-cv-00760

Signify North America Corp v. Shenzhen Intellirocks Tech Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:22-cv-00760, W.D. Tex., 07/08/2022
  • Venue Allegations: Venue is alleged on the basis that the Defendant is not a resident of the United States and may therefore be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s Govee and Minger brand smart LED lighting products infringe five patents related to LED package design, user interface control, modular light strings, and entertainment system integration.
  • Technical Context: The technology at issue involves smart, network-connected LED lighting systems that allow users to control color, intensity, and dynamic effects, often via a mobile application.
  • Key Procedural History: The complaint alleges Defendant received actual notice of infringement for all five patents-in-suit on dates ranging from December 2021 to June 2022, prior to the complaint's filing. These allegations form the basis for the claim of willful infringement.

Case Timeline

Date Event
1997-12-17 Earliest Priority Date for ’026 Patent
2003-05-07 Earliest Priority Date for ’961 Patent
2004-07-08 Earliest Priority Date for ’029 Patent
2007-04-12 Earliest Priority Date for ’541 Patent
2007-11-30 Earliest Priority Date for ’591 Patent
2008-04-15 ’961 Patent Issued
2010-01-12 ’029 Patent Issued
2010-07-27 ’026 Patent Issued
2012-06-26 ’541 Patent Issued
2013-02-19 ’591 Patent Issued
2021-12-28 Alleged Notice of Infringement for ’961 and ’026 Patents
2022-05-12 Alleged Notice of Infringement for ’591 and ’541 Patents
2022-06-13 Alleged Notice of Infringement for ’029 Patent
2022-07-08 Complaint Filed

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

U.S. Patent No. 7,646,029 - "LED PACKAGE METHODS AND SYSTEMS"

  • Patent Identification: U.S. Patent No. 7,646,029, titled “LED PACKAGE METHODS AND SYSTEMS,” issued January 12, 2010.

The Invention Explained

  • Problem Addressed: The patent describes the challenges of powering and controlling LED lighting systems, including issues with power conversion, power factor correction, and the prohibitive cost and space requirements of integrating separate power supplies and control electronics into lighting fixtures (’029 Patent, col. 1:15-67).
  • The Patented Solution: The invention proposes a more integrated LED light source where an electronic component for controlling the LED is incorporated directly onto the submount of the LED package itself (’029 Patent, Abstract). This design aims to simplify the overall system by packaging control functionality closer to the LED die, reducing the need for separate, bulky external components (’029 Patent, col. 2:25-42). Figure 56 illustrates an LED module with an LED, submount (5670), and encapsulating package (5664).
  • Technical Importance: Integrating control logic at the package level was a step toward creating "smart" or "addressable" LEDs, enabling complex, individualized control over many light sources on a single circuit.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶45).
  • Claim 1 requires:
    • A light source comprising: at least one LED die, a first electronic component with a control facility, and a package for the LED die that includes a submount.
    • The submount must incorporate at least one second electronic component for controlling the LED.
    • This second electronic component must be coupled between the first electronic component and the LED die.
    • The second electronic component must facilitate control of the LED die's intensity or apparent intensity.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,358,961 - "User Interface for Controlling Light Emitting Diodes"

  • Patent Identification: U.S. Patent No. 7,358,961, titled “User Interface for Controlling Light Emitting Diodes,” issued April 15, 2008.

The Invention Explained

  • Problem Addressed: The patent notes the difficulty of accurately controlling the color and intensity of multi-color LED systems due to variations in LED performance with temperature, current, and time (’961 Patent, col. 1:39-47). Prior art methods that adjusted intensity by changing the number of active LEDs were described as leading to inaccurate spectral output (’961 Patent, col. 1:47-53).
  • The Patented Solution: The invention discloses a system that combines a touch-screen user interface with a control method based on regulating the "variable time average flow" of current to the LEDs, such as through pulse width modulation (’961 Patent, col. 1:55-68; col. 6:25-28). This approach is intended to provide a more accurate and intuitive way for a user to select a desired color and intensity, as depicted in the graphical user interface of Figure 5, which includes a chromaticity diagram (510) for color selection.
  • Technical Importance: This patent describes a foundational user experience for modern smart lighting: selecting a precise color from a digital interface and having a controller translate that selection into the complex electrical signals needed to produce the color accurately.

Key Claims at a Glance

  • The complaint asserts independent claim 10 (Compl. ¶61).
  • Claim 10 requires:
    • A LED light source with colored LEDs that emit spectral outputs based on a current having a "variable time average flow."
    • A user interface with a touch screen that allows a user to select a "first color point corresponding to the first spectral output."
    • A controller that communicates with the user interface and the light source to control this variable time average flow of current based on the user's selection.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,378,591 - "Light Output Device"

  • Patent Identification: U.S. Patent No. 8,378,591, titled “Light Output Device,” issued February 19, 2013.
  • Technology Synopsis: The patent addresses the problem of controlling individual LEDs in a string light while still allowing the string to be cut to a desired length (Compl. ¶23). The solution involves a device where each light source arrangement has an associated control circuit that processes a serial data signal, allowing the remaining light sources to function independently even after the string is disconnected downstream (’591 Patent, claim 1).
  • Asserted Claims: At least independent claim 1 (Compl. ¶76).
  • Accused Features: The complaint alleges that products like the Govee Model H6062 are modular LED strips where individual segments can be disconnected while the remaining segments stay independently controlled by a serial data signal (Compl. ¶¶78-82).

U.S. Patent No. 7,764,026 - "Systems and Methods for Digital Entertainment"

  • Patent Identification: U.S. Patent No. 7,764,026, titled “Systems and Methods for Digital Entertainment,” issued July 27, 2010.
  • Technology Synopsis: The patent describes improving entertainment systems not just through on-screen graphics or sound, but by coordinating an external lighting system with the content displayed on a screen (Compl. ¶24). The disclosed method involves obtaining a signal related to the screen content and using a control system to deliver a pulse-width modulated signal to an illumination source, thereby synchronizing the room's ambient lighting with the on-screen action (’026 Patent, claim 1).
  • Asserted Claims: At least independent claim 1 (Compl. ¶95).
  • Accused Features: The complaint alleges that products like the Govee Flow Plus Light Bar (Model H6054) use a camera to capture on-screen content and control an array of LEDs to illuminate the surrounding environment in coordination with that content (Compl. ¶¶97-101).

U.S. Patent No. 8,207,541 - "Light Output Device"

  • Patent Identification: U.S. Patent No. 8,207,541, titled “Light Output Device,” issued June 26, 2012.
  • Technology Synopsis: The patent addresses the structural difficulty of enabling individual on/off control for discrete light sources (Compl. ¶25). The solution is a light output device comprising a plurality of light sources and a corresponding plurality of controllers embedded together in a substrate, where a data line connects the controllers in series to selectively turn on each light source (’541 Patent, claim 11).
  • Asserted Claims: At least independent claim 11 (Compl. ¶109).
  • Accused Features: The complaint alleges that products like the Govee RGBICWW Floor Lamp (Model H6072) contain a plurality of light source devices and controllers embedded in a substrate, connected by a data line for selective control (Compl. ¶¶111-115).

III. The Accused Instrumentality

  • Product Identification: Defendant’s Govee and Minger branded smart lighting products, including but not limited to LED strip lights, table lamps, light bars, and floor lamps (Compl. ¶¶4, 13, 29-33). Specific models charted include H6102, H6055, H6062, H6054, and H6072.
  • Functionality and Market Context: The accused products are consumer-grade, multi-color LED lighting systems controlled via a smartphone application, the “Govee Home App” (Compl. ¶15). Their functionality includes changing color and brightness and synchronizing lighting effects with on-screen entertainment content, which is allegedly achieved using a camera that captures the display (Compl. ¶99). The complaint provides a photograph of the Govee Flow Plus Light Bar's "Smart Camera Technology" to illustrate this feature (Compl. ¶99). The products are sold through Defendant's website and major U.S. retailers such as Best Buy, Walmart, and Amazon.com (Compl. ¶¶13, 15).

IV. Analysis of Infringement Allegations

’029 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A light source, comprising: at least one LED die including an LED; The accused Model H6102 includes an LED on a circuit board. A photograph shows the LED component (Compl. ¶47). ¶47 col. 2:50-51
a first electronic component, including a control facility; The product includes an in-line controller attached to the LED strip, which is alleged to be the control facility. ¶48 col. 9:48-49
and a package for the LED die, the package including a submount, The LED is housed in a package mounted on a submount within the product. ¶49 col. 68:7-13
wherein the submount incorporates at least one second electronic component for controlling the LED, The submount allegedly includes a second electronic component, identified by an arrow in a product teardown photograph (Compl. ¶50). ¶50 col. 69:10-12
wherein the at least one second electronic component is coupled between the first electronic component and the LED die, This second component is alleged to be electrically coupled between the in-line controller and the LED die itself. ¶51 col. 80:9-11
and wherein the at least one second electronic component facilitates control of at least one of the intensity and the apparent intensity of the LED die. The component allegedly controls the LED's intensity, with the complaint citing a datasheet for a component believed to be used in the product (Compl. ¶52). ¶52 col. 2:40-42
  • Identified Points of Contention:
    • Scope Questions: The case may turn on whether the accused product's architecture fits the claim's specific two-part controller structure. A question for the court could be whether an off-the-shelf addressable LED, which monolithically integrates a driver IC, meets the limitation of a "submount" that "incorporates" a "second electronic component," or if the patent requires physically distinct components to be assembled onto the submount.
    • Technical Questions: What is the precise identity and function of the alleged "second electronic component"? The complaint points to a component on the submount, suggesting it is the integrated driver circuit within the addressable LED package itself (Compl. ¶50). The factual analysis will depend on the physical construction of this component and its relationship to the "LED die" and "submount" as those terms are construed.

’961 Patent Infringement Allegations

Claim Element (from Independent Claim 10) Alleged Infringing Functionality Complaint Citation Patent Citation
a LED light source including a plurality of colored LEDs operable to emit one of a plurality of spectral outputs as a function of at least one current flowing through said plurality of colored LEDs, each current of the at least one current having a variable time average flow; The accused Model H6055 lamp contains a board with a plurality of colored LEDs. The complaint alleges that testing shows these LEDs are controlled by a current with a variable time average flow. ¶¶64-65 col. 6:58-63
a user interface operable to facilitate a first user selection of a first spectral output from the plurality of spectral outputs, the user interface including a touch screen operable to facilitate the first user selection of a first color point corresponding to the first spectral output; The Govee Home App, which runs on a smartphone or tablet, provides a touch screen color wheel for users to select a desired color output. A screenshot of this interface is provided (Compl. ¶66). ¶66 col. 8:1-3
and a controller in electrical communication with said user interface and said LED light source to control the variable time average flow of each current...as a function of the user selection of the first spectral output. The lamp contains a controller circuit that allegedly communicates with the app and controls the LEDs based on the user's color selection. A photograph of the controller board is provided (Compl. ¶67). ¶67 col. 2:1-4
  • Identified Points of Contention:
    • Scope Questions: A potential issue is whether a system composed of a separate smartphone running an app (the "user interface") and a lamp containing the "controller" and "LED light source" constitutes a single, infringing "LED lighting system" as claimed.
    • Technical Questions: A key evidentiary question will be what proof exists that the accused product controls the LEDs using a "variable time average flow" of current. The complaint makes this assertion based on "testing of products" (Compl. ¶65) but does not provide the underlying data, which will be a focus of discovery.

V. Key Claim Terms for Construction

For the ’029 Patent:

  • The Term: "submount incorporates at least one second electronic component"
  • Context and Importance: This term is central to the patent's contribution of integrating control electronics with the LED at the package level. The infringement analysis for claim 1 depends entirely on whether the accused product's design, which likely uses a modern addressable LED with an integrated driver IC, falls within the scope of this language.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that "the submount 5670 may include one or more other electronic components" (’029 Patent, col. 69:10-12) and lists numerous types of components that could be included, such as a processor, memory, or data interface (’029 Patent, col. 3:3-4:65). This broad language may support an interpretation that includes an integrated control circuit.
    • Evidence for a Narrower Interpretation: The figures, such as Figure 56, depict the LED, submount, and other elements as distinct layers or components assembled together. A party could argue that "incorporates" requires the assembly of a separate component onto the submount, not a monolithic chip where the controller and LED die are fabricated as a single unit.

For the ’961 Patent:

  • The Term: "variable time average flow"
  • Context and Importance: This term defines the technical mechanism of LED control that the patent purports to improve upon prior art. To prove infringement, Plaintiff must show that the accused products use a control method that meets this definition. Practitioners may focus on this term because it distinguishes the claimed invention from simpler on/off control.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification explicitly provides examples of what this term means, stating the control is based on "varying the time average flow of current(s) (e.g, a DC level current or pulse width modulated current)" (’961 Patent, col. 6:25-28). This language suggests the term is intended to be broad enough to cover common techniques like PWM.
    • Evidence for a Narrower Interpretation: A party might argue that the term should be limited by the context of the problems described in the specification, potentially attempting to narrow its scope to exclude certain modern digital control techniques if they can be distinguished from the specific methods disclosed.

VI. Other Allegations

  • Indirect Infringement: For all asserted patents, the complaint alleges active inducement under 35 U.S.C. § 271(b), based on Defendant marketing the infringing products and providing instructions and support that encourage infringing uses (e.g., Compl. ¶¶55, 70). It also alleges contributory infringement under § 271(c), stating the products are not staple articles of commerce and are especially adapted for use in an infringing manner (e.g., Compl. ¶¶56, 71).
  • Willful Infringement: The complaint alleges willful infringement for all five patents. This allegation is based on claims that Defendant had actual, pre-suit notice of its infringement for each patent but "continued its infringing activities despite being aware of Signify's notice" (Compl. ¶¶34-37).

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

This case presents a broad challenge to a portfolio of smart lighting products, asserting infringement across multiple technological layers, from chip-level packaging to system-level user interaction. The outcome will likely depend on the court's resolution of several key questions:

  • A core issue will be one of structural scope: For the '029 and '541 patents, can claims directed at assembling discrete electronic components and LEDs onto a substrate be construed to cover modern, highly-integrated addressable LEDs where the control logic and light emitters may be part of a single, monolithic package?
  • A second central issue will be one of system definition: For patents like the '961, which claim a "system" comprising a user interface, controller, and light source, does a product ecosystem involving a user's smartphone running a downloadable app to control a separate hardware device meet the claim limitations for a single, infringing system?
  • Finally, the case will present an evidentiary question of operational proof: For claims reciting specific functional operations, such as controlling LEDs via a "variable time average flow" of current ('961 Patent) or synchronizing lights with on-screen content ('026 Patent), the dispute may turn on technical evidence from product testing and source code analysis that either confirms or refutes that the accused products perform these exact functions.