Ferruiz IP LLC v. Cooper Lighting LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ferruiz IP LLC (Texas)
  • Defendant: Cooper Lighting, LLC (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 6:23-cv-00184, W.D. Tex., 03/10/2023
• Venue Allegations: Plaintiff alleges venue is proper based on Defendant’s regular and established place of business in the district, where it allegedly committed acts of infringement and conducts substantial business.
• Core Dispute: Plaintiff alleges that Defendant’s LED lighting systems, luminaires, and lamps infringe a patent related to an optical system for coupling glass lenses to LED fixtures.
• Technical Context: The technology concerns the mechanical and optical components used to mount and seal glass lenses onto LED light sources to control light distribution and efficiency.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2014-04-22	’808 Patent Priority Date
2018-09-04	'808 Patent Issue Date
2023-03-10	Complaint Filing Date

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

U.S. Patent No. 10,066,808 - "Optical System for Luminaries and LED Lighting"

• Patent Identification: U.S. Patent No. 10,066,808, issued September 4, 2018.

The Invention Explained

• Problem Addressed: The patent identifies a need for a versatile optical system that allows high-quality glass lenses to be easily integrated into the wide variety of existing commercial and industrial LED luminaires. It notes that plastic lenses can limit light output and that existing glass lens solutions often lack a universal means for coupling to different fixture designs ('808 Patent, col. 2:7-14, 56-58).
• The Patented Solution: The invention is a multi-component system comprising a glass lens with a specific perimeter rim and a specially designed rubber seal. The rubber seal features an internal slot to receive the lens rim and precisely position the lens relative to the LED. This entire optical assembly is designed to be held in place between the luminaire’s heat sink and a "trim body" solely through compressive force, enabling a secure, removable fit without additional fasteners ('808 Patent, Abstract; col. 2:29-41).
• Technical Importance: The described system offers a standardized method for retrofitting or manufacturing various LED fixtures with efficient glass optics, aiming to improve luminous efficiency and photometric performance across different applications like downlights, industrial modules, and street lighting ('808 Patent, col. 2:7-14).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-6, with Claim 1 being the sole independent claim ('808 Patent, col. 6:55-7:7; Compl. ¶8).
• The essential elements of independent Claim 1 include:
  • A glass lens having a circular lens base with a perimeter rim protruding outward.
  • A rubber circular seal of a complementary size to the lens base.
  • The seal has a vertically straight outer side and an inner side with an internal slot for the lens's perimeter rim.
  • The inner side of the seal further comprises an upper lip (to set separation from the LED) and a lower lip (to collect the perimeter rim).
  • The optical system is "removably retained within the trim body only by pressure" exerted between the heat sink, the upper lip of the seal, the trim body's inner wall, and the seal's outer side.
• The complaint reserves the right to assert other claims, which would include dependent claims 2-6 (Compl. ¶8).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name or model number. It refers generally to Defendant’s "systems, products, and services to provide devices or light systems for LED lighting technology for lenses and optical components used in luminaires and LED lamps" (Compl. ¶8).

Functionality and Market Context

The complaint alleges that the accused products infringe by providing the claimed optical systems but does not describe their specific technical functionality or structure (Compl. ¶8). No allegations regarding the products' specific commercial importance or market position are included.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that a detailed basis for its infringement allegations is provided in an attached claim chart (Exhibit B); however, this exhibit was not included with the provided complaint document (Compl. ¶9). Therefore, a detailed claim-chart summary cannot be constructed. The analysis below identifies potential points of contention based on the claim language and the general nature of the allegations.

Identified Points of Contention

• Scope Questions: A central question may be whether the accused products are "removably retained ... only by pressure" as strictly required by Claim 1 ('808 Patent, col. 7:3-7). The use of any additional fastening means, such as adhesives, clips, or screws to secure the lens and seal assembly within the trim body, could create a significant non-infringement argument. The interpretation of the word "only" will be critical.
• Technical Questions: The infringement analysis will require a detailed structural comparison of the accused products against the claim elements. Key technical questions include:
  • Do the accused products utilize a "crown shaped trim body" with a "vertically straight inner wall," and how will those terms be defined? ('808 Patent, col. 6:57-60).
  • What evidence demonstrates that the seal in the accused products has the specific claimed two-part structure of an "upper lip" and a "lower lip" performing the distinct functions of setting separation and collecting the lens rim? ('808 Patent, col. 7:1-3).

V. Key Claim Terms for Construction

"removably retained ... only by pressure" ('808 Patent, col. 7:3-7)

• Context and Importance: This limitation appears to be a defining feature of the invention, distinguishing it from systems that use other fastening methods. Practitioners may focus on this term because its narrow phrasing could be a primary avenue for a non-infringement defense if the accused products use any additional retention mechanism.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that "only by pressure" should be understood to mean that pressure is the sole intended or primary means of retention, and that incidental contact or insignificant forces from other components do not negate this element. The specification's emphasis on achieving a "perfect coupling" via pressure from the trim body could be used to support this view ('808 Patent, col. 2:15-19).
  • Evidence for a Narrower Interpretation: A party will likely argue that "only" carries its plain and ordinary meaning of "solely" or "exclusively." Any evidence of adhesives, mechanical interlocks (e.g., snap-fits), or fasteners used to retain the lens-seal assembly would, under this interpretation, place the device outside the claim scope. The claim's specific recitation of the four surfaces between which pressure is applied supports a very precise and limited reading ('808 Patent, col. 7:3-7).

"an upper lip of suitable size to achieve a specified separation between the LED and the lens" ('808 Patent, col. 7:1-2)

• Context and Importance: This term imputes a specific function—maintaining a "specified separation"—to a structural element ("upper lip"). The dispute will center on whether the accused seal has a distinct structure that performs this exact function.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent describes the upper protrusion (5) as having an "exact height required to achieve separation" ('808 Patent, col. 4:56-58). A party could argue that any integral feature of the seal that abuts the heat sink and thereby controls the lens distance meets this definition, even if not explicitly labeled a "lip."
  • Evidence for a Narrower Interpretation: The claim language separates the "upper lip" from the "lower lip," suggesting they are distinct structural features. A party could argue that a simple, uniform seal wall does not have the claimed "lip" structure. The figures, such as Figure 2, show the upper lip (5) as a discrete protrusion, which could be used to argue for a more limited structural requirement ('808 Patent, Fig. 2).

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement. It asserts that Defendant actively encourages and instructs customers on how to use its products to infringe, and that there are no substantial non-infringing uses for the accused products and services (Compl. ¶10, ¶11).

Willful Infringement

The complaint alleges willfulness and seeks enhanced damages. The basis for knowledge is alleged to be "at least the filing date of the lawsuit," indicating a theory of post-filing willfulness, while reserving the right to prove pre-suit knowledge if discovered (Compl. ¶10, ¶11; Prayer for Relief ¶e).

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

• A core issue will be one of definitional scope: can the claim limitation "removably retained ... only by pressure" be read to cover an accused system that incorporates any other form of mechanical or adhesive retention for the optical assembly? The court's construction of the word "only" will be dispositive for this question.
• A key evidentiary question will be one of structural correspondence: given the complaint's lack of specific product identification, a central task for the plaintiff will be to produce evidence showing the accused products contain the specific, detailed structures recited in Claim 1, particularly the two-lipped rubber seal and the "crown shaped trim body." The case may turn on whether the accused products' components map directly onto these claimed elements.