LED Apogee LLC v. NXP USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: LED Apogee LLC (Delaware)
  • Defendant: NXP USA, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 6:24-cv-00021, W.D. Tex., 01/12/2024
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified semiconductor products infringe a patent related to methods for efficiently driving light-emitting diodes (LEDs).
• Technical Context: The technology concerns electronic circuits designed to power LEDs by using a feedback mechanism to minimize energy waste, a key consideration in power-sensitive electronics.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 6,982,527 - "Method for driving light emitting diode," issued Jan. 3, 2006

The Invention Explained

• Problem Addressed: The patent describes a problem in prior art circuits for driving LEDs where a current mirror is controlled by a charge pump with a fixed high-voltage output (e.g., 5V). This fixed voltage often results in significant excess power loss, as the voltage drop across the current mirror can be unnecessarily large depending on the LED's specific forward voltage requirements (PLEDLOSS = ILED(VOUT - VF)). (’527 Patent, col. 1:37-48).
• The Patented Solution: The invention proposes a method where the input voltage to the current mirror is not fixed but is actively regulated. It achieves this by using the input of the LED itself as a "voltage feedback point." This feedback loop works to maintain a constant, and presumably small, voltage difference between the input and output of the current mirror, thereby significantly reducing the power loss described in the prior art. (’527 Patent, Abstract; col. 4:5-18).
• Technical Importance: This approach to dynamically regulating voltage based on the LED's operating state allows for more power-efficient driver circuits, which is critical for extending battery life in portable devices and managing heat in compact electronics. (’527 Patent, col. 1:49-53).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead incorporating by reference charts from an external exhibit that identify the "Exemplary '527 Patent Claims" (Compl. ¶11). The patent contains four independent claims (1, 6, 11, and 16). Independent Claim 1 is representative:
• Claim 1 (Method):
  • providing a control terminal voltage of said current mirror as a reference voltage;
  • increasing a voltage of an input of said current mirror and providing an input of said light emitting diode as a voltage feedback point for keeping a constant voltage difference between said input and said output of said current mirror; and
  • driving said light emitting diode by a voltage at said output of said current mirror.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" but does not name any specific products, models, or product families in the body of the document (Compl. ¶11). It states these products are identified in "Exhibit 2" (Compl. ¶16), which was not filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functions or market position. It makes only a conclusory allegation that the accused products "practice the technology claimed by the '527 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or detailed infringement allegations in its body, instead stating that it "incorporates by reference in its allegations herein the claim charts of Exhibit 2" (Compl. ¶17). As Exhibit 2 was not provided, a claim chart summary cannot be constructed.

The narrative theory of infringement is that Defendant directly infringes by making, using, and selling the "Exemplary Defendant Products," and that these products "satisfy all elements of the Exemplary '527 Patent Claims" (Compl. ¶¶11, 16). No specific technical explanation of how the accused products meet any claim limitations is provided in the complaint itself.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Evidentiary Question: A threshold issue is what evidence Plaintiff will offer to show that the internal circuitry of any accused NXP product performs the specific method steps of the asserted claims. The complaint's current reliance on an un-provided exhibit leaves the factual basis for the allegations entirely unspecified.
• Technical Question: Assuming an accused product is identified, a key technical question will be whether its LED driver circuit actually uses the input of the LED as a "voltage feedback point" for the purpose of "keeping a constant voltage difference" across the current mirror, as required by the claim. The case may turn on whether the accused circuit employs a fundamentally different control mechanism.

V. Key Claim Terms for Construction

The Term: "voltage feedback point"

• Context and Importance: This term is central to the novel aspect of the invention. The infringement analysis will likely depend on whether the control loop in an accused device can be characterized as using the LED input as a "feedback point" in the manner claimed.
• Intrinsic Evidence for a Broader Interpretation: The specification states that "the nodes A42, A43 and A44 of the respective inputs of the white light emitting diodes D42, D43 and D44 are provided as voltage feedback points," which could support an interpretation covering various feedback mechanisms originating at the LED inputs (’527 Patent, col. 4:14-18).
• Intrinsic Evidence for a Narrower Interpretation: A party could argue the term is limited by the embodiment shown in Figure 4, where the feedback appears to regulate the "inductive charge pumping circuit 40." This might suggest the term requires a specific type of control relationship not present in all feedback systems (’527 Patent, Fig. 4).

The Term: "increasing a voltage of an input of said current mirror"

• Context and Importance: This step defines how the circuit generates the necessary voltage. The interpretation of "increasing" could determine whether certain types of voltage-boosting circuits fall within the claim's scope.
• Intrinsic Evidence for a Broader Interpretation: The claim language itself is broad and does not specify the mechanism for "increasing" the voltage.
• Intrinsic Evidence for a Narrower Interpretation: The specification repeatedly and almost exclusively describes this step as being performed by an "inductive charge pumping circuit" (’527 Patent, col. 3:50-52; col. 4:2-4). This focus on an inductor-based solution could be used to argue that the scope of "increasing" should be construed narrowly to distinguish it from the prior art's capacitor-based charge pumps, which the patent criticizes (’527 Patent, col. 1:14-26).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, asserting that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '527 Patent" (Compl. ¶14).

Willful Infringement

The complaint alleges that Defendant has had "actual knowledge of infringement" from the moment of service of the complaint and its attached (but un-filed) claim charts (Compl. ¶13). The allegations appear to establish a basis for post-suit willfulness only.

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

• A Primary Evidentiary Question: The case's immediate future will be defined by an evidentiary question: What specific NXP products are accused of infringement, and can the plaintiff produce technical evidence demonstrating that their internal circuits actually perform each step of the asserted method claims? The complaint, as filed, provides no basis to evaluate this.
• A Core Technical Question: The central technical dispute will likely be one of functional operation. Assuming evidence is presented, the court will have to determine if the accused product's control system uses the LED's input as a "voltage feedback point" to maintain a "constant voltage difference" across a current mirror, or if it achieves power management through a technically distinct, non-infringing method.
• A Defining Claim Construction Question: A key legal battle may center on the scope of the claims. Specifically, will the term "increasing a voltage," which is described in the patent almost exclusively in the context of an inductor, be construed broadly enough to read on the specific voltage-boosting technology employed in the defendant's products?