LED Apogee LLC v. Onsemi

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: LED Apogee LLC (Delaware)
  • Defendant: Onsemi (Arizona)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:24-cv-00311, W.D. Tex., 12/03/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district, has committed acts of infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s unnamed semiconductor products infringe a patent related to methods for driving light-emitting diodes (LEDs).
• Technical Context: The lawsuit concerns the field of power electronics, specifically the design of driver circuits that supply power to LEDs efficiently.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events 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"

• Patent Identification: U.S. Patent No. 6,982,527, "Method for driving light emitting diode", issued January 3, 2006.

The Invention Explained

• Problem Addressed: The patent describes drawbacks in prior art circuits used to drive LEDs, particularly those using conventional charge pumps. These prior methods suffered from low efficiency tied to the input voltage and excess power loss occurring across the current mirror that supplied the LED. (’527 Patent, col. 1:27-49).
• The Patented Solution: The invention proposes a method to improve efficiency by actively managing the voltage supplied to the LED driver circuit. Instead of a fixed high-voltage input, the patented method uses an inductive charge pumping circuit to increase the input voltage to a current mirror, and then uses the voltage at the LED itself as a feedback point. This feedback mechanism is used to maintain a "constant voltage difference" between the input and output of the current mirror, which minimizes the power lost as heat and improves overall efficiency. (’527 Patent, col. 1:62 - col. 2:5; Fig. 4).
• Technical Importance: This approach seeks to decouple driver efficiency from fixed input voltages, allowing for more dynamic and efficient power delivery to LEDs, which was a significant consideration as LEDs became more prevalent in various lighting applications. (’527 Patent, col. 3:55-58).

Key Claims at a Glance

• The complaint references "Exemplary ’527 Patent Claims" contained in an exhibit, but does not identify specific claims in the body of the complaint. (Compl. ¶11). Independent method claim 1 is representative of the core invention.
• Independent Claim 1:
  • 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.

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products. It refers generally to "Exemplary Defendant Products" that are identified in "charts incorporated into this Count." (Compl. ¶11). These charts are part of Exhibit 2, which was not filed with the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. It alleges in a conclusory manner that the unspecified products "practice the technology claimed by the ’527 Patent." (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts provided in Exhibit 2. (Compl. ¶13). As this exhibit is not publicly available, the specific factual basis for the infringement allegations cannot be analyzed. The complaint itself offers no narrative description of how any accused product meets the limitations of the asserted claims, stating only that the "Exemplary Defendant Products incorporated in these charts satisfy all elements of the Exemplary ’527 Patent Claims." (Compl. ¶13). No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "keeping a constant voltage difference"

  • Context and Importance: This term describes the core control mechanism of the invention. The outcome of the infringement analysis may depend on the degree of "constancy" required and what circuit behavior qualifies as "keeping" this state. Practitioners may focus on this term because it defines the active feedback loop alleged to be the inventive concept over the prior art.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not specify a particular mechanism, suggesting any method that achieves this functional result could infringe.
    • Evidence for a Narrower Interpretation: The specification describes this step in the context of a specific embodiment using an "inductive charge pumping circuit" and a feedback point to "control" the voltage difference. (’527 Patent, col. 4:5-18). A defendant might argue the term should be limited to the disclosed feedback and control structure.

• The Term: "current mirror"

  • Context and Importance: This is the central circuit component being controlled. The definition of what constitutes a "current mirror" for the purposes of the claims will be critical.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term is a standard one in electrical engineering, and a plaintiff may argue it should be given its plain and ordinary meaning to one of skill in the art.
    • Evidence for a Narrower Interpretation: The patent states that "the current mirror is formed by coupling a plurality of MOS transistors." (’527 Patent, col. 2:9-10). The exemplary figures, such as Figure 4, exclusively show current mirrors constructed from metal-oxide-semiconductor (MOS) transistors. (’527 Patent, Fig. 4). A defendant could argue this disclosure limits the term to MOS-based implementations.

VI. Other Allegations

• Willful Infringement: The complaint does not explicitly allege willful infringement or plead any facts related to pre-suit knowledge by the Defendant. However, the prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285, which could entitle the Plaintiff to attorneys' fees. (Compl. ¶E.i).

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

The initial phase of this case will be defined by the contents of the infringement charts referenced but not included in the complaint. Based on the available documents, the dispute will likely center on the following questions:

1. A Factual and Evidentiary Question: What specific products are accused, and what evidence will Plaintiff provide to show that their internal circuitry performs the precise feedback control method recited in the claims, particularly the step of "keeping a constant voltage difference"?
2. A Claim Construction Question: Will the term "current mirror" be construed broadly to cover various circuit implementations, or will it be limited to the specific MOS-transistor-based embodiments described and depicted in the patent specification?
3. A Procedural Question: Given the sparseness of the initial complaint, a primary issue will be whether the infringement contentions, once served, provide sufficient detail to substantiate the conclusory allegations and move the case beyond a motion to dismiss.