Graziano LEP IP LLC v. Wayfair Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Graziano LED IP LLC (Texas)
  • Defendant: Wayfair, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:24-cv-00343, W.D. Tex., 12/27/2024
• Venue Allegations: Venue is alleged to be proper in the Western District of Texas because Defendant has a regular and established place of business in the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s sale of lighting products, specifically LED lamps integrated with electric fans, infringes a patent related to the structure and functionality of such integrated lighting systems.
• Technical Context: The technology concerns the integration of customizable, color-changing LED lighting modules into electric ceiling fans, replacing traditional, less versatile light sources.
• Key Procedural History: The complaint body substantively alleges infringement of U.S. Patent No. 10,125,971. The prayer for relief, however, references different patent numbers ('984 and '793), suggesting a potential scrivener's error that may require a corrected pleading. Plaintiff states it is a non-practicing entity and addresses the patent marking statute by noting it has entered into settlement licenses that did not permit the production of a patented article.

Case Timeline

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

U.S. Patent No. 10,125,971 - LED lamp integrated to electric fan

Issued November 13, 2018

The Invention Explained

• Problem Addressed: The patent's background describes prior art lighting fixtures for ceiling fans as employing traditional incandescent or fluorescent lamps, which can be bulky and lack the ability to change the color of the emitted light on demand (’971 Patent, col. 2:55-63; col. 2:9-16).
• The Patented Solution: The invention proposes a compact, integrated LED lamp for an electric fan that uses a "flat" light box containing a multiplicity of light-emitting diodes (LEDs), including programmable Red, Green, and Blue (RGB) LEDs. This assembly, comprising a translucent body, an internal reflective coating, a diffuser, and vent holes, allows a user to programmatically change the color and hue of the light, for instance, based on the time of day (’971 Patent, Abstract; col. 2:17-31). The specific arrangement and spacing of the LEDs relative to the diffuser are designed to produce uniform light emission (’971 Patent, col. 4:30-34).
• Technical Importance: The described technology provides a method for creating more versatile, aesthetically customizable, and potentially more compact and energy-efficient lighting solutions for ceiling fans compared to prior art options (’971 Patent, col. 2:32-49).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 of the ’971 Patent (Compl. ¶13). Independent claim 1 is central to the dispute.
• Independent Claim 1 requires:
  • A combination of a light box with an electric fan.
  • The light box must have a translucent plastic outer body defining a cavity, with an optical diffuser placed on its rim to form an enclosure.
  • A plurality of the internal surfaces must be coated with an optically reflective coating.
  • The body must have a plurality of vent holes configured for cooling.
  • The light box must contain multiple LED packages assembled with a "predetermined pitch" and at a "predetermined distance" from the diffuser.
  • This pitch and distance must bear a "fixed relationship for uniform light emission."
  • The LED packages must contain LED chips that emit different colors of light when powered.
  • The light box must be "continuously powered during operation of said fan."
• The complaint does not specify which dependent claims may be asserted.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "lights with ceiling fans and related systems" sold, offered for sale, or imported by Wayfair (Compl. ¶14).

Functionality and Market Context

The complaint alleges that Wayfair commercializes products that integrate LED lights with ceiling fans (Compl. ¶6). The functionality central to the infringement allegations is the use of an integrated LED lighting system within a ceiling fan assembly. The complaint references an installation and assembly manual for an unspecified product, suggesting that the instructions provided to customers to assemble and use these products are relevant to the infringement claims (Compl. ¶14). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a non-appended "Exhibits B" for its infringement allegations and does not provide a claim chart (Compl. ¶12). The narrative alleges that Defendant's products, such as those with installation instructions available at the URL cited in paragraph 14, infringe claims 1-20 of the '971 Patent (Compl. ¶13, ¶14). The infringement theory appears to be that commercially available ceiling fans with integrated LED light kits sold by Wayfair contain the structural and functional elements recited in the patent's claims.

• Identified Points of Contention:
  • Structural Questions: A central question will be whether the accused products meet the specific structural limitations of claim 1. This includes whether they possess a "translucent plastic outer body," whether their "internal surfaces" have an "optically reflective coating," and whether they have "vent holes configured to cool." The complaint does not provide specific evidence on these points.
  • Functional Relationship Question: The claim requires a "fixed relationship" between the LED pitch and distance from the diffuser specifically for achieving "uniform light emission." The court may need to determine if the accused products are designed with this specific functional purpose, or if any resulting uniformity of light is merely incidental to a standard design.
  • Operational Question: Claim 1 requires the light box to be "continuously powered during operation of said fan." This raises the question of whether the accused products are wired such that the light kit receives power whenever the fan motor is operating, or if, as is common, the fan and light are on separate circuits that can be operated independently.

V. Key Claim Terms for Construction

• The Term: "a fixed relationship for uniform light emission"

• Context and Importance: This term, which links the structural limitations of "predetermined pitch" and "predetermined distance" to a functional outcome, will likely be a focal point. Infringement may depend on whether this requires a specific, optimized design intended to produce uniform light, or if it can read on any standard arrangement of LEDs that results in a generally uniform appearance.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party might argue the plain and ordinary meaning covers any configuration where the pitch and distance are set and result in light that a person would perceive as uniform.
  • Evidence for a Narrower Interpretation: The specification states that the parameters "'d' [pitch] and 'h' [distance] are optimized to obtain an uniform and high brightness of light rays" (’971 Patent, col. 4:30-32). This language suggests a specific, deliberate optimization process is part of the claimed "fixed relationship."

• The Term: "continuously powered during operation of said fan"

• Context and Importance: This limitation appears to describe the operational state of the device. Practitioners may focus on this term because its plain meaning suggests the light and fan are not independently switchable, which may not reflect the actual operation of most accused products. The viability of the infringement claim could hinge on the interpretation of this phrase.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue this means only that the circuitry is "live" or capable of being powered while the fan operates, not that the LEDs must be illuminated.
  • Evidence for a Narrower Interpretation: The plain language strongly suggests that when the fan is operating, the light box is also receiving power. The specification does not appear to offer an alternative definition, potentially limiting the claim to fan models with non-standard wiring.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement and contributory infringement based on Defendant actively encouraging and instructing customers on how to use the accused products in an infringing manner, citing product manuals and website instructions as evidence (Compl. ¶13, ¶14).
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’971 Patent from "at least the filing date of the lawsuit" (Compl. ¶13, ¶14). Plaintiff reserves the right to amend if pre-suit knowledge is discovered (Compl. ¶13, fn. 3).

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

This case will likely depend on the resolution of two primary categories of questions:

1. A key evidentiary issue will be one of structural correspondence: does the complaint, and subsequent discovery, provide sufficient evidence that Wayfair's accused products contain the specific, granular structural elements required by claim 1, such as the "optically reflective coating" on internal surfaces and the purpose-driven "vent holes"?

2. A core issue will be one of operational scope: can the claim limitation "continuously powered during operation of said fan" be construed to read on standard ceiling fans where the light kit and fan motor are independently switched, or is the claim limited to a less common configuration where the two are inextricably linked? The answer to this may be dispositive for the infringement analysis.