DCT

7:25-cv-00360

EdisonLED LLC v. Home Depot Inc

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00360, W.D. Tex., 11/13/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendants maintain regular and established places of business in the district—including corporate offices, technology centers, distribution centers, and retail stores—and have committed the alleged acts of infringement there.
  • Core Dispute: Plaintiff alleges that a wide range of Defendant’s Ecosmart brand LED light bulbs infringe fifteen patents related to LED structure, packaging, optical efficiency, and thermal management.
  • Technical Context: The technology relates to solid-state lighting, specifically LED filament-style bulbs, which have largely replaced incandescent and compact fluorescent lamps in the consumer and commercial lighting markets.
  • Key Procedural History: The patents-in-suit were assigned to Plaintiff from Epistar Corporation, a major LED manufacturer. The complaint notes that Epistar has previously litigated several of the patents-in-suit against other retailers, including a case against Lowe's Companies that resulted in a jury verdict finding U.S. Patent No. 7,560,738 valid and infringed. Plaintiff also alleges providing Defendant with pre-suit notice of infringement through multiple letters and over 244 detailed claim charts beginning in September 2024.

Case Timeline

Date Event
2003-07-04 U.S. Patent No. 7,560,738 Priority Date
2005-01-25 U.S. Patent No. 7,489,068 Priority Date
2008-11-13 U.S. Patent No. 8,240,881 Filing Date
2009-02-10 U.S. Patent No. 7,489,068 Issue Date
2009-07-14 U.S. Patent No. 7,560,738 Issue Date
2011-10-26 U.S. Patent No. 9,793,451 Priority Date
2012-05-29 U.S. Patent No. 9,166,116 Priority Date
2012-05-29 U.S. Patent No. 9,741,699 Priority Date
2012-05-29 U.S. Patent No. 11,808,436 Priority Date
2012-08-15 U.S. Patent No. 10,319,703 Priority Date
2012-12-01 Defendant The Home Depot acquires BlackLocus, Inc. (approximate)
2013-03-18 U.S. Patent No. 9,065,022 Filing Date
2013-06-11 U.S. Patent No. 9,664,340 Priority Date
2013-06-11 U.S. Patent No. 11,519,564 Priority Date
2013-08-29 U.S. Patent No. 9,368,483 Priority Date
2013-10-22 U.S. Patent No. 10,281,123 Priority Date
2013-10-22 U.S. Patent No. 10,989,396 Priority Date
2013-12-19 U.S. Patent No. 10,224,455 Filing Date
2015-06-23 U.S. Patent No. 9,065,022 Issue Date
2015-10-20 U.S. Patent No. 9,166,116 Issue Date
2016-06-14 U.S. Patent No. 9,368,483 Issue Date
2017-01-01 Epistar litigation against Lowe's initiated (approximate)
2017-05-30 U.S. Patent No. 9,664,340 Issue Date
2017-08-22 U.S. Patent No. 9,741,699 Issue Date
2017-10-17 U.S. Patent No. 9,793,451 Issue Date
2019-03-05 U.S. Patent No. 10,224,455 Issue Date
2019-05-07 U.S. Patent No. 10,281,123 Issue Date
2019-06-11 U.S. Patent No. 10,319,703 Issue Date
2021-04-27 U.S. Patent No. 10,989,396 Issue Date
2022-12-06 U.S. Patent No. 11,519,564 Issue Date
2023-11-07 U.S. Patent No. 11,808,436 Issue Date
2024-09-06 Plaintiff sends first notice letter to Defendant
2025-01-30 Plaintiff sends follow-up notice letter to Defendant
2025-03-24 Plaintiff sends over 244 detailed claim charts to Defendant
2025-11-13 Complaint Filing Date

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

U.S. Patent No. 7,489,068 - “Light emitting device” (issued Feb. 10, 2009)

The Invention Explained

  • Problem Addressed: The patent addresses the problem of poor light extraction efficiency in LEDs, where light becomes trapped and absorbed within the device due to total internal reflection when traveling from a high-refractive-index material (the epitaxial layer) to a low-refractive-index medium (like air or a substrate) (’068 Patent, col. 1:35-45).
  • The Patented Solution: The invention proposes a structure to "increase the light extraction efficiency" by introducing a "diffusing surface" into the light-emitting stack (’068 Patent, col. 1:63-66). This is achieved by placing a transparent adhesive layer between a transparent substrate and the light-emitting stack. The stack itself has a diffusing surface facing the adhesive layer, and the refractive indices of the stack and the adhesive layer are different, a combination designed to scatter light and reduce internal reflection (Compl. ¶48).
  • Technical Importance: This approach provided a structural solution to the fundamental physics problem of light trapping, which was a significant barrier to improving the brightness and overall efficiency of early LED technology (’068 Patent, col. 6:34-40).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶143).
  • Claim 1 requires:
    • a transparent substrate;
    • a light emitting stack having a first diffusing surface above the transparent substrate;
    • a transparent adhesive layer between the transparent substrate and the first diffusing surface;
    • wherein an index of refraction of the light emitting stack is different from that of the transparent adhesive layer.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,560,738 - “Light-emitting diode array having an adhesive layer” (issued Jul. 14, 2009)

The Invention Explained

  • Problem Addressed: The patent describes drawbacks in prior art LED arrays, particularly for certain diode types (quaternary Al-In-Ga-P) that used conductive substrates. This configuration, with electrical contacts on opposite sides of the substrate, made it difficult to connect diodes in series or parallel and created significant heat dissipation challenges as the arrays grew larger (’738 Patent, col. 1:31-41).
  • The Patented Solution: The invention discloses an LED array constructed by forming an adhesive layer on a new substrate, then disposing a plurality of epitaxial light-emitting stack layers on that adhesive layer (’738 Patent, col. 1:45-47). A key aspect of the solution is that each of these stack layers has its positive (P-contact) and negative (N-contact) electrical contacts on the same side, which facilitates electrical connection and improves "heat-dissipation efficiency" (Compl. ¶55; ’738 Patent, col. 4:17-23).
  • Technical Importance: This "same side contact" architecture, enabled by transferring LED layers to a new substrate via an adhesive, was a key step in allowing the fabrication of larger, more complex, and more thermally stable LED arrays (’738 Patent, col. 4:17-23).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶156).
  • Claim 1 requires:
    • a substrate;
    • an adhesive layer formed on the substrate;
    • a plurality of electrically connected epitaxial light-emitting stack layers disposed on the adhesive layer;
    • each of the epitaxial light-emitting stack layers comprising a P-contact and an N-contact;
    • wherein the P-contact and the N-contact are disposed on the same side of the epitaxial light-emitting stack layer.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 8,240,881

  • Patent Identification: U.S. Patent No. 8,240,881, “Light-emitting device package,” issued August 14, 2012 (Compl. ¶56).
  • Technology Synopsis: The patent addresses light absorption and reduced efficiency in traditional LED packages where the diode chip is mounted parallel to a carrier surface (Compl. ¶¶61-62). The complaint includes a diagram from the patent, FIG. 1, showing light being reflected back into the multi-quantum well layer, causing absorption (Compl. ¶61, p. 16). The solution is a package where the light-emitting device is mounted on a platform at an angle between 45 and 135 degrees to improve light extraction (Compl. ¶63).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶169).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’881 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶168-169).

U.S. Patent No. 9,065,022

  • Patent Identification: U.S. Patent No. 9,065,022, “Light-emitting apparatus,” issued June 23, 2015 (Compl. ¶64).
  • Technology Synopsis: The patent describes limitations of traditional LEDs for wide-angle lighting, including low efficiency and inflexibility due to planar, opaque substrates (Compl. ¶¶68-69). The invention is a light-emitting apparatus where the LED chip has a light emitting angle wider than 180°, allowing light to penetrate into the substrate and emerge from the opposing side. This light-emitting device is coupled to a support base at an angle (Compl. ¶70).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶182).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’022 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶181-182).

U.S. Patent No. 9,166,116

  • Patent Identification: U.S. Patent No. 9,166,116, “Light emitting device,” issued October 20, 2015 (Compl. ¶71).
  • Technology Synopsis: This patent addresses similar problems as the ’022 Patent: low efficiency and inflexible substrates for wide-angle lighting (Compl. ¶¶75-76). The solution is a device with multiple LED chips on a substrate where the light emitting angle is wider than 180°, light penetrates the substrate, and the area of the substrate’s main surface is at least five times the total area of the chips’ light-emitting surfaces (Compl. ¶77).
  • Asserted Claims: At least independent Claim 17 (Compl. ¶195).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’116 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶194-195).

U.S. Patent No. 9,368,483

  • Patent Identification: U.S. Patent No. 9,368,483, “Illumination device capable of decreasing shadow of lighting effect,” issued June 14, 2016 (Compl. ¶78).
  • Technology Synopsis: The patent addresses the inability of conventional single-sided LEDs to provide required lighting effects and their tendency to create shadows (Compl. ¶82). The invention is an illumination device with a symmetrical supporting base where light-emitting elements are disposed on tilted supports around a center, providing bidirectional light emission to decrease shadowing (Compl. ¶83).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶208).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’483 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶207-208).

U.S. Patent No. 9,664,340

  • Patent Identification: U.S. Patent No. 9,664,340, “Light-emitting device,” issued May 30, 2017 (Compl. ¶84).
  • Technology Synopsis: The patent addresses the need for a light-emitting apparatus with an omnidirectional light pattern not available in conventional devices (Compl. ¶88). The solution is a device with a carrier having electrodes on its top and bottom surfaces and a light-emitting unit on top, all covered by a transparent body, to achieve omnidirectional emission (Compl. ¶89).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶221).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’340 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶220-221).

U.S. Patent No. 9,741,699

  • Patent Identification: U.S. Patent No. 9,741,699, “Light emitting device,” issued August 22, 2017 (Compl. ¶90).
  • Technology Synopsis: The patent addresses similar problems as the ’022 and ’116 Patents, including low efficiency and inflexible substrates (Compl. ¶¶94-95). The invention is an apparatus where a light-emitting device (containing two diode chips on a substrate with a continuous wavelength conversion layer) is coupled to a support base at an angle (Compl. ¶96).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶234).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’699 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶233-234).

U.S. Patent No. 9,793,451

  • Patent Identification: U.S. Patent No. 9,793,451, “Light-emitting diode device,” issued October 17, 2017 (Compl. ¶97).
  • Technology Synopsis: The patent addresses light absorption and reduced efficiency in larger LED chips (Compl. ¶102). The complaint includes a diagram from the patent, FIG. 1, illustrating downward-emitted light being reflected by a reflector (Compl. ¶101, p. 25). The solution is an encapsulated device where a transparent substrate is mounted non-parallel to a circuit carrier, with specific layers of transparent glue covering the chip and substrate to enhance light efficiency (Compl. ¶103).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶247).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’451 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶246-247).

U.S. Patent No. 10,224,455

  • Patent Identification: U.S. Patent No. 10,224,455, “Light-emitting device and method of forming the same,” issued March 5, 2019 (Compl. ¶104).
  • Technology Synopsis: The patent addresses light absorption caused by total internal reflection, which reduces brightness and efficiency (Compl. ¶¶108-109). The invention is a light-emitting device with a specific layered structure, including a transparent substrate with a top surface area at least 1.6 times that of the active layer, and first and second transparent layers between the substrate and the epitaxial structure, to improve brightness (Compl. ¶110).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶260).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’455 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶259-260).

U.S. Patent No. 10,281,123

  • Patent Identification: U.S. Patent No. 10,281,123, “Illumination device,” issued May 7, 2019 (Compl. ¶111).
  • Technology Synopsis: The patent addresses the low luminous efficiency of conventional single-sided LEDs (Compl. ¶115). The solution is a device where a light-emitting element is inserted into a supporting base, and a wavelength conversion layer covers the light-emitting chip and only a portion of the supporting surface, leaving the side surface uncovered, to enhance efficiency (Compl. ¶116).
  • Asserted Claims: At least independent Claim 11 (Compl. ¶273).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’123 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶272-273).

U.S. Patent No. 10,319,703

  • Patent Identification: U.S. Patent No. 10,319,703, “Light bulb,” issued June 11, 2019 (Compl. ¶117).
  • Technology Synopsis: The patent addresses the inefficiency of incandescent lamps and the environmental pollution from CFLs (Compl. ¶121). The invention is a light-emitting device comprising light-emitting units, a transparent structure, and a conductive element that connects at least two of the light-emitting units (Compl. ¶121).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶286).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’703 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶285-286).

U.S. Patent No. 10,989,396

  • Patent Identification: U.S. Patent No. 10,989,396, “Illumination Device,” issued April 27, 2021 (Compl. ¶122).
  • Technology Synopsis: This patent addresses the same problem as the ’123 patent: low efficiency of conventional single-sided LEDs (Compl. ¶126). The solution is also similar: a light-emitting element inserted into a supporting base, where a wavelength conversion layer covers the chip but only a portion of the supporting surface, leaving the side surface uncovered (Compl. ¶127).
  • Asserted Claims: At least independent Claim 11 (Compl. ¶299).
  • Accused Features: The Ecosmart Smart A19 Filament Bulb is accused of infringing the ’396 Patent (Compl. ¶¶298-299).

U.S. Patent No. 11,519,564

  • Patent Identification: U.S. Patent No. 11,519,564, “Light emitting bulb,” issued December 6, 2022 (Compl. ¶128).
  • Technology Synopsis: This patent addresses the need for an omnidirectional light pattern unavailable in conventional devices (Compl. ¶132). The invention is a device with a carrier and two separate electrode strips, each with a main stripe and multiple branches. Light-emitting units are connected between the branches of the two strips to create an omnidirectional light pattern (Compl. ¶133).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶312).
  • Accused Features: The Ecosmart Smart A19 Filament Bulb is among the products accused of infringing the ’564 Patent (Compl. ¶¶311-312).

U.S. Patent No. 11,808,436

  • Patent Identification: U.S. Patent No. 11,808,436, “Light-emitting apparatus,” issued November 7, 2023 (Compl. ¶134).
  • Technology Synopsis: The patent identifies challenges in applying LEDs to traditional lamps, including low efficiency and inflexible substrates (Compl. ¶¶138-139). The solution is an apparatus with two separate light-emitting devices connected to a support base, where each device has LED chips on a substrate and wavelength conversion layers on both the top and bottom surfaces (Compl. ¶140).
  • Asserted Claims: At least independent Claim 1 (Compl. ¶325).
  • Accused Features: A range of Ecosmart bulbs are accused of infringing the ’436 Patent, with the Ecosmart A19 60W Soft White cited as a representative example (Compl. ¶¶324-325).

III. The Accused Instrumentality

Product Identification

The complaint names a wide range of "Ecosmart" brand commercial lighting products, including various models of LED filament bulbs such as the Ecosmart A19, B11, G25, and ST19 types (Compl. ¶2). The complaint frequently uses the "Ecosmart A19 60W Soft White (1006 777 838)" as a representative accused product for its infringement allegations (Compl. ¶¶143, 156).

Functionality and Market Context

The Accused Products are solid-state light bulbs intended for general illumination in consumer and commercial applications (Compl. ¶8). They are sold through Defendant The Home Depot's nationwide retail stores and e-commerce website, homedepot.com (Compl. ¶¶32, 40). The "Ecosmart" brand is owned by Defendant Home Depot Product Authority, LLC, underscoring the products' direct connection to the defendants (Compl. ¶42).

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts attached as exhibits for each asserted patent but does not include the exhibits themselves in the provided document (e.g., Compl. ¶143, referring to Exhibit 24; Compl. ¶156, referring to Exhibit 25). The narrative infringement allegations are summarized below.

U.S. Patent No. 7,489,068 Infringement Allegations

The complaint alleges that the '068 Accused Products, such as the Ecosmart A19 60W Soft White bulb, infringe at least Claim 1 of the '068 Patent (Compl. ¶¶142-143). The infringement theory is that the accused bulbs contain a light-emitting device constructed with the claimed elements: a transparent substrate, a light-emitting stack that has a diffusing surface, and a transparent adhesive layer positioned between the substrate and the diffusing surface, where the stack and adhesive have different refractive indices.

  • Identified Points of Contention:
    • Scope Questions: A central question will be whether any surface texturing or layered interface within the accused product's LED package constitutes a "diffusing surface" as that term is defined and used within the patent's specification and claims.
    • Technical Questions: The analysis may turn on evidence demonstrating the presence and properties of the claimed "transparent adhesive layer." It will be necessary to determine if a distinct adhesive layer exists between the substrate and the light-emitting stack and, if so, whether its index of refraction differs from that of the stack.

U.S. Patent No. 7,560,738 Infringement Allegations

The complaint alleges that the '738 Accused Products, including the Ecosmart A19 60W Soft White bulb, infringe at least Claim 1 of the '738 Patent (Compl. ¶¶155-156). The infringement theory is that the accused products are made with an LED array comprising a substrate, an adhesive layer on the substrate, and multiple "epitaxial light-emitting stack layers" on the adhesive layer, where the P-contact and N-contact for each stack layer are located on the "same side."

  • Identified Points of Contention:
    • Scope Questions: The definition of an "epitaxial light-emitting stack layer" will be critical. The dispute may focus on whether the individual LED dies or chips used in the accused products meet this definition, especially concerning how they are manufactured and assembled.
    • Technical Questions: A key factual question will be the physical location of the positive and negative electrical contacts for each light-emitting element in the accused products. Evidence will be required to show that both contacts are disposed on the "same side" of each element, as required by the claim.

V. Key Claim Terms for Construction

U.S. Patent No. 7,489,068

  • The Term: "diffusing surface" (Claim 1)
  • Context and Importance: This term is the central feature of the claimed solution for improving light extraction. The scope of this term will determine whether various microstructures, textures, or interfaces within the accused product's LED assembly meet the claim limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the diffusing surface as a "rough surface" which "comprises a plurality of micro protrusions" or a "convex-concave surface," language that may support a broader interpretation covering various non-smooth surfaces (’068 Patent, col. 2:25-32).
    • Evidence for a Narrower Interpretation: The patent’s solution is directed at a specific problem of light trapping, and the figures illustrate intentionally created, defined textures. This context may support an argument that the term requires more than incidental surface roughness and implies a structure specifically engineered for diffusion.

U.S. Patent No. 7,560,738

  • The Term: "disposed on the same side of the epitaxial light-emitting stack layer" (Claim 1)
  • Context and Importance: This limitation defines the core structural departure from the prior art, which had contacts on opposite sides of a conductive substrate. The interpretation of "side" will be determinative of infringement, as it defines the required physical arrangement of the P- and N-contacts.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "side" is not explicitly defined and could be argued to mean any general face or surface of the stack layer, potentially encompassing various modern flip-chip or vertical contact configurations.
    • Evidence for a Narrower Interpretation: Figure 1 of the patent depicts both the P-contact (18) and N-contact (19) located on the top surface of the stack layer, opposite the surface bonded to the adhesive layer (12). This could support a narrower construction where "same side" is limited to this specific top-surface configuration (’738 Patent, Fig. 1).

VI. Other Allegations

Indirect Infringement

For each of the fifteen patents-in-suit, the complaint alleges both induced and contributory infringement. The basis for inducement is that Defendants allegedly encourage and instruct customers to use the Accused Products in an infringing manner through promotion, advertising, and user instructions (e.g., Compl. ¶¶145-146). Contributory infringement is alleged on the basis that the Accused Products are not staple articles of commerce suitable for substantial noninfringing use and were especially adapted for infringement (e.g., Compl. ¶148).

Willful Infringement

Willfulness is alleged for all asserted patents. The complaint bases this allegation on Defendant’s alleged pre-suit knowledge of the patents, stemming from multiple notice letters with detailed claim charts sent by Plaintiff starting on September 6, 2024, as well as Defendant’s awareness of prior industry litigation involving the patents-in-suit against competitors (Compl. ¶¶10-18, 149). The allegations suggest a theory of deliberate infringement or willful blindness after being put on notice.

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

  1. A core issue will be one of structural correspondence: Do the micro-architectures of the mass-produced Ecosmart LED bulbs—including their substrates, adhesive layers, contact placements, and optical surfaces—actually embody the specific structural limitations recited in the claims of the fifteen patents-in-suit, such as the "diffusing surface" of the ’068 patent or the "same side" contacts of the ’738 patent?
  2. A significant legal and factual question will concern willfulness and the extent of pre-suit knowledge: Given the complaint’s specific allegations of notice letters containing hundreds of claim charts, the case may turn on what actions, if any, Defendant took to investigate the claims of infringement after September 2024, and whether its continued sales constitute deliberate infringement.
  3. The case presents a question of claim scope in a mature technology field: Many of the patents date to an earlier stage of LED development. A central battleground will likely be whether the claim terms, as construed in light of their specifications, are broad enough to read on modern, highly integrated LED filament and chip-on-board designs, or if those designs represent non-infringing technological advancements.