DCT

3:18-cv-00027

Unity Opto Technology Co Ltd v. Lowe's Home Centers LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:18-cv-00027, W.D. Wis., 01/12/2018
  • Venue Allegations: Venue is alleged to be proper in the Western District of Wisconsin because Defendants sell the accused products in the district and maintain a regular and established place of business, specifically a retail store in Plover, Wisconsin.
  • Core Dispute: Plaintiff alleges that Defendants’ Utilitech-branded LED panel light fixtures infringe four patents related to the structural design and internal component layout of flat panel lighting devices.
  • Technical Context: The technology concerns flat panel LED luminaires, an energy-efficient lighting solution designed to replace legacy fluorescent troffer fixtures commonly found in commercial and residential ceilings.
  • Key Procedural History: The complaint alleges that Plaintiff notified Defendants of infringement on October 25, 2017, approximately two and a half months prior to filing suit, which forms the basis for the willfulness allegations. All four asserted patents stem from the same provisional application, indicating a focused patenting strategy around a core set of related inventions.

Case Timeline

Date Event
2011-12-22 Earliest Priority Date for all Patents-in-Suit
2016-05-10 ’036 Patent Issued
2016-08-23 ’113 Patent Issued
2016-09-20 ’954 Patent Issued
2016-12-20 ’487 Patent Issued
2017-10-25 Date of Alleged Notice of Infringement to Defendants
2018-01-12 Complaint Filing Date

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

U.S. Patent No. 9,423,113 - "[f]lat panel lighting device and driving circuitry,"

  • Issued: August 23, 2016 (Compl. ¶10)

The Invention Explained

  • Problem Addressed: The patent family addresses challenges with prior art lighting systems, including the high operating costs of fluorescent lights and the design limitations of early LED panels, which often required bulky AC-to-DC power converters external to the fixture's main housing ('036 Patent, col. 1:36-40, col. 2:20-29).
  • The Patented Solution: The invention integrates the power conversion circuitry directly into a channel within the fixture's frame. To achieve this, the circuitry is designed with a long, narrow form factor (a high length-to-width ratio), enabling a self-contained and substantially flat final product. The design utilizes an edge-lit configuration where LEDs are placed along the perimeter of an optically transmissive panel to generate a uniform light output (Compl. ¶13; ’036 Patent, col. 2:55-62, Fig. 14).
  • Technical Importance: This integrated design eliminates the need for an external power supply box, facilitating the creation of thinner, more versatile LED fixtures that are simpler to install and can serve as direct replacements for standard ceiling troffers ('036 Patent, col. 2:35-39).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶29).
  • The essential elements of claim 1 include:
    • A frame configured to define a first channel.
    • A substantially flat light emitting diode (LED) panel disposed within the frame.
    • Power circuitry disposed within the first channel and configured to couple the LED panel to an external AC power supply.
    • The power circuitry is sized to be positioned entirely within the first channel and has a length-to-width ratio of at least 5 to 1.
  • The complaint also asserts dependent claims 2-11, 13-20, 22-24, and 26-27 (Compl. ¶30).

U.S. Patent No. 9,335,036 - "[f]lat panel lighting device and driving circuitry,"

  • Issued: May 10, 2016 (Compl. ¶14)

The Invention Explained

  • Problem Addressed: As with the ’113 Patent, this patent addresses the need for a thin, integrated LED lighting fixture ('036 Patent, col. 1:20-24).
  • The Patented Solution: This patent claims a specific arrangement featuring two separate arrays of LEDs placed on opposite sides of the frame. It further claims a "driver" housed on a third side of the frame, where this driver itself "includes a first LED driver" coupled to the first array and a "second LED driver" coupled to the second array. This architecture allows for more complex electrical control within the integrated, flat-panel form factor (Compl. ¶37; '036 Patent, Fig. 25, col. 21:5-10).
  • Technical Importance: This configuration enables designs with dual power circuits, which may provide redundancy, improved light uniformity across a larger panel, or the ability to power different sets of LEDs for varied lighting effects ('036 Patent, col. 4:38-50).

Key Claims at a Glance

  • The complaint asserts independent claim 9 (Compl. ¶37).
  • The essential elements of claim 9 include:
    • A frame with channels on opposite first and second sides.
    • An LED panel with a first LED array adjacent the first side and a second LED array adjacent the second side.
    • A driver housed within the frame at a third side.
    • The driver includes a first LED driver coupled to the first array and a second LED driver coupled to the second array.
    • The drivers are configured to connect the LED arrays to an external power supply.
    • The driver has a length-to-width ratio of at least 5 to 1.
    • Each driver converts AC input to a DC output.
  • The complaint also asserts dependent claims 10-13 and 15-20 (Compl. ¶38).

U.S. Patent No. 9,523,487 - "[f]lat panel lighting device and driving circuitry,"

  • Issued: December 20, 2016 (Compl. ¶18)
  • Technology Synopsis: This patent claims a flat panel light with a frame thickness of no more than about 1.0 inch. It specifies the structural relationship where an LED strip is mounted to one part of the frame adjacent to the light-input edge of an optically transmissive panel, while the LED driver is housed entirely within a channel formed by another part of the frame (Compl. ¶¶ 21, 44).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶44).
  • Accused Features: The accused product is alleged to have a frame thickness under 1.0 inch, an LED strip that edge-lights a panel, and a driver housed entirely within a channel in the frame (Compl. ¶44).

U.S. Patent No. 9,447,954 - "[l]ight fixture having a central wire-way,"

  • Issued: September 20, 2016 (Compl. ¶22)
  • Technology Synopsis: This patent addresses the practical challenge of wiring by claiming a light fixture with a "central wire-way" on its back surface. This feature is configured to route electrical wiring from a central entry point to the power circuitry, which is located in channels at the opposite edges of the frame (Compl. ¶¶ 25, 51).
  • Asserted Claims: Independent claim 18 is asserted (Compl. ¶51).
  • Accused Features: The accused product is alleged to have a central wire-way on its back surface configured to route wiring to power circuitry disposed in channels on opposite edges of the frame (Compl. ¶51).

III. The Accused Instrumentality

Product Identification

  • The Utilitech 2x2 LED Panel Light Model Number SL4K22 (Item/Article #0728003) (Compl. ¶2).

Functionality and Market Context

  • The complaint describes the Accused Product as a flat panel LED light fixture sold by Lowe's, a national home improvement retailer (Compl. ¶¶ 2, 4). The allegations indicate the product incorporates its power conversion electronics ("drivers") within channels in its frame, uses an edge-lighting architecture, has a frame less than one inch thick, and includes a central channel on its back for routing wires (Compl. ¶¶ 29, 37, 44, 51). This suggests the product is a mass-market device designed for easy installation in place of standard ceiling fixtures.
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,423,113 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a frame configured to define a first channel The Accused Products contain a frame configured to define a first channel. ¶29 col. 2:55-56
a substantially flat light emitting diode (LED) panel disposed within the frame The Accused Products contain a substantially flat light emitting diode (LED) panel disposed within the frame. ¶29 col. 2:56-57
power circuitry disposed within the first channel, the power circuitry being configured to electrically couple the substantially flat LED panel to an external AC power supply The Accused Products contain drivers disposed within the first channel, and each driver is configured to electrically couple the panel to an external AC power supply. ¶29 col. 2:57-60
wherein the power circuitry is sized to be positioned entirely within the first channel and has a length and a width, the length-to-width ratio being at least 5 to 1 The drivers are sized to be positioned entirely within the first channel and have a length-to-width ratio of at least 5 to 1. ¶29 col. 2:60-62
  • Identified Points of Contention:
    • Scope Questions: A potential issue for claim construction may be whether the term "power circuitry" is synonymous with the "drivers" identified in the Accused Products. While the complaint treats them as equivalent, a defendant may argue that "power circuitry" as defined in the patent requires additional components not present in the accused "drivers".
    • Technical Questions: The complaint makes a conclusory allegation that the accused drivers meet the specific "length-to-width ratio of at least 5 to 1" limitation. A central evidentiary question will be what proof Plaintiff offers to substantiate this specific dimensional requirement.

U.S. Patent No. 9,335,036 Infringement Allegations

Claim Element (from Independent Claim 9) Alleged Infringing Functionality Complaint Citation Patent Citation
a frame configured to define a first channel and a second channel on opposite first and second sides of the frame The Accused Products contain a frame configured to define a first channel and a second channel on opposite first and second sides of the frame. ¶37 col. 20:59-61
a substantially flat light emitting diode (LED) panel disposed within the frame, the substantially flat LED panel including a first array of LEDs disposed adjacent the first side of the frame and a second array of LEDs disposed adjacent the second side of the frame The Accused Products contain a substantially flat LED panel that includes a first array of LEDs disposed adjacent the first side and a second array of LEDs disposed adjacent the second side. ¶37 col. 21:1-4
a driver housed within the frame at a third side of the frame, wherein the driver includes a first LED driver operatively coupled to the first array of LEDs and a second LED driver operatively coupled to the second array of LEDs The Accused Products contain a driver housed within the frame at a third side, wherein the driver includes a first LED driver operatively coupled to the first array of LEDs and a second LED driver operatively coupled to the second array of LEDs. ¶37 col. 21:5-10
wherein the driver has a length and a width, wherein the length-to-width ratio is at least 5 to 1 The power circuitry in the Accused Products has a length-to-width ratio of at least 5 to 1. ¶37 col. 21:15-17
  • Identified Points of Contention:
    • Scope Questions: The claim requires "a driver...wherein the driver includes a first LED driver...and a second LED driver." The interpretation of this "driver-within-a-driver" structure will be critical. The dispute may focus on whether this requires two physically distinct sub-components within a single housing, or if a single integrated circuit performing two driving functions can meet the limitation.
    • Technical Questions: The complaint alleges that the "power circuitry" has the required 5-to-1 ratio, but the claim applies this limitation specifically to "the driver" housed at the third side. This raises the question of whether the complaint's allegation accurately maps to the claim language and whether the specific accused component meets the dimensional requirement.

V. Key Claim Terms for Construction

  • The Term: "power circuitry" (’113 Patent, Claim 1)

    • Context and Importance: This term's definition is foundational to the infringement theory for the ’113 Patent. The complaint uses the term "drivers" to describe the accused feature, and the relationship between "power circuitry" and "driver" will be a central point of construction. Practitioners may focus on this term because a narrow definition could create a mismatch with the accused product's architecture.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests the terms may be interchangeable, stating that "power circuitry" is "also referred to as driving circuitry, and as LED power circuitry or LED driving circuitry" ('036 Patent, col. 3:9-12).
      • Evidence for a Narrower Interpretation: The specification also states that "the power circuitry includes driving circuitry configured to convert an AC input into a DC output" ('036 Patent, col. 2:37-39). This language could support an argument that "driving circuitry" is merely a sub-component of the broader "power circuitry," implying that the full claim limitation requires more than just a driver.

  • The Term: "a driver housed within the frame at a third side of the frame, wherein the driver includes a first LED driver...and a second LED driver" (’036 Patent, Claim 9)

    • Context and Importance: The infringement reading of claim 9 hinges on the physical and electrical structure of the accused "driver." The dispute will likely concern whether a single integrated component can satisfy the requirement of a "driver" that "includes" two other drivers.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's block diagrams, such as Figure 25, depict a single "Driving Circuitry" block (16) that contains separate blocks for a "First Driver" (52) and a "Second Driver" (54) ('036 Patent, Fig. 25). This may support an interpretation that a single physical housing can contain functionally distinct driver circuits to meet the claim.
      • Evidence for a Narrower Interpretation: The claim language "a driver...includes a first LED driver...and a second LED driver" could be interpreted to require three distinct physical structures: a main housing ("the driver") that in turn contains two smaller, separate components ("first LED driver" and "second LED driver").

VI. Other Allegations

  • Willful Infringement: The complaint alleges that Defendants had actual knowledge of all four patents-in-suit as of October 25, 2017, due to being notified by Plaintiff. It is alleged that Defendants' continued infringement after this date constitutes willful infringement, entitling Plaintiff to enhanced damages (Compl. ¶¶ 31, 39, 46, 53).

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

  • A core issue will be one of definitional scope: can the term "power circuitry" be construed as synonymous with the accused product's "driver", and can the accused "driver" be shown to contain the two distinct "LED drivers" required by the '036 patent? The resolution will depend on whether these claim terms require physically separate components or can be met by integrated, multi-function circuits.
  • A key evidentiary question will be one of factual proof: what technical evidence will substantiate the complaint's conclusory allegations, particularly the assertion that the accused product's internal components meet the specific "length-to-width ratio of at least 5 to 1" required by the asserted claims?
  • A central infringement question will be one of structural correspondence: does the physical layout of the accused product—including its frame channels, component placement, and central wire-way—map directly onto the specific geometric and functional relationships recited across the four asserted patents, or do material differences exist?