PTAB

IPR2025-01328

JESCO Lighting Group LLC v. AGS Lighting Management LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Linear Light-Emitting Diode (LED) Lighting Apparatus
  • Brief Description: The ’302 patent discloses a linear, modular LED lighting apparatus that uses separate strings of LEDs with different color temperatures. The system includes a driver and switch assembly to control the brightness and mix the light from the LED strings to produce a user-selected color temperature, and the apparatus can be serially connected to other similar fixtures.

3. Grounds for Unpatentability

Ground 1: Obviousness over Edwards and Sadwick - Claims 1, 2, 4-7, and 9-20 are obvious over Edwards in view of Sadwick.

  • Prior Art Relied Upon: Edwards (Patent 9,995,440) and Sadwick (Application # 2019/0320515).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Edwards discloses the core elements of the challenged claims. Specifically, Edwards teaches a linear LED lighting apparatus with two sets of LEDs arranged in linear shapes, each producing a different color temperature. Edwards also discloses a driver circuit (control circuit 217) and a switch assembly (dimmer switch 215a and color temperature switch 215b) to control brightness and color. Further, Edwards describes the ability to connect multiple linear lamp fixtures of varying lengths in series. Petitioner contended that to the extent Edwards’ use of a remote wavelength conversion component is distinct from the claimed invention, Sadwick teaches the use of conventional, "phosphor coated" white LEDs to achieve different color temperatures. Sadwick also discloses more granular current control mechanisms than Edwards.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Sadwick’s conventional phosphor-coated LEDs with the Edwards system to achieve substantial advantages in cost and ease of manufacturing compared to Edwards’ separate wavelength conversion component. Additionally, a POSITA would be motivated to incorporate Sadwick's current control circuits into Edwards to achieve more granular and predictable control over brightness, a known design goal.
    • Expectation of Success (for §103 grounds): Because both Edwards and Sadwick are directed to controlling color temperature in LED lighting and use standard, well-known circuit components, a POSITA would have had a reasonable expectation of success in combining their features to obtain a predictable result.

Ground 2: Obviousness over May and Jeswani - Claims 1-14 and 16-20 are obvious over May in view of Jeswani.

  • Prior Art Relied Upon: May (Application # 2019/0041009) and Jeswani (Patent 10,683,969).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that May discloses a linear LED lamp with key features of the ’302 patent, including two parallel strings of LED emitters with different color temperature ranges. May’s control module acts as a driver circuit, varying the current to each string to control brightness and color, and can receive instructions via data communications. May also discloses connecting multiple lamps of different lengths in series via Ethernet cables for power and data. Petitioner argued that for any claimed switch features not explicitly taught by May’s networked control system, Jeswani discloses a physical switch assembly mounted on a lamp housing with separate, user-selectable positions for brightness (lumens) and color temperature (CCT).
    • Motivation to Combine (for §103 grounds): A POSITA would combine Jeswani’s physical switches with May’s networked system to provide a simple, local, and reliable method for user control. This would be desirable as a primary interface or as a backup in case of network failure, representing a common design choice of adding manual controls to electronically-controlled devices for improved usability.
    • Expectation of Success (for §103 grounds): The integration of a conventional manual switch (Jeswani) to control an electronic module (May) was a well-understood and routine modification in the art. Therefore, a POSITA would have reasonably expected the combination to function predictably.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 2, 3, and 8 are obvious over Edwards, Sadwick, and further in view of Jeswani for its teaching of a flush-mounted switch with specific selectable positions. Petitioner also asserted that claim 15 is obvious over May, Jeswani, and further in view of Sadwick for its teaching of a driver circuit comprising a current regulator.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-20 of the ’302 patent as unpatentable.