A previous post reported on GE's patent infringement suit
asserting several patents relating to LED string light engine structures and
In a recent
decision the U.S. District Court for the Northern District of Ohio
granted AgiLight's motion for summary judgment on the remaining claims of two
patents, U.S. Patent Nos. 7,633,055 ('055 Patent) and 7,832,896 ('896 Patent).
The '055 and '896 Patents are entitled "Sealed light
emitting diode assemblies including annular gaskets and method of making same"
and "LED light engine," respectively.
A key claim term at issue with respect to the
'055 Patent was an "annular gasket," which the court had previously interpreted
to require an opening in its center that is capable of sealing off its center
GE argued that the blue element in Figure 1 below meets
the "annular gasket" element because it is brought into direct sealing contact
with a hollow opening (or socket) in the tooling mold to seal off
the center of the opening.
The court disagreed because the AgiLight device has
multiple openings and GE's argument would encompass any concave structure,
citing precedents more likely to be found at a pâtisserie than a
This interpretation goes too far. First, even
accepting GE's argument, AgiLight's design has multiple openings in a single
blue element to house LEDs, not "an opening." Second, under GE's
understanding, the term "opening" would be synonymous with the inside of any
concave surface. The Court declines to give "opening" such a strained
meaning. Simply put, a croissant is not a donut.
On the '896 Patent, the claim term at issue was a
"substantially ellipsoidal inner profile" to increase the spread of the LED's
light. The court held this feature was lacking from the accused
device because it has important portions that are conical, not ellipsoidal:
The Court finds the "substantially ellipsoidal inner
profile" lacking from AgiLight's designs. In particular, to the sides of
what is arguably an ellipsoidal portion of AgiLight's lens appears a portion
that is conical, and not ellipsoidal. The Sasian Declaration, which is
unrebutted, explains that "[i]t is through the use of all three portions
[spherical, cylindrical, and conical] of the inner surface of the lens that the
lens used in the AgiLight products widens the pattern of light rays emitted by
the LED over which the lens is placed." Given the importance of the
conical portions of AgiLight's lens the Court finds that the entirety of the
lens cannot be considered substantially ellipsoidal.
Accordingly, the court granted AgiLight's motion for
summary judgment that it does not infringe the '055 and '896 Patents.
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