Citing Pastry Precedents Court Rules Agilight Does Not Infringe GE LED Patents
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 area.
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 semiconductor fab:
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.
Eric Lane is a patent attorney at McKenna Long & Aldridge LLP in San Diego and the author of Green Patent Blog. Mr. Lane can be reached at email@example.com
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