Litepanels Files New 337 Complaint Regarding Certain LED Photographic Lighting Devices
On August 3, 2011, Litepanels, Inc. of Van Nuys, California and Litepanels, Ltd. of the United Kingdom (collectively, “Litepanels”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337.
The complaint alleges that the following entities (collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain LED photographic lighting devices, components thereof, and products containing same that infringe certain claims of U.S. Patent Nos. 7,972,022 (the ‘022 patent), 7,510,290 (the ‘290 patent), 7,429,117 (the ‘117 patent), 7,318,652 (the ‘652 patent), and 6,948,823 (the ‘823 patent) (collectively, the “asserted patents”):
- FloLight, LLC of Campbell, California
- Prompter People, Inc. of Campbell, California
- Ikan Corporation of Houston, Texas
- Advanced Business Computer Services, LLC of Reno, Nevada
- Elation Lighting, Inc. of Los Angeles, California
- Fotodiox Inc. of Waukegan, Illinois
- Fuzhou F&V Photographic Equipment Co., Ltd. of China
- Yuyao Lishuai Photo-Facility Co., Ltd. of China
- Yuyao Fotodiox Photo Equipment Co., Ltd. of China
- Shantou Nanguang Photographic Equipment Co., Ltd. of China
- Visio Light, Inc. of Taiwan
- Tianjin Wuqing Huanyu Film and TV Equipment Factory of China
- Stellar Lighting Systems of Los Angeles, California
- Yuyao Lily Collection Co., Ltd. of China
According to the complaint, the asserted patents generally relate to advanced camera-mountable and standalone lighting systems for use in television, broadcast news, and motion picture productions. In particular, the ‘823 patent discloses a system that may include a portable frame that tracks camera movement, a mechanism for attachment to a yoke, a plurality of detachable panel members having a plurality of semiconductor light elements, an integrated lens for adjusting the focus of the light emitted, and a color gel that may be securely attached to the frame. The ‘290, ‘117, ‘652, and ‘022 patents claim priority to the ‘823 patent and similarly disclose an advanced camera mountable lighting system that is directed towards use in television, broadcast news, and motion picture productions. The ‘022 patent’s claims are specifically directed toward a photographic lighting device that can emit light in a plurality of color-temperatures.
In the complaint, Litepanels states that the Proposed Respondents import and sell products that infringe the asserted patents. The complaint specifically identifies a number of allegedly infringing products associated with the various Proposed Respondents.
Regarding domestic industry, Litepanels states that certain of its LED-based lighting systems —including its 1×1 series devices and its Micro series devices — practice the claims of the asserted patents. As to the economic prong, Litepanels states that it has made significant investments in plant and equipment, engaged in significant employment of labor and capital, and devoted substantial resources in the U.S. to developing, manufacturing, and testing devices that practice one or more claims of the asserted patents. The complaint specifically refers to Litepanels’ facilities in Van Nuys, California where Litepanels conducts all of its research, development and manufacturing activities in the U.S.
As to related litigation, Litepanels states that it is asserting the ‘823, ‘290 and ‘117 patents in a co-pending action in the U.S. District Court for the Eastern District of Texas against various entities, including Proposed Respondents FloLight, LLC and Prompter People, Inc.
With respect to potential remedy, Litepanels requests that the Commission issue a permanent general exclusion order. In particular, Litepanels states that there is a pattern of violation of Section 337, it is difficult to identify the sources of infringing products, and a general exclusion order is necessary to prevent circumvention of an exclusion order limited to products of the Proposed Respondents.
