AMP Plus Inc v. Nora Lighting Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: AMP Plus, Inc. d/b/a ELCO Lighting (California)
  • Defendant: Nora Lighting, Inc. (California)
  • Plaintiff's Counsel: RUTTENBERG IP LAW, A PROFESSIONAL CORPORATION
• Case Identification: 2:24-cv-08460, C.D. Cal., 07/16/2026
• Venue Allegations: Venue is alleged to be proper as the Defendant, Nora Lighting, Inc., is a California corporation that resides in and maintains a regular and established place of business within the Central District of California, where a substantial part of the events giving rise to the claims occurred.
• Core Dispute: Plaintiff alleges that Defendant's "Pearl" series of LED downlights infringes a patent related to the mechanical and thermal design of integrated lighting modules.
• Technical Context: The technology pertains to modular LED lighting fixtures that integrate a power driver, a light-emitting diode (LED), and a heat sink into a single, compact unit designed for efficient heat dissipation and compatibility with standard installation hardware.
• Key Procedural History: The complaint details a significant history of pre-suit communications, including a cease-and-desist letter sent in September 2021. Notably, Defendant initiated an Ex Parte Reexamination of the patent-in-suit, which concluded with the U.S. Patent and Trademark Office issuing a certificate confirming the patentability of the asserted claims, which had been rewritten from dependent to independent form. The complaint also alleges that Defendant threatened, but never filed, a Post-Grant Review (PGR) petition.

Case Timeline

Date	Event
2019-06-03	Priority Date for U.S. Patent No. 11,092,326
2021-08-17	U.S. Patent No. 11,092,326 Issued
2021-09-10	Plaintiff provided actual notice of infringement to Defendant
2021-11-11	Plaintiff provided an element-by-element claim chart to Defendant's sales representatives
2022-02-21	Defendant sent letter asserting patent invalidity and threatening a PGR petition
2024-01-02	Plaintiff sent a further cease-and-desist letter to Defendant
2025-05-09	Defendant filed a petition for Ex Parte Reexamination of the '326 Patent
2026-03-23	U.S. Patent and Trademark Office issued Ex Parte Reexamination Certificate
2026-07-16	Amended Complaint for Patent Infringement Filed

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

U.S. Patent No. 11,092,326 - "Integrated Lighting Module"

• Patent Identification: U.S. Patent No. 11,092,326 ("'326 Patent"), "Integrated Lighting Module," issued August 17, 2021.

The Invention Explained

• Problem Addressed: The patent's background section identifies a need for an integrated LED lighting module with improved thermal performance. Specifically, it sought a design that could increase heat dissipation, allowing for higher lumen output, while remaining compatible with standard-sized trims (e.g., MR16) and allowing for adjustment without interference '326 Patent, col. 1:45-59
• The Patented Solution: The invention is a multi-component lighting module comprising a driver housing, a heat sink module, an LED element, an optical reflector, and a holder '326 Patent, abstract The core of the solution is the heat sink's geometry: it features an upper, finned portion with a larger exterior diameter and a lower, non-finned portion with a smaller exterior diameter '326 Patent, col. 10:50-54 This two-tiered design allows the driver housing to attach at the top and a separate holder to attach at the bottom, creating a compact, thermally efficient, and mechanically integrated assembly '326 Patent, col. 13:11-25 '326 Patent, Fig. 11
• Technical Importance: The described configuration aims to solve the competing demands of thermal management and physical constraints in recessed lighting, enabling a brighter, more efficient, and more versatile product. '326 Patent, col. 1:49-53

Key Claims at a Glance

• The complaint asserts independent Claims 15 and 19, which were confirmed as patentable in their independent form during an Ex Parte Reexamination Compl. ¶¶21, 52-53
• Independent Claim 15 recites an integrated lighting module with the following essential elements:
  • A driver housing for a power driver.
  • A heat sink module with a larger-diameter upper portion and a smaller-diameter lower portion, where the driver housing attaches to the top of the heat sink.
  • A light emitting diode (LED) element.
  • A substantially conical optical reflector.
  • Specific spatial arrangement: the LED is disposed above the reflector's top-hole and underneath the heat sink.
  • A holder with side-walls to receive the bottom of the heat sink, open at its top and bottom.
  • Specific assembly configuration: the components are attached in a specific order, with the reflector between the heat sink and the holder.
  • Specific overall orientation: the driver housing is at the overall top and the holder is at the overall bottom, with the driver housing located entirely above the heat sink.
• Independent Claim 19 includes the elements of the preamble and limitations [A] through [F] of Claim 15 but replaces limitations [G] and [H] with a new limitation, requiring that "the larger exterior diameter of the upper portion of the heat sink module is substantially similar to a diameter of the driver housing" Compl. ¶¶138-139 Compl. p. 11
• The complaint does not explicitly reserve the right to assert other dependent claims, focusing solely on Claims 15 and 19 Compl. ¶21

III. The Accused Instrumentality

Product Identification

• The complaint identifies Defendant Nora Lighting's "Pearl LED Retrofit Series LED downlights" (the "Pearl") as the accused instrumentality Compl. ¶19

Functionality and Market Context

• The complaint alleges the Pearl is an integrated lighting module that functions as a direct competitor to the Plaintiff's own "Koto" product line Compl. ¶¶6, 15 The Pearl is described as a multi-part assembly including a driver housing, a heat sink, an LED, a reflector, and a holder Compl. ¶¶62, 75, 95, 112 The complaint alleges that Nora sells the Pearl module as a complete unit and also in configurations where the heat sink/driver assembly is sold separately from the holder Compl. ¶145 Compl. ¶149 An image provided in the complaint shows the assembled Pearl module installed in a trim fixture. Compl. ¶132, Fig. G.1 This image, labeled "Figure G.1," depicts the assembled accused product with callouts identifying the "LED Element," "Trim," "Optical Reflector," "'holder'," and "Driver Housing."

IV. Analysis of Infringement Allegations

The complaint provides a detailed, element-by-element analysis of how the accused Pearl product allegedly infringes Claims 15 and 19 of the '326 Patent.

• '326 Patent Infringement Allegations

Claim Element (from Independent Claim 15)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a driver housing that has first side walls, a first top that caps the first side walls... wherein the first volume is configured to receive a driver...	The Pearl product includes a driver housing with cylindrical side walls and a top, which contains a driver to power the LED.	¶62; ¶72	col. 3:26-32
a heat sink module... has an upper portion that has a larger exterior diameter that is larger than a smaller exterior diameter of a lower portion... wherein a first bottom portion of the driver housing is attachable to a second top... of the heat sink module;	The Pearl's heat sink has a wider upper portion that transitions to a narrower lower portion, and its driver housing attaches to the top of this heat sink. An annotated photo is provided as evidence.	¶76; ¶84-¶85; ¶141, Fig. I.1	col. 5:6-9; col. 10:50-54
the light emitting diode element that is configured to emit light;	The Pearl product includes an LED configured to emit light, which Nora allegedly admitted in discovery responses.	¶88; ¶90	col. 5:14-15
at least one optical reflector that is substantially conical in shape configured for reflecting and directing... light... out of a second bottom...	The Pearl includes a substantially conical optical reflector for directing light. This is supported by an annotated image.	¶95; ¶101, Fig. D.2	col. 10:6-14
wherein the light emitting diode element is disposed above a top-hole of the... optical reflector and underneath the heat sink module...	The Pearl's LED is positioned above the top-hole of the reflector and below the heat sink. The complaint includes an annotated photo showing this arrangement.	¶103; ¶108-¶109; ¶108, Fig. E.3	col. 10:14-20
a holder that has second side-walls that substantially surround a second volume... configured to receive at least a bottom region of the lower portion of the heat sink module...	The Pearl includes a component identified as the "holder" which threads onto the bottom of the heat sink. The complaint explicitly distinguishes this "holder" from a cosmetic "trim."	¶111-¶112; ¶117; ¶120	col. 6:12-16
wherein... the driver housing is attached to the heat sink module, the heat sink module is attached to... [the] holder with the... optical reflector disposed between the heat sink module and the holder;	When assembled, the Pearl's driver housing attaches to the heat sink, and the heat sink attaches to the holder with the reflector positioned in between.	¶127-¶131	col. 13:50-55
wherein... the driver housing is located at an overall top... and the holder is located at an overall bottom... such that the driver housing is located entirely above the heat sink module.	In its assembled state, the Pearl's driver housing is at the top of the module, the holder is at the bottom, and the driver housing sits entirely above the heat sink. A labeled image is provided to illustrate this orientation.	¶134; ¶136; ¶136, Fig. H.1	col. 14:15-26

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over the term "holder". The complaint dedicates significant space to arguing that a specific component of the Pearl product is the claimed "holder" and is functionally distinct from a "trim," which is not a claimed element (Compl. ¶¶114, 118, 120). This suggests an anticipated defense that the accused component is merely a trim and not the claimed "holder". The court will need to determine if the accused structure falls within the scope of this term.
  • Technical Questions: For Claim 19, a key question will be factual: is the exterior diameter of the Pearl's upper heat sink portion "substantially similar" to the diameter of its driver housing? The complaint presents a photograph with annotations as evidence that they are (Compl. ¶141, Fig. I.1). The interpretation of this term of degree will be critical.

V. Key Claim Terms for Construction

• The Term: "holder"

• Context and Importance: The definition of "holder" is critical because the infringement theory depends on identifying a specific component of the accused product as this element. Defendant may argue this component is a "trim" (a common but unclaimed lighting component) to escape infringement. Practitioners may focus on this term because the complaint preemptively argues the distinction, indicating it as a likely area of dispute (Compl. ¶120).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims define the "holder" functionally as having side-walls, surrounding a volume, being configured to receive the heat sink, and being open at the top and bottom '326 Patent, col. 14:36-44 A party could argue any component that meets these structural and functional requirements is a "holder", regardless of any additional cosmetic function.
  • Evidence for a Narrower Interpretation: The detailed description and figures distinguish the "holder" from the "trim". The abstract states that a "trim... may attach to bottom flanges of the holder" '326 Patent, abstract Figure 12A shows holder 125 as part of the core module (100), while trim 1221 is shown as a separate, final-assembly piece. This suggests the patentee viewed the "holder" as an internal, structural component distinct from the external, often cosmetic, "trim".

• The Term: "substantially similar"

• Context and Importance: This term, appearing in Claim 19, is a term of degree that creates a potential non-infringement argument. The infringement analysis for Claim 19 hinges on the factual question of whether the diameter of the Pearl's driver housing and its heat sink are close enough to be considered "substantially similar."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not provide an explicit numerical definition for "substantially similar." A party arguing for a broader interpretation would contend that the term should be given its plain and ordinary meaning, allowing for some noticeable difference in diameter so long as the general aesthetic and functional purpose (e.g., allowing the housing to sit atop the heat sink) is achieved.
  • Evidence for a Narrower Interpretation: While there is no explicit narrowing definition, a party could argue that the purpose of this feature is to create a flush, seamless transition between the driver housing and the heat sink. The figures, such as Figure 1, which show the driver cap 101 sitting atop the heat sink 115 with no significant overhang or gap, could be used to argue that "substantially similar" implies a very close, near-identical dimensional match. The complaint's own visual evidence in Figure I.1 will be central to this debate Compl. ¶140

VI. Other Allegations

• Indirect Infringement: The complaint alleges both contributory and induced infringement. It asserts that Nora sells a material part of the invention (the heat sink/driver assembly) which is not a staple article of commerce and has no substantial non-infringing use, knowing it is specially adapted for an infringing use Compl. ¶¶148, 151 Inducement is alleged based on Nora's knowledge of the patent and its actions in selling the Pearl products to customers and distributors, with the knowledge that their use will constitute infringement Compl. ¶¶156-157 The complaint also references marketing literature that allegedly instructs on the infringing use Compl. ¶152
• Willful Infringement: The complaint makes a strong case for willfulness by alleging a long period of knowledge and disregard for Plaintiff's rights. It alleges Defendant had pre-suit knowledge from the published patent application Compl. ¶37, received actual notice and a claim chart in late 2021 Compl. ¶¶38, 41, and continued to sell the accused product despite these notices Compl. ¶39 Compl. ¶43 The fact that the asserted claims survived an Ex Parte Reexamination initiated by the Defendant itself is presented as further evidence of the objective baselessness of any continued infringement Compl. ¶¶52-53 Compl. ¶143

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

This case appears to be a straightforward hardware dispute between direct competitors. Based on the complaint, the litigation will likely focus on the following key questions:

1. A core issue will be one of definitional scope: can the term "holder", as defined and used in the '326 Patent, be construed to read on the accused component of the Pearl product? The case may turn on whether the court determines this component is the claimed structural "holder" or an unclaimed cosmetic "trim".

2. A second key question will be one of claim interpretation and factual application: does the accused Pearl product meet the dimensional and spatial limitations of the claims? This will involve construing terms of degree like "substantially similar" (for Claim 19) and "entirely above" (for Claim 15) and then applying those constructions to the physical realities of the accused product, likely through a battle of expert testimony.