ETI Solid State Lighting Inc v. Cooper Lighting LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ETI Solid State Lighting, Inc. (Ohio)
  • Defendant: Cooper Lighting, LLC (Delaware)
  • Plaintiff's Counsel: Buchalter Nemer; McDonald Hopkins LLC
• Case Identification: 3:26-cv-00084, N.D. Ga., 04/24/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of Georgia because Defendant Cooper Lighting, LLC is headquartered in Peachtree City, Georgia, maintains a regular and established place of business in the District, and commits alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant's "HALO RL" line of recessed LED fixtures infringes three patents related to lighting technology that allows users to manually select the correlated color temperature (CCT).
• Technical Context: The technology at issue involves user-selectable CCT in LED lighting, a feature that allows end-users to adjust the emitted light from "warm" (yellowish) to "cool" (bluish) to suit different environments or preferences.
• Key Procedural History: The complaint states that the asserted patents and accused products were the subject of prior litigation between the parties (ETI's counterclaims in ETI Solid State Lighting, Inc. v. Signify North America Corporation et al., N.D. Ga.). That action was reportedly dismissed without prejudice due to improper joinder, prompting this refiling. The complaint notes that in the prior action, the parties exchanged infringement and invalidity contentions and completed claim construction briefing, which may accelerate the proceedings in the current case.

Case Timeline

Date	Event
2017-01-13	Earliest Priority Date for '871, '262, and '030 Patents
2019-10-29	U.S. Patent No. 10,462,871 Issues
2019-11-26	U.S. Patent No. 10,492,262 Issues
2022-04-12	U.S. Patent No. RE49,030 Issues
2025-07-23	Plaintiff files Answer and Counterclaims in prior "Dismissed Action," allegedly providing Defendant with actual notice and claim charts
2026-04-24	Complaint filed in present action

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

U.S. Patent No. 10,462,871

• Patent Identification: U.S. Patent No. 10,462,871 ("Manually Controllable LED Correlated Color Temperature Light Fixture"), issued October 29, 2019.
• The Invention Explained:
  • Problem Addressed: The patent's background describes that while LED lights are popular, different environments (e.g., restaurants, offices, hospitals) and individual users have different preferences for the "warmth" or "coolness" of the light, specified by the Correlated Color Temperature (CCT) '871 Patent, col. 2:23-42 It was therefore desirable to create an inexpensive and easy-to-operate manual system for controlling the CCT of an LED fixture '871 Patent, col. 2:10-16
  • The Patented Solution: The invention is an LED light fixture with at least two different sets of LEDs, each with its own CCT. It uses at least three subcircuits and a manual switch to allow a user to select one set of LEDs, the other set, or a combination of them, thereby producing at least three different CCT outputs from a single fixture '871 Patent, abstract '871 Patent, col. 5:21-35
  • Technical Importance: This technology gives users the ability to customize lighting ambiance after installation, a significant advance in flexibility over single, fixed-CCT lighting products '871 Patent, col. 2:36-42
• Key Claims at a Glance:
  • The complaint alleges infringement of one or more claims, with prior litigation documents allegedly mapping accused products to at least independent Claim 9 Compl. ¶18 Compl. ¶27
  • Essential Elements of Independent Claim 9:
    • A set of at least two LED light sources.
    • At least three electric circuits, each for generating illumination with a different correlated color temperature.
    • A controllable correlated color temperature switching assembly with a manually controllable switch for selectively connecting one of the light sources or a combination to the electric circuits.
    • The manually controllable switch is concealed when the LED light fixture is mounted for operation.
  • The complaint reserves the right to assert additional claims Compl. ¶27

U.S. Patent No. 10,492,262

• Patent Identification: U.S. Patent No. 10,492,262 ("Manually Controllable LED Correlated Color Temperature Light Fixture"), issued November 26, 2019.
• The Invention Explained:
  • Problem Addressed: Similar to the '871 Patent, the '262 patent addresses the need for an inexpensive and user-friendly way to adjust the CCT of LED lighting fixtures to suit various applications and personal tastes '262 Patent, col. 2:15-20
  • The Patented Solution: The patent describes a light fixture containing at least two groups of LEDs with different CCTs. The fixture includes at least three subcircuits and a manually controllable switch assembly that allows a user to power one group, the other group, or a combination of the groups, thereby producing at least three different light temperatures. The switch assembly is concealed from view during normal operation '262 Patent, abstract '262 Patent, col. 15:1-30
  • Technical Importance: This design provides a cost-effective way to offer multiple lighting options in a single fixture, enhancing user control and product versatility '262 Patent, col. 2:41-46
• Key Claims at a Glance:
  • The complaint alleges infringement of one or more claims, with prior litigation documents allegedly mapping accused products to at least independent Claim 1 Compl. ¶18 Compl. ¶39
  • Essential Elements of Independent Claim 1:
    • At least two groups of LED light sources, each with a different CCT.
    • At least three subcircuits, including a different one or combination of the LED light source groups.
    • Actuable electrical switching components for connecting the subcircuits to a power source.
    • A manually controllable correlated color temperature switch assembly.
    • A concealment for concealing the switch assembly.
  • The complaint reserves the right to assert additional claims Compl. ¶39

U.S. Patent No. RE49,030

• Patent Identification: U.S. Reissue Patent No. RE49,030 ("Manually Controllable LED Correlated Color Temperature Light Fixture"), issued April 12, 2022.
• Technology Synopsis: The '030 patent discloses an LED light fixture with at least two LED light sources, each having a different CCT. A manually controllable switching assembly allows a user to select a particular light source or a combination of sources to control the output color temperature '030 Patent, abstract The patent further describes a concealment for rendering the switch inaccessible during normal operation, which can be made accessible for actuation '030 Patent, claim 1
• Asserted Claims: The complaint alleges infringement of one or more claims, with prior litigation documents allegedly mapping accused products to at least independent Claim 1 Compl. ¶18 Compl. ¶51
• Accused Features: The accused HALO RL fixtures are alleged to infringe by incorporating a manually controllable switch to select from different color temperatures provided by multiple LED light sources Compl. ¶15 Compl. ¶16 Compl. ¶51

III. The Accused Instrumentality

• Product Identification: The accused products are the "HALO RL" Recessed LED fixtures with selectable color, including at least model numbers RL3059FSD2W1EWH, RL4LS9FSD2W1EWH, RL56069FSD2W1EWH, and RL56LS9FSD2W1EWH Compl. ¶15
• Functionality and Market Context: The complaint alleges these are recessed LED downlights that feature "manually selectable correlated color temperature switches" Compl. ¶16 This functionality allows users to change the color output of the light fixture. The complaint includes an image showing three different sizes of the accused HALO RL downlights, labeled RL3, RL4, and RL56 Compl. p. 5 Plaintiff ETI and Defendant Cooper are alleged to be direct competitors selling recessed LED downlights through the same trade channels Compl. ¶16

IV. Analysis of Infringement Allegations

U.S. Patent No. 10,462,871 Infringement Allegations

Claim Element (from Independent Claim 9)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a set of at least two LED light sources...	The HALO RL fixtures are described as having "selectable color," which the complaint alleges is achieved using multiple LED sources as covered by the asserted patents Compl. ¶10	¶10; ¶15	col. 5:21-23
...at least three electric circuits, each of said at least three electric circuits effecting the generation of illumination having a correlated color temperature different from the correlated color temperature emitted by the LED light sources in each of the others of said at least three electric circuits...	The complaint alleges the accused products have "selectable color" Compl. ¶15 and that the asserted patent relates to fixtures with "at least three subcircuits where each subcircuit produces a different correlated color temperature" Compl. ¶10	¶10; ¶15	col. 5:24-29
a controllable correlated color temperature switching assembly comprising a manually controllable correlated color temperature switch for selectively connecting one of said at least two LED light sources...and a combination of said at least two LED light sources...	The HALO RL fixtures are alleged to contain "manually selectable correlated color temperature switches" Compl. ¶16	¶16	col. 5:30-35
...said manually controllable correlated color temperature switch being concealed when said LED light fixture is mounted for operation.	The complaint does not provide sufficient detail for analysis of this element.		col. 5:36-39

U.S. Patent No. 10,492,262 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
at least two groups of LED light sources, each of said at least two groups of LED light sources emitting illumination...having a correlated color temperature different from the...other...	The HALO RL fixtures are described as having "selectable color" Compl. ¶15, which the complaint alleges is achieved using multiple LED groups as covered by the asserted patents Compl. ¶11	¶11; ¶15	col. 15:4-11
at least three subcircuits, each of said at least three subcircuits including a different one of said at least two groups of LED light sources and at least one selected combination of said at least two groups of LEDs...	The complaint alleges the accused products have "selectable color" Compl. ¶15 and that the asserted patent relates to fixtures with "at least three circuits, each producing a different color temperature" Compl. ¶11	¶11; ¶15	col. 15:12-18
a manually controllable correlated color temperature switch assembly...	The HALO RL fixtures are alleged to contain "manually selectable correlated color temperature switches" Compl. ¶16	¶16	col. 15:25-26
a concealment for concealing said manually controllable correlated color temperature switch assembly.	The complaint does not provide sufficient detail for analysis of this element.		col. 15:29-30

• Identified Points of Contention:
  • Scope Questions: A central question for all asserted patents will be the construction and application of the terms "concealed" or "concealment." The claims require the manual switch to be hidden or inaccessible during normal operation. The infringement analysis will depend on whether the switch on the accused HALO RL products, which the complaint does not describe, meets this limitation under the court's interpretation.
  • Technical Questions: An evidentiary dispute may arise over whether the accused products' circuitry for producing "selectable color" technically aligns with the claimed architecture of using "at least three" distinct subcircuits for individual LED groups and their combinations. The complaint's allegations are high-level, and the actual implementation within the accused products will be a focus of discovery.

V. Key Claim Terms for Construction

• The Term: "concealed" / "concealment" (from '871 Claim 9 and '262 Claim 1)
• Context and Importance: This limitation is present in the independent claims of all three asserted patents and is critical to defining the scope of the invention. Practitioners may focus on this term because the infringement dispute could turn on whether the switch on the accused product is considered "concealed" when installed. If the switch is readily accessible on the face of the installed fixture, Defendant may argue non-infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patents state an object is to provide a switch that is "not readily visible when the light fixture is in an operative position, but is easily rendered in an operable position for finger actuation" '871 Patent, col. 3:21-25 This language may support a construction where "concealed" means out of the user's immediate line of sight, rather than being physically enclosed.
  • Evidence for a Narrower Interpretation: The patents disclose specific embodiments where the switch is hidden behind a removable diffuser or a dedicated door '871 Patent, Fig. 52 '871 Patent, col. 10:30-40 This may support a narrower construction requiring a physical barrier that must be moved or removed to access the switch.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on allegations that Cooper markets the infringing features and provides instructions and technical support encouraging infringing use by customers Compl. ¶34 Compl. ¶46 Compl. ¶58 Contributory infringement is based on allegations that the accused products are not staple articles of commerce and have no substantial non-infringing uses Compl. ¶35 Compl. ¶47 Compl. ¶59
• Willful Infringement: The complaint makes detailed allegations of willful infringement. It claims Cooper had constructive notice through ETI's patent marking on its competing products Compl. ¶17 More significantly, it alleges Cooper gained actual, specific knowledge on July 23, 2025, when ETI served counterclaims in a prior lawsuit that included "a claim-by-claim mapping of the accused products" to the asserted patents Compl. ¶18 Compl. ¶23 The complaint alleges that Cooper's continued sales after this date constitute knowing and willful disregard of ETI's patent rights Compl. ¶24

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

1. A core issue will be one of definitional scope: can the term "concealed," which is central to the asserted claims, be construed to read on the placement and accessibility of the manual CCT switch on the accused HALO RL fixtures? The court's claim construction of this term may be dispositive for infringement.
2. A key evidentiary question will be one of technical implementation: will discovery show that the accused products' circuitry for providing "selectable color" operates in a manner that maps onto the claimed structure of "at least three" distinct subcircuits for individual and combined LED sets, or will it reveal a technically distinct method?
3. A central question for damages will be willfulness: given the complaint's specific allegations of actual notice via claim charts served in prior litigation, the case will likely feature a significant dispute over whether Cooper's post-notice conduct was objectively reckless, which could expose it to enhanced damages.