Pure Edge Lighting LLC v. Lightblue USA & Associates LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Pure Edge Lighting LLC (Illinois)
  • Defendant: Lightblue USA & Associates, LLC d/b/a Rayhil Inc. (New York)
  • Plaintiff's Counsel: Bishop & Diehl, Ltd.
• Case Identification: 1:26-cv-01458, E.D.N.Y., 03/12/2026
• Venue Allegations: Venue is asserted based on the defendant being registered, organized, and having a regular and established place of business in the Eastern District of New York.
• Core Dispute: Plaintiff alleges that Defendant's line of recessed track lighting products infringes a patent related to an electric recessible track assembly designed for installation in standard 5/8-inch drywall.
• Technical Context: The technology concerns architectural lighting, specifically systems that aim to combine the aesthetic of seamlessly recessed lighting with the functional flexibility of adjustable track lighting.
• Key Procedural History: Plaintiff alleges it sent a cease-and-desist letter to Defendant on September 19, 2025, providing actual notice of the patent-in-suit and its alleged infringement prior to the filing of the complaint.

Case Timeline

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

U.S. Patent No. 10,240,762 - "Electric Recessible Track Assembly and Method of Installation in Standard 5/8-Inch Thick Drywall"

• Patent Identification: U.S. Patent No. 10,240,762, titled "Electric Recessible Track Assembly and Method of Installation in Standard 5/8-Inch Thick Drywall," issued on March 26, 2019 (the "'762 Patent").

The Invention Explained

• Problem Addressed: The patent's background section identifies the aesthetic and practical drawbacks of conventional lighting systems Compl., Ex. A, '762 Patent Traditional track lighting is functionally flexible but can be visually obtrusive, while standard recessed lighting offers a clean look but is fixed in place and can require altering ceiling joists for installation '762 Patent, col. 1:23-54
• The Patented Solution: The invention is a track lighting system specifically dimensioned to be recessed into standard 5/8-inch thick drywall without requiring structural modification of joists or studs '762 Patent, col. 3:53-56 The system features an extruded track with lateral flanges that mount onto the outer surface of the drywall '762 Patent, col. 2:25-30 These flanges are designed to be concealed with joint compound, creating a seamless, "trimless" appearance while retaining the ability to move light fixtures along the track '762 Patent, abstract
• Technical Importance: This approach seeks to merge the aesthetic advantages of recessed lighting with the functional versatility of track lighting, offering a solution for architectural designs that require both a clean ceiling line and adaptable illumination '762 Patent, col. 1:55-63

Key Claims at a Glance

The complaint asserts infringement of at least independent claims 1, 11, and 16, and reserves the right to assert dependent claims Compl. ¶16 Compl. ¶18 Compl. ¶20 Compl. ¶26

• Independent Claim 1 (Apparatus): An electric track system with elements including:

  • a section of extruded track defined by a channel with opposing sidewalls, a base wall, and a longitudinal opening
  • first and second bus rods extending the length of the track section, secured to the opposing sidewalls
  • first and second lateral flanges extending from the exterior of the sidewalls, substantially parallel to the base wall
  • wherein the height of the channel sidewalls is "approximately equal to a 5/8-inch surface thickness"

• Independent Claim 11 (System): A track lighting system comprising:

  • a section of extruded track with a channel, opposing sidewalls, a base wall, and a longitudinal opening
  • first and second lateral flanges
  • first and second bus rods
  • at least one light fixture with a base "slidably retained within the channel" and having contacts engaged with the bus rods
  • wherein the channel sidewall height is "approximately equal to a 5/8-inch surface thickness" and the flanges are secured to a surface to recess the channel

• Independent Claim 16 (Method): A method for recessing a lighting track, comprising steps of:

  • providing a track with a channel, bus rods, and lateral flanges
  • creating an opening in a surface "having a thickness of 5/8-inch"
  • coupling the bus rods to a power source
  • placing the channel within the opening
  • securing the flanges to the surface to retain the channel within the opening

III. The Accused Instrumentality

Product Identification

• The accused products are Defendant's "QUE Track Light System," specifically the "Trimless Track Products," which include the "Trimless Mount Mud-In Track" and "Trimless Mount Non-Mud-In Track" Compl. ¶11

Functionality and Market Context

• The complaint describes the accused products as a magnetic LED track light system Compl. ¶11 The system is offered for sale on Defendant's website and is alleged to be advertised for recessed installation Compl. ¶11 The complaint alleges these products were displayed and installed at the Dallas International Lighting Show, suggesting they are marketed for commercial and residential architectural lighting applications Compl. ¶21 The complaint provides an annotated diagram showing the accused product's cross-section with key components labeled, such as an extruded track, sidewalls, bus rods, and lateral flanges Compl. ¶26

IV. Analysis of Infringement Allegations

• Claim Chart Summary: The complaint provides a claim chart with annotated images for Claim 1 of the '762 Patent.

'762 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over the claim term "approximately equal to a 5/8-inch surface thickness." The complaint alleges the accused product's channel height is 0.5 inches, while 5/8 of an inch is 0.625 inches Compl. ¶26 This 20% difference raises the question of whether "0.5 inches" falls within the scope of "approximately equal" to 0.625 inches, a determination that will be critical to the infringement analysis.
  • Technical Questions: The infringement allegation for the "height" limitation relies on a legal conclusion ("is approx. equal to") rather than a direct factual match Compl. ¶26 The case will likely require extrinsic evidence, such as expert testimony, to establish whether a person of ordinary skill in the art would consider this dimensional variance to be within the claimed scope.

V. Key Claim Terms for Construction

• The Term: "approximately equal to a 5/8-inch surface thickness"

• Context and Importance: This term is the central technical limitation that enables the invention's purported benefit: recessing a track into standard drywall without altering structural supports. The infringement case for Claim 1 and Claim 11 hinges on the interpretation of "approximately," as the complaint's own evidence shows a numerical disparity between the accused product's dimension (0.5") and the patent's specified dimension (0.625") Compl. ¶26 Practitioners may focus on this term because its construction could be dispositive of infringement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party arguing for a broader scope may contend that the term should be interpreted functionally to mean any dimension that allows the track to be recessed into standard drywall without protruding, fulfilling the invention's overall purpose.
  • Evidence for a Narrower Interpretation: A party arguing for a narrower scope may point to the patent's title, which explicitly recites "STANDARD 5/8-INCH THICK DRYWALL," and the repeated references to this specific dimension throughout the specification '762 Patent, title '762 Patent, col. 1:11-12 '762 Patent, col. 3:53-56 This emphasis could suggest that the 5/8-inch dimension is not merely exemplary but a defining characteristic of the invention, potentially limiting the permissible deviation implied by "approximately."

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), asserting that Defendant provides an "Installation Guide" that instructs customers and contractors on how to install the accused products in an infringing manner Compl. ¶27 Compl. ¶44 It further alleges that Defendant's "Where to Buy" link directs customers to third-party representatives who sell, display, and install the products, thereby contributing to direct infringement Compl. ¶23 Compl. ¶42 The complaint also alleges contributory infringement under 35 U.S.C. § 271(c), stating the accused products are especially made for infringement and are not staple articles of commerce Compl. ¶¶57-58
• Willful Infringement: Willfulness is alleged based on both pre- and post-suit knowledge. The complaint alleges, "on information and belief," that Defendant had actual knowledge of the '762 Patent prior to infringing Compl. ¶35 It also pleads knowledge based on a cease-and-desist letter sent by Plaintiff to Defendant on September 19, 2025, several months before the suit was filed Compl. ¶30 Compl. ¶34

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

• A core issue will be one of definitional scope: can the term "approximately equal to a 5/8-inch surface thickness" be construed to cover the accused product's 0.5-inch channel height? The resolution of this claim construction dispute, which centers on a 20% dimensional difference, may be determinative of the direct infringement claim.

• A second key issue will concern intent for indirect infringement: what evidence exists to show that Defendant, by providing installation guides and dealer locators, specifically intended for its customers and distributors to perform the patented method and assemble the patented system? The outcome will depend on the content of the guides and the nature of Defendant's relationships with its distributors.