ElectraLED Inc v. Griven SRL

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ElectraLED, Inc. (Florida)
  • Defendant: Griven S.r.l. (Italy)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-00069, E.D. Tex., 01/23/2026
• Venue Allegations: Plaintiff alleges venue is proper under 28 U.S.C. §§ 1391 and 1400, and specifically invokes the "alien venue rule" on the grounds that Defendant is a foreign entity with a regular and established business presence in the United States.
• Core Dispute: Plaintiff alleges that Defendant’s commercial LED lighting products infringe patents related to the structural design and thermal management of durable LED light fixtures.
• Technical Context: The technology relates to commercial and industrial LED lighting, where managing heat generated by LEDs is critical to ensuring the longevity and reliability of the fixture and its internal components.
• Key Procedural History: The complaint notes that U.S. Patent No. 7,651,245 is a "pioneering patent" that has been cited as relevant prior art in 191 subsequent U.S. patent applications.

Case Timeline

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

U.S. Patent No. 7,651,245 - "LED Light Fixture with Internal Power Supply"

The Invention Explained

• Problem Addressed: The patent’s background section describes prior art commercial light fixtures as durable but reliant on inefficient light sources like fluorescent or halogen bulbs, which suffered from high cost, high power consumption, and poor light quality ’245 Patent, col. 1:26-44 While LED fixtures offered efficiency, embedding the power supply inside a rugged housing made it susceptible to failure from the heat generated by the LEDs Compl. ¶17
• The Patented Solution: The invention discloses a durable LED light fixture that houses the power supply internally but thermally isolates it from the heat-generating light engine ’245 Patent, col. 1:48-58 This is achieved by placing the power supply within a box that resides in a "rear receptacle" defined by an array of external heat-dissipating fins, creating a physical air gap or cavity that insulates the power supply while the fins draw heat away from the light engine and dissipate it into the ambient environment ’245 Patent, col. 4:50-59; Fig. 5
• Technical Importance: This design sought to combine the durability needed for commercial applications with the energy efficiency of LEDs by solving the critical reliability issue of heat-induced power supply failure Compl. ¶17

Key Claims at a Glance

• The complaint asserts independent claim 21 Compl. ¶27
• Key elements of claim 21 include:
  • A housing with a flange, an internal receiver, a frontal lens, and an array of fins extending rearward to define a "rear receptacle."
  • A rear cover that encloses the rear receptacle.
  • A light engine assembly mounted to the receiver.
  • A power supply residing "within the rear receptacle" and enclosed by the cover.
  • The dissipation of heat from the LEDs by the array of fins "without the use of a fan."
• The complaint reserves the right to assert additional claims Compl. ¶23

U.S. Patent No. 9,618,187 - "LED Light Fixture"

The Invention Explained

• Problem Addressed: As a continuation of the '245 Patent family, this patent addresses similar challenges in thermal management for commercial LED fixtures ’187 Patent, col. 1:40-54 It particularly focuses on configurations with an optional external power supply and on improving convective cooling through structural design ’187 Patent, col. 1:33-37
• The Patented Solution: The invention describes a light fixture with a housing having a circular main body and an array of fins extending from its rear wall to dissipate heat ’187 Patent, Abstract The specification contemplates an "air flow passageway" that moves air from a central inlet, across the light modules, and out a rear vent to improve cooling ’187 Patent, col. 2:16-20 The light engine is positioned within the main body, and the power supply can be housed in a separate external enclosure ’187 Patent, col. 2:2-7
• Technical Importance: This design enhances thermal management by defining a specific path for convective airflow, a different approach than the thermal isolation emphasized in the parent '245 Patent, and explicitly provides for configurations where the power supply is physically separate from the main light housing.

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶37
• Key elements of claim 1 include:
  • A housing with a circular main body portion, a rear wall, a front flange, and a side wall.
  • The front flange defines both a "first internal mounting surface" and a "second internal mounting surface," with the second being closer to the rear wall.
  • A front lens cover affixed to the first internal mounting surface.
  • A plurality of fins extending from the outer surface of the rear wall.
  • A light engine assembly with a printed circuit board that "resides against the second internal mounting surface."
• The complaint reserves the right to assert additional claims Compl. ¶24

III. The Accused Instrumentality

Product Identification

• The complaint names a range of product models, including the CP100, CP600, JUPITER, MARS, and OXXQ series, collectively referred to as the "Accused Instrumentalities" Compl. ¶¶21-22

Functionality and Market Context

• The complaint alleges these are durable light fixtures with improved thermal management properties for use in commercial lighting applications Compl. ¶21 As shown in the complaint, the accused "JUPITER DISCRETE RGBW" product features a rugged, circular housing with an array of external cooling fins Compl. p. 7 This product is described as a "Compact and powerful surface-mount floodlight" using "High brightness RGB+W... power LEDs" Compl. p. 7 The complaint alleges Defendant sells these products in the United States through various channels Compl. ¶¶6, 28

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or a detailed narrative mapping specific features of the Accused Instrumentalities to the elements of the asserted claims. The infringement allegations are made on "information and belief" and are supported by a single, external product image Compl. ¶¶23, 24, p. 7

'245 Patent Infringement Allegations

The complaint alleges that the Accused Instrumentalities meet every limitation of at least claim 21 Compl. ¶27 While no specific evidence is offered for the internal structure, the external product photograph of the Jupiter model shows a housing with external fins, which the plaintiff may contend forms the claimed "array of fins" that defines a "rear receptacle" Compl. p. 7 The complaint does not provide any information regarding the internal placement of the power supply or the structure of the "receiver" and "flange" within the accused products.

• Identified Points of Contention:
  • Scope Questions: A central question will be whether the internal void space within the accused products' finned housings constitutes a "rear receptacle" as claimed. A further question is whether the accused products contain a power supply that is "residing within" that specific receptacle.
  • Technical Questions: Does discovery show that the accused products dissipate heat from the LEDs "without the use of a fan"? The complaint provides no evidence to affirm or deny this negative limitation.

'187 Patent Infringement Allegations

The complaint alleges that the Accused Instrumentalities meet every limitation of at least claim 1 Compl. ¶37 The product image shows a fixture with a "circular" front profile and rear fins, which may be the basis for alleging the "circular main body portion" and "plurality of fins" elements Compl. p. 7 The complaint provides no information or evidence regarding the specific internal mounting surfaces or the precise placement of the printed circuit board as required by the claim.

• Identified Points of Contention:
  • Scope Questions: Do the accused products possess the distinct "first internal mounting surface" and "second internal mounting surface" as structurally defined in the claim? Without cross-sectional views or internal product specifications, this remains a key open question.
  • Technical Questions: What evidence does the plaintiff possess that the printed circuit board in the accused products "resides against the second internal mounting surface"? This specific positional relationship is critical for infringement and is not ascertainable from the evidence provided in the complaint.

V. Key Claim Terms for Construction

'245 Patent, Claim 21

• The Term: "rear receptacle"
• Context and Importance: The claim requires that the power supply reside "within" this receptacle, which is itself "define[d]" by the fins. The construction of this term is fundamental to the patent's thermal isolation concept and will be a focal point of the infringement analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification refers to the receptacle as a "pocket... that receives the... power supply," which could suggest any sufficiently-sized void in that general location ’245 Patent, col. 4:20-23
  • Evidence for a Narrower Interpretation: The claim language states the "array of fins... define a rear receptacle," suggesting the fins themselves must form the boundaries of the space. The specification further states that the fins extending outward "defines a rear receptacle" ’245 Patent, col. 4:18-20 This language may support an interpretation that the receptacle is the volume enclosed by the fins.

'187 Patent, Claim 1

• The Term: "wherein the printed circuit board resides against the second internal mounting surface"
• Context and Importance: This clause specifies the exact physical arrangement of the light engine's core component relative to the housing. This contact is critical for the intended conductive heat transfer path, making its definition central to determining infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue "resides against" only requires close proximity sufficient to achieve the functional goal of heat transfer, not necessarily continuous, direct physical contact across the entire surface.
  • Evidence for a Narrower Interpretation: The common meaning of "against" implies direct contact. The patent family specification describes positioning a heat transfer element "between a rear surface of the circuit board and the... mounting surface to facilitate heat transfer," reinforcing the importance of a direct or near-direct physical interface ’187 Patent, col. 6:56-60, referencing parent application

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement based on Defendant's creation and distribution of materials like manuals and brochures that allegedly instruct others on how to use the products in an infringing manner Compl. ¶¶29, 39 Contributory infringement is alleged based on the sale of material parts of the invention that are not staple articles of commerce Compl. ¶¶30, 40
• Willful Infringement: Willfulness is alleged based on notice of the patents provided by the filing of the complaint itself Compl. ¶¶31, 41 The complaint does not allege any pre-suit knowledge on the part of the Defendant.

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

• A primary issue will be one of structural correspondence: Can the plaintiff demonstrate through discovery that the internal architecture of the accused products matches the specific and detailed structural limitations of the asserted claims? The case appears to hinge on whether Griven's products contain the '245 patent's "rear receptacle" housing a power supply, or the '187 patent's distinct "first" and "second" internal mounting surfaces with a PCB residing against the latter.
• A key evidentiary question will be the sufficiency of the pre-suit investigation: The complaint's reliance on a single external product photograph for its infringement allegations against two structurally-focused patents raises the question of what technical evidence supported the filing. The viability of the case will likely depend on whether post-filing discovery substantiates the complaint's "information and belief" allegations regarding the internal configuration of the accused products.