ElectraLED Inc v. Music & Lights SRL

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ElectraLED, Inc. (Florida)
  • Defendant: Music & Lights S.r.l. (Italy)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-00070, E.D. Tex., 01/23/2026
• Venue Allegations: Plaintiff asserts venue is proper under the "alien venue rule," alleging Defendant is a foreign entity that maintains a regular and established business presence in the United States and transacts substantial business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s commercial-grade LED lighting products infringe patents related to durable fixture design and thermal management systems for dissipating heat generated by LEDs.
• Technical Context: The technology addresses the need for rugged, energy-efficient LED light fixtures in commercial and industrial settings, where managing heat is critical to ensuring the longevity and reliability of both the LEDs and their associated power electronics.
• Key Procedural History: The complaint alleges that one of the patents-in-suit 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 (Issued Jan. 26, 2010)

The Invention Explained

• Problem Addressed: The patent describes a problem with prior art commercial light fixtures which, while durable, used inefficient and costly light sources like fluorescent or halogen bulbs. While LED fixtures are more efficient, embedding the power supply inside a rugged housing for protection exposes the heat-sensitive power supply to damaging heat generated by the LED light engine Compl. ¶¶15-16 ’245 Patent, col. 1:26-44, 1:55-61
• The Patented Solution: The invention proposes a light fixture with a rugged housing that contains an internal power supply but is designed to thermally isolate that power supply from the light engine. This is achieved by placing the power supply module within a rear receptacle defined by an array of external heat-dissipating fins, creating a heat flow path that directs thermal energy away from the power supply and into the ambient environment ’245 Patent, Abstract; col. 2:1-7
• Technical Importance: This design sought to provide a commercial LED fixture that was both durable enough for high-traffic industrial use and reliable by solving the inherent conflict between protecting the power supply internally and isolating it from internal heat sources Compl. ¶16

Key Claims at a Glance

• The complaint asserts independent claim 21 ’245 Patent, col. 9:19-10:18
• Essential Elements of Claim 21:
  • A housing with a flange, internal receiver, frontal lens, and an array of fins extending rearward to define a rear receptacle, with a rear cover enclosing the receptacle.
  • A light engine assembly mounted to the receiver, comprising multiple light modules with LEDs and optical lenses mounted on a printed circuit board.
  • A power supply that resides within the rear receptacle and is enclosed by the cover.
  • A functional limitation wherein heat from the LEDs is dissipated by the fins without using a fan.
• The complaint reserves the right to assert additional claims Compl. ¶23

U.S. Patent No. 9,618,187 - LED LIGHT FIXTURE (Issued Apr. 11, 2017)

The Invention Explained

• Problem Addressed: As with the parent ’245 Patent, this patent addresses the need for durable, high-performance commercial LED fixtures that effectively manage thermal loads to ensure reliability Compl. ¶13 ’187 Patent, col. 1:40-59
• The Patented Solution: This invention discloses a different fixture geometry, featuring a housing with a circular main body and an array of fins extending from the rear wall. A key aspect is the creation of an air flow passageway across the light engine to enhance convective cooling ’187 Patent, col. 2:4-6, 2:15-20 The design also contemplates the use of a separate, external enclosure for the power supply, further isolating it from the heat-generating light engine ’187 Patent, col. 2:2-4
• Technical Importance: The design's emphasis on a specific circular geometry and integrated air flow path suggests an approach tailored for optimizing thermal performance in form factors such as track lighting or other architectural fixtures Compl. ¶13

Key Claims at a Glance

• The complaint asserts independent claim 1 ’187 Patent, col. 14:10-35
• Essential Elements of Claim 1:
  • A housing with a circular main body portion, a rear wall, a side wall, and a front flange.
  • The front flange defines a first internal mounting surface and also a "receiver" that provides a second internal mounting surface positioned 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 LED modules on a printed circuit board, where the board 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 identifies a range of products, including the Astra Wash, LumiPar, and ArcSpot series, collectively termed the "Accused Instrumentalities" Compl. ¶¶21-22

Functionality and Market Context

• The Accused Instrumentalities are alleged to be durable light fixtures with improved thermal management properties for reliable operation Compl. ¶21 The complaint provides a screenshot of the LumiPar 12Arc model, describing it as having an "IP65 die-cast aluminium housing" and being "Fan-free," designed as a "robust workhorse" for outdoor architectural lighting Compl. p. 7 This visual evidence shows a fixture with a circular front face and prominent cooling fins on its housing Compl. p. 7

IV. Analysis of Infringement Allegations

’245 Patent Infringement Allegations

’187 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question for the ’245 Patent will be whether the Accused Instrumentalities contain an internal power supply residing within a "rear receptacle" as claimed. For the ’187 Patent, a dispute may arise over whether the internal housing structure contains both a "first internal mounting surface" and a distinct "receiver that provides a second internal mounting surface."
• Technical Questions: Evidentiary questions will focus on the actual internal construction of the accused products. The complaint's allegations regarding the specific mounting surfaces for the ’187 Patent and the location of the power supply for the ’245 Patent will depend on technical evidence obtained during discovery.

V. Key Claim Terms for Construction

• The Term: "rear receptacle" (’245 Patent, Claim 21)

• Context and Importance: This term is critical because it defines the location of the power supply relative to the housing's heat-dissipating fins. The infringement analysis will turn on whether the internal cavity of the accused product, which houses its power electronics, can be characterized as a "receptacle" that is "defined" by the fins.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the structure as a "rear receptacle or pocket 105" ’245 Patent, col. 4:20-21, suggesting the term is not limited to one specific configuration. Plaintiff may argue that any cavity formed by the fins that serves to hold the power supply meets the claim’s functional definition.
  • Evidence for a Narrower Interpretation: The specification also describes the receptacle as "substantially rectangular" and shows it in figures (e.g., Fig. 3, 5) as a distinct, box-like void into which a power supply box is inserted ’245 Patent, col. 4:21-23 Defendant may argue the term is limited to this more defined structural arrangement.

• The Term: "receiver that provides a second internal mounting surface" (’187 Patent, Claim 1)

• Context and Importance: This term describes a specific internal geometry for mounting the light engine's circuit board. Practitioners may focus on this term because infringement depends on the accused product having a two-part mounting structure—a "first" surface for the lens cover and a distinct "second" surface on a "receiver" for the circuit board—rather than a simpler, single-plane mounting design.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Plaintiff may argue that any housing with a stepped internal surface that provides separate seating planes for the lens and the circuit board meets the limitation, regardless of whether the product's own schematics label that feature a "receiver."
  • Evidence for a Narrower Interpretation: Defendant may point to the patent's detailed figures, such as Figure 12, which illustrates the "receiver 195" as a discrete feature defining mounting surface 196, separate from the "flange 200" that defines mounting surface 201 ’187 Patent, Fig. 12 This could support an argument that the term requires two structurally distinct components or features.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for each patent. Inducement allegations are based on Defendant’s creation and distribution of "tutorials, brochures, manuals, [and] instructional documents" with the alleged intent to cause others to use the products in an infringing manner Compl. ¶¶29, 39
• Willful Infringement: Willfulness is alleged for both patents, based on alleged knowledge acquired no later than the filing date of the complaint Compl. ¶¶31, 41

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

• A core issue will be one of structural correspondence: Do the internal architectures of the Accused Instrumentalities map onto the specific geometric limitations of the asserted claims? This will require comparing the products' actual construction to claim elements such as the '245 patent's "rear receptacle" for an internal power supply and the '187 patent's two-part "receiver" and "mounting surface" structure.
• A key evidentiary question will be one of component location: Can Plaintiff produce evidence confirming that the accused products that are alleged to infringe the ’245 patent actually contain an internal power supply, as opposed to an external one, and that it is thermally managed in the manner claimed? The provided evidence shows external features consistent with the patents but does not resolve this internal configuration question.