Polaris PowerLED Tech LLC v. Apple Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Polaris PowerLED Technologies, LLC (California)
  • Defendant: Apple Inc. (California)
  • Plaintiff’s Counsel: Kramer Alberti Lim & Tonkovich LLP; Cherry Johnson Siegmund James, PC
• Case Identification: 1:25-cv-01821, W.D. Tex., 01/26/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Apple Inc. maintains numerous regular and established places of business in the district, including offices, a manufacturing facility, an engineering center, and retail stores, and has committed acts of infringement within the district. The complaint also cites a recent Federal Circuit decision upholding venue against Apple in the same district.
• Core Dispute: Plaintiff alleges that Defendant’s automatic brightness features in its iPhone and MacBook products infringe a patent related to controlling display brightness by combining ambient light sensor data with user preferences.
• Technical Context: The technology concerns methods for dynamically adjusting screen brightness on electronic devices to conserve battery life, reduce user eye strain, and improve visibility in varying light conditions.
• Key Procedural History: The complaint notes that the patent-in-suit, U.S. Patent No. 8,223,117, was previously asserted in Polaris PowerLED Technologies, LLC v. Dell et al. in the same court. It states that the court in the Dell case has already conducted a Markman hearing on the patent, which may influence claim construction proceedings in the present case. The complaint also alleges that Plaintiff provided Defendant with notice of infringement via a letter dated January 27, 2020.

Case Timeline

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

U.S. Patent No. 8,223,117 - “Method and Apparatus to Control Display Brightness with Ambient Light Correction”

• Patent Identification: U.S. Patent No. 8,223,117, “Method and Apparatus to Control Display Brightness with Ambient Light Correction,” issued July 17, 2012.

The Invention Explained

• Problem Addressed: The patent’s background describes the challenge of maintaining a readable display under varying ambient light conditions. High ambient light can "wash out" a display, while low light can make a bright screen cause eye fatigue. Prior systems that automatically adjusted brightness in a closed loop often failed to account for individual user preferences. Compl. ¶16 ’117 Patent, col. 1:25-58
• The Patented Solution: The invention proposes a control circuit that combines two inputs: a signal from an ambient light sensor and a signal representing a user's brightness preference. The core of the solution is the mathematical combination—specifically, multiplication—of these two signals to generate a final brightness control signal. It also introduces a "dark level bias" to ensure the display maintains a minimum, predefined brightness even in total darkness, preventing it from turning off completely. ’117 Patent, Abstract col. 3:45-67
• Technical Importance: This approach allows for an automatic brightness adjustment that is also personalized to a user's comfort level, aiming to balance power conservation, display longevity, and user ergonomics. Compl. ¶2 ’117 Patent, col. 2:45-53

Key Claims at a Glance

• The complaint asserts at least independent Claim 1. Compl. ¶23
• Essential elements of Claim 1 include:
  • a first input configured to receive a user signal indicative of a user selectable brightness setting;
  • a light sensor configured to sense ambient light and to output a sensing signal indicative of the ambient light level;
  • a multiplier configured to selectively generate a combined signal based on both the user signal and the sensing signal; and
  • a dark level bias configured to adjust the combined signal to generate a brightness control signal...such that the brightness control signal is maintained above a predetermined level when the ambient light level decreases to approximately zero.
• The complaint asserts infringement literally and/or under the doctrine of equivalents. Compl. ¶23

III. The Accused Instrumentality

Product Identification

• Product Identification: MacBook Air and MacBook Pro series laptop computers, and iPhone models from the iPhone 11 through the iPhone 17 series, along with other specified models (the "Apple Accused Products"). Compl. ¶23

Functionality and Market Context

• Functionality and Market Context: The accused functionality is the "Automatically adjust brightness" feature on macOS and the "Auto-Brightness" feature on iOS. Compl. ¶¶25, 27 These features utilize an integrated ambient light sensor to detect surrounding light levels and automatically adjust the display's brightness. The complaint alleges that this feature is enabled by default on the accused products when sold to customers. Compl. ¶¶26, 28 A screenshot from a MacBook Pro's settings menu shows a toggle switch for "Automatically adjust brightness." Compl. p. 11 The complaint also cites Apple's marketing materials, which state that disabling this feature may negatively affect battery life and energy consumption, positioning it as a key power-saving technology. Compl. ¶21

IV. Analysis of Infringement Allegations

’117 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A primary issue may be the scope of the term "multiplier." The complaint alleges infringement by software that adjusts a brightness curve. The defense may argue that "multiplier," in the context of the patent's disclosure of specific analog circuits like "current steering diodes," requires a more direct mathematical multiplication than the algorithmic curve-shaping performed by the accused software. ’117 Patent, col. 3:38-41
  • Technical Questions: A key evidentiary question will be whether the accused software's operation is technically equivalent to the claimed "multiplier." The complaint provides graphs purporting to show a multiplicative relationship between a user setting and the brightness output curve. Compl. pp. 15-17 The central technical dispute may concern whether these graphs accurately represent the function of a "multiplier" as claimed, or if the underlying accused algorithm operates in a fundamentally different, non-multiplicative way.

V. Key Claim Terms for Construction

• The Term: "multiplier"

• Context and Importance: The infringement analysis for claim 1 hinges on whether Apple's software-based system for adjusting brightness curves based on user input constitutes a "multiplier." Practitioners may focus on this term because the patent's specification describes hardware implementations, which could be contrasted with the software-based functionality of the accused products.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself is functional: "a multiplier configured to selectively generate a combined signal based on both the user signal and the sensing signal." Compl. ¶13 The specification also refers to using a "software algorithm" to "multiply the light sensor output with the user selectable brightness control." ’117 Patent, col. 2:7-9 This may support an interpretation that covers software implementations.
  • Evidence for a Narrower Interpretation: The detailed description provides specific hardware examples, such as "a pair of current steering diodes to multiply the sensor current signal with a PWM logic signal." ’117 Patent, col. 3:38-41 This language could be used to argue that the term should be limited to the disclosed circuit structures or their direct equivalents, rather than general-purpose software algorithms.

• The Term: "dark level bias"

• Context and Importance: This term is critical for distinguishing the invention from a system that might simply turn the backlight off in complete darkness. The dispute may turn on whether the minimum brightness level set by the accused products functions as the claimed "dark level bias."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim defines the term functionally as being "configured to adjust the combined signal...such that the brightness control signal is maintained above a predetermined level when the ambient light level decreases to approximately zero." Compl. ¶13 This functional language may support a broad reading.
  • Evidence for a Narrower Interpretation: The specification describes the "dark level bias" as a distinct circuit element or input that is summed with the light sensor output before being multiplied by the user input (as in Figure 1), or summed with the product of the user and sensor inputs (as in Figure 2). ’117 Patent, Figs. 1-2 An argument could be made that a simple software-defined minimum brightness floor in the accused products does not meet the more specific circuit configurations disclosed.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Apple induces infringement by providing customers with advertising, product manuals, and website materials that instruct users on how to use the accused "Auto-Brightness" features. Compl. ¶38
• Willful Infringement: Willfulness is alleged based on pre-suit knowledge. The complaint states that Plaintiff sent Apple a letter identifying the ’117 patent and its alleged infringement on January 27, 2020, more than six years before the complaint was filed. Compl. ¶¶42-43

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

• A core issue will be one of claim scope and technical equivalence: Can the term "multiplier," described in the patent with reference to specific analog circuit embodiments, be construed to cover the software algorithms that Apple uses to adjust brightness curves in its operating systems?
• A central evidentiary question will be one of functional operation: Do the graphs presented in the complaint accurately demonstrate that the accused products perform the specific function of a "multiplier" as claimed, or will discovery reveal a more complex, non-multiplicative technical operation that falls outside the patent's scope?
• A key procedural question will be the impact of prior litigation: How will the claim constructions adopted by the court during the Markman hearing in the related Dell case, which involved the same patent, influence the court’s interpretation of disputed terms in this action?