Ultravision Tech LLC v. Current Lighting Solutions LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ultravision Technologies, LLC (Delaware)
  • Defendant: Current Lighting Solutions, LLC (Delaware)
  • Plaintiff's Counsel: BRAGALONE OLEJKO SAAD PC
• Case Identification: 7:26-cv-00238, W.D. Tex., 06/22/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant conducts substantial business in the district, including offering for sale and selling accused products through distributors, and maintains a "regular and established place of business" in Round Rock, Texas.
• Core Dispute: Plaintiff alleges that Defendant's outdoor LED area and site lighting products infringe four patents related to modular LED lighting assemblies and optical systems designed to produce uniform illumination while maintaining reliability.
• Technical Context: The technology concerns high-efficiency LED luminaires for large-area outdoor lighting (e.g., parking lots, roadways), a market where uniform light distribution, energy efficiency, and low maintenance are critical competitive factors.
• Key Procedural History: The complaint alleges that Plaintiff has marked its own products pursuant to 35 U.S.C. § 287, which may be relevant to the calculation of damages and allegations of willful infringement.

Case Timeline

Date	Event
2012-07-30	Earliest Patent Priority Date ('881, '102, '488, '511 Patents)
2017-03-07	U.S. Patent No. 9,589,488 Issues
2017-05-23	U.S. Patent No. 9,659,511 Issues
2017-06-20	U.S. Patent No. 9,685,102 Issues
2021-01-12	U.S. Patent No. 10,891,881 Issues
2022-02-01	Defendant Current acquires Hubbell Inc.'s C&I lighting business
2026-06-22	Complaint Filed

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

U.S. Patent No. 10,891,881 - "LIGHTING ASSEMBLY WITH LEDS AND OPTICAL ELEMENTS" (issued Jan. 12, 2021)

The Invention Explained

• Problem Addressed: The patent describes the difficulty of using LEDs for large-scale external illumination, noting that conventional designs can create uneven lighting with undesirable "hot spots" and "light pollution" where light is wasted by spilling beyond the target area '881 Patent, col. 4:1-10
• The Patented Solution: The invention discloses a lighting apparatus where each LED on a circuit board is paired with its own dedicated optical element '881 Patent, col. 6:12-16 These optical elements are specifically designed to redirect light from a single, edge-mounted LED to evenly illuminate an entire, and often large, off-center rectangular surface, such as a billboard '881 Patent, abstract '881 Patent, col. 6:3-33 This modular design also provides redundancy, allowing the surface to remain uniformly lit, albeit at a lower intensity, even if one or more LEDs fail '881 Patent, col. 7:23-33
• Technical Importance: This approach sought to improve the efficiency and reliability of LED-based area lighting by ensuring precise light control and fault tolerance, key requirements for commercial and industrial applications.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶36
• Essential elements of independent claim 1, a lighting apparatus, include:
  • a circuit board;
  • a plurality of LEDs attached to the circuit board in a single plane array;
  • a thermally conductive support substrate for heat dissipation;
  • a plurality of optical elements, "each optical element being substantially the same as all other optical elements," configured to shape light in a rectangular waveform, with each LED associated with a single optical element;
  • the apparatus being configured to illuminate a "substantially rectangular surface that is off-center" with a specific "illumination level and a uniformity"; and
  • a configuration wherein "failure of one or more of the LEDs" causes the illumination level to decrease while the "uniformity of light...remains substantially the same."
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 9,685,102 - "LED LIGHTING ASSEMBLY WITH UNIFORM OUTPUT INDEPENDENT OF NUMBER OF NUMBER OF ACTIVE LEDS, AND METHOD" (issued Jun. 20, 2017)

The Invention Explained

• Problem Addressed: Like the related '881 patent, this invention addresses the challenge of providing consistent and uniform illumination from an LED array, particularly when individual LEDs may fail over time '881 Patent, col. 4:1-10
• The Patented Solution: The patent claims a method of illuminating an area. The method involves using a light assembly with a plurality of LEDs and associated optical elements, where each optical element has a specific three-part structure '102 Patent, claim 1 The method comprises directing light from the LEDs through these unique optical elements in such a way that light from each element is cast "across the area," ensuring continued coverage even if some LEDs become inoperative Compl. ¶¶55-57 The geometry of the optical elements, with intersecting surfaces, is a key aspect of how this light distribution is achieved Compl. ¶56
• Technical Importance: This method provides a systematic approach to designing fault-tolerant lighting systems that maintain their intended coverage pattern, which is crucial for applications where consistent illumination is a safety or operational requirement.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶53
• Essential elements of independent claim 1, a method of illuminating an area, include:
  • using a light assembly with a plurality of LEDs and a plurality of optical elements, with one-to-one association between LEDs and optical elements;
  • "directing light away from the plurality of LEDs toward the area," wherein the light from each optical element is "directed across the area";
  • wherein each optical element includes a "first element," a "second element that intersects with the first element," and a "third element extending beyond the region between the first and second element";
  • shaping the first and second elements so that at least one surface normal of each intersects; and
  • if some LEDs fail, the step of directing light comprises directing it from the "operative ones" of the LEDs such that light from each is still directed across the area.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

Multi-Patent Capsule: U.S. Patent No. 9,589,488

• Patent Identification: U.S. Patent No. 9,589,488, "LED LIGHT ASSEMBLY WITH THREE-PART LENS," issued March 7, 2017.
• Technology Synopsis: The '488 patent claims a method of illuminating an area using an apparatus with specially designed optical elements. Each optical element features first and second convex-shaped surfaces that intersect at an acute angle, and a third element extending away from the LED, to direct light "across all of the area" Compl. ¶¶73-74
• Asserted Claims: At least independent claim 1 Compl. ¶71
• Accused Features: The complaint alleges that the method is performed by Defendant's RAR2 product, whose optical elements are alleged to have the claimed three-part structure with intersecting convex surfaces Compl. ¶¶72-74

Multi-Patent Capsule: U.S. Patent No. 9,659,511

• Patent Identification: U.S. Patent No. 9,659,511, "LED LIGHT ASSEMBLY HAVING THREE-PART OPTICAL ELEMENTS," issued May 23, 2017.
• Technology Synopsis: The '511 patent claims an apparatus comprising a lighting assembly where each optical element is separate and includes a first, second, and third portion with specific curved and intersecting surfaces. The patent specifies that the arrangement is designed to prevent "hot spots or... dead spots on the area so long as some of the LEDs are functional" Compl. ¶¶90-94
• Asserted Claims: At least independent claim 1 Compl. ¶88
• Accused Features: The complaint alleges Defendant's RAR2 product is an apparatus whose optical elements embody the claimed three-part structure with intersecting curved surfaces, designed for fault-tolerant operation Compl. ¶¶89-94

III. The Accused Instrumentality

• Product Identification: The complaint names numerous products across Defendant's BEACON, ARCHITECTURAL AREA LIGHTING, KIM, and other brands Compl. ¶20 The infringement allegations focus specifically on the BEACON RATIO "RAR2" product (e.g., RAR2-140-4k-3) as the exemplary accused instrumentality Compl. ¶20
• Functionality and Market Context: The RAR2 is an outdoor LED area/site luminaire, marketed for applications such as auto dealerships, retail, and campus parking lots Compl. ¶7, footnote 1 The complaint alleges, based on photographs of a product teardown, that the RAR2 product comprises one or more circuit boards populated with an array of LEDs Compl. ¶21 A photograph shows a circuit board with LEDs arranged in rows and columns in a single plane Compl. ¶21 Overlying the LEDs is a corresponding array of plastic optical elements, or lenses, which are alleged to shape and direct the light Compl. ¶21 The complaint includes an image of the light distribution pattern for a "Type 3" optic, showing an off-center, rectangular illumination area Compl. ¶21

IV. Analysis of Infringement Allegations

10,891,881 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A lighting apparatus comprising: a circuit board;	The RAR2 product contains a circuit board. A teardown photograph shows the circuit board component Compl. ¶21	¶38	col. 5:40-41
a plurality of light emitting diodes (LEDs) attached to the circuit board... arranged in an array of row and columns, wherein all of the LEDs attached to the circuit board are arranged in a single plane;	The RAR2 product's circuit board has multiple LEDs attached in an array of rows and columns, all lying in a single plane. This is shown in a teardown photograph Compl. ¶21	¶38	col. 5:41-44
a support substrate supporting the circuit board, the support structure made of a thermally conductive material and configured to dissipate heat...;	The RAR2 product's circuit board is supported by a thermally conductive support substrate configured to dissipate heat. This is depicted in a labeled photograph Compl. ¶21	¶38	col. 5:45-49
a plurality of optical elements configured to redirect light... each optical element being substantially the same as all other optical elements and configured to shape and direct light in a rectangular waveform...;	The RAR2 product includes a plurality of substantially identical optical elements, which are configured to produce a rectangular light pattern (Type 3 distribution). This is shown in diagrams Compl. ¶21	¶38	col. 6:3-9
wherein each LED is associated with a single optical element and each optical element is associated with a single LED, wherein each optical element comprises a convex portion at least partially overlying the associated LED...;	In the RAR2 product, each LED is associated with a single optical element containing a convex portion that overlies the LED. A close-up photograph illustrates this one-to-one association Compl. ¶21	¶38	col. 6:12-19
wherein the lighting apparatus is configured so that when all of the LEDs are operating a substantially rectangular surface that is off-center relative to the lighting apparatus is illuminated with an illumination level and a uniformity;	The RAR2 product is configured to illuminate an off-center, substantially rectangular surface with a certain illumination level and uniformity, as shown in the "Type 3" light distribution chart Compl. ¶21	¶39	col. 6:34-39
and wherein failure of one or more of the LEDs will cause the illumination level... to decrease while the uniformity of light... remains substantially the same.	The complaint alleges that the modular design of the RAR2 product's optics ensures that the failure of one or more LEDs will decrease the overall light level but maintain the uniformity of the light pattern. This is illustrated with a diagram comparing all-operative vs. partial-failure states Compl. ¶21	¶40	col. 7:23-33

• Identified Points of Contention:
  • Scope Questions: The analysis may turn on how the court construes several key terms. A primary question will be the scope of "substantially the same" as applied to the optical elements and "substantially rectangular" as applied to the illuminated surface. Another point of contention could be the definition of "uniformity" and whether the patent's specification, which suggests a "3:1 ratio of the average illumination to the minimum" '881 Patent, col. 6:36-39, limits the claim scope.
  • Technical Questions: A key evidentiary question will be whether the accused RAR2 product, upon failure of one or more LEDs, actually maintains its light "uniformity" while the "illumination level" decreases, as required by the final limitation of the claim. The complaint's visual depiction of this functionality Compl. ¶21 will likely be central to this inquiry.

9,685,102 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method of illuminating an area using a light assembly that includes a plurality of light emitting diodes (LEDs) and a plurality of optical elements, each optical element associated with one of the plurality of LEDs and each LED associated with one of the optical elements;	The RAR2 product performs a method of illumination using an assembly of LEDs and associated optical elements. A photograph illustrates the one-to-one relationship between LEDs and optical elements Compl. ¶22	¶54	col. 8:10-18
the method comprises directing light away from the plurality of LEDs toward the area, wherein directing the light comprises directing the light such that light exiting from each optical element is directed across the area;	The method performed by the RAR2 product involves directing light from each optical element across the target area. A diagram illustrates this concept with arrows showing light paths Compl. ¶22	¶55	col. 6:25-33
wherein each optical element... includes: a first element; a second element that intersects with the first element... wherein the first element and the second element are shaped so that at least one surface normal of the first element intersect with at least one surface normal of the second element;	The optical elements in the RAR2 product allegedly include first and second elements that intersect, with their surfaces shaped such that their surface normals also intersect. A detailed photograph with callouts points to these specific geometric features Compl. ¶22	¶56	col. 8:50-59
and a third element extending beyond the region between the first element and the second element in a direction away from the associated LED;	The optical elements in the RAR2 product allegedly include a third element extending away from the LED beyond the intersection region of the first two elements. This is shown in a close-up photograph Compl. ¶22	¶56	col. 8:60-64
wherein if some of the LEDs... fail to operate... the step of directing the light comprises directing the light from operative ones of the plurality of LEDs toward the area such that the light from each operative LED is directed across the area.	The complaint alleges that due to the optical design, if some LEDs in the RAR2 product fail, the remaining operative LEDs continue to direct light across the entire area, maintaining coverage. This is illustrated with side-by-side diagrams Compl. ¶22	¶57	col. 9:18-24

Note: Patent citations for the '102 Patent are drawn from the highly similar specification of the related, co-familial U.S. Patent No. 9,589,488 for illustrative purposes.

• Identified Points of Contention:
  • Scope Questions: The infringement analysis for this method claim will raise questions about the physical structures required to perform it. The meaning of geometric terms like "intersects," "surface normal," and "extending beyond" will be critical. The defendant may argue that its lens geometry does not meet the specific structural limitations recited in the method claim.
  • Technical Questions: The central technical question is whether the accused RAR2 product actually performs the claimed method step of directing light "across the area" from each operative LED. Plaintiff supports this with diagrams Compl. ¶22, but Defendant will likely challenge the evidence and argue its product operates differently.

V. Key Claim Terms for Construction

For the '881 Patent

• The Term: "uniformity"
• Context and Importance: This term is critical because it defines a required performance characteristic of the claimed apparatus. The dispute will likely center on whether the accused product achieves the level of "uniformity" required by the claim, and what the proper standard for measuring that uniformity is.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The defense may argue that "uniformity" should be given its plain and ordinary meaning of general evenness, without being tied to a specific numerical ratio, as the term is not explicitly defined in the claims themselves.
  • Evidence for a Narrower Interpretation: The plaintiff may point to the specification, which states, "What is meant by 'evenly' is that the illumination with a uniformity that achieves a 3:1 ratio of the average illumination to the minimum" '881 Patent, col. 6:35-39 Practitioners may focus on this term because this passage provides a potential definition that could significantly narrow the claim scope to a specific, measurable performance metric.

For the '102 Patent

• The Term: "directed across the area"
• Context and Importance: This phrase is the core of the claimed method, describing how light from individual LEDs contributes to illuminating the entire target. Its construction will determine whether the accused product's light distribution method infringes. The dispute will question if light from each accused lens is truly cast "across the area" or if it primarily illuminates only a portion.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A defendant might argue for a plain meaning, suggesting that any light contributing to the overall illumination of the area meets this limitation, even if its primary contribution is localized.
  • Evidence for a Narrower Interpretation: The plaintiff may argue the specification gives the term a more specific technical meaning. For example, the related '488 patent describes how "the light emitted from each LED... is projected onto the entire surface" '488 Patent, col. 6:25-27 This language suggests that light from a single source must cover the whole area, not just part of it, which would support a narrower interpretation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by "actively encouraging others to make, use, offer to sell" the accused products Compl. ¶43 Compl. ¶61 The basis for this allegation includes Defendant's creation and distribution of marketing materials, product specifications, instruction manuals, and technical support that allegedly promote the infringing use of the products Compl. ¶47 Compl. ¶65
• Willful Infringement: Willfulness is alleged for all asserted patents. The complaint bases this on Defendant's alleged knowledge of the patents-in-suit, stemming from Plaintiff's marking of its own products and website with the patent numbers "at or around the time of issuance" Compl. ¶19 Compl. ¶41 Compl. ¶59 The complaint alleges that despite this awareness, Defendant "disregarded an objectively high likelihood of infringement" Compl. ¶48 Compl. ¶66

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

This dispute centers on sophisticated optical designs for LED lighting. The outcome will likely depend on the court's resolution of several key technical and legal questions:

1. A central issue will be one of definitional scope: How will the court construe functional terms like "uniformity" and directional terms like "directed across the area"? The patent specifications provide potentially limiting language (e.g., a "3:1 ratio" for uniformity), and the court's adoption or rejection of these specific metrics as claim limitations will be a critical factor.

2. A key evidentiary question will be one of technical operation: Does the accused RAR2 product's optical system function in the specific manner claimed? The case will require a detailed factual analysis of whether the accused lenses, with their particular geometry, actually direct light from single LEDs "across the area" and maintain the claimed "uniformity" when LEDs fail, or if they operate on a different technical principle.

3. A third question relates to knowledge and intent: For the willfulness allegations to succeed, a key question will be whether Plaintiff can prove that Defendant had pre-suit knowledge of the specific patents-in-suit and their alleged infringement, based on the constructive notice provided by Plaintiff's patent marking activities.