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., 08/28/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established place of business within the district, specifically a facility in Round Rock, Texas, and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant's LED area, site, and roadway lighting products infringe four patents related to LED assemblies and optical systems designed for uniform, fault-tolerant illumination.
• Technical Context: The technology addresses challenges in large-area LED lighting, such as for billboards and parking lots, focusing on achieving uniform light distribution from an off-center source and ensuring operational reliability through thermal management and redundancy.
• Key Procedural History: This action was initiated via a First Amended Complaint. The complaint alleges that Defendant was served with the original complaint on June 24, 2026, establishing a date for potential post-filing willful infringement. Plaintiff also alleges pre-suit knowledge based on its patent marking practices.

Case Timeline

Date	Event
2012-07-30	Earliest Priority Date for '881, '102, '488, and '511 Patents
2017-03-07	U.S. Patent No. 9,589,488 Issued
2017-05-23	U.S. Patent No. 9,659,511 Issued
2017-06-20	U.S. Patent No. 9,685,102 Issued
2021-01-12	U.S. Patent No. 10,891,881 Issued
2022-02-01	Defendant acquired Hubbell Inc.'s C&I lighting business
2026-06-24	Original Complaint served on Defendant
2026-08-28	First Amended Complaint Filed

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

U.S. Patent No. 10,891,881 - LIGHTING ASSEMBLY WITH LEDS AND OPTICAL ELEMENTS

• Patent Identification: U.S. Patent No. 10,891,881, "LIGHTING ASSEMBLY WITH LEDS AND OPTICAL ELEMENTS," issued January 12, 2021.

The Invention Explained

• Problem Addressed: The patent addresses the difficulty of using LEDs to evenly illuminate a large, externally-lit surface, such as a billboard, from an off-center position. Problems include creating "hot spots," wasting light that spills past the target area, and managing heat dissipation and environmental protection for the LEDs. '881 Patent, col. 3:9-24
• The Patented Solution: The invention is a lighting apparatus featuring an array of LEDs on a circuit board, which is mounted to a thermally conductive support substrate for heat dissipation. A key feature is the use of a plurality of substantially identical optical elements, with one element per LED. These optical elements are configured to shape and direct light into a rectangular waveform, allowing an off-center fixture to illuminate a large rectangular surface. The design also provides fault tolerance, as the failure of one or more LEDs is claimed to decrease the overall illumination level without substantially affecting the uniformity of the light distribution. '881 Patent, abstract '881 Patent, col. 6:25-41
• Technical Importance: This approach provides a redundant, reliable, and efficient lighting solution for large-scale applications like billboards by ensuring uniform illumination and maintaining performance even with partial component failure. '881 Patent, col. 4:1-10

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶36
• Essential elements of independent claim 1 include:
  • A circuit board with a plurality of LEDs arranged in a single-plane array.
  • A thermally conductive support substrate for dissipating heat.
  • A plurality of substantially identical optical elements, each associated with a single LED, configured to shape and direct light in a rectangular waveform.
  • Each optical element has a convex portion overlying its associated LED and is part of an exposed outer surface.
  • The apparatus is configured to illuminate a substantially rectangular surface off-center with a specific illumination level and uniformity.
  • The failure of one or more LEDs causes the illumination level to decrease while the uniformity remains substantially the same.
• The complaint does not explicitly reserve the right to assert dependent claims but refers to "one or more claims" of the patent Compl. ¶36

U.S. Patent No. 9,685,102 - LED LIGHTING ASSEMBLY WITH UNIFORM OUTPUT INDEPENDENT OF NUMBER OF ACTIVE LEDS, AND METHOD

• Patent Identification: U.S. Patent No. 9,685,102, "LED LIGHTING ASSEMBLY WITH UNIFORM OUTPUT INDEPENDENT OF NUMBER OF ACTIVE LEDS, AND METHOD," issued June 20, 2017.

The Invention Explained

• Problem Addressed: Similar to the '881 Patent, the technology seeks to solve the problem of achieving uniform illumination over a target area and maintaining that uniformity even when some LEDs fail. '102 Patent, col. 3:9-24
• The Patented Solution: The patent claims a method of illumination using a light assembly where each optical element has a specific three-part structure. This structure comprises a "first element", a "second element" that intersects the first, and a "third element" that extends away from the LED. This geometry is designed to direct light from each individual LED across the entire target area, providing robust redundancy. If some LEDs fail, the remaining operative LEDs continue to illuminate the whole area, maintaining coverage at a reduced brightness. '102 Patent, abstract '102 Patent, col. 8:8-28
• Technical Importance: The claimed method provides a fault-tolerant lighting system that ensures continued, uniform area coverage despite partial LED failure, a critical feature for applications where consistent illumination is required. '102 Patent, col. 8:52-67

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶53
• Essential elements of independent claim 1 (a method claim) include:
  • Illuminating an area using a light assembly with LEDs and associated optical elements.
  • Directing light from the plurality of LEDs toward the area such that light from each optical element is directed across the entire area.
  • Each optical element includes a specific three-part geometry: a "first element", a "second element" that intersects the first (with intersecting surface normals), and a "third element" extending beyond the intersection region away from the LED.
  • If some LEDs fail, the method includes directing light from the remaining operative LEDs such that light from each operative LED is still directed across the area.
• The complaint refers to "one or more claims" of the patent Compl. ¶53

U.S. Patent No. 9,589,488 - LED LIGHT ASSEMBLY WITH THREE-PART LENS

• Patent Identification: U.S. Patent No. 9,589,488, "LED LIGHT ASSEMBLY WITH THREE-PART LENS," issued March 7, 2017.
• Technology Synopsis: This patent claims a method of illuminating an area using an apparatus with specific optical elements. The key feature is the geometry of each optical element, which comprises a first convex-shaped surface, a second convex-shaped surface that intersects the first at an acute angle, and a third element extending away from the LED. This design ensures that light from the associated LED exits through both convex surfaces to be directed across the entire target area. '488 Patent, abstract
• Asserted Claims: At least independent claim 1 Compl. ¶71
• Accused Features: The complaint alleges that the method of operation of the RAR2 product, which uses its specific optical elements to illuminate an area, infringes the '488 Patent Compl. ¶¶72-74

U.S. Patent No. 9,659,511 - LED LIGHT ASSEMBLY HAVING THREE-PART OPTICAL ELEMENTS

• Patent Identification: U.S. Patent No. 9,659,511, "LED LIGHT ASSEMBLY HAVING THREE-PART OPTICAL ELEMENTS," issued May 23, 2017.
• Technology Synopsis: This patent claims an apparatus comprising a lighting assembly with LEDs on a circuit board and a plurality of separate optical elements. Each element has a three-part structure with first and second intersecting curved surfaces and a third portion extending away from the LED. The arrangement is claimed to prevent hot spots or dead spots during operation, even if some LEDs are non-functional. '511 Patent, abstract
• Asserted Claims: At least independent claim 1 Compl. ¶88
• Accused Features: The complaint alleges that the physical construction of the RAR2 product's lighting assembly-including its circuit board, LEDs, and particularly the structure of its optical elements-infringes the '511 Patent Compl. ¶¶89-94

III. The Accused Instrumentality

Product Identification

The complaint identifies a wide range of LED lighting products sold under brands including BEACON, RATIO, KIM, ARCHITECTURAL AREA LIGHTING, EXO, and EVOLVE Compl. ¶20 The allegations focus primarily on the BEACON RATIO "RAR2" product (e.g., RAR2-140-4k-3) as the exemplary accused product Compl. ¶21 Compl. ¶37

Functionality and Market Context

The RAR2 product is an outdoor LED luminaire, described as a "traditional shoebox aesthetic," intended for area, site, and roadway lighting applications such as parking lots Compl. ¶7, footnote 1 Compl. ¶32 It is marketed as featuring "Micro Strike Optics" designed to "maximize target zone illumination with minimal losses at the house-side, reducing light trespass issues" Compl. ¶7, footnote 1 The complaint provides teardown photographs of the RAR2 product, showing its internal components, including the LED circuit board, the thermally conductive support structure, and the array of optical elements (lenses) that cover the LEDs Compl. ¶¶21-24 A diagram from Defendant's materials shows the RAR2 producing a "Type 3" light distribution pattern, which is a long and narrow pattern typically used for illuminating roadways or parking areas from the side Compl. p. 13

IV. Analysis of Infringement Allegations

U.S. Patent No. 10,891,881 Infringement Allegations

The complaint alleges that the RAR2 product directly infringes at least claim 1 of the '881 Patent Compl. ¶36 The complaint includes an annotated photograph showing a circuit board with LEDs arranged in rows and columns in a single plane Compl. p. 12 Another image alleges that a support substrate made of a thermally conductive material dissipates heat Compl. p. 12

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a circuit board;	The accused RAR2 product contains a circuit board.	¶38	col. 6:25-26
a plurality of light emitting diodes (LEDs) attached to the circuit board, the LEDs being 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 accused product's LEDs are attached to the circuit board in an array of rows and columns and are arranged in a single plane.	¶38	col. 6:26-29
a support substrate supporting the circuit board, the support structure made of a thermally conductive material and configured to dissipate heat during operation of the LEDs;	The accused product includes a support substrate made of a thermally conductive material that supports the circuit board and dissipates heat.	¶38	col. 6:29-32
a plurality of optical elements configured to redirect light from the plurality of LEDs, each optical element being substantially the same as all other optical elements and configured to shape and direct light in a rectangular waveform...	The accused product has a plurality of optical elements that are substantially the same and are configured to shape light into a rectangular "Type 3" waveform.	¶38	col. 6:32-37
...wherein each optical element comprises a convex portion at least partially overlying the associated LED...	Each optical element in the accused product includes a convex portion that at least partially overlies the associated LED.	¶38	col. 6:39-41
...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 accused product is configured to illuminate an off-center, substantially rectangular surface with a certain illumination level and uniformity.	¶39	col. 6:44-49
...wherein failure of one or more of the LEDs will cause the illumination level of light impinging the substantially rectangular surface to decrease while the uniformity of light impinging the substantially rectangular surface remains substantially the same.	In the accused product, the failure of one or more LEDs allegedly causes the illumination level to decrease while uniformity remains substantially the same.	¶40	col. 6:50-55

• Identified Points of Contention:
  • Scope Questions: A central question may be the interpretation of "substantially rectangular surface." The patent specification heavily features large billboards as the target surface '881 Patent, Fig. 1A, and the abstract mentions an edge length of at least 14 feet. The court may need to determine whether the general illumination area of a parking lot or roadway luminaire, as targeted by the accused RAR2 product, falls within the scope of this claim term.
  • Technical Questions: The allegation that the "uniformity of light... remains substantially the same" upon LED failure is a technical assertion that will likely require expert testimony and testing to substantiate or refute Compl. ¶40 The complaint presents this claim using a comparative diagram, but does not provide underlying test data Compl. p. 14

U.S. Patent No. 9,685,102 Infringement Allegations

The complaint alleges that the method of using the RAR2 product infringes at least claim 1 of the '102 Patent Compl. ¶53 The complaint offers several detailed, annotated photographs purporting to show the claimed multi-part lens structure in the accused product Compl. pp. 18-19

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 accused RAR2 product performs a method of illuminating an area using a light assembly with LEDs and associated optical elements.	¶54	col. 8:8-12
...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 comprises directing light from the LEDs toward the area such that light from each optical element is directed across the area.	¶55	col. 8:13-17
...wherein each optical element of the plurality of optical elements 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;	Each optical element of the accused product allegedly includes a first and second element that intersect, with their surface normals also intersecting.	¶56	col. 8:18-25
...and a third element extending beyond the region between the first element and the second element in a direction away from the associated LED.	Each optical element of the accused product allegedly includes a third element extending beyond the intersection region in a direction away from the associated LED.	¶56	col. 8:25-28
...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... such that the light from each operative LED is directed across the area.	If some LEDs in the accused product fail, the method of directing light allegedly comprises directing light from the operative LEDs so that each directs light across the area.	¶57	col. 8:29-34

• Identified Points of Contention:
  • Technical Questions: The infringement analysis will likely center on the detailed geometry of the accused "Micro Strike Optics." The claim recites a very specific three-part structure for each optical element. A key question for the court will be whether the physical lens in the RAR2 product can be technically mapped to the claimed "first element", "second element", and "third element" with the required intersection of surface normals and the specific "extending beyond" relationship. The complaint's annotated visuals represent Plaintiff's position on this technical mapping, which will be a primary focus of dispute.

V. Key Claim Terms for Construction

For U.S. Patent No. 10,891,881

• The Term: "substantially rectangular surface"
• Context and Importance: This term defines the target of the illumination. Its scope is critical because the patent's examples focus on very large billboards, while the accused products are general-purpose area and site luminaires. Practitioners may focus on this term to determine if the patent's scope can extend from its specific billboard embodiment to the broader market of outdoor area lighting.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not explicitly limit the size or application of the "surface," only its general shape. The use of "substantially" suggests that some deviation from a perfect rectangle is contemplated.
  • Evidence for a Narrower Interpretation: The specification's background and detailed description are heavily focused on billboards '881 Patent, col. 3:9-12 Figure 1A explicitly depicts a billboard. The abstract states the "substantially rectangular area has an edge that is at least 14 feet in length," which could be used to argue the term is limited to large-scale surfaces and does not cover smaller areas like single parking spaces.

For U.S. Patent No. 9,685,102

• The Term: "a third element extending beyond the region between the first element and the second element"
• Context and Importance: This term is a key structural limitation defining the specific geometry of the claimed three-part lens. The infringement analysis for the '102, '488, and '511 patents will likely hinge on whether the accused product's optical structure meets this precise definition. Practitioners may focus on this term as it represents a potential non-infringement argument if the accused lens lacks this specific structural feature.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that "element" should be interpreted functionally, where any portion of the lens that performs the final light-shaping function in the specified direction qualifies as the "third element," regardless of whether it is a distinct physical structure.
  • Evidence for a Narrower Interpretation: The patent figures, such as Figure 8E in the related '488 and '511 patents, depict a distinct physical part of the lens that extends away from the intersection of the other two parts. A party could argue that the term requires a physically identifiable structure that "extends beyond" the intersection region, not just a functional area of a monolithic lens.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by encouraging customers, installers, and end-users to use the accused products in an infringing manner Compl. ¶42 Compl. ¶43 The factual basis cited includes Defendant's creation and distribution of marketing materials, advertisements, product specifications, instructions, and manuals that promote the infringing use of the products Compl. ¶47 Compl. ¶65
• Willful Infringement: Plaintiff alleges willful infringement based on both pre-suit and post-suit conduct. Pre-suit knowledge is alleged based on Plaintiff's product marking and virtual marking website, which allegedly put Defendant on notice of the patents Compl. ¶19 Compl. ¶41 Post-suit willfulness is alleged based on Defendant's continued infringement after being served with the original complaint on June 24, 2026 Compl. ¶32 Compl. ¶48 Compl. ¶66

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

1. A core issue will be one of definitional scope: can the term "substantially rectangular surface," which is described in the context of large-scale billboard lighting in the '881 patent, be construed to cover the general illumination targets of the accused outdoor luminaires used for site and roadway lighting?
2. A key evidentiary question will be one of structural mapping: do Defendant's "Micro Strike Optics" actually embody the specific three-part geometric structure-including a "first element", an intersecting "second element", and a "third element extending beyond" the intersection-as recited in the independent claims of the '102, '488, and '511 patents, or is there a fundamental mismatch in physical construction?
3. A central technical question will be one of functional equivalence and proof: does the accused RAR2 product exhibit the claimed fault-tolerant behavior-maintaining light distribution uniformity upon partial LED failure-and if so, does it achieve this function through the same claimed means, an issue that will likely depend on competing expert analyses of photometric data.