LED Engin v. Luminus Devices

8/13/2019 LED Engin v. Luminus Devices

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COMPLAINT FOR PATENT INFRINGEMENT - 1 -

Plaintiff Luminus Devices, Inc. (Luminus), for its Complaint against Defendant LED

Engin, Inc., (Defendant), alleges as follows:

THE PARTIES

1. LED Engin, Inc. is a California corporation with its principal place of business inSan Jose, California.

2. Upon information and belief, Luminus Devices, Inc. is a Delaware corporation witits principal place of business in Billerica, Massachusetts.

NATURE OF THE ACTION

3. This is an action for patent infringement.4. LED Engin is informed and believes, and thereupon alleges, that Defendant has

been and is infringing, contributing to the infringement of, and/or actively inducing others to

infringe claims of U.S. Patent No. 7,473,933 (the 933 patent).

JURISDICTION

5. This action arises under the patent laws of the United States, 35 U.S.C. 1, et seq.,including 35 U.S.C. 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C.

1331 and 1338(a).

VENUE

6. Venue is proper in this court under 28 U.S.C 1391(b), 1391(c), 1391(d) and/or1400(b) because a substantial part of the events giving rise to Luminus claims occurred in the

Northern District of California and because Defendant is subject to personal jurisdiction in the

Northern District of California.

INTRADISTRICT ASSIGNMENT

7. This is an intellectual property action and therefore shall be assigned on a district-wide basis per Civil L.R. 3-2(c).

FACTS

8. LED Engin develops and manufactures high performance light emitting diode(LED) lighting devices which are used in entertainment lighting; architectural lighting; high-


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15. LED Engin is informed and believes, and thereupon alleges, that every feature ofclaims 5, 8 and 11 of the 933 patent is found in each of the Accused Products, including but no

limited to:

Claim 5:

a top body layer;

a cavity disposed through the top body layer and having a floor for bonding to the

multiple LED's;

a thermal conduction layer bonded to the top body layer and having a top surface

forming the floor of the cavity and a bottom surface, the thermal conduction layer

including a thermally conducting ceramic material disposed between the floor and the

bottom surface;

a plurality of LED bonding pads in direct contact with the floor and configured to

bond to the multiple LED's;

and a plurality of electrical bonding pads in direct contact with the floor, proximat

to the LED bonding pads, and in electrical communication with a plurality of electrical

contacts disposed on a surface of the body.

Claim 8:

The package of claim 5 wherein the plurality of electrical contacts are disposed on

the bottom surface of the thermal conduction layer.

Claim 11:

The light emitting device of claim 5 wherein the plurality of LED bonding pads are

electrically conductive.

16. LED Engin realleges and incorporates by reference the allegations of Paragraphs 1through 15.

17. Defendant has directly infringed the 933 patent by making, using, importing,selling or offering for sale the Accused Products in the United States.

18. The willful and intentional nature of Defendants patent infringement makes this a


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exceptional case under 35 U.S.C. 285.

19. As a result of Defendants patent infringement, LED Engin has suffered damages ian amount to be determined at trial.

20. As a result of Defendants patent infringement, LED Engin has also sufferedirreparable injury to its business, reputation, and goodwill. LED Engin will continue to suffer

irreparable injury unless Defendants misconduct is enjoined by the Court.

PRAYER FOR RELIEF

Wherefore, LED Engin asks this Court to enter judgment in its favor against Defendant

and grant the following relief:

1. a judgment that Defendant has infringed and continues to infringe the 933 Patent

as alleged above;

2. a judgment accounting for all damages sustained by LED Engin as a result of

Defendants acts of infringement of the 933 Patent;

3. a judgment enjoining Defendant, and all of their officers, directors, employees,

agents, and representatives, from making, using, offering to sell, or selling any products that

infringe the 933 Patent including at least Luminus Luminus CBM380, Luminus CBT90C and

Luminus SM160 LED emitters.

4. A judgment ordering Defendant to file with this Court and serve upon Led Engin

with thirty (30) days after entry of the injunction a report in writing under oath setting forth in

detail the manner and form in which Defendant has complied with the injunction;

5. A judgment awarding LED Engin actual damagesm adequate to compensate LED

Engin for Defendants acts of patent infringement, together with prejudgment and post-judgment

interest;

6. A judgment awarding LED Engin enhanced damages, up to and including three

times Luminus damages, plus interest, under 35 U.S.C. 284.

7. A judgment that LED Engin recover its attorneys fees in connection with this

action pursuant to 35 U.S.C. 285;


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8. A judgment that LED Engin recover the costs of this action plus interest; and,

9. A judgment that LED Engin be granted such other and further relief as the Court

deems just and proper.

DEMAND FOR JURY TRIAL

LED Engin hereby demands trial by jury of all issues so triable.

DATED: January 13, 2014 Respectfully submitted,

KILPATRICK TOWNSEND & STOCKTON LLP

By: /s/ Roger L. Cook ROGER L. COOK

Attorneys for PlaintiffLED ENGIN, INC.

65989937V.1


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EXHIBIT A


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Documents

LED Engin v. Luminus Devices