IP Law Daily, PATENT—D. Nev.: Summary judgment granted in part in LED lighting dispute, (Aug 4, 2025)

By Kevin M. Finson, J.D.

Summary judgment of several infringement claims was granted, either because the motion was unopposed or because the opposing party relied entirely on attorney argument, rather than on admissible evidence.

A holder of LED lighting technology patents was entitled to summary judgment on several claims of infringement against a competing seller, the U.S. District Court in Las Vegas has held. Genuine questions of material fact still existed about the obviousness of two patents’ claims and the date the alleged infringer had actual knowledge of the alleged infringement (Signify North America Corp. v. Lepro Innovation Inc., No. 2:22-cv-02095-JAD-EJY (D. Nev. July 31, 2025)).

Signify North America Corporation and Signify Holding, B.V. (collectively, Signify) were the owners of U.S. Patents Nos. 7,014,336 (the ’336 patent), 7,038,399 (the ’399 patent), 7,348,604 (the ’604 patent), 7,352,138 (the ’138 patent), 8,063,577 (the ’577 patent), and RE 49,320 (the ’320 patent), each of which were related to LED lighting products. Signify brought suit for infringement against Lepro Innovation, Inc. and related entities (collectively, Lepro) alleging infringement of all six patents. After claim construction, both parties moved for partial summary judgment.

Signify’s unopposed claims. Based on the court’s claim construction, Lepro did not oppose summary judgment of infringement of the ’138 and ’399 patents, affirmative defenses based on the specifications of the ’339, ’604, ’138, ’577, and ’253 patents, prior-art invalidity of the ’320 patent, and anticipation defenses of the ’138 and ’399 patents. The court granted summary judgment on these matters as unopposed.

Signify’s opposed claims. The court granted summary judgment of infringement of the ’577 patent, finding that Lepro had failed to produce any actual evidence to contradict the prima facie case made by Signify, but instead relied entirely on attorney argument. Summary judgment against affirmative defenses of invalidity was granted because they relied on theories raised for the first time that were too late, after the deadlines set by local patent rules. Summary judgment against Lepro’s obviousness defenses to the ’138 and ’399 patents was denied, however, because it was unclear whether the argument matched the expert testimony supporting obviousness in that they were, at least potentially, referring to different components.

Lepro’s motion. Lepro moved for summary judgment on the issue of when it had actual notice of the alleged infringement, which was necessarily a part of computing damages. The court found that a genuine question of material fact existed as to when Lepro received actual notice, because the scope of what a person of reasonable skill in the art would understand from several notice letters, specifically whether an alleged infringement of by one product should implicate other, similar products, was a matter for the jury.

The court granted in part Signify’s motion and denied Lepro’s motion.

The Case is No. 2:22-cv-02095-JAD-EJY.

Judge: Dorsey, J.

Attorneys: Adam D. Swain (Alston and Bird LLP) for Signify North America Corp. and Signify Holding B.V. Callie J. Sand (Greenberg Traurig, P.A.) for Lepro Innovation Inc., LE Innovation Inc., Innovation Rules Inc., Home Ever Inc., and Letianlighting, Inc.

Companies: Signify North America Corp.; Signify Holding B.V.; Lepro Innovation Inc.; LE Innovation Inc.; Innovation Rules Inc.; Home Ever Inc.; Letianlighting, Inc.

Cases: Patent DelawareNews