Case 6:16-cv-01084-RBD-GJK Document 13 Filed 07/18/16 Page 1 of 12 PageID 115
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`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`ORLANDO DIVISION
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`Case No.: 6:16-cv-1084-Orl-37GJK
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`JURY TRIAL DEMANDED
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`LIGHTING SCIENCE GROUP
`CORPORATION,
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`Plaintiff,
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`
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`v.
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`HUBBELL LIGHTING, INC.,
`HUBBELL INCORPORATED,
`and PROGRESS LIGHTING, INC.
`
`
`
`Defendant.
`_______________________________/
`
`
`AMENDED COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff Lighting Science Group Corporation, through its attorneys, alleges the following:
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`PARTIES
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`1.
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`Plaintiff Lighting Science Group Corporation (“LSG” and/or “Plaintiff”) is a
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`corporation organized and existing under the laws of the state of Delaware, with its principal place
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`of business at 811 N. Atlantic Avenue, Cocoa Beach, Florida 32931.
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`2.
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`Defendant Hubbell Lighting, Inc. (“Hubbell Lighting”) is a corporation organized
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`and existing under the laws of the state of Connecticut with its principal place of business located
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`at 701 Millennium Blvd., Greenville, SC, 29607, but doing business throughout the United States,
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`including Florida, and whose registered agent in Florida is Corporation Service Company located
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`at 1201 Hays Street, Tallahassee, Florida 32301-2525.
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`3.
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`Defendant Hubbell Incorporated (“Hubbell Inc.”), an affiliate of Hubbell Lighting,
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`is a corporation organized and existing under the laws of the state of Connecticut with its principal
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`place of business located at 40 Waterview Drive, Shelton, Connecticut 06484, but doing business
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`throughout the United States, including Florida, and whose registered agent in Florida, upon
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`information and belief, is Registered Services, Inc., 13385 West Dixie Hwy. North Miami, FL
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`33161.
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`4.
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`Defendant Progress Lighting, Inc. (“Progress”, and collectively with Hubbell
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`Lighting and Hubbell Inc., the “Defendants”), an affiliate of Hubbell Lighting, is a corporation
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`organized under the laws of the state of Delaware with its principal place of business located at
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`701 Millennium Boulevard, Greenville, SC 29607, but upon information and belief, is doing
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`business throughout the United States, including Florida.
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`JURISDICTION AND VENUE
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`5.
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`This is a claim for patent infringement and arises under the patent laws of the United
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`States, Title 35 of the United States Code. This Court has jurisdiction over the subject matter of
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`this claim under 28 U.S.C. §§ 1331 and 1338(a).
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`6.
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`This Court has personal jurisdiction over the Defendants because the Defendants
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`are transacting business within this District and have committed acts and, on information and
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`belief, will continue to commit acts within this District giving rise to this action, including offering
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`to sell and selling infringing products and/or placing infringing products, directly or through
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`intermediaries (including distributors, retailers, and others), into the stream of commerce in such
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`a way as to reach customers in this District. Defendants have purposefully and voluntarily sold
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`one or more of their infringing products with the expectation that they will be purchased by
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`consumers in this District. These infringing products have been and continue to be purchased by
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`consumers in this District. Defendants have committed acts of patent infringement within the
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`United States and more particularly, within this District.
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`7.
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`Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b).
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`COUNT I
`(Infringement of U.S. Patent No. 8,201,968)
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`8.
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`9.
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`Plaintiff repeats and re-alleges Paragraphs 1-7 as though fully set forth herein.
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`Plaintiff LSG is the owner by assignment of United States Patent No. 8,201,968
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`entitled “Low Profile Light,” which was duly and legally issued by the USPTO on June 19, 2012
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`(the “’968 Patent”). A true and correct copy of the ’968 Patent is attached hereto as Exhibit A.
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`10.
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`The ’968 Patent is valid and enforceable and Plaintiff has the full right to recover
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`for past infringement damages and the right to recover future royalties, damages and income.
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`11.
`
`To the extent any marking or notice was required by 35 U.S.C. § 287, Plaintiff, and
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`all predecessors in interest and/or implied or express licensees of the ’968 Patent, if any, have
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`complied with the marking requirements of 35 U.S.C. § 287 by placing a notice of the ’968 Patent
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`on all goods made, offered for sale, sold, and/or imported into the United States that embody one
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`or more claims of that patent and/or providing actual or constructive notice to Defendant.
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`12.
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`On December 9, 2015, Defendants received notice of the ‘968 Patent. Plaintiff’s
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`notice to Defendants referred to Defendants’ “Surface Mount family of products”. The Surface
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`Mount family of products are a subject of this complaint.
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`13.
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`Upon information and belief, since at least December 9, 2015, when Plaintiff
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`formally placed Defendants on notice of their infringement, Defendants have infringed and will
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`continue to infringe at least Claims 1, 2, 5, 6, 14, 15, 16, and 18 of the ‘968 Patent by, among other
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`activities, making, using, selling or offering to sell in or importing into the United States its
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`LBSLEDA10L products. Defendants have also infringed and will continue to infringe at least
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`Claims 1, 2, 14, 15 and 16 of the ‘968 Patent by, among other activities, making, using, selling or
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`offering to sell in or importing into the United States its P8222-28/30K9-AC1-L10 products.
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`Defendants are liable for direct infringement, either literally or under the doctrine of equivalents,
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`of the ’968 Patent pursuant to 35 U.S.C. §271 (a).
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`14.
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`Upon information and belief, since at least December 9, 2015, when Plaintiff
`
`formally placed Defendants on notice of their infringement, Defendants have been and continue
`
`to induce, under 35 U.S.C. §271(b), consumers, distributors, importers and/or resellers that
`
`purchase or sell LBSLEDA10L products to directly infringe at least Claims 1, 2, 5, 6, 14, 15, 16
`
`and 18 of the ‘968 Patent. Since at least December 9, 2015, the date when Plaintiff formally placed
`
`Defendants on notice of their infringement, Defendants do so with knowledge, or with willful
`
`blindness of the fact, that the induced acts constitute infringement of the ’968 patent. Upon
`
`information and belief, Defendants intend to cause, and have taken affirmative steps to induce,
`
`infringement by these third-party manufacturers, distributors, importers, and/or consumers by,
`
`inter alia, creating advertisements that promote the infringing use of LBSLEDA10L products,
`
`creating established distribution channels for these products into and within the United States,
`
`purchasing these products, manufacturing these products in conformity with U.S. laws and
`
`regulations, distributing or making available instructions or manuals for these products to
`
`purchasers and prospective purchasers, and/or providing technical support, replacement parts, or
`
`services for these products to these purchasers in the United States.
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`15.
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`Upon information and belief, since at least December 9, 2015, when Plaintiff
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`formally placed Defendants on notice of their infringement, Defendants have infringed and will
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`continue to infringe at least Claims 1, 2, 14, 15, and 16 of the ‘968 Patent by, among other
`
`activities, making, using, selling or offering to sell in or importing into the United States its P8222-
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`28/30K9-AC1-L10 products. Defendants are liable for direct infringement, either literally or under
`
`the doctrine of equivalents, of the ’968 Patent pursuant to 35 U.S.C. §271 (a).
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`16.
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`Upon information and belief, since at least December 9, 2015, when Plaintiff
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`formally placed Defendants on notice of the infringement of their LBSLEDA10L products,
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`Defendants have been and continue to induce, under 35 U.S.C. §271(b), consumers, distributors,
`
`importers and/or resellers that purchase or sell P8222-28/30K9-AC1-L10 products, to directly
`
`infringe at least Claims 1, 2, 14, 15, and 16 of the ’968 Patent. Since at least December 9, 2015,
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`the date when Plaintiff formally placed Defendants on notice of their infringement, Defendants do
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`so with knowledge, or with willful blindness of the fact, that the induced acts constitute
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`infringement of the ’968 patent. Upon information and belief, Defendants intend to cause, and
`
`have taken affirmative steps to induce, infringement by these third-party manufacturers,
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`distributors, importers, and/or consumers by, inter alia, creating advertisements that promote the
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`infringing use of P8222-28/30K9-AC1-L10 products, creating established distribution channels
`
`for these products into and within the United States, purchasing these products, manufacturing
`
`these products in conformity with U.S. laws and regulations, distributing or making available
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`instructions or manuals for these products to purchasers and prospective purchasers, and/or
`
`providing technical support, replacement parts, or services for these products to these purchasers
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`in the United States.
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`17.
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`Plaintiff has at no time either expressly or impliedly licensed any of the Defendants
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`to practice the ’968 Patent.
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`18.
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`Defendants’ infringement has injured Plaintiff, and Plaintiff is entitled to recover
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`damages adequate to compensate it for such infringement.
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`19.
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`Upon information and belief, Defendants’ acts of infringement are willful,
`
`warranting the assessment of increased damages pursuant to 35 U.S.C. § 284, and warrant a finding
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`that this is an exceptional case, pursuant to 35 U.S.C. § 285.
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`20.
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`Defendants’ infringing activities have injured and will continue to injure Plaintiff,
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`unless and until this Court enters an injunction prohibiting further infringement and, specifically,
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`Page 5 of 12
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`enjoining further manufacture, use, sale, importation, and/or offer for sale of products that come
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`within the scope of the claims of the ’968 Patent.
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`COUNT II
`(Infringement of U.S. Patent No. 8,672,518)
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`21.
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`22.
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`Plaintiff repeats and re-alleges Paragraphs 1-7 as though fully set forth herein.
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`Plaintiff LSG is the owner by assignment of United States Patent No. 8,672,518
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`entitled “Low Profile Light And Accessory Kit For The Same,” which was duly and legally issued
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`by the USPTO on March 18, 2014 (the “’518 Patent”). A true and correct copy of the ’518 Patent
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`is attached hereto as Exhibit B.
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`23.
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`The ’518 Patent is valid and enforceable and Plaintiff has the full right to recover
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`for past infringement damages and the right to recover future royalties, damages and income.
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`24.
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`To the extent any marking or notice was required by 35 U.S.C. § 287, Plaintiff, and
`
`all predecessors in interest and/or implied or express licensees of the ‘518 Patent, if any, have
`
`complied with the marking requirements of 35 U.S.C. § 287 by placing a notice of the ’518 Patent
`
`on all goods made, offered for sale, sold, and/or imported into the United States that embody one
`
`or more claims of that patent and/or providing actual or constructive notice to Defendant.
`
`25.
`
`On December 9, 2015, Defendants received notice of the ‘518 Patent. Plaintiff’s
`
`notice to Defendants referred to Defendants’ “Surface Mount family of products”. The Surface
`
`Mount family of products are a subject of this complaint.
`
`26.
`
`Upon information and belief, since at least, December 9, 2015, when Plaintiff
`
`formally placed Defendants on notice of their infringement, Defendants have infringed and will
`
`continue to infringe at least Claims 1, 3, 4, 5, 6, 9, 11, 12 and 13 of the ’518 Patent by, among
`
`other activities, making, using, selling or offering to sell in or importing into the United States its
`
`LBSLEDA10L products. Defendants are liable for direct infringement, either literally or under the
`
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`Page 6 of 12
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`doctrine of equivalents, of the ’518 Patent pursuant to 35 U.S.C. §271 (a).
`
`27.
`
`Upon information and belief, since at least December 9, 2015, when Plaintiff
`
`formally placed Defendants on notice of their infringement, Defendants have been and continue
`
`to induce, under 35 U.S.C. §271(b), consumers, distributors, importers and/or resellers that
`
`purchase or sell LBSLEDA10L products, to directly infringe at least Claims 1, 3, 4, 5, 6, 9, 11, 12,
`
`and 13 of the ’518 Patent. Since at least December 9, 2015, the date when Plaintiff formally
`
`placed Defendants on notice of their infringement, Defendants do so with knowledge, or with
`
`willful blindness of the fact, that the induced acts constitute infringement of the ’518 patent. Upon
`
`information and belief, Defendants intend to cause, and have taken affirmative steps to induce,
`
`infringement by these third-party manufacturers, distributors, importers, and/or consumers by,
`
`inter alia, creating advertisements that promote the infringing use of LBSLEDA10L products,
`
`creating established distribution channels for these products into and within the United States,
`
`purchasing these products, manufacturing these products in conformity with U.S. laws and
`
`regulations, distributing or making available instructions or manuals for these products to
`
`purchasers and prospective purchasers, and/or providing technical support, replacement parts, or
`
`services for these products to these purchasers in the United States.
`
`28.
`
`Upon information and belief, since at least, December 9, 2015, when Plaintiff
`
`formally placed Defendants on notice of their infringement, Defendants have infringed and will
`
`continue to infringe at least Claims 1, 3, 5, 6, 7, 8, 11, and 14 of the ’518 Patent by, among other
`
`activities, making, using, selling or offering to sell in or importing into the United States its P8080-
`
`28/30K9-AC1-L06 and P8061-28/30K9-AC1-L06 products. Defendants are liable for direct
`
`infringement, either literally or under the doctrine of equivalents, of the ’518 Patent pursuant to 35
`
`U.S.C. §271 (a).
`
`29.
`
`Upon information and belief, since at least December 9, 2015, when Plaintiff
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`Page 7 of 12
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`Case 6:16-cv-01084-RBD-GJK Document 13 Filed 07/18/16 Page 8 of 12 PageID 122
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`formally placed Defendants on notice of the infringement of their LBSLEDA10L products,
`
`Defendants have been and continue to induce, under 35 U.S.C. §271(b), consumers, distributors,
`
`importers and/or resellers that purchase or sell P8080-28/30K9-AC1-L06 products, to directly
`
`infringe at least Claims 1, 3, 5, 6, 7, 8, 11, and 14 of the ’518 Patent. Since at least December 9,
`
`2015, the date when Plaintiff formally placed Defendants on notice of their infringement,
`
`Defendants do so with knowledge, or with willful blindness of the fact, that the induced acts
`
`constitute infringement of the ’518 patent. Upon information and belief, Defendants intend to
`
`cause, and have taken affirmative steps to induce, infringement by these third-party manufacturers,
`
`distributors, importers, and/or consumers by, inter alia, creating advertisements that promote the
`
`infringing use of P8080-28/30K9-AC1-L06 and P8061-28/30K9-AC1-L06 products, creating
`
`established distribution channels for these products into and within the United States, purchasing
`
`these products, manufacturing these products in conformity with U.S. laws and regulations,
`
`distributing or making available instructions or manuals for these products to purchasers and
`
`prospective purchasers, and/or providing technical support, replacement parts, or services for these
`
`products to these purchasers in the United States.
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`30.
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`Plaintiff has at no time either expressly or impliedly licensed any of the Defendants
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`to practice the ’518 Patent.
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`31.
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`Defendants’ infringement has injured Plaintiff, and Plaintiff is entitled to recover
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`damages adequate to compensate it for such infringement.
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`32.
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`Upon information and belief, Defendants’ acts of infringement are willful,
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`warranting the assessment of increased damages pursuant to 35 U.S.C. § 284, and warrant a finding
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`that this is an exceptional case, pursuant to 35 U.S.C. § 285.
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`33.
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`Defendants’ infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement and, specifically,
`
`
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`Page 8 of 12
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`enjoining further manufacture, use, sale, importation, and/or offer for sale of products that come
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`within the scope of the claims of the ’518 Patent.
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`COUNT III
`(Infringement of U.S. Patent No. 8,967,844)
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`34.
`
`35.
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`Plaintiff repeats and re-alleges Paragraphs 1-7 as though fully set forth herein.
`
`Plaintiff is the owner by assignment of United States Patent No. 8,967,844 entitled
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`“Low Profile Light And Accessory Kit For The Same,” which was duly and legally issued by the
`
`USPTO on March 3, 2015 (the “‘844 Patent”). A true and correct copy of the ‘844 Patent is
`
`attached hereto as Exhibit C.
`
`36.
`
`The ‘844 Patent is valid and enforceable and Plaintiff has the full right to recover
`
`for past infringement damages and the right to recover future royalties, damages and income.
`
`37.
`
`To the extent any marking or notice was required by 35 U.S.C. § 287, Plaintiff, and
`
`all predecessors in interest and/or implied or express licensees of the ‘844 Patent, if any, have
`
`complied with the marking requirements of 35 U.S.C. § 287 by placing a notice of the ‘844 Patent
`
`on all goods made, offered for sale, sold, and/or imported into the United States that embody one
`
`or more claims of that patent and/or providing actual or constructive notice to Defendants.
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`38.
`
`Upon information and belief, since at least, December 9, 2015, when Plaintiff
`
`formally placed Defendants on notice of their infringement, Defendants have infringed and will
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`continue to infringe at least Claims 1, 2, 7, 9, 11, 12, 14, 16, 17, 21, 22, 23, and 24 of the ‘844
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`Patent by, among other activities, making, using, selling or offering to sell in or importing into the
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`United States
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`its P8080-28/30K9-AC1-L06 products. Defendants are
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`liable for direct
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`infringement, either literally or under the doctrine of equivalents, of the ’844 Patent pursuant to 35
`
`U.S.C. §271 (a).
`
`39.
`
`Upon information and belief, since at least, December 9, 2015, when Plaintiff
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`formally placed Defendants on notice of their infringement, Defendants have infringed and will
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`continue to infringe at least Claims 1, 2, 7, 9, 11, 12, 14, 16, 17, 21, 22, and 24 of the ‘844 Patent
`
`by, among other activities, making, using, selling or offering to sell in or importing into the United
`
`States its P8061-28/30K9-AC1-L06 products. Defendants are liable for direct infringement, either
`
`literally or under the doctrine of equivalents, of the ’844 Patent pursuant to 35 U.S.C. §271 (a).
`
`40.
`
`Upon information and belief, since at least December 9, 2015, when Plaintiff
`
`formally placed Defendants on notice of the infringement of their LBSLEDA10L products,
`
`Defendants have been and continue to induce, under 35 U.S.C. §271(b), consumers, distributors,
`
`importers and/or resellers that purchase or sell P8080-28/30K9-AC1-L06 and P8061-28/30K9-
`
`AC1-L06 products, to directly infringe at least Claims 1, 2, 7, 9, 11, 12, 14, 16, 17, 21, 22, 23, and
`
`24 of the ’844 Patent. Since at least December 9, 2015, the date when Plaintiff formally placed
`
`Defendants on notice of their infringement, Defendants do so with knowledge, or with willful
`
`blindness of the fact, that the induced acts constitute infringement of the ’844 patent. Upon
`
`information and belief, Defendants intend to cause, and have taken affirmative steps to induce,
`
`infringement by these third-party manufacturers, distributors, importers, and/or consumers by,
`
`inter alia, creating advertisements that promote the infringing use of P8080 products, creating
`
`established distribution channels for these products into and within the United States, purchasing
`
`these products, manufacturing these products in conformity with U.S. laws and regulations,
`
`distributing or making available instructions or manuals for these products to purchasers and
`
`prospective purchasers, and/or providing technical support, replacement parts, or services for these
`
`products to these purchasers in the United States.
`
`41.
`
`Plaintiff has at no time either expressly or impliedly licensed any of the Defendants
`
`to practice the ‘844 Patent.
`
`42.
`
`Defendants’ infringement has injured Plaintiff, and Plaintiff is entitled to recover
`
`
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`damages adequate to compensate it for such infringement.
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`43.
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`Defendants’ acts of infringement are willful, warranting the assessment of
`
`increased damages pursuant to 35 U.S.C. § 284, and warrant a finding that this is an exceptional
`
`case, pursuant to 35 U.S.C. § 285.
`
`44.
`
`Defendants’ infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement and, specifically,
`
`enjoining further manufacture, use, sale, importation, and/or offer for sale of products that come
`
`within the scope of the claims of the ‘844 Patent.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff respectfully asks this Court to enter judgment against Defendants
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`and against its respective subsidiaries, successors, parents, affiliates, officers, directors, agents,
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`servants, and employees, and all persons in privity or active concert or participation with
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`Defendants, granting the following relief:
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`A. the entry of judgment in favor of Plaintiff and against Defendants for the
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`infringement of the ’968 Patent, the ’518 Patent, and the ‘844 Patent;
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`B. a preliminary injunction prohibiting further infringement of each of the ’968 Patent,
`
`the ’518 Patent, and the ‘844 Patent by Defendants, their agents, employees,
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`representatives, successors and assigns and those acting in privity or in concert with
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`them;
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`C. a permanent injunction prohibiting further infringement of each of the ’968 Patent,
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`the ’518 Patent, and the ‘844 Patent by Defendants, their agents, employees,
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`representatives, successors and assigns and those acting in privity or in concert with
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`them;
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`D. an award of actual damages against Defendants for damages arising from the
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`infringement of each of the ’968 Patent, the ’518 Patent, and the ‘844 Patent
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`including treble damages for willful infringement, pursuant to 35 U.S.C. § 284;
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`E. an award of damages against Defendants for pre-judgment and post-judgment
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`interest on the damages awarded, including an award of prejudgment interest,
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`pursuant to 35 U.S.C. §284, from the date of each act of infringement of the ’968
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`Patent, the ’518 Patent, and the ‘844 Patent by Defendants to the day a damages
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`judgment is entered and a further award of post-judgment interest, pursuant to 28
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`U.S.C. §1961, continuing until such judgment is paid, at the maximum rate allowed
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`by law;
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`F. the entry of judgment that this case is exceptional, and award treble damages,
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`attorney fees, and the costs of this action, pursuant to 35 U.S.C. § 285;
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`G. in the event a final injunction is not granted, a compulsory ongoing royalty; and
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`H. such other relief to which Plaintiff is entitled under law, and any other and further
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`relief that this Court or a jury may deem just and proper.
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`JURY DEMAND
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`triable.
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`Pursuant to Fed. R. Civ. P. 38(b), Plaintiff demands a trial by jury on all issues so
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`/s/Mark F. Warzecha
`Mark F. Warzecha
`Florida Bar No. 95779
`WIDERMAN MALEK PL
`1990 W. New Haven Ave., Ste. 201
`Melbourne, Florida 32904
`Tel. (321) 255-2332
`Fax (321) 255-2351
`MFW@USLegalTeam.com
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