Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 1 of 14 PageID 1
`
`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`ORLANDO DIVISION
`
`KONINKLIJKE PHILIPS N.V. and
`PHILIPS SOLID-STATE LIGHTING
`SOLUTIONS, INC.
`
`Plaintiffs,
`
`v.
`
`JST PERFORMANCE, INC., d/b/a
`RIGID INDUSTRIES,
`
`Defendant.
`
`1189-Orl-31GJK
`Case No.: 6:14-cv-____________
`
`COMPLAINT
`
`(JURY TRIAL DEMANDED)
`
`Plaintiffs Koninklijke Philips N.V. (“KPNV”) and Philips Solid-State Lighting
`
`Solutions, Inc. (“PSSL” and, together with KPNV, collectively, “Philips”) bring this
`
`complaint for patent infringement against Defendant JST Performance, Inc. d/b/a Rigid
`
`Industries (“Rigid”).
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement under 35 U.S.C. § 271, et seq., by
`
`Philips against Rigid for infringement of United States Patent Nos. 6,250,774 (“the ’774
`
`patent”), 6,561,690 (“the ’690 patent”), 6,586,890 (“the ’890 patent”), 6,692,136 (“the ’136
`
`patent”), 6,788,011 (“the ’011 patent”), 6,806,659 (“the ’659 patent”), 6,967,448 (“the ’448
`
`patent”), 7,030,572 (“the ’572 patent”), 7,262,559 (“the ’559 patent”), 7,348,604 (“the ’604
`
`patent”), and 7,566,155 (“the ’155 patent”) (collectively, the “patents-in-suit”).
`
`
`
`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`ORLANDO DIVISION
`
`KONINKLIJKE PHILIPS N.V. and
`PHILIPS SOLID-STATE LIGHTING
`SOLUTIONS, INC.
`
`Plaintiffs,
`
`v.
`
`JST PERFORMANCE, INC., d/b/a
`RIGID INDUSTRIES,
`
`Defendant.
`
`1189-Orl-31GJK
`Case No.: 6:14-cv-____________
`
`COMPLAINT
`
`(JURY TRIAL DEMANDED)
`
`Plaintiffs Koninklijke Philips N.V. (“KPNV”) and Philips Solid-State Lighting
`
`Solutions, Inc. (“PSSL” and, together with KPNV, collectively, “Philips”) bring this
`
`complaint for patent infringement against Defendant JST Performance, Inc. d/b/a Rigid
`
`Industries (“Rigid”).
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement under 35 U.S.C. § 271, et seq., by
`
`Philips against Rigid for infringement of United States Patent Nos. 6,250,774 (“the ’774
`
`patent”), 6,561,690 (“the ’690 patent”), 6,586,890 (“the ’890 patent”), 6,692,136 (“the ’136
`
`patent”), 6,788,011 (“the ’011 patent”), 6,806,659 (“the ’659 patent”), 6,967,448 (“the ’448
`
`patent”), 7,030,572 (“the ’572 patent”), 7,262,559 (“the ’559 patent”), 7,348,604 (“the ’604
`
`patent”), and 7,566,155 (“the ’155 patent”) (collectively, the “patents-in-suit”).
`
`
`
`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 2 of 14 PageID 2
`
`
`THE PARTIES
`
`2.
`
`Plaintiff Koninklijke Philips N.V., formerly known as Koninklijke Philips
`
`Electronics N.V., is a corporation organized and existing under the laws of the Netherlands,
`
`with a principal place of business at Breitner Center, Amstelplein 2, 1096 BC Amsterdam,
`
`The Netherlands.
`
`3.
`
`Plaintiff Philips Solid-State Lighting Solutions, Inc. is a corporation organized
`
`and existing under the laws of Delaware, with a principal place of business at 3 Burlington
`
`Woods Drive, Burlington, Massachusetts 01803.
`
`4.
`
`Upon information and belief, Defendant JST Performance, Inc. d/b/a Rigid
`
`Industries is a corporation organized and existing under the laws of Arizona, with a principal
`
`place of business at 779 N Colorado St., Gilbert, Arizona 85233.
`
`JURISDICTION AND VENUE
`
`5.
`
`This Court has subject matter jurisdiction over this action pursuant to
`
`28 U.S.C. §§ 1331 and 1338.
`
`6.
`
`Upon information and belief, Rigid has made, used, provided, sold, offered to
`
`sell, imported, or distributed to others for such purposes, lighting products and systems
`
`employing light-emitting diodes (“LEDs”) for illumination (“LED Lighting Devices”)
`
`throughout the United States, including Florida and this judicial district.
`
`7.
`
`Upon information and belief, Rigid maintains or has maintained continuous
`
`and systematic contacts with Florida and this judicial district and has committed tortious
`
`activity within the district.
`
`
`
`-2-
`
`
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`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 3 of 14 PageID 3
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`
`8.
`
`Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b), (c) and/or
`
`1400(b) because, inter alia, Rigid is subject to personal jurisdiction in this district.
`
`FACTUAL BACKGROUND
`
`9.
`
`Upon information and belief, Rigid’s LED Lighting Devices include, without
`
`limitation, products in the A-Series, D-Series, E-Series, SR-Series, SR-M, SR-Q, RDS-
`
`Series, Q-Series, and Wake Flame product lines, and LED products that Rigid manufactures
`
`as a private label original equipment manufacturer for other lighting company customers.
`
`Rigid’s LED Lighting Devices include, without limitation, dome lights, deck lights, driving
`
`lights, fog lights, light bars, spotlights, floodlights, diffused lights, and marine lighting
`
`products.
`
`COUNT I: PATENT INFRINGEMENT OF U.S. PATENT NO. 6,250,774
`
`10.
`
`11.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On June 26, 2001, the United States Patent & Trademark Office (“Patent
`
`Office”) duly and legally issued the ’774 patent, entitled “Luminaire,” to Simon H. A.
`
`Begemann et al. Plaintiff KPNV is the assignee and owner of the ’774 patent.
`
`12.
`
`13.
`
`A true and correct copy of the ’774 patent is attached hereto as Exhibit 1.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’774 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its E-Series light bars, D-Series lights,
`
`and SR-M lights, in the United States.
`
`
`
`-3-
`
`
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`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 4 of 14 PageID 4
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`
`14.
`
`Philips provided notice of
`
`the ʼ774 patent
`
`to Rigid on or before
`
`February 12, 2013.
`
`15.
`
`Upon information and belief, Rigid’s infringement is deliberate, willful, and
`
`in reckless disregard of Philips’ patent rights.
`
`16.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`COUNT II: PATENT INFRINGEMENT OF U.S. PATENT NO. 6,561,690
`
`17.
`
`18.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On May 13, 2003, the Patent Office duly and legally issued the ’690 patent,
`
`entitled “Luminaire Based on the Light Emission of Light-Emitting Diodes,” to Christophe
`
`Balestriero et al. Plaintiff KPNV is the assignee and owner of the ’690 patent.
`
`19.
`
`20.
`
`A true and correct copy of the ’690 patent is attached hereto as Exhibit 2.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’690 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its E-Series light bars, D-Series lights,
`
`and SR-M lights, in the United States.
`
`21.
`
`Philips provided notice of
`
`the ʼ690 patent
`
`to Rigid on or before
`
`March 6, 2013.
`
`22.
`
`Upon information and belief, Rigid’s infringement is deliberate, willful, and
`
`in reckless disregard of Philips’ patent rights.
`
`23.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`
`
`-4-
`
`
`
`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 5 of 14 PageID 5
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`
`COUNT III: PATENT INFRINGEMENT OF U.S. PATENT NO. 6,586,890
`
`24.
`
`25.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On July 1, 2003, the Patent Office duly and legally issued the ’890 patent,
`
`entitled “LED Driver Circuit with PWM Output,” to Young-Kee Min et al. Plaintiff KPNV
`
`is the assignee and owner of the ’890 patent.
`
`26.
`
`27.
`
`A true and correct copy of the ’890 patent is attached hereto as Exhibit 3.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’890 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its E-Series light bars, D-Series lights,
`
`and SR-M lights, in the United States.
`
`28.
`
`Philips provided notice of
`
`the ʼ890 patent
`
`to Rigid on or before
`
`February 12, 2013.
`
`29.
`
`Upon information and belief, Rigid’s infringement is deliberate, willful, and
`
`in reckless disregard of Philips’ patent rights.
`
`30.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`COUNT IV: PATENT INFRINGEMENT OF U.S. PATENT NO. 6,692,136
`
`31.
`
`32.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On February 17, 2004, the Patent Office duly and legally issued the ’136
`
`patent, entitled “LED/Phosphor-LED Hybrid Lighting Systems,” to Thomas M. Marshall et
`
`al. Plaintiff KPNV is the assignee and owner of the ’136 patent.
`
`33.
`
`A true and correct copy of the ’136 patent is attached hereto as Exhibit 4.
`
`
`
`-5-
`
`
`
`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 6 of 14 PageID 6
`
`
`34.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’136 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its SR-Q RGBW and Wake Flame
`
`RGBW products, in the United States.
`
`35.
`
`Philips provided notice of
`
`the ʼ136 patent
`
`to Rigid on or before
`
`March 6, 2013.
`
`36.
`
`Upon information and belief, Rigid’s infringement is deliberate, willful, and
`
`in reckless disregard of Philips’ patent rights.
`
`37.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`COUNT V: PATENT INFRINGEMENT OF U.S. PATENT NO. 6,788,011
`
`38.
`
`39.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On September 7, 2004, the Patent Office duly and legally issued the ’011
`
`patent, entitled “Multicolored LED Lighting Method and Apparatus,” to George G. Mueller
`
`et al. Plaintiff PSSL is the assignee and owner of the ’011 patent.
`
`40.
`
`41.
`
`A true and correct copy of the ’011 patent is attached hereto as Exhibit 5.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’011 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its SR-Q RGBW and Wake Flame
`
`RGBW products, in the United States.
`
`42.
`
`Philips provided notice of
`
`the ʼ011 patent
`
`to Rigid on or before
`
`March 6, 2013.
`
`
`
`-6-
`
`
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`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 7 of 14 PageID 7
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`
`43.
`
`Upon information and belief, Rigid’s infringement is deliberate, willful, and
`
`in reckless disregard of Philips’ patent rights.
`
`44.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`COUNT VI: PATENT INFRINGEMENT OF U.S. PATENT NO. 6,806,659
`
`45.
`
`46.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On October 19, 2004, the Patent Office duly and legally issued the ’659
`
`patent, entitled “Multicolored LED Lighting Method and Apparatus,” to George G. Mueller
`
`et al. Plaintiff PSSL is the assignee and owner of the ’659 patent.
`
`47.
`
`48.
`
`A true and correct copy of the ’659 patent is attached hereto as Exhibit 6.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’659 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its SR-Q RGBW and Wake Flame
`
`RGBW products, in the United States.
`
`49.
`
`Philips provided notice of
`
`the ʼ659 patent
`
`to Rigid on or before
`
`March 6, 2013.
`
`50.
`
`Upon information and belief, Rigid’s infringement is deliberate, willful, and
`
`in reckless disregard of Philips’ patent rights.
`
`51.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`
`
`-7-
`
`
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`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 8 of 14 PageID 8
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`COUNT VII: PATENT INFRINGEMENT OF U.S. PATENT NO. 6,967,448
`
`52.
`
`53.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On November 22, 2005, the Patent Office duly and legally issued the ’448
`
`patent, entitled “Methods and Apparatus for Controlling Illumination,” to Frederick M.
`
`Morgan et al. Plaintiff PSSL is the assignee and owner of the ’448 patent.
`
`54.
`
`55.
`
`A true and correct copy of the ’448 patent is attached hereto as Exhibit 7.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’448 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its SR-Q RGBW and Wake Flame
`
`RGBW products, in the United States.
`
`56.
`
`Philips provided notice of
`
`the ʼ448 patent
`
`to Rigid on or before
`
`March 6, 2013.
`
`57.
`
`Upon information and belief, Rigid’s infringement is deliberate, willful, and
`
`in reckless disregard of Philips’ patent rights.
`
`58.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`COUNT VIII: PATENT INFRINGEMENT OF U.S. PATENT NO. 7,030,572
`
`59.
`
`60.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On April 18, 2006, the Patent Office duly and legally issued the ’572 patent,
`
`entitled “Lighting Arrangement,” to Engbert Bernard Gerard Nijhof et al. Plaintiff KPNV is
`
`the assignee and owner of the ’572 patent.
`
`61.
`
`A true and correct copy of the ’572 patent is attached hereto as Exhibit 8.
`
`
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`-8-
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`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 9 of 14 PageID 9
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`62.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’572 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its E-Series light bars, D-Series lights,
`
`and SR-M lights, in the United States.
`
`63.
`
`Upon information and belief, Rigid is aware of the ’572 patent, at least as of
`
`the filing of this Complaint.
`
`64.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`COUNT IX: PATENT INFRINGEMENT OF U.S. PATENT NO. 7,262,559
`
`65.
`
`66.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On August 28, 2007, the Patent Office duly and legally issued the ’559 patent,
`
`entitled “LEDS Driver,” to Ajay Tripathi et al. Plaintiff KPNV is the assignee and owner of
`
`the ’559 patent.
`
`67.
`
`68.
`
`A true and correct copy of the ’559 patent is attached hereto as Exhibit 9.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’559 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its E-Series light bars, D-Series lights,
`
`and SR-M lights, in the United States.
`
`69.
`
`Philips provided notice of
`
`the ʼ559 patent
`
`to Rigid on or before
`
`February 12, 2013.
`
`70.
`
`Upon information and belief, Rigid’s infringement is deliberate, willful, and
`
`in reckless disregard of Philips’ patent rights.
`
`
`
`-9-
`
`
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`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 10 of 14 PageID 10
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`71.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`COUNT X: PATENT INFRINGEMENT OF U.S. PATENT NO. 7,348,604
`
`72.
`
`73.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On March 25, 2008, the Patent Office duly and legally issued the ’604 patent,
`
`entitled “Light-Emitting Module,” to George E. Matheson. Plaintiff KPNV is the assignee
`
`and owner of the ’604 patent.
`
`74.
`
`75.
`
`A true and correct copy of the ’604 patent is attached hereto as Exhibit 10.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’604 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its E-Series light bars, D-Series lights,
`
`and SR-M lights, in the United States.
`
`76.
`
`Upon information and belief, Rigid is aware of the ’604 patent, at least as of
`
`the filing of this Complaint.
`
`77.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`COUNT XI: PATENT INFRINGEMENT OF U.S. PATENT NO. 7,566,155
`
`78.
`
`79.
`
`Philips incorporates by reference paragraphs 1-9 as if fully set forth herein.
`
`On July 28, 2009, the Patent Office duly and legally issued the ’155 patent,
`
`entitled “LED Light System,” to Josef Andreas Schug et al. Plaintiff KPNV is the assignee
`
`and owner of the ’155 patent.
`
`
`
`-10-
`
`
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`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 11 of 14 PageID 11
`
`
`80.
`
`81.
`
`A true and correct copy of the ’155 patent is attached hereto as Exhibit 11.
`
`Upon information and belief, Rigid is engaged in activities that infringe the
`
`’155 patent under 35 U.S.C. § 271 by making, using, offering to sell, selling and/or importing
`
`LED Lighting Devices, including without limitation its E-Series Diffused light bars, D-Series
`
`Diffused lights, and SR-M Diffused lights, in the United States.
`
`82.
`
`Upon information and belief, Rigid is aware of the ’155 patent, at least as of
`
`the filing of this Complaint.
`
`83.
`
`Philips has been and continues to be injured by the infringing activities of
`
`Rigid.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Philips respectfully requests the following relief:
`
`
`
`(a) a declaration that Rigid infringes the patents-in-suit and a final judgment
`
`incorporating same;
`
`
`
`(b) entry of preliminary and/or permanent equitable relief, including but not limited to
`
`a preliminary and/or permanent injunction that enjoins Rigid and any of its officers, agents,
`
`employees, assigns, representatives, privies, successors, and those acting in concert or
`
`participation with them from infringing and/or inducing infringement of the patents-in-suit;
`
`
`
`(c) an award of damages sufficient to compensate Philips for infringement of the
`
`patents-in-suit by Rigid, together with prejudgment and post-judgment interest;
`
`
`
`(d) a declaration or order finding that Rigid’s infringement is willful and/or an order
`
`increasing damages under 35 U.S.C. § 284;
`
`
`
`-11-
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`
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`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 12 of 14 PageID 12
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`(e) a judgment holding that this is an exceptional case under 35 U.S.C. § 285 and
`
`awarding Philips its reasonable attorneys’ fees, costs, and expenses; and
`
`
`
`(f) such other relief deemed just and proper.
`
`JURY DEMAND
`
`Under Rule 38 of the Federal Rules of Civil Procedure, Philips hereby demands trial
`
`by jury of all issues so triable by a jury in this action.
`
`Dated: July 23, 2014
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`/s/ Thomas A. Zehnder
`Thomas A. Zehnder
`Florida Bar No.: 0063274
`Taylor F. Ford
`Florida Bar No.: 0041008
`KING, BLACKWELL, ZEHNDER & WERMUTH, P.A.
`P.O. BOX 1631
`Orlando, Florida 32802-1631
`Telephone: (407) 422-2472
`Facsimile: (407) 648-0161
`tzehnder@kbzwlaw.com
`tford@kbzwlaw.com
`
`Denise W. DeFranco*
`denise.defranco@finnegan.com
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`Two Seaport Lane
`Boston, MA 02210
`Telephone: (617) 646-1600
`Facsimile: (617) 646-1666
`C. Brandon Rash*
`brandon.rash@finnegan.com
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`901 New York Avenue, NW
`Washington, DC 20001
`Telephone: (202) 408-4000
`Facsimile: (202) 408-4400
`
`*(Motion to Appear Pro Hac Vice Forthcoming)
`
`
`
`
`
`-12-
`
`
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`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 13 of 14 PageID 13
`
`
`
`Counsel for Plaintiffs
`
`Koninklijke Philips N.V. and
`Philips Solid-State Lighting Solutions, Inc.
`
`
`
`-13-
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`
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`Case 6:14-cv-01198-GAP-GJK Document 1 Filed 07/23/14 Page 14 of 14 PageID 14
`
`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`ORLANDO DIVISION
`
`
`Plaintiffs,
`
`KONINKLIJKE PHILIPS N.V. and
`PHILIPS SOLID-STATE LIGHTING
`SOLUTIONS, INC.
`
`
`
`v.
`
`JST PERFORMANCE, INC., d/b/a
`RIGID INDUSTRIES,
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`Defendant.
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`Case No.: 6:14-cv-____________
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`Exhibit Index to Plaintiffs’ Complaint
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`Exhibit
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`Description
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`’774 Patent
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`’690 Patent
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`’890 Patent
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`’136 Patent
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`’011 Patent
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`’659 Patent
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`’448 Patent
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`’572 Patent
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`’559 Patent
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`’604 Patent
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`’155 Patent
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