Signify North America Corporation v. Lepro Innovation Inc.
2:22-cv-02095
| D. Nev. | Jul 31, 2025Background
- Plaintiffs Signify North America and Signify Holding (collectively, Signify) allege that several defendants (collectively, Lepro) infringed six of Signify’s patents related to LED lighting technologies.
- Earlier, the court issued a claim-construction order, clarifying key terms and finding several terms definite.
- Both parties moved for partial summary judgment: Signify largely on infringement and validity issues, Lepro chiefly on the timing of actual notice of alleged infringement (which affects damages).
- Certain infringement and invalidity defenses by Lepro were conceded, narrowing the dispute to a subset of patents and defenses.
- Expert testimony played a key role, particularly from Dr. Jonathan Wood (Signify) and Dr. John Curran (Lepro), though Lepro did not offer expert counter-evidence on some key issues.
- The court granted Signify’s motion in part, denied Lepro’s, and set remaining issues—especially on actual notice and some patent claims—for trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Infringement of ’577 patent | Dr. Wood’s expert report shows infringement; Lepro has no contrary evidence | Dr. Wood’s modeling is flawed; no competent rebuttal offered | Summary judgment for Signify—Lepro's attorney argument alone insufficient |
| Lepro’s § 112 invalidity defenses (’336, ’320) | Lepro has no evidence; alternative theories not timely disclosed | Indefiniteness/enablement issues; want to use alternative legal theories | Summary judgment for Signify; Lepro cannot raise new or rejected theories |
| Lepro’s anticipation & obviousness defenses (’138, ’399) | Prior art not enabling; Dr. Curran conceded key limitation is missing | Obviousness not reliant on challenged circuit; summary judgment premature | Partially for Signify; anticipation defense gone, obviousness remains |
| Actual notice of infringement (timing for damages) | Notice letters covered accused products or similar ones | Notice letters too vague, did not specifically identify some products | Denied for Lepro; factual issues preclude summary judgment |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standards)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (genuine dispute standard at summary judgment)
- Markman v. Westview Instruments, Inc., 517 U.S. 370 (claim construction in patent cases)
- Amsted Indus. Inc. v. Buckeye Steel Castings Co., 24 F.3d 178 (actual notice in patent infringement)
- Funai Elec. Co., Ltd. v. Daewoo Elecs. Corp., 616 F.3d 1357 (actual notice applies to similar products)
- K-TEC, Inc. v. Vita-Mix Corp., 696 F.3d 1364 (notice extends to sufficiently similar products)